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

1

U.S. Patent No. 7,657,849

Apple Patent
2

Technology Tutorial

I. The Technology Of The ‘849 Patent

3

U.S. Patent No. 7,657,849

4

‘849 Patent: The Alleged Problems
 The ‘849 patent contended that the prior art procedures for
unlocking a touch-screen device were limited to methods
“such as pressing a predefined set of buttons (simultaneously
or sequentially) or entering a code or password.”
‘849 patent at 1:43-45

 The ‘849 patent described these prior-art procedures as
“hard to perform” and “burdensome.”
‘849 patent at 1:45-49

 The ‘849 patent also described the need for a unlock
procedure that was “user-friendly” and provided “sensory
feedback to the user regarding progress“ towards
completion.
‘849 patent at 1:51-62

5

‘849 Patent: The Disclosed Unlock Procedure
“A device with a touch-sensitive display may be unlocked via
gestures performed on the touch -sensitive display. The device
is unlocked if contact with the display corresponds to a
predefined gesture for unlocking the device.”
„849 patent at Abstract

“The device may also display visual cues of the predefined
gesture on the touch screen to remind a user of the gesture.”
„849 patent at Abstract

6

The ‘849 Patent Technology

The Unlock Procedure Has Several Visual Cues
1. Movement of a graphical image from one location to
another on a touch screen;

2. Displaying a predefined path along which the graphical
image must travel;
3. Ignoring user input that does not correspond to a
“predefined gesture;” and / or
4. Other visual cues.

7

The ‘849 Patent Technology
The Visual Cues
1. Moving a graphical image from one location to another on a
touch screen.
For Example:
From Here

To Here

8

The ‘849 Patent Technology
The Visual Cues
1. Moving a graphical image from one location to another on a
touch screen.
For Example:
From Here

“unlock
image”
402

To Here

9

The ‘849 Patent Technology
The Visual Cues
1. Moving a graphical image from one location to another on
a touch screen.

10

The ‘849 Patent Technology
The Visual Cues
1. Moving a graphical image from one location to another on
a touch screen.

11

The ‘849 Patent Technology
The Visual Cues
1. Moving a graphical image from one location to another on
a touch screen.

“*D+ragging the unlock image . . . moves the unlock
image across the touch screen”
‘849 patent at 10:50-53; see also 12:20-30, 11:57-12:3

12

The ‘849 Patent Technology
The Visual Cues
1. Moving a graphical image from one location to another on
a touch screen.

If the user input condition includes dragging an
image to a predefined location, then “indication of
progress may be defined in terms of the distance
between the initial location of the image and the
predefined location to which the image is to be
dragged.”
‘849 patent at 15:27-32

13

The ‘849 Patent Technology
The Visual Cues
2. Displaying a predefined path along which the graphical
image must travel;
For Example:

“channel”
404

14

The ‘849 Patent Technology
The Visual Cues
2. Displaying a predefined path along which the graphical
image must travel;

“The visual cues shown include a channel *+ indicating the
path . . . which the unlock image is to be dragged, similar to
a groove. . . . The end of the channel . . . also serves as a
predefined location to which the unlock image is to be
dragged.”
‘849 patent at 12:24-27

15

The ‘849 Patent Technology
The Visual Cues
2. Displaying a predefined path along which the graphical
image must travel;

“If the user input condition includes dragging an
image along a predefined path, then the indication
of progress may be defined in terms of the length
of the predefined path.”
‘849 patent at 15:32-35

16

The ‘849 Patent Technology
The Visual Cues
3. Ignoring user input that does not correspond to a
“predefined gesture.”

“Gesture” is defined as “a motion of the object
/ appendage making contact with the touch
screen.”
‘849 patent at 9:26-28

17

The ‘849 Patent Technology
The Visual Cues
3. Ignoring user input that does not correspond to a
“predefined gesture.”

 Thus, a “predefined gesture” is “a predefined
motion of the object / appendage making
contact with the touch screen.”

18

The ‘849 Patent Technology
The Visual Cues
3. Ignoring user input that does not correspond to a
“predefined gesture.”

“For example, the predefined gesture may
include a contact of the touch screen on the left
edge (to initialize the gesture), a horizontal
movement of the point of contact to the opposite
edge while maintaining continuous contact with
the touch screen, and a breaking of the contact at
the opposite edge (to complete the gesture).”
‘849 patent at 9:28-33
19

The ‘849 Patent Technology
The Visual Cues
3. Ignoring user input that does not correspond to a
“predefined gesture.”
For Example:
From Here

To Here

20

The ‘849 Patent Technology
The Visual Cues
3. Ignoring user input that does not correspond to a
“predefined gesture.”
For Example:
From Here

To Here

“finger”
502

21

The ‘849 Patent Technology
The Visual Cues
3. Ignoring user input that does not correspond to a
“predefined gesture.”
For Example:
From Here

To Here

22

The ‘849 Patent Technology
The Visual Cues
3. Ignoring user input that does not correspond to a
“predefined gesture.”

The device will stay “in the user-interface lock
state if the detected contact does not correspond
to the predefined gesture.”
‘849 patent at 2:6-8

23

The ‘849 Patent Technology
The Disclosed Sensory Feedback
3. Ignoring user input that does not correspond to a
“predefined gesture.”

“If the user input condition includes a predefined
gesture then the indication of progress of the
gesture may be defined in terms of how much of the
gesture is completed and how much of the gesture
is remaining.”
‘849 patent at 15:18-21

24

The ‘849 Patent
II. Apple’s Embodiments: iPhones & iPads

25

Apple’s Embodiments
iPhones & iPads
1. The “unlock image” moves its location across the touch screen.
2. A predefined path is displayed.
3. A predefined gesture is required to unlock to the device.

26

The ‘849 Patent

III. Accused Motorola devices

27

Accused Motorola devices

 Apple accuses 18 Motorola devices of infringing the ‘849 patent
 There is not a single, uniform process used to unlock all the
accused devices.

28

Accused Motorola devices
 Apple accuses Motorola phones that do not have a user move an
unlock image.
 Apple accuses Motorola phones that do not have a predefined
displayed path.
 Apple accuses Motorola phones that do not require a user to input
predefined gesture in order to unlock the phone.

29

U.S. Patent No. 6,282,646
and
U.S. Patent No. 7,380,116
Apple Patents
30

U.S. Patent No. 7,380,116

31

U.S. Patent No. 6,282,646

32

Technology Tutorial

I. The Technology Of The Display Space Patents

33

The Display Space Patents: The Alleged Problem
The patents contend that prior-art computer systems
required a restart to change the display configuration

“In the past, changes in the
configuration of the computer system,
such as the addition or removal of
display devices, only became effective
upon a restart, or reboot, of the
computer system.”
‘646 patent at 1:40-43

34

The Display Space Patents: The Alleged Solution
To accomplish a “real-time reconfiguration of the display environment,”
the Display Space patents use two operating system components:

1. A “Device Manager” to determine whether an
attached device is a video device; and
2. A “Display Manager” to reconfigure the “Display
Space.”

35

The Display Space Patents Technology
The Patents Disclose A “Device Manager” To
Determine Whether A Device Is A Video Device
“The detection of the presence of such *video+ devices,
as well as their removal from the system, is handled by
a portion of the computer's operating system that is
referred to herein as a device manager.”
‘646 patent at 5:17-21

36

The Display Space Patents Technology
The Patents Disclose A “Display Manager” To
Reconfigure The “Display Space”
“*T+he display manager reconfigures the display space
for the computer system, to accommodate an
additional frame buffer that is associated with the
added component. With this change in the
configuration of the display space, the added
component becomes immediately available for use. By
means of this approach, the user can add a second
monitor or other hardware component to a computer
and begin to use the monitor as soon as it has been
connected, without the need to reboot the computer
or otherwise interrupt its current operating state.”
‘646 Patent at 2:39-44

37

The Display Space Patents Technology

Using A Display Space To Display Images
1.

A computer system
allocates memory (RAM)
for the rendering of
graphical images.

2.

This allocated memory is
a virtual “display space.”

3.

The computer system
will allocate the “display
space” to a “frame
buffer” of one or more
video devices.

4.

Images sent to the
“display space” will be
displayed on the video
device(s).

1

2

3
4
38

The Display Space Patents Technology

Using A Display Space To Display Images
“The display environment can generally be considered
to be defined by a global coordinate space 30, as
depicted in FIG. 2. Objects and other information to
be displayed can be positioned anywhere within this
space, as determined by the user and/or the software
program that generates the information.”
‘646 patent at 3:65-4:4

39

The Display Space Patents Technology

Using A Display Space To Display Images

‘646 patent at Figure 2
40

The Display Space Patents Technology

Using A Display Space To Display Images

The Display Space

‘646 patent at Figure 2
41

The Display Space Patents Technology

Using A Display Space To Display Images

‘646 patent at Figure 2
42

The Display Space Patents Technology

Using A Display Space To Display Images

“*E+ach video card includes a frame buffer, e.g.
random access memory, which stores the data for
the image that is displayed on its associated
display.”
‘646 patent at 4:47-49

43

The Display Space Patents Technology

Using A Display Space To Display Images
“If a new video card is inserted, for example, the
display manager assigns a portion of the global
coordinate space 30 to the frame buffer in the video
card.”
‘646 patent at 6:46-48

44

The Display Space Patents Technology

Using A Display Space To Display Images

Portion of
Display Space
allotted to
frame buffer of
video device 1

‘646 patent at Figure 2
45

The Display Space Patents Technology

Using A Display Space To Display Images

Portion of
Display Space
allotted to
frame buffer of
video device 1
(e.g. laptop
screen)
‘646 patent at Figure 2

Portion of
Display Space
allotted to
frame buffer of
video device 2
(e.g. external
monitor screen)
46

The Display Space Patents Technology

Using A Display Space To Display Images
 Not all of the
Display Space is
necessarily
displayed on the
attached video
devices

‘646 patent at Figure 2
47

The Display Space Patents Technology

Using A Display Space To Display Images
 Not all of the
Display Space is
necessarily
displayed on the
attached video
devices

48

The Display Space Patents Technology

Using A Display Space To Display Images
 Not all of the
Display Space is
necessarily
displayed on the
attached video
devices
 B not on screen, but
still in display
space.

49

The Display Space Patents Technology

Using A Display Space To Display Images
“*I+f the removed device is a video card, the display
manager deletes the assignment of a portion of the
display space to the now-removed frame buffer.”
‘646 patent at 7:56-58

50

The Display Space Patents Technology

Using A Display Space To Display Images

‘646 patent at Figure 2
51

The Display Space Patents Technology

Using A Display Space To Display Images

‘646 patent at Figure 2
52

The Display Space Patents Technology

Using A Display Space To Display Images
“If a display device is disconnected from one video
card and connected to a different video card, the
display manager moves objects within the global
space 30 so that they are presented to the appropriate
frame buffer for the display device.”
‘646 patent at 6:51-55

53

The Display Space Patents Technology

Using A Display Space To Display Images

‘646 patent at Figure 2

Object
(software
window)
displayed on
Video Device 2
(external
monitor)
54

The Display Space Patents Technology

Using A Display Space To Display Images

Object
(software
window) now
displayed on
Video Device 1
(laptop screen)
After Video
Device 2 was
removed

‘646 patent at Figure 2
55

The Display Space Patents Technology
The Patents Reconfigure A “Display Space”

 The patents do not disclose or suggest reserving
separate portions of memory for each video device.
 Rather, the Display Space patents disclose
reconfiguring the shared “Display Space” through the
use of a “Device Manager” and “Display Manager.”

56

The Display Space Patents
II. Apple’s Embodiments: Apple Computers

57

Apple’s Embodiments
1. All video devices can share the Display Space, so that all
attached video devices share a global coordinate system.
2. When a video device is added or removed to the computer
system, the allocation of the Display Space is modified.
3. Because all video devices share the Display Space, icons and
other graphical objects can be moved among the attached video
devices.

58

Apple’s Embodiments

59

The Display Space Patents

III. Accused Motorola devices

60

Accused Motorola devices

 Apple accuses 3 Motorola devices of infringing the Display Space
patents.

61

Accused Motorola devices

62

Accused Motorola devices



Apple accuses Motorola devices that do not create or modify the
allocation of a display space.



Instead, Motorola devices reserve separate, distinct portions of
memory for each video device.

63

U.S. Patent No. 5,621,456
U.S. Patent No. 5,594,509
U.S. Patent No. 5,583,560
Apple Patents
(the “Florin patents”)

64

The Florin set-top box interface patents
U.S. Patent No. 5,583,560
Method and Apparatus for Audio-Visual
Interface for the Selective Display of
Listing Information on a Display
U.S. Pat. No. 5,594,509
Method and Apparatus for Audio-Visual
Interface for the Display of Multiple
Levels of Information on a Display
U.S. Pat. No. 5,621,456
Methods and Apparatus for Audio-Visual
Interface for the Display of Multiple
Program Categories
65

The Florin set-top box interface patents
‘560, ‘456 and ‘509 patents

 Inventors: Fabrice Florin, et al.
 Priority date: June 22, 1993
 Identical patent specifications
and drawings in all patents

66

I.

Set-top Box and Related Technology

67

Set-top box technology

Set-top box
A computerized
device that lets audiovisual programs and
graphics display on TV
Where?
Generally, in the
viewer’s home,
it connects a signal
source (cable,
satellite, etc.) to the
television

Signal
source

Data

Set-top
Box

TV (displaying guide)
Data

Data

Viewer
68

Set-top box technology
Signal
source

How used
Viewer uses remote
control to order
set-top box to:
• Select TV content

Data

Set-top
Box

TV (displaying guide)
Data

• View program info
• Record content
•Other (pay bills,
order movies, etc.)

Data

Viewer
69

Set-top box hardware
Includes:





CPU (central processing unit)
System memory (stores data)
Connections (switches, ports,
bus wires, etc.)
Interior of Phillips DVDR 3460 set-top box

Connector ports on Sharp TU-T2HR32 set-top box

An Intel CPU
70

Set-top box hardware
Specialized A/V equipment






Tuner (receives A/V signal,
such as from a fiber cable)
Demodulator (processes
signal from the tuner into
demodulated “bits”)
Signal “decoder” (makes
demodulated bits
viewable on TV)

Alps Electric DVB-S2 Digital television tuner
and demodulator (circa 2007)

71

Software: Graphical User Interface (“GUI”)

 GUI: a type of user
interface generated
by hardware and
software

A set-top box GUI from Apple’s EZTV
prototype incorporated into Florin patents

72

Remote control
Typical command
buttons

G

B

A

C

E

D

A) TV commands (channel
up/down, volume, etc.)
B) Numeric keypad
C) Arrow keys
D) TV guide
E) Enter (or go, select, etc.)
F) Record
G) “Info”

C

E

D
F
A
B

F
Remote control from
Hendricks patent
application (1992)

Remote control from
Florin patents
73

Prior art solutions
Set-top boxes and GUIs existed in 1993

1. The hardware existed
• Remote controls, tuners and demodulators, CPUs, etc.

2. The software existed
• GUIs let viewers interact with on-screen content using remotes

3. Interactive TV guides existed
• Viewers could highlight and select programs to watch or record

4. Picture-in-picture existed
• TVs were capable of both “split screen” and miniature windows

5. Several set-top systems were patented
• Discovery Channel (Hendricks), Starlight Telecast (Young), etc.
74

Prior art solutions
Example 1. U.S. Patent No. 5,990,927

 Priority date: December 9, 1992
 Interactive set-top box GUI
developed by Discovery Channel
 GUI lets viewer highlight, select
items from TV listing guide
 “Incremental levels of menu
options” (‘927 patent at
12:53-54) let user get more
information on selected items

U.S. Pat. No. 5,990,927
75

Prior art solutions
Example 1. U.S. Patent No. 5,990,927

How it worked:

A

A) Set-top box hardware
B) Remote control
B C) Interactive TV guide
menu
D) Pressing remote
C
buttons selects
highlighted
menu items
D

U.S. Pat. No. 5,990,927

U.S. Pat. No. 5,990,927
76

Prior art solutions
Example 2. Canadian Pat. No. 2,553,384

 Priority date: 9/10/1990

 Interactive set-top box GUI
developed by Starsight
Telecast, Inc.
 GUI lets viewer highlight,
select and mark items
from TV listing guide
 Multiple levels let viewer
get more information on
selected items

Can. Pat. No. 2,553,384

77

Prior art solutions
Example 2. Canadian Pat. No. 2,553,384

A) Set-top box displays
on-screen TV guide
B) Viewer uses remote control
to select channels

C) GUI highlights currently
selected show
D) Arrow buttons let user mark
shows for recording, etc.
A

B
D

C

Can. Pat. No. 2,553,384

Can. Pat. No. 2,553,384
78

II. The Florin Set-Top Box Patents

79

Purpose of Florin patents: Improved GUI
 “Challenge:” Make easy, fun interface

‘560 patent at 1:65-67

80

Purpose of Florin patents: Improved GUI
 Solution: Improved, “user-friendly”
A/V user interface using remote control

‘560 patent at 2:18-22, 24-27

81

Purpose of Florin patents: Improved GUI

 Any A/V user interface is generated by
both hardware and software

‘560 patent at Abstract;
‘560 patent at 2:49-52

‘560 patent at 24:64-67
82

Purpose of Florin patents: Improved GUI
 Lists 12 types of interfaces/functions:

1. Full-Screen Viewing Function
2. Information Function
3. List Function
4. Record Function
5. Mark Function
6. Jump Function
7. Categories Function
8. Pix Function
9. Menu Function
10.Pay-Per-View Interface
11.Home Shopping Interface
12.Other (e.g. financial transactions)
Source: ‘560 patent 13:20-24:57

83

Florin set-top box technology components

A. Set-top box receives TV
signals and program
schedules from
A
service provider
(cable, satellite)
B. Viewer uses remote to
request program
schedules and other
data
C. Set-top box hardware
and software displays
requested information
on TV screen using
improved GUI

B

C
‘560 patent at Fig. 1

84

Florin set-top box technology components

Viewer accesses interface with remote control

‘560 Patent at Abstract (cover page)

‘560 patent at Fig. 1

85

Florin set-top box technology components
The remote control

A) List
B) Mark
C) Info
D) Jump
E) Arrows
F)

Select

‘560 patent at Figs. 4, 5

86

Florin set-top box technology components
In Florin patent, remote control is “in
communication with” set-top box…

‘560 patent at Claim 1

…not “coupled to” it like other hardware
components

‘560 patent at 8:40-51

Remote control from
Florin patents
87

Steps of Florin set-top technology
Displaying A/V signals and graphics on TV

‘560 patent at Fig. 2

88

Steps of Florin set-top technology

Signal from source
A) Signal in from provider

‘560 patent at Fig. 2

89

Steps of Florin set-top technology

Signal from source
A) Signal in from provider
B) Decoded program
signal goes to TV

‘560 patent at Fig. 2

90

Steps of Florin set-top technology

Signal from source
A) Signal in from provider
B) Decoded program
signal to TVto TV
goes
C) Digital program guide
information goes to
computer memory

‘560 patent at Fig. 2

91

Steps of Florin set-top technology

Receiving user commands
D) Viewer issues
command (e.g. “list”)
through remote

‘560 patent at Fig. 2

92

Steps of Florin set-top technology

Processing user commands
D) Viewer issues
command (e.g. “list”)
through remote
E) CPU, graphics chips
process command
using GUI software

‘560 patent at Fig. 2

93

Steps of Florin set-top technology

Displaying A/V graphics
D) Viewer issues
command (e.g. “list”)
through remote
E) CPU, graphics chips
process command
using GUI software
F) A/V graphics are
transmitted to TV

‘560 patent at Fig. 2

94

The Florin set-top box interface
The GUI for listing information

Pressing “list”
displays program
listing

‘560 patent at Fig. 12
95

The Florin set-top box interface
The GUI for listing information

Listing includes
PIP and
highlighting of
current program

‘560 patent at Fig. 12
96

The Florin set-top box interface
The GUI for listing information

Pressing “up” arrow
highlights next
program up screen

‘560 patent at Fig. 13
97

The Florin set-top box interface
The GUI for listing information

Continuously
pressing “up” arrow
scrolls guide upwards

‘560 patent at Fig. 14

98

The Florin set-top box interface
The GUI for listing information

Pressing right or left
arrows scrolls guide
right or left

‘560 patent at Fig. 16

99

The Florin set-top box interface
The GUI for listing information

“Mark” button
marks highlighted
program with check
mark for later
retrieval

‘560 patent at Fig. 15

100

The Florin set-top box interface
The GUI also lets
viewers interact with
the current TV show

Individual program GUI

“Info” button
retrieves information
on current program

‘560 patent at Fig. 7
101

The Florin set-top box interface
Individual program GUI

From there, pressing
right/left buttons
retrieves additional
levels of program
information (‘560
patent at 11:49-51)

‘560 patent at Fig. 8
102

The Florin set-top box interface
Individual program GUI

“Mark” button
marks program
“Jump” button
displays marked
show on TV screen

‘560 patent at Fig. 6

103

The Florin set-top box interface

Reminding viewers of marked programs
When marked
shows start, they
are displayed
in a PIP reminder
window

‘560 patent at Fig. 20

104

The Florin set-top box interface

Reminding viewers of marked programs
Pressing “jump”
button will cause
the TV display to
switch to the
marked program

‘560 patent at Fig. 21

105

Technology Tutorial

III. EZTV Video Incorporated Into Florin Patents

106

Apple prototype: EZTV
EZTV

 Promotional video
produced by Apple
describes the Florin patent
invention
 Video is incorporated into
Florin patents:

Still shot from EZTV promotional video

‘560 patent at 25:10-14

107

Apple prototype: EZTV
EZTV video

 Discusses technological advances in TV, need for improved interface

“Watching TV used to be
simple. If you didn’t like what
was on, you just walked over
to the set and switched to the
other channel.
Now we have dozens of
channels to choose from,
VCRs, multiple
remotes...watching TV will
present some real problems.
One solution: EZTV.”
--Quote from EZTV video
Excerpt from EZTV promotional video

108

Apple prototype: EZTV
EZTV video

 Depicts using remote control to get individual program information,
get listing information, and mark, record, and jump between programs

“This new remote
allows us to use all
of EZTV’s interactive
functions, as well as
operate any
standard TV and
VCR.”
--Quote from EZTV video

Excerpt from EZTV promotional video

109

Apple prototype: EZTV
EZTV video

 Shows the remote control depicted in Figures 4a and 4b

Still shot from EZTV promotional video

110

Apple prototype: EZTV
EZTV video

 Shows the program listing GUI depicted in Figures 12-17, including PIP

Still shot from EZTV promotional video

111

Apple prototype: EZTV
EZTV video

 Shows viewer hitting “list” button on remote to call up listing GUI

Still shot from EZTV promotional video
Still shot from EZTV promotional video

112

Apple prototype: EZTV
EZTV video

 Shows viewer hitting “mark” button on remote to mark program

Still shot from EZTV promotional video
Still shot from EZTV promotional video

113

Apple prototype: EZTV
EZTV video

 Shows the individual program GUI depicted in Figures 7-11

Still shot from EZTV promotional video

114

Apple prototype: EZTV
EZTV video

 Shows user hitting “info” button to call up program info GUI

Still shot from EZTV promotional video
Still shot from EZTV promotional video

115

Apple prototype: EZTV
EZTV video

 Shows user hitting “jump” button to jump to marked program

Still shot from EZTV promotional video
Still shot from EZTV promotional video

116

Technology Tutorial

IV. Accused Motorola devices

117

Accused Motorola devices
Motorola set-top boxes

 Apple accuses 27 Motorola
devices of infringing Florin patents
 Devices are manufactured by
Motorola and/or Motorola
contractors
 Motorola sells accused devices to
cable providers
 Cable providers then sell and/or
provide modified accused devices
to customers

Motorola DCX3400 accused device

118

Accused Motorola devices
Motorola set-top boxes

 Motorola provides no remote
control with accused devices
 Devices ship without the
graphic user interface described
in the Florin patents; most ship
without any GUI
 Cable providers develop and
add their own GUIs before
providing devices to customers
 Cable providers provide
remote controls for customers

Motorola DCX3200 accused device

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Accused Motorola devices
Motorola products generally lack a remote control or any
type of graphic user interface such as program guide

Picture source: Apple’s Preliminary Infringement Contentions, Ex. A at 7
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