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 J

EXHIBIT J
UNITED STATES PATENT NO. 7,024,183
PRELIMINARY INFRINGEMENT CONTENTIONS1
Accused Apple Products:

Apple’s iPhone line of products running Apple iOS 5 and later, including at least the iPhone 3GS,
iPhone 4, iPhone 4S, and iPhone 52.

Apple directly infringes the ‘183 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 ‘183 patent through its development, testing, use, distribution and sale of its
products and services, Apple also indirectly infringes the ‘183 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 the infringement of the asserted claims 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 ‘183 patent and did
so with specific intent to encourage direct infringement, at least as of April 13, 2012, Motorola served Apple with Motorola’s motion
for leave to file Motorola’s first amended complaint in this litigation, which attached the ‘183 patent as an exhibit. Despite knowing
of the ‘072 patent, Apple continues to make, use, offer to sell, and sell its products and has continued to circulate marketing literature

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 J
and user guides encouraging users of the Accused Apple 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.

‘183 Patent Claim
Claim 1
1. A method for intelligent
communication management
within a communication
device comprising the steps
of:

Representative Apple Products: Apple iPhone3
Upon information and belief, an “Apple iPhone” (i.e., an Apple iPhone product running Apple iOS 5
or later, as defined above) is a communication device having intelligent communication management.
For instance, an Apple iPhone can send messages using Apple’s “iMessage” service, but when
iMessage is off or unavailable, can send such messages using an SMS/MMS service. Similarly, for
example, a text message that cannot be sent to a phone number may be sent to an email address.
See generally Apple iPhone User Guide For iOS 6 Software, (“iPhone User Guide”), available at
http://manuals.info.apple.com/en/iphone_user_guide.pdf, and produced at MOTO-SDFL-0000016133,
at Chap. 9 (pp. 64-66).
See id. at 64:

3

This chart provides Motorola’s infringement analysis for the Accused Apple Products. Upon information and belief, the analysis
set forth in this chart applies equally to all of the Accused Apple Products. In this claim chart, "Apple iPhone" refers to Apple’s
iPhone line of products running Apple iOS 5 and later, including at least the iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5.
2

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also, e.g., http://www.apple.com/ios/messages/ (MOTO-SDFL-0000018793):

3

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

***

4

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also iPhone User Guide at 64:

5

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
See also demonstration screenshot:

See also screenshots below, demonstrating that the text message with the content “Testing” sent by an
iPhone (“646-943-2743”) to a contact (“Demonstration”) may be delivered using email where a phone
number for the contact is unavailable.

6

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Also, upon information and belief, an Apple iPhone can initiate a video call using Apple’s
“FaceTime” program, but when FaceTime is off or unavailable, initiate the call as a voice call over a

7

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
cellular connection.
See, e.g., http://www.apple.com/ios/facetime/:

***

8

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 47; see generally id. Chap. 5:

9

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also http://support.apple.com/kb/ht4319 (last accessed September 1, 2012, and produced at
MOTO-SDFL-0000018842):

10

EXHIBIT J

‘183 Patent Claim

storing a communication
preference identifying one or
more communication means
for sequentially initiating
communication with the
contact,

Representative Apple Products: Apple iPhone3

Upon information and belief, an Apple iPhone stores a communication preference identifying one or
more communication means for sequentially initiating communication with the contact.
For example, upon information and belief, the memory of an Apple iPhone stores a communication
preference identifying that, when iMessage (e.g., using an Apple ID, email address, or phone number)
is unavailable, communication with the contact should be initiated by SMS text message (e.g., using a
phone number or email address) (i.e., in that sequential order).
See iPhone User Guide at 64:

11

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also demonstration screenshots:

12

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

13

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 64:

14

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Similarly, upon information and belief, the memory of an Apple iPhone stores a communication
preference identifying that, when FaceTime (e.g., using an Apple ID, email address, or phone number)
is unavailable, a voice call (using a phone number) should be initiated with the contact (i.e., in that
sequential order).
See, e.g., iPhone User Guide at 47:

See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

wherein the communication
preference comprises a
communication preference
chosen from a group

Upon information and belief, such communication preference is chosen from a group consisting of a
fixed communication order, a pattern communication order, a time based communication order, and a
calendar based communication order.

15

EXHIBIT J

‘183 Patent Claim
consisting of a fixed
communication order, a
pattern communication order,
a time based communication
order, and a calendar based
communication order;

Representative Apple Products: Apple iPhone3
For example, upon information and belief, the memory of an Apple iPhone stores a communication
preference identifying that, when iMessage (e.g., using an Apple ID, email address, or phone number)
is unavailable, communication with the contact should be initiated by SMS text message (e.g., using a
phone number or email address) (i.e., in that fixed, sequential order).
See iPhone User Guide at 64:

***

16

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
See also demonstration screenshots:

17

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 64 (discussing iMessage):

18

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Similarly, upon information and belief, the memory of an Apple iPhone stores a communication
preference identifying that, when FaceTime (e.g., using an Apple ID, email address, or phone number)
is unavailable, a voice call (using a phone number) should be initiated with the contact (i.e., in that
fixed, sequential order).
See, e.g., iPhone User Guide at 47:

See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

initiating communication
with a contact using a first
communication means via a
first communication

Upon information and belief, an Apple iPhone will initiate communication with a contact using a first
communication means via a first communication connection.
For example, upon information and belief, an Apple iPhone will, when sending a text message, initiate
19

EXHIBIT J

‘183 Patent Claim
connection;

Representative Apple Products: Apple iPhone3
communication with a contact using iMessage (e.g., using an Apple ID, email address, or phone
number) as the first communication means via a first communication connection.
See iPhone User Guide at 64:

***

See also demonstration screenshots:

20

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

21

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 64 (discussing iMessage):

22

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Similarly, upon information and belief, an Apple iPhone will, initiate communication with a contact
using FaceTime (e.g., using an Apple ID, email address, or phone number) as the first communication
means via a first communication connection.
See, e.g., iPhone User Guide at 47:

See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

detecting that the first
Upon information and belief, an Apple iPhone can detect that a first communication connection with a
communication connection is contact is disconnected; for instance, if a communication connection using iMessage (e.g., using an
disconnected;
Apple ID, email address, or phone number) cannot be established.
See iPhone User Guide at 64:
23

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also demonstration screenshot:

24

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also screenshots below, demonstrating that the text message with the content “Testing” sent by an
iPhone (“646-943-2743”) to a contact (“Demonstration”) may be delivered using email where a phone
number for the contact is unavailable.

25

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Similarly, upon information and belief, an Apple iPhone can detect that a first communication
connection with a contact is disconnected when a communication connection using FaceTime (e.g.,

26

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
using an Apple ID, email address, or phone number) cannot be established.
See, e.g., iPhone User Guide at 47:

See also iPhone User Guide (iOS 5.1) at 60:

identifying a second
communication means
associated with the contact,

Upon information and belief, when an Apple iPhone detects that the first communication connection
with the contact is disconnected, it will identify a second communication means associated with the
contact; for example, when the first communication connection would have been using iMessage, an
Apple iPhone will identify SMS text message using a phone number or email as a second
communication means; when the first communication connection would have been using FaceTime,
an Apple iPhone will identify voice call using a phone number as a second communication means.
See, e.g., iPhone User Guide at 64:

27

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also demonstration screenshot:

28

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 64 (discussing iMessage):

See also demonstration screenshots:

29

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 47:

30

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

wherein the second
communication means is
identified by the
communication preference;

Upon information and belief, the second communication means is identified by the communication
preference.
For example, upon information and belief, the memory of an Apple iPhone stores a communication
preference identifying that, when iMessage (e.g., using an Apple ID, email address, or phone number)
is unavailable, the second communication means is by SMS text message (e.g., using a phone number
or email address).
See iPhone User Guide at 64:

31

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also demonstration screenshots:

32

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

33

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 64 (discussing iMessage):

34

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Similarly, upon information and belief, the memory of an Apple iPhone stores a communication
preference identifying that, when FaceTime (e.g., using an Apple ID, email address, or phone number)
is unavailable, the second communication means is by voice call (using a phone number).
See, e.g., iPhone User Guide at 47:

See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

initiating communication
with the contact via a second
communication connection
to the second communication
means.

Upon information and belief, an Apple iPhone will initiate communication with the contact via a
second communication connection to the second communication means.
For example, upon information and belief, an Apple iPhone will, when iMessage (e.g., using an Apple
ID, email address, or phone number) is unavailable, initiate communication with the contact via a
35

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
second communication connection to the second communication means (i.e., by SMS text message,
e.g., using a phone number or email address).
See iPhone User Guide at 64:

***

See also demonstration screenshots:

36

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

37

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 64 (discussing iMessage):

38

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Similarly, upon information and belief, an Apple iPhone will, when FaceTime (e.g., using an Apple
ID, email address, or phone number) is unavailable, initiate communication with the contact via a
second communication connection to the second communication means (i.e., by voice call, using a
phone number).
See, e.g., iPhone User Guide at 47:

See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

Claim 2
2. A method as recited in
claim 1, wherein the
detecting step comprises:

Claim 1 is hereby incorporated by reference.

39

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

determining that the first
Upon information and belief, an Apple iPhone can detect that a first communication connection with a
communication connection is contact is disconnected, and such detection comprises determining that the first communication
not established.
connection is not established.
For instance, upon information and belief, an Apple iPhone can determine that a communication
connection using iMessage (e.g., using an Apple ID, email address, or phone number) cannot be
established.
See iPhone User Guide at 64:

40

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also demonstration screenshot:

41

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Similarly, upon information and belief, an Apple iPhone can detect that a first communication
connection using FaceTime (e.g., using an Apple ID, email address, or phone number) cannot be
established.
See, e.g., iPhone User Guide at 47:

42

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide (iOS 5.1) at 60:

Claim 6
6. A method as recited in
claim 1 further comprising
the steps of:

Claim 1 is hereby incorporated by reference.

storing one or more
communication means for
the contact;

Upon information and belief, an Apple iPhone also stores one of more communication means for a
contact. For example, iMessage using an Apple ID, email address, or phone number; an SMS or
MMS message using a phone number or email address; FaceTime using an Apple ID, email address,
or phone number; or a voice call using a phone number.
See, e.g., iPhone User Guide at 100

43

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also id. at 66:

44

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also http://www.apple.com/ios/messages/:

***

45

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also http://www.apple.com/ios/facetime/ (MOTO-SDFL-0000018790):

See also demonstration screenshots:
46

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See generally, iPhone User Guide, Chap. 25 (pp. 100-102).
displaying the stored one or Upon information and belief, an Apple iPhone displays the stored one or more communication means,
more communication means; e.g., iMessage using an Apple ID, email address, or phone number; SMS or MMS message using a
and
phone number or email address; FaceTime using an Apple ID, email address, or phone number; or a
voice call using a phone number.
See, e.g., iPhone User Guide at 100

47

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also demonstration screenshots:

48

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See generally, iPhone User Guide, Chap. 25 (pp. 100-102).
selecting the second
communication means from
the displayed one or more
communication means prior
to the initiating the second
communication step.

Upon information and belief, such second communication means (e.g., SMS text message using a
phone number or email address; voice call using a phone number) is selected from the displayed one
or more communication means prior to the initiating the second communication step.
See iPhone User Guide at 64 (discussing iMessage):

***

49

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

Claim 7
7. A method as recited in
claim 1 further comprising
the steps of:

Claim 1 is hereby incorporated by reference.

displaying the second
communication means; and

Upon information and belief, an Apple iPhone displays the stored second communication means, e.g.,
SMS or MMS message using a phone number or email address; voice call using a phone number.
See, e.g., iPhone User Guide at 100

50

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also demonstration screenshots:

51

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See generally, iPhone User Guide, Chap. 25 (pp. 100-102).
selecting the second
communication means prior
to the initiating the second
communication connection
step.

Upon information and belief, such second communication means (e.g., SMS text message using a
phone number or email address; voice call using a phone number) is selected prior to the initiating the
second communication step.
See iPhone User Guide at 64 (discussing iMessage):

***

52

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

Claim 8
8. A communication device
having intelligent
communication management,
the communication device
comprising:

Upon information and belief, an “Apple iPhone” (i.e., an Apple iPhone product running Apple iOS 5
or later, as defined above) is a communication device having intelligent communication management.
For instance, an Apple iPhone can send messages using Apple’s “iMessage” service, but when
iMessage is off or unavailable, can send such messages using an SMS/MMS service. Similarly, for
example, a text message that cannot be sent to a phone number may be sent to an email address.
See generally Apple iPhone User Guide For iOS 6 Software, (“iPhone User Guide”), available at
http://manuals.info.apple.com/en/iphone_user_guide.pdf, at Chap. 9 (pp. 64-66).
See id. at 64:

53

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also, e.g., http://www.apple.com/ios/messages/:

54

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

***

55

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also iPhone User Guide at 64:

56

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
See also demonstration screenshot:

See also screenshots below, demonstrating that the text message with the content “Testing” sent by an
iPhone (“646-943-2743”) to a contact (“Demonstration”) may be delivered using email where a phone
number for the contact is unavailable.

57

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Also, upon information and belief, an Apple iPhone can initiate a video call using Apple’s
“FaceTime” program, but when FaceTime is off or unavailable, initiate the call as a voice call over a

58

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
cellular connection.
See, e.g., http://www.apple.com/ios/facetime/:

***

59

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 47; see generally id. Chap. 5:

60

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also http://support.apple.com/kb/ht4319 (last accessed September 1, 2012):

61

EXHIBIT J

‘183 Patent Claim

a transceiver for
communicating with a
contact using a first
communication means via a
first communication
connection;

Representative Apple Products: Apple iPhone3

Upon information and belief, an Apple iPhone has a transceiver for communicating with a contact
using a first communication means (e.g., iMessage using an Apple ID, email address, or phone
number; a video call over FaceTime) via a first communication connection (e.g., the user of the Apple
iPhone can connect to a contact who has a device capable of receiving an iMessage, and iMessage is
activated on that Apple iPhone; the user of the Apple iPhone can initiate a video call to a contact who
has a device capable of FaceTime, and FaceTime is activated on that Apple iPhone).
Upon information and belief, an Apple iPhone contains one or more radios for communicating over
Wi-Fi or cellular connections using iMessage.
See, e.g., iPhone User Guide at 64:

62

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
See also id. at 130:

Upon information and belief, an Apple iPhone contains one or more radios for communicating over
Wi-Fi or cellular connections using FaceTime.
See, e.g., http://www.apple.com/ios/facetime/:

63

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 47:

64

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also http://www.apple.com/iphone/compare-iphones/:

***

65

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also http://www.apple.com/iphone/specs.html (iPhone 5) (MOTO-SDFL-0000016104):

See also
http://twimgs.com/informationweek/galleries/automated/874/06_iPhone5_comm_front_full.jpg:

66

EXHIBIT J

‘183 Patent Claim

a processor coupled to the
transceiver for processing
signals received from the
transceiver and sending
commands to the transceiver
for communicating with one
or more communication
means including the first
communication means and a
second communication
means;

Representative Apple Products: Apple iPhone3

Upon information and belief, an Apple iPhone has a processor coupled to the transceiver for
processing signals received from the transceiver, and for sending commands to the transceiver for
communicating with one or more communication means including the first communication means
(e.g., iMessage using an Apple ID, email address, or phone number; FaceTime using a phone number
or email address) and a second communication means (e.g., SMS or MMS text Message using a phone
number; a voice call using a phone number).
See, e.g., iPhone User Guide at 64:

67

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also, e.g., http://www.apple.com/ios/messages/:

68

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also demonstration screenshot:

69

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See, e.g., http://www.apple.com/ios/facetime/:

70

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

71

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 47:

See also demonstration screenshots:

72

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also screenshots below, demonstrating that the text message with the content “Testing” sent by an
iPhone (“646-943-2743”) to a contact (“Demonstration”) may be delivered using email where a phone
number for the contact is unavailable.

73

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also http://www.apple.com/iphone/compare-iphones/:

74

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also
http://twimgs.com/informationweek/galleries/automated/874/06_iPhone5_comm_front_full.jpg:

75

EXHIBIT J

‘183 Patent Claim

a memory coupled to the
processor for storing one or
more contacts each having
one or more associated
communication means,

Representative Apple Products: Apple iPhone3

Upon information and belief, an Apple iPhone includes a memory coupled to the processor for storing
one or more contacts.
See, e.g., iPhone User Guide at 100:

76

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also demonstration screenshot:

77

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Upon information and belief, the Apple iPhone internal memory is coupled to the processor, and
stores the one or more contacts.
See, e.g., http://www.apple.com/iphone/compare-iphones/:

78

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

***

Upon information and belief, each such contact is associated with one or more communication means
that can be used to establish a communication connection. For example, iMessage using an Apple ID,
email address, or phone number; an SMS or MMS message using a phone number or email address;
FaceTime using an Apple ID, email address, or phone number; or a voice call using a phone number.
79

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
See, e.g., iPhone User Guide at 100

See also id. at 66:

80

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also http://www.apple.com/ios/messages/:

***

81

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also http://www.apple.com/ios/facetime/:

See also demonstration screenshots:
82

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See generally, iPhone User Guide, Chap. 25 (pp. 100-102).
the memory storing the
contact associated with the
first communication means
and the second
communication means; and

Upon information and belief, the Apple iPhone internal memory stores the contact associated with the
first communication means and the second communication means.
See, e.g., http://www.apple.com/iphone/compare-iphones/:

83

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also demonstration screenshots:

84

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 66:

85

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also http://www.apple.com/ios/messages/:

***

86

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also http://www.apple.com/ios/facetime/:

Upon information and belief, and as also discussed elsewhere herein, an Apple iPhone can determine
87

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
whether a communication connection with a contact may be made using iMessage, for instance if that
contact has the iMessage service on a supported Apple iPhone, iPad, iPod touch, or Mac product.
See, e.g., http://www.apple.com/ios/messages/:

***

88

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Upon information and belief, and as also discussed elsewhere herein, an Apple iPhone can determine
whether a communication connection with a contact may be made using FaceTime, for instance if that
contact has the FaceTime service on a supported Apple iPhone, iPad, iPod touch, or Mac product.
See, e.g., http://www.apple.com/ios/facetime/:

89

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

90

EXHIBIT J

‘183 Patent Claim

a communications manager
application coupled to the
processor and to the memory,
wherein the communications
manager application is
adapted to:

Representative Apple Products: Apple iPhone3

Upon information and belief, an Apple iPhone has a communication manager application known as
the Apple “Messages” application, which is coupled to the processor and to the memory, and is
adapted to perform the claimed steps.
See generally Apple iPhone User Guide For iOS 6 Software, (“iPhone User Guide”), available at
http://manuals.info.apple.com/en/iphone_user_guide.pdf, at Chap. 9 (pp. 64-66).
See id. at 64:

91

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also, e.g., http://www.apple.com/ios/messages/:

92

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also demonstration screenshots:

Apple Messages Application Icon

93

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Apple Messages Application Settings
See also http://www.apple.com/iphone/compare-iphones/:

94

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

***

Upon information and belief, Apple’s FaceTime application is a communication manager application,
also coupled to the processor and to the memory, and adapted to perform the claimed steps.
See, e.g., http://www.apple.com/ios/facetime/:
95

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

detect that the first
communication connection
with the contact is
disconnected;

Upon information and belief, the Apple Messages application can detect that a first communication
connection with a contact is disconnected; for instance, if a communication connection using
iMessage (e.g., using an Apple ID, email address, or phone number) cannot be established.
See iPhone User Guide at 64:

96

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also demonstration screenshot:

97

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also screenshots below, demonstrating that the text message with the content “Testing” sent by an
iPhone (“646-943-2743”) to a contact (“Demonstration”) may be delivered using email where a phone
number for the contact is unavailable.

98

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Upon information and belief, the Apple FaceTime application also can detect that a first
communication connection with a contact is disconnected; for instance, if a communication

99

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
connection using FaceTime (e.g., using an Apple ID, email address, or phone number) cannot be
established.
See, e.g., iPhone User Guide at 47:

See also iPhone User Guide (iOS 5.1) at 60:

identify the second
communication means
associated with the contact;
and

Upon information and belief, when the Messages application (i.e., the communications manager
application) detects that the first communication connection with the contact is disconnected, the
Messages application, based on the Apple iPhone Messages settings, will identify the second
communication means associated with the contact, a send, e.g., the message as an SMS text message
using a phone number.
See demonstration screenshot:

100

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 64:

101

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also demonstration screenshot:

102

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 64:

See also screenshots below, demonstrating that the text message with the content “Testing” sent by an
iPhone (“646-943-2743”) to a contact (“Demonstration”) may be delivered using email where a phone
number for the contact is unavailable.

103

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Upon information and belief, such message could be delivered also as an iMessage to the email
address (the second communication means) on a device where the Messages settings specify that the

104

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
email address may be used with Messages, or using another second communication means, such as an
Apple ID.
See, e.g., iPhone User Guide at 66:

See also http://www.apple.com/ios/messages/:

***

105

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Upon information and belief, when the FaceTime application (i.e., the communications manager
application) detects that the first communication connection with the contact is disconnected, the
FaceTime application will identify the second communication means associated with the contact, e.g.,
a voice call using a phone number
See, e.g., iPhone User Guide at 47:

106

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

cause the processor to initiate Upon information and belief, an Apple iPhone as described above will cause the processor to initiate a
a second communication
second communication connection to the second communication means. For instance, where
connection to the second
iMessage is unavailable, the processor will send a message as an SMS message using a phone number.
communication means.
See iPhone User Guide at 64:

107

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also demonstration screenshot:

108

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 64:

See also screenshots below, demonstrating that the text message with the content “Testing” sent by an
iPhone (“646-943-2743”) to a contact (“Demonstration”) may be delivered using email (a second
communication means) where a phone number (a first communication means) for the contact is
unavailable.
109

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Upon information and belief, such message could be delivered also as an iMessage to the email

110

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
address (the second communication means) on a device where the Messages settings specify that the
email address may be used with Messages, or using another second communication means, such as an
Apple ID.
See, e.g., iPhone User Guide at 66:

See also http://www.apple.com/ios/messages/:

***

111

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Upon information and belief, an Apple iPhone as described above also will cause the processor to
initiate a second communication connection to the second communication means where FaceTime is
unavailable, in that the processor will initiate a voice call using a phone number.
See, e.g., iPhone User Guide at 47:

112

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

Claim 9
9. A communication device Claim 8 is incorporated herein by reference.
having intelligent
communication management Upon information and belief, and as further described in Motorola’s infringement contentions for
as recited in claim 8
Claim 8, an Apple iPhone is a communication device having intelligent communication management,
as recited in claim 8.
wherein the memory further
stores one or more
communication preferences
identifying the sequential
order of the communication
means for initiating
communication with the
contact,

Upon information and belief, the memory of an Apple iPhone stores one or more communication
preferences identifying the sequential order of the communication means for initiating communication
with the contact.
For example, upon information and belief, the memory of an Apple iPhone stores a communication
preference identifying that, when iMessage (e.g., using an Apple ID, email address, or phone number)
is unavailable, communication with the contact should be initiated by SMS text message (e.g., using a
phone number or email address) (i.e., in that sequential order).
See iPhone User Guide at 64:

113

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

***

See also demonstration screenshots:

114

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

115

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

See also iPhone User Guide at 64:

116

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3

Similarly, upon information and belief, the memory of an Apple iPhone stores a communication
preference identifying that, when FaceTime (e.g., using an Apple ID, email address, or phone number)
is unavailable, a voice call (using a phone number) should be initiated with the contact (i.e., in that
sequential order).
See, e.g., iPhone User Guide at 47:

See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

wherein the second
communication means is
identified by the
communication preference.

Upon information and belief, such second communication means (e.g., SMS text message using a
phone number or email address; voice call using a phone number) is identified by the communication
preference stored in the memory of an Apple iPhone.

117

EXHIBIT J

‘183 Patent Claim

Representative Apple Products: Apple iPhone3
See iPhone User Guide at 64 (discussing iMessage):

***

See also iPhone User Guide (iOS 5.1) at 60 (discussing FaceTime):

118