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 H

Motorola's Proposed Claim Constructions
Case No. 1:10cv023580-Civ-UU
#
1

Patent
Number(s)
'531

Claim Term / Phrase
To Be Construed
Subsequent filtered data units

2

'646 / '116

Determi[ning][es] whether [a]
device . . . is a video device

Motorola's Proposed Construction
Data units that have been filtered by both the first and second set of
user-selected criteria
Having the device manager, which is an operating system component
and not a device driver, specifically determine that the device is a
video display device

Detect[ing][s] . . . a display
device

4

'646 / '116

'560

02426.51753/4221429.3

Modifying the allocation of
display space

Changing the allotment of the global coordinate space available for
use by display devices

A portion of the display space
to be modified

3

An allotment of the global coordinate space, available for use by
display devices, to be changed

Interface generator

A software application executing on the CPU that causes the A/V
display to display a graphical user interface for selecting and
displaying cable television or other audio-visual programs, as well as
controlling various audio-visual devices and interactive services.

5

'509 / '456

Interface generation means

This element is subject to U.S.C. § 112 ¶ 6.
Structure: A central processing unit (CPU), a system bus; an A/V
decoder; a wireless control unit; a system memory unit; an A/V
memory unit; a memory and bus controller; an A/V encoder; a highspeed digital A/V bus; an A/V processor; one or more
tuners/demodulators, wherein one tuner/demodulator reads and
displays a current program from one of the channels received;
additional tuners/demodulators (or the same tuner/demodulator, used
in alternation) to read and display data from the side-band channels in
picture-in-picture (pip) windows; a remote control device including a
transmitter for transmitting signals to the audio-visual system; and
software applications that generate picture-in-picture windows,
program listing information, program recording, and other interactive
functions. See, e.g., '509 patent, FIG. 2; 8:50-10:46.
Function: Causing the A/V display to display a graphical user
interface for selecting and displaying cable television or other audiovisual programs, as well as controlling various audio-visual devices
and interactive services.

6

'560 / '509 /
'456

02426.51753/4221429.3

Listing interface

A software application executing on the CPU causing the A/V
display to selectively display one level of the multiple levels of
information related to an audio-visual program, that level containing
a list of information (including at least channel numbers, channel
names, and/or titles) about the viewable audio-visual programs

7

'509 / '456

Listing means / Listing
interface means

This element is subject to U.S.C. § 112 ¶ 6.
Structure: A central processing unit (CPU), a system bus; an A/V
decoder; a wireless control unit; a system memory unit; an A/V
memory unit; a memory and bus controller; an A/V encoder; a highspeed digital A/V bus; an A/V processor; one or more
tuners/demodulators, wherein one tuner/demodulator reads and
displays a current program from one of the channels received;
additional tuners/demodulators (or the same tuner/demodulator, used
in alternation) to read and display data from the side-band channels in
picture-in-picture (pip) windows; a remote control device including a
transmitter for transmitting signals to the audio-visual system; and
software applications that generate picture-in-picture windows,
program listing information, and other interactive listing functions.
See, e.g., '509 patent FIG. 2; 8:50-10-46.

8

'560 / '509 /
'456

Controller in communication
with /
Control means in
communication with

Function: Causeing the A/V display to selectively display one level
of the multiple levels of information related to an audio-visual
program, that level containing a list of information (including at least
channel numbers, channel names, and titles) about the viewable
audio-visual programs
Controller in communication with : A hand-held remote control
containing a transmitter for transmitting signals wirelessly to the
transceiver.
Control means in communication with: This element is subject to
U.S.C. § 112 ¶ 6.
Structure: A hand-held remote control containing a transmitter.
See, e.g., Abstract; col. 8:42-46.
Function: transmitting signals wirelessly to the transceiver

02426.51753/4221429.3

9

'849

Gesture

A motion of the object/appendage making contact with the
touch screen display..

10

'849

Moving an unlock image

11

‘006

12

‘531

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

Translating the unlock image from one portion of the coordinate
space of touch-sensitive display to another
Ordinary meaning

13

‘531

“virtual session”

14

‘531

"filtered data unit"

15

‘119

16

‘119

17

‘987

18

‘987

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

02426.51753/4221429.3

Ordinary meaning, but in the alternative, two or more devices
whose interconnection(s) is implemented, at least in part, without the
use of wires
a communication that occurs on an event-driven basis, at least in part,
over a wireless network
Ordinary meaning, but in the alternative, a data unit that has been
filtered.
Ordinary meaning

Ordinary meaning, but in the alternative, providing an indication of
the second status
Ordinary meaning, but in the alternative, the antenna . . . is arranged
between an exposed surface of the housing and at least a portion on
the user interface
Ordinary meaning, but in the alternative, a detachable cover that has
at least one surface that is substantially flat . . . for concealing the
antenna.

19

‘737

20

‘737

02426.51753/4221429.3

“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”
“address identifying the
portable communication
device”

hardware and/or software . . . for securely obtaining authorization to
use software in the portable communication device, in which the
hardware and/or software generates an external authorization request,
and in which the hardware and/or software securely communicates
with the fixed portion to obtain the authorization to use the software

Ordinary meaning, but in the alternative, some reference uniquely
identifying the portable communication device

02426.51753/4221429.3