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 K

EXHIBIT K
UNITED STATES PATENT NO. 7,243,072
PRELIMINARY INFRINGEMENT CONTENTIONS1
Accused Apple Products:

All Apple products on which Siri is available, including but not limited to the 5th Generation Apple iPod
Touch2, Apple iPhone 4S, Apple iPhone 53, 3rd Generation Apple iPad, 3rd Generation Apple iPad + 4G,
4th Generation Apple iPad4, 4th Generation Apple iPad [with cellular] Apple iPad mini,5 and Apple iPad
mini [with cellular]; Apple Siri Servers (as further defined below).

Apple directly infringes the ‘072 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 ‘072 patent through its development, testing, use, distribution and sale of its
products and services, Apple also indirectly infringes the ‘072 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
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 “5th Generation Apple iPod Touch” means Apple’s new iPod Touch announced by Apple on September 12, 2012. See
http://www.apple.com/pr/library/2012/09/12Apple-Introduces-New-iPod-touch-iPod-nano.html.
3

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.
4

The terms "4th Generation Apple iPad" and "4th Generation Apple iPad [with cellular]" mean Apple's new iPad devices announced
by Apple on October 23, 2012. See http://www.apple.com/pr/library/2012/10/23Apple-Introduces-iPad-mini.html.
5

The terms "Apple iPad mini" and "Apple iPad mini [with cellular]" mean Apple's new iPad mini devices announced by Apple on
October 23, 2012. See http://www.apple.com/pr/library/2012/10/23Apple-Introduces-iPad-mini.html.

1

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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 ‘072 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 ‘072 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
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.

‘072 Patent Claim
Claim 1
1. A method for a remote
agent to assist with control of
a subscriber device, the
method comprising:

Representative Apple Products: Apple iOS Devices6
Upon information and belief, the Accused Apple Products that include the Siri application, such as the
Apple iOS Devices, are subscriber devices that operate to obtain and transmit spoken instructions to
an Apple server that processes those instructions (hereinafter, “Apple Siri Server”), which is a remote
agent that assists with control of the Apple iOS Devices.
See, e.g., iPhone User Guide, For iOS 6 Software, available at
http://manuals.info.apple.com/en/iphone_user_guide.pdf, and produced at MOTO-SDFL-0000016133
(“iPhone User Guide”):

6

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 iOS Device" refers to all Apple
products on which Siri is available, including but not limited to the 5th Generation Apple iPod Touch, Apple iPhone 4S, Apple iPhone
5, 3rd Generation Apple iPad, 3rd Generation Apple iPad + 4G, 4th Generation Apple iPad, 4th Generation Apple iPad [with cellular],
Apple iPad mini, and Apple iPad mini [with cellular].
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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also http://www.apple.com/iphone/built-in-apps/ (MOTO-SDFL-0000018818):

3

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6
See also http://www.apple.com/ios/siri/siri-faq/ (MOTO-SDFL-0000018787):

See also http://www.apple.com/ios/siri/ (demonstrating use of Siri on an iPhone 5 and an iPad)
(MOTO-SDFL-0000018797):

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6
See also id. (demonstrating use of Siri on an iPod touch (5th generation):

See also http://support.apple.com/kb/HT4992 (MOTO-SDFL-0000018834):

See also iPhone User Guide at 42:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added) (MOTO-SDFL0000018844):

See generally iPhone User Guide, Chap. 4 (pp. 36-42).
See also, e.g., http://www.apple.com/iphone/compare-iphones/ (MOTO-SDFL-0000018829):

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

***

See also http://www.apple.com/ipad/compare/ (MOTO-SDFL-0000018815):

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

***

See also http://www.apple.com/pr/library/2011/10/04Apple-Launches-iPhone-4S-iOS-5-iCloud.html
(MOTO-SDFL-0000018832):

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‘072 Patent Claim

receiving from the subscriber
device, an instruction
message that corresponds to
spoken instructions;

Representative Apple Products: Apple iOS Devices6

Upon information and belief, the Apple iOS Devices are subscriber devices which, through the use of
the Siri application, transmit an instruction message corresponding to spoken instructions over a
network, which is received by a remote agent (i.e., an Apple Siri Server) to assist with control of the
subscriber device.
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also id.:

See also http://www.apple.com/ios/siri/ (demonstrating use of Siri on an iPhone 5 and an iPad):

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also id. (demonstrating use of Siri on an iPod touch (5th generation):

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also http://support.apple.com/kb/HT4992:

See also iPhone User Guide at 38:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also iPhone User Guide at 42:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also generally iPhone User Guide, Chap. 4 (pp. 36-42).
See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

converting the spoken
instructions to control
commands;

Upon information and belief, the remote agent at the Apple Siri Server converts the spoken
instructions collected by the Siri application on the subscriber device, and the remote agent converts
those spoken instructions into control commands.
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also id.:

See also https://www.apple.com/ios/siri/:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also iPhone User Guide at 36:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also id. at 37:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also iPhone User Guide at 42:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also generally iPhone User Guide, Chap. 4 (pp. 36-42).
See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

providing a control message
corresponding to the control
commands; and

Upon information and belief, the remote agent at the Apple Siri Server additionally provides a control
message corresponding to the control commands received.
See, e.g., https://www.apple.com/ios/siri/:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also iPhone User Guide at 36:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also id. at 37:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also iPhone User Guide at 42:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also generally iPhone User Guide, Chap. 4 (pp. 36-42).
See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

sending the control message
from the remote agent to the
subscriber device, thereby
assisting with the control of
the subscriber device.

Upon information and belief, the remote agent at the Apple Siri Server sends the control message to
the Apple iOS Device (i.e., the subscriber device), such control message assisting with the control of
the Apple iOS Device.
See, e.g., https://www.apple.com/ios/siri/:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also iPhone User Guide at 36:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also id. at 37:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also http://support.apple.com/kb/HT4992:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also iPhone User Guide at 42:

See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

See also generally iPhone User Guide, Chap. 4; iPad User Guide (available at
http://manuals.info.apple.com/en_US/ipad_user_guide.pdf, and produced at MOTO-SDFL0000019140 ), Chap. 4; iPod Touch User Guide (available at
http://manuals.info.apple.com/en_US/ipod_touch_user_guide.pdf, and produced at MOTO-SDFL0000019276 ), Chap. 4.

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‘072 Patent Claim
Claim 2
2. The method of claim 1:
wherein the receiving the
instruction message further
includes receiving specific
information sufficient to
identify the subscriber
device; and

Representative Apple Products: Apple iOS Devices6
Claim 1 is hereby incorporated by reference.
Upon information and belief, the Apple iOS Devices are subscriber devices which, through the use of
the Siri application, transmit an instruction message corresponding to spoken instructions over a
network, which is received by a remote agent (i.e., an Apple Siri Server) to assist with control of the
subscriber device, and that instruction message further includes receiving specific information
sufficient to identify the subscriber device.
For instance, upon information and belief, an instruction message includes information sufficient to
identify the subscriber device, including, e.g., Apple ID, device Unique Device ID (UDID), and/or
other identifying information.
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

See also http://support.apple.com/kb/TS4079 (MOTO-SDFL-0000018838):

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6
See also generally iPhone User Guide, Chap. 4; iPad User Guide, Chap. 4; iPod Touch User Guide,
Chap. 4.
See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

wherein the converting the
spoken instructions includes
converting the spoken
instructions to the control
commands that correspond to
a type of subscriber device.

Upon information and belief, converting the spoken instructions includes converting the spoken
instructions to the control commands that correspond to a type of subscriber device.
For example, upon information and belief, converting the spoken instructions includes converting the
spoken instructions to control commands for placing a phone call.
See, e.g., http://www.apple.com/ios/siri/:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

Upon information and belief, such control commands for placing a call further correspond to a type of
subscriber device; for instance, whereas control commands for placing a voice call to a telephone
number over a cellular network are used to assist with the control of a subscriber device that is an
Apple iPhone, such control commands are not used to assist with the control of a subscriber device
that is an Apple iPad or Apple iPod Touch; however an Apple iPad or Apple iPod Touch may place a
call using FaceTime.
Compare, e.g., iPhone User Guide at 36:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

with iPad User Guide at 35:

and with iPod Touch User Guide at 35:

Upon information and belief, converting spoken instructions to control commands also corresponds to
a type of subscriber device, in that certain other control commands may only be used to assist with the
control of certain subscriber devices, for example, the spoken instructions “Open Passbook” will be
converted to control commands only where the subscriber device is an iPhone or iPod Touch, and not
where the subscriber device is an iPad.

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6
Compare, e.g., iPhone User Guide at 36, iPod Touch User Guide at 35, with iPad User Guide at 35
(providing examples of spoken instructions that will be converted to control commands on the
subscriber devices).

Claim 3
3. The method of claim 2
wherein the spoken
instructions are converted to
the control commands that
correspond to keypad
activations at the subscriber
device.

Claim 2 is hereby incorporated by reference
Upon information and belief, the spoken instructions of claim 2 are further converted to the control
commands that correspond to keypad activations at the subscriber device.
For example, upon information and belief, spoken instructions are converted to the control commands
on the Apple iOS Devices (i.e., subscriber devices) that correspond to keypad activations for at least
the following.
See, e.g., iPhone User Guide at 36:

See also iPad User Guide at 35:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also iPod Touch User Guide at 35:

Moreover, upon information and belief, spoken instructions are converted to control commands on
subscriber devices that correspond to specific key press patterns.
See also http://www.apple.com/ios/siri/:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

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‘072 Patent Claim

Claim 4
4. The method of claim 2
further comprising
maintaining a database
associated with the
subscriber device, the
database including one of a
parameter status and a
mirrored database associated
with the subscriber device.

Representative Apple Products: Apple iOS Devices6

Claim 2 is hereby incorporated by reference.

Upon information and belief, Apple maintains on its servers a database associated with the subscriber
device, the database including one of a parameter status and a mirrored database associated with the
subscriber device.
For example, Apple’s servers stores various User Data information including a mirrored database of
address book contacts and song names, as well as other communication unit (i.e., subscriber device)
specific information.
See, e.g., Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

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‘072 Patent Claim
Claim 5
5. The method of claim 4:
wherein the spoken
instructions corresponds to
an action comprising one of;
dialing a number, looking up
a number in a phone book
associated with the
subscriber device, the phone
book incorporated into the
mirrored database associated
with the subscriber device,
modifying contents of a
memory of the subscriber
device, and sending a text
message;

Representative Apple Products: Apple iOS Devices6

Claim 4 is hereby incorporated by reference.
Upon information and belief, the spoken instruction may correspond to numerous actions including
that of dialing a number, looking up a number in a phone book associated with the subscriber device,
the phone book incorporated into the mirrored database associated with the subscriber device,
modifying contents of a memory of the subscriber device, and sending a text message.
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

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

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also iPhone User Guide at 36:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also iPad User Guide at 35:

See also iPod Touch User Guide at 35:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

wherein the control
Upon information and belief, the control commands will affect the action when executed by an Apple
commands will effect [sic]
iOS Device (i.e., the subscriber device).
the action when executed by
the subscriber device.
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

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

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‘072 Patent Claim

Claim 6
6. The method of claim 1
further comprising
sending a confirmation
message as confirmation of
the receiving the instruction
message.

Representative Apple Products: Apple iOS Devices6

Claim 1 is hereby incorporated by reference.
Upon information and belief, the remote agent (i.e., the Apple Siri Server) sends a confirmation
message as confirmation of the receiving the instruction message. For example, after receiving an
instruction message, the Apple Siri Server sends a confirmation message that causes Siri to display
what it heard; Siri may also ask for clarification.
See, e.g., iPhone User Guide at 37:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

Claim 12

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

12. A server arranged and
constructed to assist with
control of a subscriber
device, the server
comprising:

Upon information and belief, Apple maintains, manages, and operates under its direction and control
servers arranged and constructed to assist with control of a subscriber device, those servers (i.e., the
Apple Siri Servers) comprising the following elements of the claim.

a receiver to receive from the
subscriber device an
instruction message that
corresponds to spoken
instructions;

Upon information and belief, the Apple Siri Servers contain a receiver to receive from the subscriber
device (i.e., an Apple iOS Device) an instruction message that corresponds to spoken instructions, as
the instruction message that corresponds to the spoken instructions when Siri is used is recorded and
sent to Apple, where it is received by the Apple Siri Servers.

See, e.g., Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

See, e.g., Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

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‘072 Patent Claim

a controller, coupled to the
receiver to convert the
spoken instructions to control
commands and to provide a
control message
corresponding to the control
commands;

Representative Apple Products: Apple iOS Devices6

Upon information and belief, the Apple Siri Servers further contain a controller, coupled to the
receiver to convert the spoken instructions to control commands and to provide a control message
corresponding to the control commands.
See, e.g., Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

See also http://www.apple.com/ios/siri/siri-faq/ (discussing Siri “voice recognition algorithms,” that,
upon information and belief, operate on the Apple Siri Servers in the conversion of spoken
instructions to control commands).

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‘072 Patent Claim

and a transmitter, coupled to
the controller, to send the
control message to the
subscriber device, thereby
assisting with the control of
the subscriber device.

Representative Apple Products: Apple iOS Devices6

Upon information and belief, the Apple Siri Servers further contain a transmitter, coupled to the
controller, to send the control message to the subscriber device, thereby assisting with the control of
the subscriber device.
See, e.g., Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

See also, e.g., http://www.apple.com/ios/siri/siri-faq/:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

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

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‘072 Patent Claim

Claim 13
13. The server of claim 12:

Representative Apple Products: Apple iOS Devices6

Claim 12 is hereby incorporated by reference.

wherein the receiver further Upon information and belief, the receiver of the Apple Siri Server further receives specific
receives specific information information sufficient to identify the subscriber device.
sufficient to identify the
subscriber device;
For instance, upon information and belief, the Apple Siri Server receives an instruction message that
includes information sufficient to identify the subscriber device, including, e.g., Apple ID, device
Unique Device ID (UDID), and/or other identifying information.

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

See also http://support.apple.com/kb/TS4079:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6
See also generally iPhone User Guide, Chap. 4; iPad User Guide, Chap. 4; iPod Touch User Guide,
Chap. 4.
See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

and wherein the controller
converts the spoken
instructions to the control
commands that correspond to
a type of subscriber device.

Upon information and belief, the controller of the Apple Siri Server further converts the spoken
instructions to the control commands that correspond to a type of subscriber device.
For example, upon information and belief, converting the spoken instructions includes converting the
spoken instructions to control commands for placing a phone call.
See, e.g., http://www.apple.com/ios/siri/:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

Upon information and belief, such control commands for placing a call further correspond to a type of
subscriber device; for instance, whereas control commands for placing a voice call to a telephone
number over a cellular network are used to assist with the control of a subscriber device that is an
Apple iPhone, such control commands are not used to assist with the control of a subscriber device
that is an Apple iPad or Apple iPod Touch; however an Apple iPad or Apple iPod Touch may place a
call using FaceTime.
Compare, e.g., iPhone User Guide at 36:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

with iPad User Guide at 35:

and with iPod Touch User Guide at 35:

Upon information and belief, converting spoken instructions to control commands also corresponds to
a type of subscriber device, in that certain other control commands may only be used to assist with the
control of certain subscriber devices, for example, the spoken instructions “Open Passbook” will be
converted to control commands only where the subscriber device is an iPhone or iPod Touch, and not
where the subscriber device is an iPad.

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6
Compare, e.g., iPhone User Guide at 36, iPod Touch User Guide at 35, with iPad User Guide at 35
(providing examples of spoken instructions that will be converted to control commands on the
subscriber devices).

Claim 14
14. The server of claim 13
wherein the controller
converts the spoken
instructions to the control
commands that correspond to
keypad activations at the
subscriber device.

Claim 13 is hereby incorporated by reference.
Upon information and belief, the controller of the Apple Siri Servers further converts the spoken
instructions to the control commands that correspond to keypad activations at the subscriber device.
For example, upon information and belief, spoken instructions are converted to the control commands
on the Apple iOS Devices (i.e., subscriber devices) that correspond to keypad activations for at least
the following.
See, e.g., iPhone User Guide at 36:

See also iPad User Guide at 35:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

See also iPod Touch User Guide at 35:

Moreover, upon information and belief, spoken instructions are converted to control commands on
subscriber devices that correspond to specific key press patterns.
See also http://www.apple.com/ios/siri/:

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‘072 Patent Claim

Claim 15
15. The server of claim 13
further comprising
a memory for storing a
database associated with the
subscriber device, the
database including one of
unit specific information, a
parameter status, and a
mirrored database associated

Representative Apple Products: Apple iOS Devices6

Claim 13 is hereby incorporated by reference.
Upon information and belief, the Apple Siri Servers further contain a memory for storing a database
associated with the subscriber device, the database including one of unit specific information, a
parameter status, and a mirrored database associated with the subscriber device.
For instance, upon information and belief, the Apple Siri Server has a memory that stores a database
associated with the subscriber device that includes unit specific information such as, e.g., Apple ID,
device Unique Device ID (UDID), and/or other identifying information, and may also include

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‘072 Patent Claim
with the subscriber device.

Representative Apple Products: Apple iOS Devices6
parameter status, and/or a mirrored database associated with the subscriber device (such as contacts
and song names).
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

See also http://support.apple.com/kb/TS4079:

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6

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‘072 Patent Claim

Representative Apple Products: Apple iOS Devices6
See also generally iPhone User Guide, Chap. 4; iPad User Guide, Chap. 4; iPod Touch User Guide,
Chap. 4.
See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

16. The server of claim 15:

Claim 15 is hereby incorporated by reference.

wherein the controller
converts the spoken
instructions to the control
commands

Upon information and belief, the controller at the Apple Siri Server converts the spoken instructions
collected by the Siri application on the subscriber device, and the remote agent converts those spoken
instructions into control commands.
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

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Representative Apple Products: Apple iOS Devices6
See also id.:

See also https://www.apple.com/ios/siri/:

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See also iPhone User Guide at 36:

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Representative Apple Products: Apple iOS Devices6

See also id. at 37:

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See also iPhone User Guide at 42:

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See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

See also generally iPhone User Guide, Chap. 4 (pp. 36-42).
that, when executed by the
communications unit, will
effect an action comprising
one of; dialing a number,
looking up a number in a
phone book of the subscriber
device, the phone book
incorporated into the
mirrored database associated
with the subscriber device,
modifying contents of a

Upon information and belief, such control commands, when executed by the communications unit,
will effect an action comprising one of; dialing a number, looking up a number in a phone book of the
subscriber device, the phone book incorporated into the mirrored database associated with the
subscriber device, modifying contents of a memory of the subscriber device, the modifying also
performed on the mirrored database associated with the subscriber device, and sending a text message.
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

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memory of the subscriber
device, the modifying also
performed on the mirrored
database associated with the
subscriber device, and
sending a text message.

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

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See also iPhone User Guide at 36:

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Representative Apple Products: Apple iOS Devices6

See also iPad User Guide at 35:

See also iPod Touch User Guide at 35:

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Claim 17
17. The server of claim 12
wherein
the controller controls the
transmitter to further send a
confirmation message as
confirmation that the receiver
received the instruction
message.

Representative Apple Products: Apple iOS Devices6

Claim 12 is hereby incorporated by reference.
Upon information and belief, the controller of the Apple Siri Server (i.e., the server of claim 12)
controls the transmitter to further send a confirmation message as confirmation that the receiver
received the instruction message. For example, after receiving an instruction message, the Apple Siri
Server sends a confirmation message that causes Siri to display what it heard; Siri may also ask for
clarification.
See, e.g., iPhone User Guide at 37:

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Claim 23
23. A computer readable

Representative Apple Products: Apple iOS Devices6

Upon information and belief, Apple owns, maintains, and uses computer readable media encoded with

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medium encoded with a
software program for
assisting with control of a
subscriber device, the
software program when
loaded and executing on a
processor of a server
resulting in the server
performing a method
comprising:

Representative Apple Products: Apple iOS Devices6
a software program for assisting with control of a subscriber device, as set forth by the following
elements of the claim. And, upon information and belief, that software program, when loaded and
executing on a processor of an Apple Siri Server, results in the server performing a method
comprising the following claimed steps, as described more fully below.
See, e.g., Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

receiving an instruction
Upon information and belief, software program when loaded and executing performs the step of
message from the subscriber receiving an instruction message from the subscriber device that corresponds to spoken instructions.
device that corresponds to
spoken instructions;
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

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See also id.:

See also http://www.apple.com/ios/siri/ (demonstrating use of Siri on an iPhone 5 and an iPad):

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Representative Apple Products: Apple iOS Devices6

See also id. (demonstrating use of Siri on an iPod touch (5th generation):

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Representative Apple Products: Apple iOS Devices6

See also http://support.apple.com/kb/HT4992:

See also iPhone User Guide at 38:

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See also iPhone User Guide at 42:

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Representative Apple Products: Apple iOS Devices6

See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

See also generally iPhone User Guide, Chap. 4 (pp. 36-42).
converting the spoken
instructions to control
commands;

Upon information and belief, the software program when loaded and executing further performs the
step of converting the spoken instructions to control commands.
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

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See also id.:

See also https://www.apple.com/ios/siri/:

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Representative Apple Products: Apple iOS Devices6

See also iPhone User Guide at 36:

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See also id. at 37:

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Representative Apple Products: Apple iOS Devices6

See also iPhone User Guide at 42:

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Representative Apple Products: Apple iOS Devices6

See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

See also generally iPhone User Guide, Chap. 4 (pp. 36-42).
providing a control message
corresponding to the control
commands; and

Upon information and belief, the software program when loaded and executing further performs the
step of providing a control message corresponding to the control commands.

See, e.g., https://www.apple.com/ios/siri/:

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Representative Apple Products: Apple iOS Devices6

See also iPhone User Guide at 36:

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Representative Apple Products: Apple iOS Devices6

See also id. at 37:

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See also iPhone User Guide at 42:

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Representative Apple Products: Apple iOS Devices6

See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

See also generally iPhone User Guide, Chap. 4 (pp. 36-42).
sending the control message
from the server to the
subscriber device, thereby
assisting with the control of
the subscriber device.

Upon information and belief, the software program when loaded and executing further performs the
step of sending the control message from the server to the subscriber device, thereby assisting with the
control of the subscriber device.
See, e.g., https://www.apple.com/ios/siri/:

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See also iPhone User Guide at 36:

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See also id. at 37:

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Representative Apple Products: Apple iOS Devices6

See also http://support.apple.com/kb/HT4992:

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See also iPhone User Guide at 42:

See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

See generally iPhone User Guide, Chap. 4; iPad User Guide, Chap. 4; iPod Touch User Guide, Chap. 4.
Claim 24
24. The computer readable
medium encoded with a
software program of claim
23:

Claim 23 is hereby incorporated by reference.

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wherein the receiving the
instruction message further
includes receiving specific
information sufficient to
identify the subscriber
device; and

Representative Apple Products: Apple iOS Devices6
Upon information and belief, the software program of Claim 23, when loaded and executing, performs
the step of receiving an instruction message from the subscriber device that corresponds to spoken
instructions, wherein the receiving the instruction message further includes receiving specific
information sufficient to identify the subscriber device.
For instance, upon information and belief, an instruction message includes information sufficient to
identify the subscriber device, including, e.g., Apple ID, device Unique Device ID (UDID), and/or
other identifying information.
See, e.g., http://www.apple.com/ios/siri/siri-faq/:

See also http://support.apple.com/kb/TS4079:

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Representative Apple Products: Apple iOS Devices6
See also generally iPhone User Guide, Chap. 4; iPad User Guide, Chap. 4; iPod Touch User Guide,
Chap. 4.
See also Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

wherein the converting the
spoken instructions includes
converting the spoken
instructions to the control
commands that correspond to
a type of subscriber device.

Upon information and belief, the software program of Claim 23, when loaded and executing, performs
the step of converting the spoken instructions, and such converting includes converting the spoken
instructions to the control commands that correspond to a type of subscriber device.
For example, upon information and belief, converting the spoken instructions includes converting the
spoken instructions to control commands for placing a phone call.
See, e.g., http://www.apple.com/ios/siri/:

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Upon information and belief, such control commands for placing a call further correspond to a type of
subscriber device; for instance, whereas control commands for placing a voice call to a telephone
number over a cellular network are used to assist with the control of a subscriber device that is an
Apple iPhone, such control commands are not used to assist with the control of a subscriber device
that is an Apple iPad or Apple iPod Touch; however an Apple iPad or Apple iPod Touch may place a
call using FaceTime.
Compare, e.g., iPhone User Guide at 36:

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with iPad User Guide at 35:

and with iPod Touch User Guide at 35:

Upon information and belief, converting spoken instructions to control commands also corresponds to
a type of subscriber device, in that certain other control commands may only be used to assist with the
control of certain subscriber devices, for example, the spoken instructions “Open Passbook” will be
converted to control commands only where the subscriber device is an iPhone or iPod Touch, and not
where the subscriber device is an iPad.

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Compare, e.g., iPhone User Guide at 36, iPod Touch User Guide at 35, with iPad User Guide at 35
(providing examples of spoken instructions that will be converted to control commands on the
subscriber devices).

Claim 25
25. The computer readable
medium encoded with a
software program of claim
24, the method further
comprising
maintaining a database
associated with the
subscriber device, the
database including one of a
parameter status and a
mirrored database associated
with the subscriber device.

Claim 24 is hereby incorporated by reference.

Upon information and belief, the software program of claim 24 further comprises the step of
maintaining a database associated with the subscriber device, the database including one of a
parameter status and a mirrored database associated with the subscriber device.
For example, Apple’s servers stores various User Data information including a mirrored database of
address book contacts and song names, as well as other communication unit (i.e., subscriber device)
specific information.
See, e.g., Apple iPhone Software License Agreement (available at
http://images.apple.com/legal/sla/docs/ios51.pdf) at 2 (highlighting added):

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