Motorola Mobility, Inc. v. Apple, Inc.

Filing 282

NOTICE by Apple, Inc. Notice of Filing of Declaration of Jill J. Ho in Support of Apple Inc.'s Motion to Compel Production of Documents and Testimony Regarding Set-Top Box Components and Exhibits Thereto (Attachments: # 1 Affidavit Declaration of Jill J. Ho in Support of Apple Inc.'s Motion to Compel Production of Documents and Testimony Regarding Set-Top Box Components, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit G, # 6 Exhibit H)(Pace, Christopher)

EXHIBIT G

Apple v. Motorola
Proposed Constructions for SDFL Patents
Patent
’006

Term

’531

“data units not sent from the host to
the communication unit”
“wireless network”

’531

“virtual session”

’531

“filtered data unit”

’531

“subsequent filtered data unit”

’119

“responsive to receiving the second
message, transmitting a third
message”
“indicative of the second status”

’119
’987

’987
’737

“the antenna . . . is disposed between
an outside surface of the housing and
the at least a portion of the user
interface”
“substantially planar and detachable
cover . . . for concealing the antenna”
“authorization element … for
obtaining usage authorization for
utilizing software in the portable
communication device, in which the
authorization element generates an
external authorization request, and in
which the authorization element
communicates with the fixed portion
to obtain the usage authorization”

Proposed Construction
“data units present at the host and not sent to the communication unit”
“a network in which the communication server is connected to both the host device
and the client communication unit through a completely wireless path”
“a mode of communication between two devices that involves the commitment of
communication resources only on an event-driven basis but in which both devices are
in possession of and have stored information about the other on an ongoing basis”
“one of a subset of data units at the host device that are selected for download to the
client communication unit based on having passed a filter”
See proposed construction of “filtered data unit.” “Subsequent” has its plain and
ordinary meaning
“upon receiving the second message, automatically transmitting a third message”

“descriptive of the changed status”
“the entire antenna is placed between the outside surface of the receiver’s case and
the portion of the user interface surrounded by the antenna”
“a detachable cover shaped as a substantially flat sheet for concealing the entire
antenna”
Under § 112 ¶ 6, the function is “obtaining usage authorization for utilizing software
in the portable communication device, in which the authorization element generates
an external authorization request, and in which the authorization element
communicates with the fixed portion to obtain the usage authorization.”
The corresponding structure is: processor 308, secure polynomial 311, transmitter
controller 336, secure checksum calculator 338 and sender 340; the processor
programmed to perform the disclosed algorithm including calculating a secure
checksum on the software for which authorization is sought, creating a request
containing the checksum, the software name and the software size, and transmitting
the encrypted request.

Alternative construction, if § 112, ¶ 6 does not apply: “an external authorizer
algorithm, including a radio authorizer algorithm, a transmitter controller algorithm, a
secure checksum calculator algorithm that uses a secure polynomial, and a sender
algorithm”
’737
’646/’116

’646/’116

“address identifying the portable
communication device”
“Determi[ning][es] whether [a] device
. . . is a video device” /
“Detect[ing][s] . . . a display device”

“Modifying the allocation of display
space” / “a portion of the display
space to be modified”

’560

“Interface generator”

’509/’456

“Interface generation means”

“a number used to direct messages that uniquely identifies a portable communication
device”
Apple believes that these phrases should be construed separately as follows:
Determin[ing][es]…
Plain and ordinary meaning applies or, in the alternative: “determine whether a device
is or is not capable of displaying video”
Detect[ing][s]…
Plain and ordinary meaning applies or, in the alternative: “detecting a device capable
of displaying”
Apple believes that these phrases should be construed separately as follows:
Modifying…
Plain and ordinary meaning applies or, in the alternative: “allocating or deallocating
display space”
...a portion of…
Plain and ordinary meaning applies or, in the alternative: “a part of the display space
to be allocated or deallocated”
Plain and ordinary meaning applies or, in the alternative: “that which generates a
listing interface”
Apple believes that these phrases should be construed separately as follows:
’509
Under § 112 ¶ 6, the function is “causing an A/V display to display an interface.”
The corresponding structure is: a combination of the CPU module 62, which receives
the data stream of program listings, the system memory 65, which stores the section
of the program listings most relevant to the user, A/V processor 77, which is “used to
manipulate, process, render, mix, and otherwise rearrange digital data into coherent
audio-visual displays,” and A/V connect module 66, which “provides a graphic
overlay function that superimposes an A/V signal from the video encoder 78 against
another A/V signal” that allows “both signals to be simultaneously displayed on the
TV.”
’456
Under § 112 ¶ 6, the function is “causing an A/V display to selectively display a
program listing.”

2

’560/’509/’456

“Listing interface”

’509/’456

“Listing means” / “Listing interface
means”

’560/’509/’456

“Controller in communication with” /
“Control means in communication
with”

The corresponding structure is: a combination of the CPU module 62, which receives
the data stream of program listings, the system memory 65, which stores the section
of the program listings most relevant to the user, A/V processor 77, which is “used to
manipulate, process, render, mix, and otherwise rearrange digital data into coherent
audio-visual displays,” and A/V connect module 66, which “provides a graphic
overlay function that superimposes an A/V signal from the video encoder 78 against
another A/V signal” that allows “both signals to be simultaneously displayed on the
TV.”
Plain and ordinary meaning applies or, in the alternative: “an interactive interface for
listing A/V program information”
Apple believes that these phrases should be construed separately as follows:
’509
Under § 112 ¶ 6, the function is “causing an A/V display to selectively display a
program listing that contains listing information related to A/V programs viewable on
the A/V display.”
The corresponding structure is: a combination of the CPU module 62, which receives
the data stream of program listings, the system memory 65, which stores the section
of the program listings most relevant to the user, A/V processor 77, which is “used to
manipulate, process, render, mix, and otherwise rearrange digital data into coherent
audio-visual displays,” and A/V connect module 66, which “provides a graphic
overlay function that superimposes an A/V signal from the video encoder 78 against
another A/V signal” that allows “both signals to be simultaneously displayed on the
TV.”
’456
Under § 112 ¶ 6, the function is “causing an A/V display to selectively display a
program listing.”
The corresponding structure is: a combination of the CPU module 62, which receives
the data stream of program listings, the system memory 65, which stores the section
of the program listings most relevant to the user, A/V processor 77, which is “used to
manipulate, process, render, mix, and otherwise rearrange digital data into coherent
audio-visual displays,” and A/V connect module 66, which “provides a graphic
overlay function that superimposes an A/V signal from the video encoder 78 against
another A/V signal” that allows “both signals to be simultaneously displayed on the
TV.”
Apple believes that these phrases should be construed separately as follows:
’560
Plain and ordinary meaning applies or, in the alternative: “controller that sends
commands to”

3

’509
Under § 112 ¶ 6, the function is “sending commands to the transceiver to allow a user
to selectively display multiple levels of information on an A/V display.”
The corresponding structure is: remote control 60 or equivalent structure.

’849

“Gesture”

’849

“Moving an unlock image”

’456
Under § 112 ¶ 6, the function is “sending commands to the transceiver to allow a user
to display A/V programs on an A/V display.”
The corresponding structure is: remote control 60 or equivalent structure.
Plain and ordinary meaning applies or, in the alternative: “a motion of the
object/appendage making contact with the touch screen”
“causing an unlock image to change position over time via continuous contact with
the touch screen”

4