Motorola Mobility, Inc. v. Apple, Inc.

Filing 354

REPLY to Response to Motion re (83 in 1:12-cv-20271-RNS) MOTION to Sever filed by HTC America Innovation Inc., HTC America, Inc., HTC Corporation. (Attachments: # 1 Declaration of Raymond Pao, # 2 Declaration of Rebekah L. Punak)Associated Cases: 1:12-cv-20271-RNS, 1:10-cv-23580-RNS(Carey, John)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

MOTOROLA MOBILITY, INC.,
Plaintiff,

JURY TRIAL DEMANDED

v.

Consolidated Cases
Case No. 1:10-cv-23580-RNS
Case No. 1:12-cv-20271-RNS

APPLE INC.,
Defendant.
APPLE INC.,
Counterclaim Plaintiff
v.
MOTOROLA MOBILITY, INC., HTC
CORPORATION, HTC AMERICA, INC.,
ONE & COMPANY DESIGN, INC., and
HTC AMERICA INNOVATION INC.,
Counterclaim Defendants.

DECLARATION OF RAYMOND PAO IN SUPPORT OF
HTC COUNTERCLAIM DEFENDANTS’ REPLY TO MOTION TO SEVER

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671040.01

I, Raymond Pao, declare and state as follows:
1.

I am the Director, Software Project Manager for HTC Corporation, a defendant in

this action. Unless otherwise stated, I have personal knowledge of the facts set forth in this
declaration and if called as a witness, I could testify competently thereto.
2.

As a Director, Software Project Manager at HTC, my responsibilities include

managing software project and serving as Google technical contact window. As a result, I am
familiar with technical matters related to HTC products sold in the United States.
3.

I have reviewed a list of the HTC devices accused by Apple in its Counterclaims

to Plaintiff Motorola Mobility, Inc.’s First Amended Complaint for Patent Infringement in the
above-captioned matter (the “Accused Devices”).
4.

Most of the Accused Devices use software for providing word recommendations

that does not originate from Android. This software controls aspects of the user interface for
presenting word recommendations to users.
5.

HTC has developed and deployed its own methods for managing or sending

notifications about missed telephone calls that are not dictated by the Android system. In most
of the Accused Devices, HTC has modified multiple user interfaces related to providing missed
call notifications, including interfaces when the phone is unlocked.
6.

HTC has developed its own code for displaying the volume control window that

appears when volume is changed. HTC does not use Android Toast feature for this function.
7.

Consistent with the open-source environment of Android, anyone can access

Android source code by downloading it from the Android website following the steps described
at http://source.android.com/source/downloading.html. Often, HTC obtains the source code for
the Android platform from the Android Open Source Project. In general, HTC engineers in

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671040.01

Taiwan receive this source code for HTC. To the best of my knowledge, HTC employees in the
United States are not involved in obtaining code from the Android Open Source Project.
8.

As part of my normal job responsibilities, I regularly interface with employees of

Google on issues related to HTC’s use of Android in its products. As a result of these job
responsibilities, I am aware of HTC’s participation in the Open Handset Alliance (“OHA”) and I
have an understanding of what that membership entails.
9.

In addition to HTC, I understand that the OHA has approximately 83 member

companies. This understanding is consistent with the information available on the OHA’s
website. Attached hereto as Exhibit A is a true and correct copy of the information available in
the “Members” section of the OHA website as it appeared on June 7, 2012, available at URL
http://www.openhandsetalliance.com/oha_members.html.
10.

It is my understanding that Google leads the OHA and is responsible for Android

product management and the engineering process for the core framework and platform. It is also
my understanding that Google works internally on the next version of the Android platform and
framework. This understanding is consistent with the information available on the Android
Open Source Project website. Attached hereto as Exhibit B is a true and correct copy of the
information available on the “Philosophy and Goals” section of the Android Open Source Project
website as it appeared on June 7, 2012, available at URL
http://source.android.com/about/philosophy.html.
11.

Attached hereto as Exhibit C is a true and correct copy of the information

available on the “People and Roles” section of the Android Open Source Project website as it
appeared on June 7, 2012, available at URL http://source.android.com/source/roles.html.
12.

As far as I am aware, the OHA does not hold regular meetings of its membership.

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13.

As far as I am aware, the OHA has no formal mechanisms through which its

members collaboratively work together to contribute to the Android platform.
14.

It is my understanding that anyone, whether or not an OHA member, can submit

to Google for consideration certain Android-related or Android-compatible code, such as
software patches or other bug fixes, or applications that can run on Android operating system.
Google in turn evaluates and decides whether to incorporate or reject (or otherwise modify) such
code. I do not know of any special opportunities for OHA members to contribute code to
Android by virtue of their membership in the OHA.
15.

In general, HTC does not contribute to the core Android framework. For

example, for the current version of Android, 4.0 or “ice cream sandwich,” there have been over
1000 patches contributed by others, but only 1 contributed by HTC. Other than using Google’s
Android source code as a starting point, none of the coding contributions by HTC was done in
collaboration with any other commercial hardware or software developer, including Motorola.
16.

It is my understanding that anyone, whether or not an OHA member, can access

the current release of the Android platform through the Android Open Source Project website. I
do not know of any means by which an OHA member can obtain access to Android code that is
unavailable to the general public by virtue of their membership in the OHA.
17.

Occasionally, a device manufacturer like HTC will partner with Google to create

a flagship device to that is released in connection with the next version of Android. In these
instances, the device manufacturer may have some increased access to Android code. However,
it is my understanding that the device manufacturer’s increased access to Android code in these
circumstances is the result of its partnership with Google, and not directly connected to
membership in the OHA.

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18.

I have reviewed exhibits 31 and 38 submitted by Apple. The author listed on that

exhibit, Vladimir Chtchetkine, is not an HTC employee.
I declare under penalty of perjury. under the laws of the United States that the foregoing is
true and COlTect. Executed this

~tk

day of June, 2012, in ~eI,

5
671040.01

~fLv{lV\

EXHIBIT A

Alliance Members | Open Handset Alliance

Members
Mobile Operators
Handset Manufacturers
Semiconductor Companies
Software Companies
Commercialization Companies

Mobile Operators
Bouygues Telecom
www.bouyguestelecom.fr
Created in 1994, Bouygues Telecom provides mobile, fixed, TV and
internet communications services to the French customers.

China Mobile Communications Corporation
www.chinamobile.com/en

China Telecommunications Corporation
en.chinatelecom.com.cn
China Telecommunications Corporation (China Telecom) is an extra
-large State-owned telecom operator in China. China Telecom
mainly provides the integrated information services including the
fixed-line telephone, mobile service, satellite communications
services,Internet connection and applications services,etc.

China United Network Communications
www.chinaunicom.com
China Unicom is the only Chinese telecom operator listed on the
stock exchanges in New York, Hong Kong and Shanghai. On 7
January 2009, China Unicom was granted a WCDMA license.

KDDI CORPORATION
www.kddi.com
KDDI is a telecommunication operator that provides wide-ranging
services from mobile to fixed in Japan.

NTT DOCOMO, INC.
www.nttdocomo.com
NTT DOCOMO is the world's leading mobile communications
operator, with 53 million customers, of which 40 million use the 3G/
FOMA service based on W-CDMA technology.

SOFTBANK MOBILE Corp.
mb.softbank.jp/mb/en
SOFTBANK MOBILE Corp. is a leading mobile operator in Japan
with over 19 million customers and a member of the SOFTBANK
Group. (as of 31 October 2008)

Sprint Nextel
www2.sprint.com/mr/aboutsprint.do
Sprint Nextel offers a comprehensive range of wireless and wireline
communications services including the fastest and largest national
mobile broadband network, a broad portfolio of devices and an wide
array of applications, which enable customers to do the things that
matter the most to them instantly and on the go – at SprintSpeed™.

http://www.openhandsetalliance.com/oha_members.html

6/8/2012

Alliance Members | Open Handset Alliance

T-Mobile
www.t-mobile.net
Serving more than 112 million mobile customers in Europe and the
U.S., T-Mobile is one of the world's leading companies in mobile
communications, and the mobile telecommunications subsidiary of
Deutsche Telekom AG (NYSE: DT)

Telecom Italia
www.telecomitalia.it
Supplying 34.3 mobile lines, around 23 million landlines and 7.3
million broadband clients, Telecom Italia is a Italy's leading ICT
enterprise with a significant international presence in Europe and
South America. The Group trades through pre-eminent brands
Telecom Italia, Alice, TIM, La7, MTV Italia, APCom and Olivetti in
fixed-line and mobile telecommunications, Internet and media, office
& system solutions.

Telefónica
www.telefonica.es
Telefónica is one of the largest telecommunication companies in the
world, providing communication, information and entertainment
solutions, with presence in Europe, Africa and Latin America and
with more than 212 million clients of fixed and mobile services.

TELUS
www.telus.com
TELUS is a leading national telecommunications company in
Canada, providing a wide range of communications products and
services including data, Internet protocol (IP), voice, entertainment
and video.

Vodafone
www.vodafone.com
Vodafone is the world's leading international mobile communications
group with approximately 280 million proportionate customers as of
30 September 2008. Vodafone currently has equity interests in 27
countries across five continents and over 40 partner networks
worldwide. For more information, please visit www.vodafone.com.
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6/8/2012

Alliance Members | Open Handset Alliance

Members
Mobile Operators
Handset Manufacturers
Semiconductor Companies
Software Companies
Commercialization Companies

Handset Manufacturers
Acer Inc.
www.acer-group.com
Acer ranks as the world's No. 3 vendor for total PCs and No. 2 for
notebooks, with the fastest growth among the top-five players.
Revenues in 2008 reached US$16.65 billion.

Alcatel mobile phones
www.alcatel-mobilephones.com
Alcatel mobile phones offer eye-catching handsets, with unique
designs at competitive prices. ALCATEL handsets are managed by
TCT Mobile, who is part of TCL Communication listed on the Hong
Kong Stock Exchange (HKSE: 2618).

ASUSTeK Computer Inc.
www.asus.com
ASUS is a leading company in the new digital era for IT and
communication products. The company's turnover for 2007 was 6.9
billion U.S. dollars.

CCI
www.compalcomm.com
Innovated, 1st tier qualified and fast track for smartphone design
and integration, mass production in competitive cost and completely
cover WCDMA/CDMA/TD-SCDMA wireless technologies.

Dell
www.dell.com
Dell listens to customers and uses that insight to make technology
simpler, reliable, and deliver long-term value.

Foxconn International Holdings Limited
www.fih-foxconn.com/home/default.aspx
FIH is the global leader in the handset and wireless communications
manufacturing and service.

FUJITSU LIMITED
www.fujitsu.com
Manufacturing and sales of telecommunication systems, information
processing systems and electronic devices, and providing services
related to these systems.

Garmin International, Inc.
www.garmin.com
Garmin is the global leader in satellite navigation and has built
millions of products that serve the automotive, wireless, OEM,
fitness, aviation and marine markets.

http://www.openhandsetalliance.com/oha_members.html

6/8/2012

Alliance Members | Open Handset Alliance
Haier Telecom (Qingdao) Co., Ltd.
mobile.haier.com
Haier Mobile is one of leading provider in handset design,
manufacturing and service in China.

HTC Corporation
www.htc.com
HTC Corporation focuses on driving cutting-edge innovation into a
wide variety of mobile devices to create the perfect match for
individuals. The company is listed on the Taiwan Stock Exchange
under ticker 2498.

Huawei Technologies
www.huawei.com
Huawei Technologies is a leader in providing next generation
telecommunications network solutions for operators around the
world.

Kyocera
www.kyocera.com
Kyocera is a 50 year old, $13 billion company with 190 businesses
worldwide, all working to develop products that improve customers’
lives. Kyocera's wireless devices --found worldwide from Japan to
the US - utilize the latest technology advancements to provide great
value.

Lenovo Mobile Communication Technology Ltd.
www.lenovomobile.com
Lenovo Mobile Communications is one of the leading integrated
mobile communication and information service providers in China.

LG Electronics, Inc.
www.lge.com
LG, the brand that is Delightfully Smart, is a global leader and
technology innovator in consumer electronics, home appliances and
mobile communications. LG's vision is to supply top-of-the-range
innovative digital products and services and ensure customer
satisfaction.

Motorola, Inc.
www.motorola.com
Motorola is known around the world for innovation and leadership in
wireless and broadband communications.

NEC Corporation
www.nec.com
NEC Corporation is one of the world's leading providers of
networking, mobile communications and information technology.

Pantech
www.pantech.com

http://www.openhandsetalliance.com/oha_members.html

6/8/2012

Alliance Members | Open Handset Alliance
Pantech is a worldwide mobile company, leading the global mobile
market by offering new values for customers with innovated
technologies.

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Samsung Electronics
www.samsung.com
A leading innovator and provider of mobile phones and telecom
systems.

Sharp Corporation
sharp-world.com
Sharp Corporation is a worldwide developer of innovative products
and core technologies that play a key role in shaping the future of
electronics. In the mobile phone business, in 2000 Sharp became
the first company in the industry to introduce a camera-equipped
mobile phone that enables users to instantly e-mail photos taken
with the built-in camera.

Sony Ericsson
www.sonyericsson.com
Sony Ericsson is a top global mobile phone manufacturer with sales
of over 100 million phones in 2007. With operations in over 80
countries, Sony Ericsson was established as a 50:50 joint venture
by Sony and Ericsson in October 2001. For more information about
Sony Ericsson, please visit www.sonyericsson.com.

Toshiba Corporation
www.toshiba.com
Toshiba is a world leader and innovator in pioneering high
technology, a diversified manufacturer and marketer of advanced
electronic and electrical products spanning information &
communications equipment and systems.

ZTE Corporation
www.zte.com.cn
ZTE is a leading global provider of telecommunications equipment
and network solutions. It has the widest and most complete product
range in the world – covering virtually every sector of the wireline,
wireless, service and terminals markets.
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6/8/2012

Alliance Members | Open Handset Alliance

Members
Mobile Operators
Handset Manufacturers
Semiconductor Companies
Software Companies
Commercialization Companies

Semiconductor Companies
AKM Semiconductor Inc
www.akm.com
AKM Semiconductor is a leading supplier of mixed-signal ICs for
consumer and communications applications. Devices for mobile
phones include audio products and electronic compass ICs.

Audience
www.audience.com
Audience is a voice processor company that enables clear
communications anywhere with noise suppression technology based
on the intelligence of the human hearing system.

ARM
www.arm.com
ARM designs the technology that lies at the heart of advanced
digital products, from wireless, networking and consumer
entertainment solutions to imaging, automotive and storage devices.

Atheros Communications
www.atheros.com
Atheros Communications is a leading developer of wireless system
solutions for communications products. The company’s technology
is used by leading PC, networking equipment and CE device
manufacturers.

Broadcom Corporation
www.broadcom.com
Broadcom Corporation is a major technology innovator and global
leader in semiconductors for wired and wireless communications,
providing products that enable the delivery of voice, video, data and
multimedia to and throughout the home, the office and the mobile
environment.

CSR Plc.
www.csr.com
CSR is the leading provider of GPS enabled location platforms for
mainstream markets with focus on wireless, automotive, consumer
electronic and mobile compute devices.

Cypress Semiconductor Corporation
www.cypress.com
Cypress’s programmable solutions add power, style, and
performance to multimedia handsets. Offerings include PSoC®based touch -sensing solutions, USB and memories.

Freescale Semiconductor
www.freescale.com

http://www.openhandsetalliance.com/oha_members.html

6/8/2012

Alliance Members | Open Handset Alliance
Freescale Semiconductor is a global leader in the design and
manufacture of embedded semiconductors and a leading provider of
ICs for smart mobile devices.

Gemalto
www.gemalto.com
Gemalto, the leader in digital security, provides solutions designed
to make personal digital interactions more convenient, secure and
enjoyable.

Intel Corporation
www.intel.com/products/mid
Intel, the world leader in silicon innovation, develops technologies,
products and initiatives to continually advance how people work and
live.

Marvell Semiconductor, Inc.
www.marvell.com
Marvell is a leader in development of storage, communications, and
consumer silicon solutions with a diverse product portfolio that
powers the entire communications infrastructure from enterprise
solutions to mobile consumer devices.

MediaTek, Inc.
www.mediatek.com
MediaTek Inc. is a leading fabless semiconductor company for
wireless communications and digital multimedia solutions, also a
pioneer in cutting-edge SOC system solutions for wireless
communications, high-definition TV, optical storage, DVD and Bluray products.

MIPS Technologies, Inc.
www.mips.com
MIPS Technologies is a leading provider of industry-standard
processor architectures and cores that power some of the world's
most popular products for the home entertainment, communications,
networking and portable multimedia markets.

NVIDIA Corporation
www.nvidia.com/page/handheld
NVIDIA is the worldwide leader in visual computing technologies. Its
Tegra family of computers-on-a-chip deliver rich multimedia features
including 3D graphics and high definition video for next generation
mobile devices including smartphones and personal media players.

Qualcomm Inc.
www.qualcomm.com
Qualcomm Incorporated is a leader in developing and delivering
innovative digital wireless communications products for advanced
devices around the world.

Renesas Electronics Corporation
www.renesas.com

http://www.openhandsetalliance.com/oha_members.html

6/8/2012

Alliance Members | Open Handset Alliance
Renesas Technology is the world's No.1 supplier of microcontrollers,
as well as a leading provider of Power MOSFETs, System-on-Chip
(SoC), and more.

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ST-Ericsson
www.stericsson.com
ST-Ericsson is an industry leader in design, development and
creation of mobile platforms and wireless semiconductors. Through
cutting-edge innovation backed by a complete portfolio and a
dedicated partnership approach towards customers, ST-Ericsson is
a key supplier to four of the industry’s top five handset
manufacturers.

Synaptics, Inc.
www.synaptics.com
Synaptics, Inc., providing easy-to-use interface solutions for mobile
phones, personal media players, notebooks and PC peripherals,
supplies a variety of user input solutions for mobile devices that
make accessing digital content easy and fun.

Texas Instruments Incorporated
www.ti.com/wirelessresources
TI is a leading manufacturer of wireless semiconductors, delivering
the heart of today's wireless technology and building solutions for
tomorrow.

Via Telecom
www.via-telecom.com
VIA Telecom is one of two CDMA baseband chipset providers
worldwide, offering comprehensive chipset solutions including
software packages and mature turn-key designs. Its innovative
solutions for CDMA have been adopted by many handset
companies, including Nokia and Samsung, and successfully
commercialized on the networks of principal CDMA carriers.
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6/8/2012

Alliance Members | Open Handset Alliance

Members
Mobile Operators
Handset Manufacturers
Semiconductor Companies
Software Companies
Commercialization Companies

Software Companies
Ándago Ingeniería S.L.
www.andago.com
Andago provides fully interoperable ecosystems based on Open
Source and PaaS technologies for mHealth, eGovernment,
eTourism, and Smart Energy Systems.

ACCESS CO., LTD.
www.access-company.com
ACCESS is a global company providing leading technology,
software products and platforms for Web browsing, mobile phones,
digital TVs and other networked devices.

Ascender Corp.
www.ascendercorp.com/oha.html
Ascender Corp. is a leading provider of advanced font products and
innovative applications for mobile devices.

Cooliris, Inc.
www.cooliris.com
Cooliris creates products that transform the browsing experience
across screens, making discovering and enjoying media more
exciting, efficient, and personal.

eBay Inc.
www.ebay.com

Google Inc.
www.google.com
Our mission is to organize all the world's information and make it
universally accessible and useful.

LivingImage LTD.
www.livingimage.jp
A unique company that consists of renowned engineering, marketing
and creative experts in the audio visual arena.

Myriad
www.myriadgroup.com
Myriad is a leading provider of multi-media solutions and end-to-end
integration services that accelerate time-to-market and reduce
operational costs for OEMs and Operators.

MOTOYA Co., Ltd.
www.motoya.co.jp

http://www.openhandsetalliance.com/oha_members.html

6/8/2012

Alliance Members | Open Handset Alliance
MOTOYA is leading company for Japanese digital fonts. Our
products are outline fonts (TrueType, OpenType, etc.) and bitmap
fonts.

Nuance Communications, Inc.
www.nuance.com
Nuance Communications (NASDAQ: NUAN) is a leading provider of
speech and imaging solutions for businesses and consumers
around the world.

NXP Software
www.software.nxp.com
NXP Software is the market leader in innovative multimedia
solutions, its LifeVibes software is used in over 650M mobile devices
today.

OMRON SOFTWARE Co, Ltd.
www.omronsoft.co.jp
OMRON SOFTWARE, a leading embedded device software
company, provides innovative / universal language and image
processing technologies for mobile devices.

PacketVideo (PV)
www.pv.com
PacketVideo (PV) is a multimedia software company whose
software powers the world's leading mobile entertainment services,
including Verizon Wireless' VCAST music and video services, NTT
DoCoMo's 3-G FOMA service and Orange World by Orange.

SkyPop
www.skypop.com
Next generation services for mobile devices.

SONiVOX
www.sonivoxrocks.com
SONiVOX is a premier developer of audio technologies and
solutions that empower consumers to create Sound That Rocks.

SVOX
www.svox.com
SVOX, a leading supplier of embedded speech solutions, drives
adoption of speech user interfaces in automotive and mobile device
industries.

VisualOn Inc.
www.visualon.com
VisualOn’s multimedia framework and optimized codecs are
compatible with Android to enable the best multimedia experience
for Android devices.
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6/8/2012

Alliance Members | Open Handset Alliance

Members
Mobile Operators
Handset Manufacturers
Semiconductor Companies
Software Companies
Commercialization Companies

Commercialization Companies
Accenture
www.accenture.com
Accenture is a global management consulting, technology services
and outsourcing company, with approximately 211,000 people
serving clients in more than 120 countries.

Aplix Corporation
www.aplixcorp.com
Aplix Corporation enables mobile handset manufacturers to have a
faster, lower development cost and lower risk route to deploy
wireless Java solutions

Borqs
www.borqs.com
Borqs provides best-in-class operator-centric mobile handset
operating system (OS) software products and mobile internet
service platforms and solutions.

Intrinsyc Software International
www.intrinsyc.com
Intrinsyc provides hardware, software, and service solutions that
enable companies to build next-generation mobile and embedded
products.

L&T Infotech
www.lntinfotech.com
A leading software services provider, L&T Infotech offers its
comprehensive suite of Product Engineering Services to the
Telecom industry globally.

Noser Engineering Inc.
www.noser.com/oha
Noser Engineering Inc. - core contributor of the Android Platform is
your integrator and customization partner.

Sasken Communication Technologies Limited
www.sasken.com
Sasken works with Handset OEMs and Semiconductor companies
to enable differentiated devices and user experiences. We offer an
unique combination of R&D Consultancy, Wireless Software
Products, Software and Hardware Services.

SQLStar International Inc.
www.sqlstar.com
Embinux Group of SQLStar provides system integration, customer
engineering services and custom apps. for Android and embeddedLinux on MSM & OMAP platforms.

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6/8/2012

Alliance Members | Open Handset Alliance

TAT - The Astonishing Tribe AB
www.tat.se
TAT - The Astonishing Tribe - a specialist in mobile user interfaces,
recognized for its design capabilities and for its software solutions
that enable richer user experiences on any platform, to date
embedded in more than 140 million devices.

Teleca AB
www.teleca.com
Teleca is a global supplier of innovative software and solutions to
mobile communications companies. Teleca has about 2,000
employees in Asia, Europe and North America.

Wind River
www.windriver.com/oha
Wind River enables companies to develop, run, and manage device
software faster, better, at lower cost and more reliably.

Wipro Technologies
www.wipro.com/services/pes
A leading Software Services Company and #1 provider of integrated
business, technology and process solutions, globally
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EXHIBIT B

Philosophy and Goals | Android Open Source

Page 1 of 2

Android.com

Home

Source

Links
Project Philosophy
People and Roles
Getting Involved
Compatibility
Licensing Information

Compatibility

Tech Info

Community

About

Philosophy and Goals
Android is an open-source software stack for mobile phones and other
devices.

Origin and Goal

Android was originated by a group of companies known as the Open Handset Alliance, led by Google. Today,
many companies -- both original members of the OHA and others -- have invested heavily in Android, typically in
the form of allocating significant engineering resources to improve Android and bring Android devices to Market.
We created Android in response to our own experiences launching mobile apps. We wanted to make sure that
there would always be an open platform available for carriers, OEMs, and developers to use to make their
innovative ideas a reality. We wanted to make sure that there was no central point of failure, where one industry
player could restrict or control the innovations of any other. The solution we chose was an open and opensource platform.
The goal of the Android Open Source Project is to create a successful real-world product that improves the
mobile experience for end users.

Governance Philosophy
The companies that have invested in Android have done so on its merits, because we believe that an open
platform is necessary. Android is intentionally and explicitly an open-source -- as opposed to free software -effort: a group of organizations with shared needs has pooled resources to collaborate on a single
implementation of a shared product. The Android philosophy is pragmatic, first and foremost. The objective is a
shared product that each contributor can tailor and customize.
Uncontrolled customization can, of course, lead to incompatible implementations. To prevent this, the AOSP
also maintains the Android Compatibility Program, which spells out what it means to be "Android compatible",
and what is required of device builders to achieve that status. Anyone can (and will!) use the Android source
code for any purpose, and we welcome all such uses. However, in order to take part in the shared ecosystem of
applications that we are building around Android, device builders must participate in the Compatibility Program.
Though Android consists of multiple sub-projects, this is strictly a project-management technique. We view and
manage Android as a single, holistic software product, not a "distribution", specification, or collection of
replaceable parts. Our intent is that device builders port Android to a device; they don't implement a
specification or curate a distribution.

How We Work
We know that quality does not come without hard work. Along with many partners, Google has contributed fulltime engineers, product managers, UI designers, Quality Assurance, and all the other roles required to bring
modern devices to market. We roll the open source administration and maintenance into the larger product
development cycle.
At any given moment, there is a current latest release of the Android platform. This typically takes the
form of a branch in the tree.

http://source.android.com/about/philosophy.html

6/7/2012

Philosophy and Goals | Android Open Source

Page 2 of 2

Device builders and Contributors work with the current latest release, fixing bugs, launching new devices,
experimenting with new features, and so on.
In parallel, Google works internally on the next version of the Android platform and framework, working
according to the product's needs and goals. We develop the next version of Android by working with a
device partner on a flagship device whose specifications are chosen to push Android in the direction we
believe it should go.
When the "n+1"th version is ready, it will be published to the public source tree, and become the new
latest release.
Privacy & Terms

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EXHIBIT C

People and Roles | Android Open Source

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About

People and Roles
The Android Open Source Project (AOSP) includes individuals
working in a variety of roles. As noted in Our Philosophy, Google is
responsible for Android product management and the engineering
process for the core framework and platform; however, the project
considers contributions from any source, not just Google. This page
describes the kinds of roles that interested parties can take on.
Anyone who is interested in exploring and contributing to Android can
use the Android Open Source Project resources. Anyone can join the
mailing lists, ask questions, contribute patches, report bugs, look at
submitted patches, and use the tools. To get started with the Android
code, see Get Involved.

Contributor
A "Contributor" is anyone making contributions to the AOSP source
code, including both employees of Google or other companies, as well
as external developers who are contributing to Android on their own
behalf. There is no distinction between Contributors who are employed
by Google, and those who are not: all engineers use the same tools
(git, repo, and gerrit), follow the same code review process, and are
subject to the same requirements on code style and so on.

Developer

A "Developer" is an engineer writing applications that run on Android
devices. There is, of course, no difference in skillset between a "Developer" and a "Contributor", but AOSP uses
"Developer" to distinguish between engineers using the platform and those contributing to it. Developers are
(along with end users) the "customers" of the platform that the Contributors create. As such, we talk about
Developers a lot, though this isn't technically a separate role in the AOSP per se.

Verifier
"Verifiers" are responsible for testing change requests. After individuals have submitted a significant amount of
high-quality code to the project, the Project Leads might invite them to become Verifiers. Note: at this time,
generally Verifiers are the same as Approvers.

Approver
"Approvers" are experienced members of the project who have demonstrated their design skills and have made
significant technical contributions to the project. In the code-review process, an Approver decides whether to
include or exclude a change. Project Leads (who are typically employed by Google) choose the Approvers,
sometimes promoting to this position Verifiers who have demonstrated their expertise within a specific project.

Project Leads

http://source.android.com/source/roles.html

6/7/2012

People and Roles | Android Open Source

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Android consists of a number of sub-projects; you can see these in the git repository, as individual .git files. Tech
Leads are senior Contributors who oversee the engineering for individual Android projects. Typically these tech
leads will be Google employees. A Project Lead for an individual project is responsible for the following:
Lead all technical aspects of the project; for example, the project roadmap, development, release cycles,
versioning, and QA.
Ensure that the project is QA-ed in time for scheduled Android platform releases.
Designate Verifiers and Approvers for submitted patches.
Be fair and unbiased while reviewing changes. Accept or reject patches based on technical merit and
alignment with the Android strategy.
Review changes in a timely manner and make best efforts to communicate when changes are not
accepted.
Optionally maintain a web site for the project for information and documents specific to the project.
Act as a facilitator in resolving technical conflicts.
Be a public face for the project and the go-to person for questions related to the project.
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6/7/2012