Motorola Mobility, Inc. v. Apple, Inc.

Filing 218

AFFIDAVIT signed by : Jill Ho. re 217 Response in Opposition to Motion Declaration of Jill Ho in Support of Apple's Opposition (D.E. 217) by Apple, Inc. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L)(Pace, Christopher)

Exhibit H

JUNE 20, 2011

Apple v. Motorola S.D. Florida
Motorola Mobility's and Motorola Solutions'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING
INVALIDITY OF U.S. PATENT NO. 6,282,646
Asserted Claims: 1, 10, 13, 14, 16, 32
At least the following references, alone or in combination with the knowledge of one of ordinary skill in the art or
with other prior art, establish invalidity of all Asserted Claims of U.S. Patent 6,282,646 ("the '646 Patent"), as those
claims are broadly asserted by Apple against the Accused Products.
References anticipating one or more claims of the '646 Patent under § 102 or, in the alternative, rendering them
obvious under § 103 alone or in combination with other references:
(1)

Hewlett Packard OmniBook 800 ("OmniBook")

(2)

U.S. Patent No. 6,049,316 ("Nolan")

(3)

U.S. Patent No. 6,247,079 ("Papa")

(4)

U.S. Patent No. 5,038,301 (Thoma)

(5)

U.S. Patent No. 5,072,411 (Yamaki)

(6)

U.S. Patent No. 5,386,567 (Lien et al.) ("Lien")

(7)

U.S. Patent No. 5,159,683 (Lvovsky et. al.) ("Lvovsky")
1

JUNE 20, 2011

(8)

U.S. Patent No. 5,459,825 (Anderson et al.) ("Anderson")

(9)

U.S. Patent No. 5,506,602 (Yokoyama)

(10) U.S. Patent No. 5,581,788 (Ballare)
(11) U.S. Patent No. 5,682,529 (Hendry)
(12) Azinger, Eric, "Radius display can fit different orientations," July 22, 1991 ("Radius Monitor").
(13) U.S. Patent No. 5,768,541 (Pan-Ratzlaff)
(14) Japanese Patent App. Pub. No. H7-271473 (Ninomiya)
(15) U.S. Patent No. 4,922,448 (Kunieda et al.) ("Kunieda")
(16) U.S. Patent No. 5,014,193 (Garner et al.) ("Garner")
(17) U.S. Patent No. 5,276,458 ("Sawdon")
(18) U.S. Patent No. 5,872,998 ("Chee")
(19) U.S. Patent No. 5,926,166 ("Khederzadeh")
(20) U.S. Patent No. 6,032,202 (“Lea”)
(21) U.S. Patent No. 6,263,387 ("Chrabaszcz")

2

JUNE 20, 2011

(22) U.S. Patent No. 7,053,864 (“Lee”)
(23) U.S. Patent No. 5,559,525 (“Zenda”)
(24) U.S. Patent No. 5,627,974 (“Watts”)
(25) U.S. Patent No. 5,590,376 ("Kou")
(26) U.S. Patent No. 5,825,359 ("Derby")
(27) U.S. Patent No. 5,923,307 ("Hogle, IV")
(28) Plug and Play BIOS Specification, Version 1.0A, May 5, 1994, by Compaq Computer Corporation, Phoenix
Technologies, Ltd., and Intel Corporation

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APPLE V. MOTOROLA S.D. FLORIDA
MOTOROLA MOBILITY'S AND MOTOROLA SOLUTIONS'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING INVALIDITY OF U.S. PATENT NO. 6,282,646

JUNE 20, 2011

Reference: Plug and Play BIOS Specification, Version 1.0A, May 5, 1994, by Compaq Computer Corporation,
Phoenix Technologies, Ltd., and Intel Corporation
U.S. Patent No.
6,282,646
1. A method for
reconfiguring a
computer system to
accommodate
changes in a display
environment,
comprising the
steps of:

Disclosure in PnP BIOS
PnP BIOS discloses a method for reconfiguring a computer system to accommodate changes in a display
environment.
See e.g., PnP BIOS p. 15

See e.g., PnP BIOS p. 15

detecting the
addition or removal
of an input/output
device in the
computer system;

PnP Bios discloses detecting the addition or removal of an input/output device in the computer system.
See e.g., PnP BIOS p. 5

297

APPLE V. MOTOROLA S.D. FLORIDA
MOTOROLA MOBILITY'S AND MOTOROLA SOLUTIONS'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING INVALIDITY OF U.S. PATENT NO. 6,282,646

JUNE 20, 2011

See e.g., PnP BIOS p. 21

determining
PnP Bios discloses determining whether an input/output device which has been added or removed is a video device,
whether an
in response to said detection
input/output device
See e.g., PnP BIOS p 34
which has been
added or removed is
a video device, in
response to said
detection;
See e.g., PnP BIOS p. 36

See e.g., PnP BIOS p. 21

298

APPLE V. MOTOROLA S.D. FLORIDA
MOTOROLA MOBILITY'S AND MOTOROLA SOLUTIONS'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING INVALIDITY OF U.S. PATENT NO. 6,282,646

providing a
notification to a
display manager
when a
determination is
made that a video
device has been
added or removed;
and

JUNE 20, 2011

PnP BIOS discloses providing a notification to a display manager when a determination is made that a video device
has been added or removed.
See e.g., PnP BIOS p 34

See e.g., PnP BIOS p. 36

See e.g., PnP BIOS p. 21

299

APPLE V. MOTOROLA S.D. FLORIDA
MOTOROLA MOBILITY'S AND MOTOROLA SOLUTIONS'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING INVALIDITY OF U.S. PATENT NO. 6,282,646

JUNE 20, 2011

modifying the
PnP BIOS discloses modifying the allocation of display space to display devices via said display manager, in
allocation of display accordance with the addition or removal of a video device.
space to display
See e.g., PnP BIOS p. 15
devices via said
display manager, in
accordance with the
addition or removal
of a video device.
See e.g., PnP BIOS p. 15

300

APPLE V. MOTOROLA S.D. FLORIDA
MOTOROLA MOBILITY'S AND MOTOROLA SOLUTIONS'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING INVALIDITY OF U.S. PATENT NO. 6,282,646

10. A system which
provides hotplugging
capabilities for
display devices,
comprising:

JUNE 20, 2011
PnP Bios discloses a system which provides hot-plugging capabilities for display devices.
See e.g., PnP BIOS p 34

See e.g., PnP BIOS p. 36

a video device
including a frame
buffer for storing
data that defines an
image to be
displayed on an
associated display
device;
a display manager
which defines a
display space and
assigns a portion of
said display space
to said frame buffer,
and which provides
data for images to
be displayed to said
frame buffer; and

This claim element is also contained explicitly and/or inherently in one or more of the prior art references listed in
the pleading and/or is contained in the knowledge of one of skill in the art, and one of ordinary skill in the art
would have been motivated to combine the charted reference with one or more of the prior art references and/or the
knowledge of one skilled in the art. Motorola Mobility reserves the right to supplement this chart and/or add prior
art references to the pleading.

This claim element is also contained explicitly and/or inherently in one or more of the prior art references listed in
the pleading and/or is contained in the knowledge of one of skill in the art, and one of ordinary skill in the art
would have been motivated to combine the charted reference with one or more of the prior art references and/or the
knowledge of one skilled in the art. Motorola Mobility reserves the right to supplement this chart and/or add prior
art references to the pleading.

301

APPLE V. MOTOROLA S.D. FLORIDA
MOTOROLA MOBILITY'S AND MOTOROLA SOLUTIONS'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING INVALIDITY OF U.S. PATENT NO. 6,282,646

a device manager
which detects the
addition or removal
of a device in a
computer system,
determines whether
a device which has
been added or
removed is a video
device, and
provides a
notification of such
addition or removal
to the display
manager when a
video device is
determined to have
been added or
removed, to cause
the assignment of a
portion of the
display space to be
modified in
accordance with a
detected addition or
removal.

13. A system which
provides hotplugging
capabilities for
display devices,

JUNE 20, 2011
This claim element is also contained explicitly and/or inherently in one or more of the prior art references listed in
the pleading and/or is contained in the knowledge of one of skill in the art, and one of ordinary skill in the art
would have been motivated to combine the charted reference with one or more of the prior art references and/or the
knowledge of one skilled in the art. Motorola Mobility reserves the right to supplement this chart and/or add prior
art references to the pleading.

PnP Bios discloses a system which provides hot-plugging capabilities for display devices.
See e.g., PnP BIOS p 34

302

APPLE V. MOTOROLA S.D. FLORIDA
MOTOROLA MOBILITY'S AND MOTOROLA SOLUTIONS'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING INVALIDITY OF U.S. PATENT NO. 6,282,646

JUNE 20, 2011

comprising:

See e.g., PnP BIOS p. 36

at least one display
for displaying
images;

This claim element is also contained explicitly and/or inherently in one or more of the prior art references listed in
the pleading and/or is contained in the knowledge of one of skill in the art, and one of ordinary skill in the art
would have been motivated to combine the charted reference with one or more of the prior art references and/or the
knowledge of one skilled in the art. Motorola Mobility reserves the right to supplement this chart and/or add prior
art references to the pleading.

a display manager
which defines a
display space and
assigns a portion of
said display space
to a display device,
and which provides
data for images to
be displayed on said
display device; and

This claim element is also contained explicitly and/or inherently in one or more of the prior art references listed in
the pleading and/or is contained in the knowledge of one of skill in the art, and one of ordinary skill in the art
would have been motivated to combine the charted reference with one or more of the prior art references and/or the
knowledge of one skilled in the art. Motorola Mobility reserves the right to supplement this chart and/or add prior
art references to the pleading.

a device manager
which detects the
addition or removal
of a device in a
computer system,
determines whether

This claim element is also contained explicitly and/or inherently in one or more of the prior art references listed in
the pleading and/or is contained in the knowledge of one of skill in the art, and one of ordinary skill in the art
would have been motivated to combine the charted reference with one or more of the prior art references and/or the
knowledge of one skilled in the art. Motorola Mobility reserves the right to supplement this chart and/or add prior
art references to the pleading.

303

APPLE V. MOTOROLA S.D. FLORIDA
MOTOROLA MOBILITY'S AND MOTOROLA SOLUTIONS'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING INVALIDITY OF U.S. PATENT NO. 6,282,646

JUNE 20, 2011

a device which has
been added or
removed is a
display device, and
provides a
notification of such
addition or removal
to the display
manager when a
display device is
determined to have
been added or
removed, to cause
the assignment of a
portion of the
display space to be
modified in
accordance with a
detected addition or
removal.
14. The system of
claim 13 further
including a frame
buffer which is
associated with an
assigned portion of
the display space,
and wherein said
display manager
modifies said
assignment by
associating said

This claim element is also contained explicitly and/or inherently in one or more of the prior art references listed in
the pleading and/or is contained in the knowledge of one of skill in the art, and one of ordinary skill in the art
would have been motivated to combine the charted reference with one or more of the prior art references and/or the
knowledge of one skilled in the art. Motorola Mobility reserves the right to supplement this chart and/or add prior
art references to the pleading.

304

APPLE V. MOTOROLA S.D. FLORIDA
MOTOROLA MOBILITY'S AND MOTOROLA SOLUTIONS'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING INVALIDITY OF U.S. PATENT NO. 6,282,646

frame buffer with
said display device.
16. A computerreadable medium
containing a device
manager program
and a display
manager program,
wherein said device
manager program
performs the steps
of
detecting the
addition or removal
of an input/output
device in a
computer system,
determining
whether the
input/output device
is a video device,
and
providing a
notification to the
display manager
program when a
video device is
added or removed;
and wherein said
display manager
performs the step
of: modifying the
allocation of display

JUNE 20, 2011

PnP BIOS discloses a computer-readable medium containing a device manager program and a display manager
program.

PnP Bios discloses detecting the addition or removal of an input/output device in a computer system. See Claim 1
above.

PnP Bios discloses determining whether the input/output device is a video device. See Claim 1 above.

PnP BIOS discloses providing a notification to the display manager program when a video device is added or
removed. See Claim 1 above.

PnP BIOS discloses said display manager performs the step of: modifying the allocation of display space to display
devices in response to said notification from the device manager. See Claim 1 above.

305

APPLE V. MOTOROLA S.D. FLORIDA
MOTOROLA MOBILITY'S AND MOTOROLA SOLUTIONS'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING INVALIDITY OF U.S. PATENT NO. 6,282,646

space to display
devices in response
to said notification
from the device
manager.
32. A computerreadable medium
containing a device
manager program
and a display
manager program,
wherein said device
manager program
performs the steps
of:
detecting the
addition or removal
of a video device in
a computer system,
and
providing a
notification to the
display manager
program when a
video device is
added or removed;
and wherein said
display manager
performs the step
of: modifying the
allocation of display
space to display
devices in response

JUNE 20, 2011

PnP BIOS discloses a computer-readable medium containing a device manager program and a display manager
program. See Claim 16 above.

PnP Bios discloses detecting the addition or removal of an input/output device in a computer system. See Claim 1
above.

PnP BIOS discloses providing a notification to the display manager program when a video device is added or
removed. See Claim 1 above.

PnP BIOS discloses said display manager performs the step of: modifying the allocation of display space to display
devices in response to said notification from the device manager.
See e.g., PnP BIOS p 34

306

APPLE V. MOTOROLA S.D. FLORIDA
MOTOROLA MOBILITY'S AND MOTOROLA SOLUTIONS'
REPRESENTATIVE CLAIM CHARTS ESTABLISHING INVALIDITY OF U.S. PATENT NO. 6,282,646

JUNE 20, 2011

to said notification
from the device
manager, and

See e.g., PnP BIOS p. 36

reconfiguring at
least one computer
resource in
accordance with the
modification of the
display space
allocation.

PnP BIOS discloses reconfiguring at least one computer resource in accordance with the modification of the
display space allocation.
See e.g., PnP BIOS p 34

See e.g., PnP BIOS p. 36

307