Motorola Mobility, Inc. v. Apple, Inc.

Filing 366

NOTICE by Motorola Mobility LLC Amended Infringement Contentions and Statement of Accused Products (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)Associated Cases: 1:12-cv-20271-RNS, 1:10-cv-23580-RNS(Kruse, Regan)

EXHIBIT A

EXHIBIT A
UNITED STATES PATENT NO. 5,710,987
PRELIMINARY INFRINGEMENT CONTENTIONS1
Accused Apple Products:

Apple iPhone 4, Apple iPhone 4S, Apple iPhone 52.

Apple directly infringes the ‘987 patent, either literally or through the doctrine of equivalents, pursuant to 35 U.S.C. § 271(a).
In addition to Apple's direct infringement of the ‘987 patent through its development, testing, use, distribution and sale of its
products and services, Apple also indirectly infringes the ‘987 patent pursuant to 35 U.S.C. § 271(b) and (c). End-users and others in
the distribution channel of the Accused Apple Products directly infringe this claim by using, selling, offering for sale, and/or
importing these devices into the United States. Apple contributes to and induces infringement through its promotion and provision of
marketing, sale and/or technical support of the Accused Apple Products and associated services in the United States, and through the
design, marketing, manufacture, sale, and/or technical support of the Accused Apple Products. Apple supplies Accused Apple
Products and actively encourages the use, sale, offer for sale, and importation of the same in the United States through the promotion
and provision of marketing literature, promotion, and user guides, which induces and results in direct infringement. Apple has known
or should have known that these actions would cause direct infringement of the ‘987 patent and did so with specific intent to
encourage direct infringement, at least as of 2007, when Apple and Motorola participated in talks regarding the licensing of
Motorola's patent portfolio. On information and belief, in connection with those negotiations, Apple has reviewed said portfolio,
including Motorola's '987 Patent. Moreover, Apple has known of the ‘987 patent since at least October 6, 2010, when Motorola filed
its Complaint, attaching the ‘987 patent as an exhibit. Despite knowing of the ‘987 patent, Apple continues to make, use, offer to sell,
and sell its products and has continued to circulate marketing literature and user guides encouraging users of the Accused Apple
1

Motorola Mobility's investigation is ongoing and discovery is not yet complete. Apple has, thus far, not produced all of its
documents and source code relevant to the accused methods and products. Motorola reserves the right to supplement or amend these
contentions based on subsequent discovery or disclosures made pursuant to FRCP 26. Motorola further reserves the right to amend
and supplement its contentions with respect to any products released by Apple subsequent to the service of these initial infringement
contentions, in accordance with the schedule set forth in the Court’s Order of October 25, 2012. Further, to the extent Apple releases
any new products with the same functionality accused of infringement in the Accused Apple Products in these contentions, Motorola
reserves the right to seek appropriate relief from the court in accordance with its order of October 25, 2012 and in accordance with the
Federal Rules of Civil Procedure.
2

The term "Apple iPhone 5" means Apple's new iPhone announced by Apple on September 12, 2012. See
http://www.apple.com/pr/library/2012/09/12Apple-Introduces-iPhone-5.html.

1

EXHIBIT A
Products to infringe. Additionally, the identified features of the Accused Apple Products are material parts of the inventions of the
asserted claims and have no substantial non-infringing uses.

2

EXHIBIT A

’987 Patent Claim
13. A receiver
including a user
interface
comprising:

Apple iPhone 4 and iPhone 53
Upon information and belief, Apple imports, manufactures, sells, offers to sell, and uses the Apple iPhone 4, which
includes a receiver and several user interfaces, including a touch-screen display , volume control buttons, and
speaker.
See, e.g., iPhone 4 Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed on May 12,
2011, MOTO-APPLE-0006037953_126659:

See also iPhone Design, (http://www.apple.com/iphone/design/), accessed on May 12, 2011, MOTO-APPLE0006037953_126949-50:

3

This chart provides Motorola’s infringement analysis for the Accused Apple Products. Upon information and belief, the analysis set
forth in this chart for the Apple iPhone 4 applies equally to the Apple iPhone 4S, and substantially in the same way to the Apple
iPhone 5.

3

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

4

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed on 11/06/2012,
MOTO-SDFL-0000016104:

5

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See id at MOTO-SDFL-0000016105:

6

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53
a housing;
Upon information and belief, the Apple iPhone 4 contains a housing .
See e.g., iPhone Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/2), accessed on May 13,
2011, MOTO-APPLE-0006037953_127193 (arrows and labels added):

See e.g., iPhone Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/1), accessed on May 13,
2011, MOTO-APPLE-0006037953_127208 (arrows and labels added):

7

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also iPhone Design, (http://www.apple.com/iphone/design/), accessed on May 12, 2011, MOTO-APPLE0006037953_126952:

8

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 Teardown, (http://www.ifixit.com/Teardown/iPhone+5+Teardown/10525/5), accessed on
11/06/2012, MOTO-SDFL-0000018710 (arrows and labels added):

9

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

10

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53
receiver circuitry Upon information and belief, the Apple iPhone 4 has receiver circuitry disposed in the housing.
disposed in the
See, e.g., iPhone Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/2), accessed on May 13,
housing; and
2011, MOTO-APPLE-0006037953_127192-94 (arrows and labels added):

11

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

12

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

13

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also iPhone Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/1), accessed on May 13,
2011, MOTO-APPLE-0006037953_127208 (arrows and labels added):

14

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 Teardown, (http://www.ifixit.com/Teardown/iPhone+5+Teardown/10525/5), accessed on
11/06/2012, MOTO-SDFL-0000018710 (arrows and labels added):

15

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 Teardown, (http://www.ifixit.com/Teardown/iPhone+5+Teardown/10525/2), accessed on
11/06/2012, MOTO-SDFL-0000018703:

16

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

an antenna
coupled to the
receiver circuitry

Upon information and belief, the Apple iPhone 4 contains a cellular antenna and a Wi-Fi and Bluetooth antenna,
each of which is coupled to the receiver circuitry. The stainless steel band on the outside of the iPhone 4 is coupled
to and is part of both of the iPhone 4 antennas.
See, e.g., iPhone Design, (http://www.apple.com/iphone/design/), accessed on May 12, 2011, MOTO-APPLE0006037953_126949:

See also iPhone Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/2), accessed on May 13,

17

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53
2011, MOTO-APPLE-0006037953_127193:

See also Image of iPhone 4 Antenna, (http://fortunebrainstormtech.files.wordpress.com/2010/06/iphone-4antennas.jpg), accessed on May 13, 2011, MOTO-APPLE-0006037953_127191:

18

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 (http://www.ifixit.com/Teardown/iPhone+5+Teardown/10525/2), accessed on 11/06/2012,
MOTO-SDFL-0000018702 (box added).

19

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 (http://www.ifixit.com/Guide/Installing+iPhone+5+Wi-Fi+Antenna/10897/4) (Wi-Fi antenna
coupled to the receiver circuitry), accessed on 11/06/2012, MOTO-SDFL-0000018673:

20

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

21

EXHIBIT A
’987 Patent Claim
wherein the
antenna forms a
loop surrounding
at least a portion
of the user
interface and is
disposed between
an outside surface
of the housing
and the at least a
portion of the user
interface.

Apple iPhone 4 and iPhone 53
Upon information and belief, the antenna in the iPhone 4 forms a loop that surrounds a portion of the user
interface. and is disposed between an outside surface of the housing and the at least a portion of the user interface.
Specifically, the iPhone 4 stainless steel band (the antenna) forms a loop surrounding the volume buttons, the
speaker, and the touch-screen interface (each of which is a user interface).
See, e.g., Image of iPhone 4 Antenna, (http://fortunebrainstormtech.files.wordpress.com/2010/06/iphone-4antennas.jpg), accessed on May 13, 2011, MOTO-APPLE-0006037953_127191:

In addition, the stainless steel band is disposed between the outside surface of the aluminosilicate glass screen (part
of the housing that contains the receiver circuitry) and (1) the volume buttons and (2) the speakers (user interfaces).
See also iPhone Design, (http://www.apple.com/iphone/design/), accessed on May 12, 2011, MOTO-APPLE0006037953_126951 (arrows and labels added):

22

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also iPhone Design, (http://www.apple.com/iphone/design/), accessed on May 12, 2011, MOTO-APPLE0006037953_126949:

23

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also (at 745-Apple11543563): "The iPhone 4 antenna is an exterior antenna which doesn't use internal space so
we can add more battery in the phone and give it a longer battery life and there's some other advantages as well."
Upon information and belief, the antenna in the iPhone 5 is structured substantially in the same way as the one in
the iPhone 4. Specifically, the iPhone 5 aluminum bezel (the antenna) forms a loop surrounding the volume
buttons, the speaker, and the touch-screen interface (each of which is a user interface). In addition, the aluminum
bezel is disposed between the outside glass screen (part of the housing that contains the receiver circuitry) and (1)
the volume buttons and (2) the speakers (user interfaces).
See e.g., iPhone 5 Design, (http://www.apple.com/iphone/design/), accessed on 11/06/2012, MOTO-SDFL0000018642-43 (arrows and labels added):

24

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

25

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5, (http://www.ifixit.com/Teardown/iPhone+5+Teardown/10525/2), accessed on 11/06/2012,
MOTO-SDFL-0000018702 (box added).

26

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 (http://www.ifixit.com/Guide/Installing+iPhone+5+Wi-Fi+Antenna/10897/4) (Wi-Fi antenna
coupled to the receiver circuitry), accessed on 11/06/2012, MOTO-SDFL-0000018673:

27

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

14. A receiver
according to
claim 13 wherein
the user interface
further comprises
at least one of the
following: an
acoustic, a visual
and tactile
interface.

Upon information and belief, the iPhone 4 receiver has visual (a touch-screen display), acoustic (speakers), and
tactile (volume control buttons)user interfaces.
See, e.g., iPhone 4 Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed on May 12,
2011, MOTO-APPLE-0006037953_126659:

28

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also iPhone Design, (http://www.apple.com/iphone/design/), accessed on May 12, 2011, MOTO-APPLE0006037953_126949-50:

29

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 Specs, (http://www.apple.com/iphone/specs.html), accessed on 11/06/2012, MOTO-SDFL0000016105:

30

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

17. A receiver
comprising:

Upon information and belief, Apple imports, manufactures, sells, offers to sell, and uses the Apple iPhone 4, which
includes a receiver. For example, the iPhone 4 receives, among other things, telephone calls and text messages.
In addition, through its design of the Apple iPhone 4, Apple also induced users of the Apple iPhone 4 to infringe
the '987 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 '987 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 Apple iPhone 4. In addition, Apple instructs the users of the Apple iPhone 4 to use it 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., Apple iPhone Bumper – Pink,
(http://store.apple.com/us/product/APPLE_IPHONE_BUMPERS-104238?mco=MTM3NjU0NTk), accessed on
May 9, 2011, MOTO-APPLE-0006037953_127202: “Fits all iPhone 4 models for both AT&T and Verizon.” See
also id.:

31

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

Moreover, through its design of the Apple iPhone 4, Apple also contributes to the infringement of the '987 patent
by users of the device. As indicated above, at least as early as 2007, Apple knew that offering to sell or selling the
Apple iPhone 4 and the Apple iPhone 4 bumper would contribute to direct infringement of the '987 Patent. Apple
knew that the iPhone 4 bumper, a component with no substantial non-infringing use, could be combined with the
Apple iPhone 4, and that this combination, for which the two components were especially made, was both patented
and infringing. Moreover, Apple iPhone 4 users have, in fact, combined these components into an infringing
device. Apple further contributes to the direct infringement of the users of the Apple iPhone 4, including but not
limited to by describing infringing combinations in its advertisements, promotional materials, and user manuals.
See, e.g., Apple iPhone Bumper – Pink, (http://store.apple.com/us/product/APPLE_IPHONE_BUMPERS104238?mco=MTM3NjU0NTk), accessed on May 9, 2011, MOTO-APPLE-0006037953_127202: “Fits all iPhone
4 models for both AT&T and Verizon.” See also id.:

32

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

33

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53
See also, Apple iPhone 5 case , (http://store.apple.com/us/product/HA763ZM/A/incase-snap-case-for-iphone5?fnode=47), accessed on 11/07/2012, MOTO-SDFL-0000020234:

34

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53
receiver circuitry; Upon information and belief, the Apple iPhone 4 has receiver circuitry. For instance, the iPhone contains a logic
board containing, among other things:

See iPhone Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/2), accessed on May 13, 2011,
MOTO-APPLE-0006037953_127192-94 9 (arrows and labels added):

35

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

36

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

37

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

38

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 Teardown, (http://www.ifixit.com/Teardown/iPhone+5+Teardown/10525/2), accessed on
11/06/2012, MOTO-SDFL-0000018703:

39

EXHIBIT A
’987 Patent Claim
a housing
substantially
enclosing the
receiver circuitry;

Apple iPhone 4 and iPhone 53
Upon information and belief, the Apple iPhone 4 has a housing, comprised of at least the frame to the inside of the
stainless steel band surrounding the iPhone and the non-conductive portion of the aluminosilicate glass screen,
substantially enclosing the receiver circuitry.
See, e.g., iPhone Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/1), accessed on May 13,
2011, MOTO-APPLE-0006037953_127208-10 (arrows and labels added):

40

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 Teardown, (http://www.ifixit.com/Teardown/iPhone+5+Teardown/10525/5), accessed on
11/06/2012, MOTO-SDFL-0000018710 (arrows and labels added):

41

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

42

EXHIBIT A
’987 Patent Claim
an electromagnetic
shield, disposed
in the housing and
at least partially
covering the
receiver circuitry,
formed of an
electrically
conductive,
electromagnetic
wave-absorbing
material for
absorbing
electromagnetic
energy radiated
by or towards the
receiver circuitry;

Apple iPhone 4 and iPhone 53
Upon information and belief, the Apple iPhone 4 contains an electromagnetic shield within the housing (comprised
of the metal structure inside of the stainless steel band and the aluminosilicate glass covering the front of the
iPhone 4) that at least partially covers the receiver circuitry. The electromagnetic shield is formed of an electrically
conductive, electromagnetic wave-absorbing material for absorbing electromagnetic energy radiated by or towards
the receiver circuitry.
See, e.g., iPhone Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/2), accessed on May 13,
2011, MOTO-APPLE-0006037953_127193-94 (arrows, labels, and highlighting added):

43

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

Upon information and belief, the iPhone 5 also contains an electromagnetic shield within the housing that at least
partially covers the receiver circuitry. The electromagnetic shield is formed of an electrically conductive,
electromagnetic wave-absorbing material for absorbing electromagnetic energy radiated by or towards the receiver
circuitry.
See, Replacement of the iPhone 5 EMI shield set, http://www.powerbookmedic.com/iPhone-5-EMI-Shield-Set-p23131.html, accessed on 11/01/12, MOTO-SDFL-0000018740:

44

EXHIBIT A
’987 Patent Claim
an antenna coupled
to the receiver
circuitry, carried on
an outside,
nonconductive
surface of the
housing and
disposed outside
the electromagnetic
shield; and

Apple iPhone 4 and iPhone 53
Upon information and belief, both Apple iPhone 4 antennas are coupled to the receiver circuitry, and the stainless
steel band portion of the antennas is carried on an outside, nonconductive surface of the housing, including at least
the non-conductive portion of the aluminosilicate glass screen
See e.g., iPhone Design, (http://www.apple.com/iphone/design/), accessed on May 12, 2011, MOTO-APPLE0006037953_126953 (arrows and labels added):

45

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53
See also iPhone Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/1), accessed on May 13,
2011, MOTO-APPLE-0006037953_127209-10:

Moreover, at least the stainless steel band portion of the antennas are disposed outside of the electromagnetic
46

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53
shield.
See, e.g., iPhone Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/2), accessed on May 13,
2011, MOTO-APPLE-0006037953_127193:

See, e.g., iPhone Design, (http://www.apple.com/iphone/design/), accessed on May 12, 2011, MOTO-APPLE0006037953_126949:

See, e.g., Image of iPhone 4 Antenna, (http://fortunebrainstormtech.files.wordpress.com/2010/06/iphone-4antennas.jpg), accessed on May 13, 2011, MOTO-APPLE-0006037953_127191:

47

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also (at 745-Apple11543563): "The iPhone 4 antenna is an exterior antenna which doesn't use internal space so
we can add more battery in the phone and give it a longer battery life and there's some other advantages as well."

See also, iPhone 5 Teardown, (http://www.ifixit.com/Teardown/iPhone+5+Teardown/10525/5), accessed on
11/06/2012, MOTO-SDFL-0000018710 (arrows and labels added):

48

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 (http://www.ifixit.com/Teardown/iPhone+5+Teardown/10525/2), accessed on 11/06/2012,
MOTO-SDFL-0000018702 (box added):

49

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

See also, iPhone 5 (http://www.ifixit.com/Guide/Installing+iPhone+5+Wi-Fi+Antenna/10897/4) (Wi-Fi antenna
coupled to the receiver circuitry), accessed on 11/06/2012, MOTO-SDFL-0000018673:

50

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

51

EXHIBIT A
’987 Patent Claim
a substantially
planar and
detachable cover,
attached to the
outside,
nonconductive
surface of the
housing, for
concealing the
antenna between
the cover and the
outside,
nonconductive
surface of the
housing such that
the antenna is
unnoticeable to a
user of the receiver.

Apple iPhone 4 and iPhone 53
Upon information and belief, Apple manufactures, imports, sells, offers to sell, and uses the iPhone 4 “bumper.”
The iPhone 4 bumper is a substantially planar and detachable cover. The iPhone 4 bumper is designed to be
attached to the outside, non-conductive portion of the aluminosilicate glass screen (part of the housing) that covers
the front of the iPhone 4.
The iPhone 4 bumper conceals the stainless steel band portion of the antennas between the bumper and the outside,
nonconductive surface of the housing (the non-conductive portion of the aluminosilicate glass display) such that
the antenna is unnoticeable to a user of the receiver.
Apple instructs its customers to attach the iPhone 4 bumper to the outside, nonconductive portion of the
aluminosilicate glass display, for concealing the antennas between the bumper and the outside, nonconductive
portion of the aluminosilicate glass display.
See, e.g., Apple iPhone Bumper – Pink, (http://store.apple.com/us/product/APPLE_IPHONE_BUMPERS104238?mco=MTM3NjU0NTk), accessed on May 9, 2011, MOTO-APPLE-0006037953_127202: “Fits all iPhone
4 models for both AT&T and Verizon.” See also id.:

52

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53
The iPhone 4 bumper is designed specifically for the iPhone 4 and will not fit any other phone. See, e.g,. id.
“Important note: iPhone 4 Bumpers are compatible only with iPhone 4. They will not work with any other iPhone
model.” There is no substantial non-infringing use for the iPhone 4 bumper.
See also Antennagate Article,
(http://www.msnbc.msn.com/id/38263228/ns/technology_and_sciencewireless/t/apple-gives-free-bumpers-alliphone-owners/), accessed on May 12, 2011, MOTO-APPLE-0006037953_126955:

53

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53

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EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53
Upon information and belief, the antenna in the iPhone 5 is structured substantially in the same way as the one in
the iPhone 4.
See e.g., iPhone 5 Design, (http://www.apple.com/iphone/design/), accessed on 11/06/2012, MOTO-SDFL0000018642 (arrows and labels added):

In addition, upon information and belief, Apple manufactures, imports, sells, offers to sell, and uses the iPhone 5
case that is a substantially planar and detachable cover; designed to be attached to the outside, non-conductive
portion of the housing; and conceals the aluminum bezel portion of the antennas between the cover and the outside,

55

EXHIBIT A
’987 Patent Claim Apple iPhone 4 and iPhone 53
nonconductive surface of the housing such that the antenna is unnoticeable to a user of the receiver.
See e.g., Apple iPhone 5 case , (http://store.apple.com/us/product/HA763ZM/A/incase-snap-case-for-iphone5?fnode=47), accessed on 11/07/2012, MOTO-SDFL-0000020234:

56