Motorola Mobility, Inc. v. Apple, Inc.

Filing 160

NOTICE by Motorola Mobility, Inc. of Filing Supplemental Infringement Contentions (Attachments: # 1 Exhibit Supplemental Infringement Contentions, # 2 Exhibit 1-A, # 3 Exhibit 1-B, # 4 Exhibit 1-C, # 5 Exhibit 1-D, # 6 Exhibit 1-E, # 7 Exhibit 1-F, # 8 Exhibit 2, # 9 Exhibit 3)(Giuliano, Douglas)

Exhibit F
UNITED STATES PATENT NO. 6,377,161
SUPPLEMENTAL INFRINGEMENT CONTENTIONS1
Accused Apple Products:2 Apple iPhone 3G, Apple iPhone 3GS, Apple iPhone 4, Apple iPhone 4S ("Apple iPhones"), Apple iPad,
Apple iPad with 3G, Apple iPad 2, Apple iPad 2 with 3G, Apple iPod Touch ("Apple iPads and iPods"),
Apple MacBook, Apple MacBook Pro, Apple MacBook Air, Apple iMac, Apple Mac Mini, and Apple
Mac Pro ("Apple Computers"), MobileMe, and iCloud.
’161 Patent Claim

Accused Apple Products3

1. A method in a
wireless messaging
system for facilitating
an exchange of address
information between

Upon information and belief, the Accused Apple Products perform each and every step of this claim in the
course of their normal use. Additionally, a user of the Accused Apple Products performs each and every
step of this claim in the course of such use.
In a wireless messaging system, the Accused Apple Products facilitate the exchange of address

1

Motorola Mobility's investigation is ongoing and discovery and claim construction are not yet complete. Apple has, thus far,
produced neither all documents relevant to the accused methods and products, nor the requested Rule 30(b)(6) witnesses. Mobility
reserves the right to supplement or amend these contentions with contentions arising under the doctrine of equivalents in response to
any proposed or ordered claim construction, subsequent discovery response or production, or subsequent disclosure made pursuant to
FRCP 26.
2

This list of Accused Apple Products was created based on publicly available information. Motorola reserves the right to
supplement this list of Accused Apple Products.
3

This chart provides Motorola’s infringement analysis for the Accused Apple Products. In this claim chart, "Apple iPhone"
refers to Apple iPhone 3G S, Apple iPhone 3G, Apple iPhone 4, Apple iPhone 4S. Apple iPad, Apple iPad with 3G, Apple iPad 2,
Apple iPad 2 with 3G, and Apple iPod Touch; whereas "Apple Computer" refers to Apple MacBook, Apple MacBook Pro, Apple
MacBook Air, Apple iMac, Apple Mac Mini, and Apple Mac Pro. Upon information and belief, the analysis set forth in this chart for
"Apple iPhone" applies equally to the Apple iPhone 3G S, Apple iPhone 3G, Apple iPhone 4, Apple iPhone 4S, Apple iPad, Apple
iPad with 3G, Apple iPad 2, Apple iPad 2 with 3G, and Apple iPod Touch; whereas, upon information and belief, the analysis set forth
in this chart for "Apple Computer" applies equally to the Apple MacBook, Apple MacBook Pro, Apple MacBook Air, Apple iMac,
Apple Mac Mini, and Apple Mac Pro.
1

Exhibit F

’161 Patent Claim

Accused Apple Products3

first and second
information between first and second portable messaging units. For example,
portable messaging
units, the method
(1) Using a wireless messaging system (e.g., MobileMe, iCloud, Exchange, Gmail, Yahoo, AOL, SMS,
comprising the steps of: cellular telephone network, etc.), Apple iPhones, Apple iPads and iPods, and Apple Computers can
facilitate an exchange of email address information (address information) between, e.g., an Apple iPhone
(first portable messaging unit) and, e.g., another Apple iPhone (second portable messaging unit).

iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688.
See also id. at MOTO-APPLE-0006037953_126751:

See also, (http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, at MOTOAPPLE-0006037953_126647:

2

Exhibit F

’161 Patent Claim

Accused Apple Products3

(2) In addition, over a cellular telephone network (wireless messaging system, Apple iPhones facilitate the
exchange of text message address information (address information) between, e.g., an Apple iPhone (first
portable messaging unit) and, e.g., another Apple iPhone (second portable messaging unit) ):

3

Exhibit F

’161 Patent Claim

Accused Apple Products3

iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126780.
In addition, Apple has performed each and every step of this claim and through its design of the Accused
Apple Products, Apple also induced users of the Accused Apple Products to infringe the '161 patent.
Apple and Motorola have been in talks since 2007 regarding the licensing of Motorola's patent portfolio,
and, on information and belief, in accordance with those negotiations, Apple has reviewed said portfolio,
including Motorola's '161 Patent. Thus, at least as early as 2007, Apple knew or should have known its
actions would induce actual infringement and possessed specific intent to encourage its customers' direct
infringement through the design of the Accused Apple products. In addition, Apple instructs the users of
the Accused Apple Products to use them in an infringing manner, including but not limited to by
describing infringing uses in its advertisements, promotional materials, labels, and user manuals. See
4

Exhibit F

’161 Patent Claim

Accused Apple Products3
e.g., iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688:

Id. at MOTO-APPLE-0006037953_126751:

(http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, at MOTO-APPLE0006037953_126647:

5

Exhibit F

’161 Patent Claim

Accused Apple Products3

Apple also knew that offering to sell or selling the Accused Apple Products would contribute to direct
infringement of the '161 Patent. As indicated above, at least as early as 2007, Apple knew that offering to
sell or selling the Accused Apple Products would contribute to direct infringement of the '161 Patent.
Apple knew that the Accused Apple Products contain a specific software component for facilitating the
exchange of address information, a component with no substantial non-infringing use, which could be
combined with Apple's MobileMe / iCloud service, and that this combination, for which the component
was especially made, was both patented and infringing. Moreover, users of the Accused Apple Products
have, in fact, combined these components into an infringing method. Apple further contributes to the
direct infringement of the users of the Accused Apple Products, including but not limited to by describing
infringing combinations in its advertisements, promotional materials, and user manuals. See e.g., MOTO6

Exhibit F

’161 Patent Claim

sending the address
information from the
first portable
messaging unit to the
second portable
messaging unit
through the wireless
messaging system;

Accused Apple Products3
APPLE-0006037953_126688, MOTO-APPLE-0006037953_126751, and MOTO-APPLE0006037953_126647, above.
Upon information and belief, Apple iPhones, Apple iPads and iPods, and Apple Computers send the
address information to another portable messaging unit through the wireless messaging system. For
example,
(1) Through a wireless messaging system, a first Accused Apple Product (first portable messaging unit)
can send email address information (address information) to, e.g., a second Accused Apple Product
(second portable messaging unit) :

iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688.
See also, (http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, at MOTOAPPLE-0006037953_126647:

7

Exhibit F

’161 Patent Claim

Accused Apple Products3

(2) In addition, through a cellular telephone network, a first Apple iPhone (first portable messaging unit)
can send text address information (address information) to, e.g., a second Apple iPhone (second portable
messaging unit) .

8

Exhibit F

’161 Patent Claim

Accused Apple Products3

iPhone User Guide for iOS 4.2 and 4.3 Software, MOTO-APPLE-0006037953_126780.
receiving the address
information by the
second portable
messaging unit;

Upon information and belief, the email or text address information is received by the second Accused
Apple Product. For example,
(1) a second Accused Apple Product (second portable messaging unit) can receive email address
information (address information) transmitted by a first Accused Apple Product (first portable messaging
unit):

9

Exhibit F

’161 Patent Claim

Accused Apple Products3

iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688.
See also, (http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, at MOTOAPPLE-0006037953_126647:

10

Exhibit F

’161 Patent Claim

Accused Apple Products3

(2) Also, a second Apple iPhone (second portable messaging unit) can receive text message address
information (address information) transmitted by a first Apple iPhone (first portable messaging unit):

11

Exhibit F

’161 Patent Claim

Accused Apple Products3

iPhone User Guide for iOS 4.2 and 4.3 Software, MOTO-APPLE-0006037953_126780.
checking, by the second
portable messaging unit
in response to the
receiving step, whether
information identical to
the address information
is stored in an address
book of the second
portable messaging

Upon information and belief, the second Accused Apple Product checks, in response to the receiving step,
whether information identical to the email or text address information is stored in its address book. For
example,
(1) Where the second portable messaging unit is an Apple iPhone, iPad, or iPod Touch, after receiving an
email's address information (address information), the user of the second portable messaging unit can
check to determine whether information identical to the email address information is stored in the Contacts
App (the address book) of that Apple iPhone, iPad, or iPod Touch. If not, the Apple iPhone, iPad, or iPod
Touch creates a prompt screen upon user selection of the email address, which allows the user to select the
12

Exhibit F

’161 Patent Claim

Accused Apple Products3

unit; and

email address and either create a new contact or add it to an existing contact:

Id. at MOTO-APPLE-0006037953_126751.

2) Where the second portable messaging unit is an Apple Computer, after receiving an email's address
information (address information), the user of the second portable messaging unit can check to determine
whether information identical to the email address information is stored in the Address Book Application
(the address book) of that Apple Computer. If not, the Apple Computer creates a drop-down list upon user
selection of the email address, from which the user can create a new contact or add it to an existing
contact:

13

Exhibit F

’161 Patent Claim

Accused Apple Products3

Screenshot of Apple Computer Screen, taken May 9, 2011, MOTO-APPLE-0006037953_126641.
(2) Where a text message containing address information (address information) is received by a second
Apple iPhone (second messaging unit), the user of the second portable messaging unit can check to
determine whether information identical to the email address information is stored in the Contacts App (the
address book) of that Apple iPhone. If not, the Apple iPhone creates a prompt screen upon user selection
of the email address, which allows the user to select the email address and either create a new contact or
add it to an existing contact:
14

Exhibit F

’161 Patent Claim

Accused Apple Products3

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126643 (arrows and labels
added).

15

Exhibit F

’161 Patent Claim

Accused Apple Products3

processing the address
information, by the
second portable
messaging unit, in a
predetermined manner
selected in response to
the checking step.

Upon information and belief, as the second portable messaging unit, all Accused Apple Products process
the address information in a predetermined manner selected in response to whether information identical to
the second address information is stored in the address book. For example,
(1) Where the second portable messaging unit is an Apple iPhone, iPad, or iPod Touch (second portable
messaging unit) that device checks to determine whether information identical to the email address
information is stored in the Contacts App (the address book) of the second portable messaging unit. If not,
the second portable messaging unit creates a prompt screen upon user selection of the email address, which
allows the user to either create a new contact or add it to an existing contact:
Where email address information is not in the Second iPhone's Contacts

16

Exhibit F

’161 Patent Claim

Accused Apple Products3

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126645-46 (arrows and
labels added).
See also iPhone User Guide for iOS 4.2 and 4.3 Software at MOTO-APPLE-0006037953_126751:

17

Exhibit F

’161 Patent Claim

Accused Apple Products3

Where the second portable messaging unit is an Apple Computer, that device checks to determine whether
information identical to the email address information is stored in the Address Book Application (the
address book) of the second portable messaging unit. If not, the Apple Computer creates a drop-down list
upon user selection of the email address, from which the user can create a new contact or add it to an
existing contact:

18

Exhibit F

’161 Patent Claim

Accused Apple Products3

Apple Computer Screenshots, taken May 9, 2011, MOTO-APPLE-0006037953_126641.
(2) Also, when a text message containing address information (address information) is received by a
second Apple iPhone (second messaging unit), that device checks to determine whether information
identical to the text address information is stored in the address book of the second Apple iPhone. If not,
the second Apple iPhone creates a prompt button upon user selection of the text message, which allows the
user to select the email address and either create a new contact or add it to an existing contact:

19

Exhibit F

’161 Patent Claim

Accused Apple Products3

Where text address information is not in the Second iPhone's Contacts

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126643 (arrows and labels
added).

20

Exhibit F

’161 Patent Claim

Accused Apple Products3
If identical information is stored in the address book, the contact’s name is displayed at the top of the
screen and a “Contact Info” prompt is added:

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126644 (arrows and labels
added).
See also Additional Photo of Apple Computer Screen where address information is already in the Apple
Computer's address book and no option to "Add to Address Book" is available, taken May 9, 2011,
MOTO-APPLE-0006037953_126642:
21

Exhibit F

’161 Patent Claim

Accused Apple Products3

2. The method of claim
1, wherein the
processing step
comprises the step of
storing the address
information in the

Upon information and belief, the Accused Apple Products perform each and every step of this claim in the
course of their normal use. Additionally, a user of the Accused Apple Products performs each and every
step of this claim in the course of such use. Furthermore, Apple has performed each and every step of this
claim, has actively induced users to perform such steps, and has contributed to such use by selling the
Accused Apple Products and providing directions for their use. The Accused Apple Products perform the
method of Claim 1, wherein the processing step comprises the step of storing the address information in
22

Exhibit F

’161 Patent Claim

Accused Apple Products3

address book, when no the address book, when no information identical to the address information is stored in the address book.
information identical to See Claim 1 contentions above. See, e.g.,
the address information
is stored in the address
book.

iPhone 4 Screenshot, taken January 3, 2011, MOTO-APPLE-0006037953_126645 (arrows and labels
added). As discussed above, Apple Computers generate a drop-down list that prompts the user, if he so
wishes, to store the option of adding the address information , when no information identical to the address
information is stored in the Apple Computer's Address Book application. See Claim 1 contentions above.
See, e.g., Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126641:
23

Exhibit F

’161 Patent Claim

Accused Apple Products3

3. The method of claim
1, wherein the
processing step
comprises the steps of:
generating a prompt
inquiring whether a
user of the second
portable messaging unit
wishes to store the
address information,
when no information
identical to the address
information is stored in
the address book; and

Upon information and belief, the Accused Apple Products perform each and every step of this claim in the
course of their normal use. Additionally, a user of the Accused Apple Products performs each and every
step of this claim in the course of such use. Furthermore, Apple has performed each and every step of this
claim, has actively induced users to perform such steps, and has contributed to such use by selling the
Accused Apple Products and providing directions for their use. The Accused Apple Products perform the
method of Claim 1,wherein the processing step generates a prompt screen inquiring whether the user
wishes to store the address information, when no information identical to the address information is stored
in the second portable messaging unit's Contacts App (address book). See Claim 1 contentions above.
See, e.g.,

24

Exhibit F

’161 Patent Claim

Accused Apple Products3

iPhone 4 Screenshot, taken January 3, 2011, MOTO-APPLE-0006037953_126645 (arrows and labels
added). As discussed above, Apple Computers generate a drop-down list that prompts the user, if he so
wishes, to store the option of adding the address information , when no information identical to the address
information is stored in the Apple Computer's Address Book application. See Claim 1 contentions above.
See, e.g., Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126641:

25

Exhibit F

’161 Patent Claim

Accused Apple Products3

storing the address
information in the
address book, in
response to an
affirmative response to
the prompt by the
user.

Upon information and belief, as discussed above, Apple iPhones, Apple iPads and iPods store the address
information in the Contacts App (address book) in response to an affirmative response to the prompt by
the user. See Claim 1 contentions above. See, e.g.,

26

Exhibit F

’161 Patent Claim

Accused Apple Products3

iPhone 4 Screenshot, taken January 3, 2011, MOTO-APPLE-0006037953_126646 (arrows and labels
added). As discussed above, Apple Computers store the address information in the Address Book
Application (address book) in response to an affirmative response to the prompt by the user. See Claim 1
contentions above. See, e.g., Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE0006037953_126641:
27

Exhibit F

’161 Patent Claim

Accused Apple Products3

5. The method of claim
1, wherein the address
information includes a
unique user identifier
identifying a user of the
first portable messaging
unit, and

Upon information and belief the Accused Apple Products perform each and every step of this claim in the
course of their normal use. Additionally, a user of the Accused Apple Products performs each and every
step of this claim in the course of such use. Furthermore, Apple has performed each and every step of this
claim, has actively induced users to perform such steps, and has contributed to such use by selling the
Accused Apple Products and providing directions for their use. The Accused Apple Products perform the
method of Claim 1, wherein the address information discussed above in claim 1 includes a unique user
identifier identifying a user of the first portable messaging unit.
For example, the address information received can include a cellular telephone number, a user name, or an
email address. See Claim 1 contentions above.
28

Exhibit F

’161 Patent Claim

Accused Apple Products3

wherein the checking
step comprises the step
of checking
whether the unique user
identifier is stored in
the address book.

Upon information and belief, where an Apple iPhone, Apple iPad, or iPod is the second portable
messaging unit, that device will check whether the unique user identifier is stored in the that device's
Contacts App (the address book). Where an Apple Computer is the second portable messaging unit, that
device will check whether the unique user identifier is stored in the that device's Address Book application
(the address book). See Claim 1 contentions above.

9. The method of claim
1, wherein the sending
step comprises the step
of sending to the
second portable
messaging unit a return
address for routing a
message to the first
portable messaging
unit.

Upon information and belief, the Accused Apple Products perform each and every step of this claim in the
course of their normal use. Additionally, a user of the Accused Apple Products performs each and every
step of this claim in the course of such use. Furthermore, Apple has performed each and every step of this
claim, has actively induced users to perform such steps, and has contributed to such use by selling the
Accused Apple Products and providing directions for their use. The Accused Apple Products perform the
method of Claim 1, wherein the sending step comprises the step of an Apple Accused Product (first
portable messaging unit) sending a return address for routing a message to the first portable messaging
unit to the second portable messaging unit.
For example, a first iPhone 4 (first portable messaging unit) can send to a second iPhone 4 (second
portable messaging unit) a telephone number or an email address associated with the first iPhone 4 (return
address). See Claim 1 contentions above.
Upon information and belief, Apple manufactures, sells, offers for sale, imports, and uses the Accused
Apple Products, which are portable messaging units in a wireless messaging system for facilitating the
exchange of address information.

12. A portable
messaging unit in a
wireless messaging
system for facilitating
an exchange of address For example:
information, the
portable messaging unit (1) In a wireless messaging system (e.g., MobileMe, iCloud, Exchange, Gmail, Yahoo, AOL, etc.), any
comprising
Accused Apple Product facilitates an exchange of email address information (address information):

29

Exhibit F

’161 Patent Claim

Accused Apple Products3

See iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688.
See also id. at MOTO-APPLE-0006037953_126751:

See also, (http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, MOTOAPPLE-0006037953_126647:

30

Exhibit F

’161 Patent Claim

Accused Apple Products3

See also, (http://www.apple.com/why-mac/better-hardware/), accessed on May 14, 2011, MOTO-APPLE0006037953_126649:

31

Exhibit F

’161 Patent Claim

Accused Apple Products3

(2) In a cellular telephone network (wireless messaging system), Apple iPhones facilitate the exchange of
text address information (address information):

32

Exhibit F

’161 Patent Claim

Accused Apple Products3

iPhone User Guide for iOS 4.2 and 4.3 Software, MOTO-APPLE-0006037953_126780.
In addition, Apple has performed each and every step of this claim and through its design of the Accused
Apple Products, Apple also induced users of the Accused Apple Products to infringe the '161 patent.
Apple and Motorola have been in talks since 2007 regarding the licensing of Motorola's patent portfolio,
and, on information and belief, in accordance with those negotiations, Apple has reviewed said portfolio,
including Motorola's '161 Patent. Thus, at least as early as 2007, Apple knew or should have known its
actions would induce actual infringement and possessed specific intent to encourage its customers' direct
infringement through the design of the Accused Apple products. In addition, Apple instructs the users of
the Accused Apple Products to use them in an infringing manner, including but not limited to by
describing infringing uses in its advertisements, promotional materials, labels, and user manuals. See
e.g., iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688:
33

Exhibit F

’161 Patent Claim

Accused Apple Products3

Id. at MOTO-APPLE-0006037953_126751:

(http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, at MOTO-APPLE0006037953_126647:

34

Exhibit F

’161 Patent Claim

Accused Apple Products3

Apple also knew that offering to sell or selling the Accused Apple Products would contribute to direct
infringement of the '161 Patent. As indicated above, at least as early as 2007, Apple knew that offering to
sell or selling the Accused Apple Products would contribute to direct infringement of the '161 Patent.
Apple knew that the Accused Apple Products contain a specific software component for facilitating the
exchange of address information, a component with no substantial non-infringing use, which could be
combined with Apple's MobileMe / iCloud service, and that this combination, for which the component
was especially made, was both patented and infringing. Moreover, users of the Accused Apple Products
have, in fact, combined these components into an infringing method. Apple further contributes to the
direct infringement of the users of the Accused Apple Products, including but not limited to by describing
infringing combinations in its advertisements, promotional materials, and user manuals. See e.g., MOTO35

Exhibit F

’161 Patent Claim

Accused Apple Products3
APPLE-0006037953_126688, MOTO-APPLE-0006037953_126751, and MOTO-APPLE0006037953_126647, above.

a transmitter for
sending address
information to another
portable messaging unit
through the wireless
messaging system

Upon information and belief, all Accused Apple Products have a transmitter for sending address
information to another portable messaging unit (e.g., another Accused Apple Product) through the wireless
messaging system. For example:
1) Apple iPhones and Apple iPads with 3G contain cellular hardware and software (transmitter) for
sending text message and/or email address information to another portable messaging unit, e.g., an Apple
iPhone through a cellular telephone network (wireless messaging system):

iPhone 4 Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed on May 12, 2011,
MOTO-APPLE-0006037953_126659.
See also iPhone User Guide for iOS 4.2 and 4.3 Software, MOTO-APPLE-0006037953_126780.

36

Exhibit F

’161 Patent Claim

Accused Apple Products3

2) All Accused Apple Products contain wireless hardware (transmitter) allowing it to send, e.g., email
address information to another portable messaging unit (e.g., another Accused Apple Product) though a
wireless messaging system (MobileMe, iCloud, Exchange, Gmail, Yahoo, AOL, etc.):

37

Exhibit F

’161 Patent Claim

Accused Apple Products3

MobileMe Features, (http://www.apple.com/mobileme/features/), accessed on May 13, 2011, MOTOAPPLE-0006037953_127187.
See iPad Features, (http://www.apple.com/ipad/features/), accessed on May 14, 2011, MOTO-APPLE0006037953_127244-45:

38

Exhibit F

’161 Patent Claim

Accused Apple Products3

See also iPad Built-in-Apps, (http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14,
2011, MOTO-APPLE-0006037953_126647:

39

Exhibit F

’161 Patent Claim

Accused Apple Products3

See also iPhone Features, (http://www.apple.com/iphone/features/mail.html), accessed on May 14, 2011,
MOTO-APPLE-0006037953_126648:

40

Exhibit F

’161 Patent Claim

Accused Apple Products3

See also, (http://www.apple.com/why-mac/better-hardware/), accessed on May 14, 2011, MOTO-APPLE0006037953_126649:

41

Exhibit F

’161 Patent Claim

Accused Apple Products3

a receiver coupled to
the processing system
for receiving second
address information
from another portable
messaging unit

Upon information and belief, the Accused Apple Products each have a receiver coupled to the processing
system for receiving second address information from another portable messaging unit.
For example, the Apple iPhone contains a logic board with receiver circuitry (receiver coupled to the
processing system) that allows the Apple iPhone to receive, e.g., email and text message address
information from another Apple iPhone (another portable messaging unit).
See, e.g., iPhone 3G Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/2), accessed
on May 13, 2011, MOTO-APPLE-0006037953_127192-95 (arrows and labels added):

42

Exhibit F

’161 Patent Claim

Accused Apple Products3

43

Exhibit F

’161 Patent Claim

Accused Apple Products3

44

Exhibit F

’161 Patent Claim

Accused Apple Products3

45

Exhibit F

’161 Patent Claim

Accused Apple Products3
For example, the Apple iPhone contains a logic board with receiver circuitry (receiver coupled to the
processing system) that allows the Apple iPhone to receive, e.g., email address information from another
Accused Apple Product (another portable messaging unit).
See, e.g., iPad 3G Teardown, (http://www.ifixit.com/Teardown/iPad-3G-Teardown/2374/2), accessed on
May 14, 2011, MOTO-APPLE-0006037953_127230-31:

46

Exhibit F

’161 Patent Claim

Accused Apple Products3

For example, the Apple Computer contains a logic board with receiver circuitry (receiver coupled to the
processing system) that allows the Apple Computer to receive, e.g., email address information from
another Accused Apple Product (another portable messaging unit).
See, e.g., MacBook Pro 15" Core 2 Duo Model A1211 Teardown,
(http://www.ifixit.com/Teardown/MacBook-Pro-15-Inch-Core-2-Duo-Model-A1211-Teardown/593/1),
accessed on May 14, 2011, MOTO-APPLE-0006037953_127250:

47

Exhibit F

’161 Patent Claim

Accused Apple Products3

where the processing
system is programmed
to: check in response
to receiving the second
address information,
whether information
identical to the second
address information is
stored in an address
book of the portable
messaging unit; and

Upon information and belief, the processing system in any Accused Apple Devices is programmed to
check in response to receiving the second address information whether information identical to the second
address information is stored in its address book. For example:
(1) where the portable messaging unit is an Apple iPhone, iPad, or iPod Touch that has received the second
address information, it will check whether information identical to the address information contained in the
email is stored in the Contacts App (address book) of the second Apple iPhone. If not, a prompt screen is
displayed upon user selection of the email address, and the user can then either create a new contact or add
it to an existing contact:

48

Exhibit F

’161 Patent Claim

Accused Apple Products3

49

Exhibit F

’161 Patent Claim

Accused Apple Products3

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126645-46 (arrows and
labels added).
See also iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126751.
50

Exhibit F

’161 Patent Claim

Accused Apple Products3

Where the second portable messaging unit is an Apple Computer that has received the second address
information, it will check whether information identical to the address information contained in the email
is stored in the Address Book Application (address book) of the second portable messaging unit. If not, the
Apple Computers generates a drop-down list that prompts the user, if he so wishes, to store the option of
adding the address information.

51

Exhibit F

’161 Patent Claim

Accused Apple Products3

Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126641.

(2) Where a text message containing address information (address information) is received, a second Apple
iPhone (second messaging unit) checks to determine whether information identical to the address
information contained in the text message is stored in the address book of the second Apple iPhone. If not,
the second Apple iPhone creates a prompt button upon user selection of the text message, which allows the
user to select the email address and either create a new contact or add it to an existing contact:
52

Exhibit F

’161 Patent Claim

Accused Apple Products3

See iPhone 4 Screen, taken January 3, 2011, MOTO-APPLE-0006037953_126643 (arrows and labels
added).
process the second
address information in
a predetermined

Upon information and belief, the Accused Apple Products process the address information in a
predetermined manner selected in response to whether information identical to the second address
information is stored in the address book. For example,
53

Exhibit F

’161 Patent Claim

Accused Apple Products3

manner selected in
response to whether
information identical to
the second address
information is stored in
the address book.

(1) Where an email message containing address information (address information) is received, a second
Apple iPhone (second messaging unit) checks to determine whether information identical to the address
information contained in the email is stored in the address book of the second Apple iPhone. If not, the
second Apple iPhone creates a prompt screen upon user selection of the email address, which allows the
user to select the email address and either create a new contact or add it to an existing contact:

54

Exhibit F

’161 Patent Claim

Accused Apple Products3

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126645-46 (arrows and
labels added).
55

Exhibit F

’161 Patent Claim

Accused Apple Products3
See also User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126751:

Where an email message containing address information (address information) is received, a second Apple
Computer (second messaging unit) checks to determine whether information identical to the address
information contained in the email is stored in the address book of the second Apple Computer. If not, the
Apple Computers generates a drop-down list that prompts the user, if he so wishes, to store the option of
adding the address information.

56

Exhibit F

’161 Patent Claim

Accused Apple Products3

See Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126641.
(2) Where a text message containing address information (address information) is received, a second Apple
iPhone (second messaging unit) checks to determine whether information identical to the address
information contained in the text message is stored in the address book of the second Apple iPhone. If not,
the second Apple iPhone creates a prompt button upon user selection of the text message, which allows the
user to select the email address and either create a new contact or add it to an existing contact:

57

Exhibit F

’161 Patent Claim

Accused Apple Products3

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126643 (arrows and labels
added).

If identical information is stored in the address book, the contact’s name is displayed at the top of the
screen and a “Contact Info” prompt is added:

58

Exhibit F

’161 Patent Claim

Accused Apple Products3

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126644 (arrows and labels
added).
See also Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126642:

59

Exhibit F

’161 Patent Claim

Accused Apple Products3

13. The method of
claim 12, wherein the
processing system is
further programmed to
store the second
address information in
the address book, when
no information
identical to the second

Upon information and belief, Apple manufactures, sells, offers for sale, imports, and uses the Accused
Apple Products, which are portable messaging units according to claim 12, wherein the processing system
of the Accused Apple Products are programmed to store the second address information in the address
book, when no information identical to the second address information is stored in the address book. See,
e.g.,

60

Exhibit F

’161 Patent Claim

Accused Apple Products3

address information is
stored in the address
book.

iPhone 4 Screenshot, taken January 3, 2011, MOTO-APPLE-0006037953_126645 (arrows and labels
added). As discussed above, Apple Computers generate a drop-down list that prompts the user, if he so
wishes, to store the option of adding the address information , when no information identical to the address
information is stored in the Apple Computer's Address Book application. See Claim 12 contentions above.
See, e.g., Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126641:
14. The portable
Upon information and belief, Apple manufactures, sells, offers for sale, imports, and uses the Accused
messaging unit of claim Apple Products, which are portable messaging units according to claim 12, wherein the processing system
61

Exhibit F

’161 Patent Claim

Accused Apple Products3

12, wherein the
processing system is
further programmed to
generate a prompt
inquiring whether a
user of the portable
messaging unit wishes
to store the address
information, when no
information identical to
the second address
information is stored in
the address book; and
store the second
address information in
the address book, in
response to an
affirmative response to
the prompt by the user.

of the Accused Apple Products are programmed to generate a prompt inquiring whether a user wishes to
store address information, when no information identical to the second address information is stored in the
address book. See Claim 12 contentions above.

Upon information and belief, the Accused Apple Products store the second address information in the
address book, in response to an affirmative response to the prompt by the user. See Claim 12 contentions
above.

62