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)

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EXHIBIT L EXHIBIT L UNITED STATES PATENT NO. 7,509,148 PRELIMINARY INFRINGEMENT CONTENTIONS1 Accused Apple Products: Apple iPhone 3GS, Apple iPhone 4, Apple iPhone 4S, Apple iPhone 52, Apple iPad, Apple iPad + 3G, Apple iPad 2, Apple iPad 2 + 3G, 3rd Generation iPad, 3rd Generation iPad + 4G, 3rd Generation Apple iPod Touch, 4th Generation Apple iPod Touch, 5th Generation Apple iPod Touch,3 4th Generation Apple iPad,4 4th Generation Apple iPad [with cellular], Apple iPad mini,5 Apple iPad mini [with cellular]. Apple directly infringes the ‘148 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 claims of the ‘148 patent through its development, testing, use, distribution and sale of its products and services, Apple also indirectly infringes the ‘148 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 ‘148 patent 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 "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. 3 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. 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 EXHIBIT L 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 ‘148 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 ‘148 patent as an exhibit. Despite knowing of the ‘148 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. '148 Patent Claim Representative Apple Products: Apple iOS Device6 [1a] A message alert system for a communication device wherein the communication device comprises a processor and a display displaying information: Upon information and belief, the Apple iOS Device comprises a message alert system for a communication device wherein the communication device comprises a processor and a display for displaying information. Upon information and belief, the Apple iOS Device is a communication device comprising a processor and a display for displaying information. See, e.g., iPhone 4S Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed August 29, 2012, MOTO-SDFL-0000006340. 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 running iOS 5 or iOS 6. In this claim chart, "Apple iOS Device" refers to the Apple iPhone 3GS, Apple iPhone 4, Apple iPhone 4S, Apple iPhone 5, Apple iPad, Apple iPad + 3G, Apple iPad 2, Apple iPad 2 + 3G, Apple 3rd Generation iPad, Apple 3rd Generation iPad + 4G, 3rd Generation Apple iPod Touch, 4th Generation Apple iPod Touch, 5th Generation Apple iPod Touch, Apple iPad mini, Apple iPad mini [with cellular], 4th Generation Apple iPad, and 4th Generation Apple iPad [with cellular]. 2 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also, e.g., iPhone 4S – See all the amazing new things iPhone can do, (http://www.apple.com/iphone/features/#performance), accessed September 5, 2012, MOTO-SDFL-0000006284. See also, iPhone 5 Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed on November 6, 2012, MOTO-SDFL-0000016104-05. 3 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also, iPhone 5 teardown analysis –A6 processor (http://www.ifixit.com/Teardown/Apple-A6-Teardown/10528/2), accessed on November 6, 2012, MOTO-SDFL-0000016117. The Apple iOS Device includes a message alert system called the notification center as part of iOS 5 and iOS 6. See, e.g., iPhone 4S – See all the amazing new things iPhone can do, (http://www.apple.com/iphone/features/#ios), accessed September 5, 2012, MOTO-SDFL0000006298. 4 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also, iPhone Notification Center, iOS6—iPhone User Guide For iOS 6 Software, p. 28 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on October 28, 2012, MOTO-SDFL-0000016160. 5 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 [1b] a computer-readable medium; Upon information and belief, the Apple iOS Device includes a computer-readable medium. The iPhone 4S includes, for example, 16GB, 32GB, or 64GB of flash memory. See, e.g., iPhone 4S – Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed August 30, 2012, MOTO-SDFL-0000006340 (emphasis added). 6 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also, iPhone 5–Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed November 6, 2012, MOTO-SDFL-0000016104 (emphasis added). [1c] a routine stored in the computerreadable medium and configured for Upon information and belief, the Apple iOS Device includes a computer-readable medium storing a first routine that receives a message intended for receipt by the communication 7 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 execution by the processor, the routine comprising: a first routine that receives a message intended for receipt by the communication device, the message comprising the information; device, the message comprising the information. The Apple iOS Device is a communication device that receives a variety of messages intended for receipt by the communication device, including but not limited to, for example, SMS text messages, iMessages, email, Facebook messages, and Twitter messages. These messages comprise information that can be displayed on the Apple iOS Device display using the iOS notification center. A particular message is received by a first routine in the Apple iOS Device. This first routine is part of iOS and configured for execution by the processor of the Apple iOS Device. See, e.g., iOS 5 User Guide (http://manuals.info.apple.com/en_US/iphone_ios5_user_guide.pdf) at 31, accessed October 31, 2012, MOTO-SDFL-000006438. See, e.g., iPhone 4S – Always know what's up in Notification Center, (http://www.apple.com/iphone/features/notification-center.html), accessed September 5, 8 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 2012, MOTO-SDFL-0000006330 (emphasis added). See also, iPhone Notification Center, iOS6—iPhone User Guide For iOS 6 Software, p. 28 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed October 28, 2012, MOTO-SDFL-0000016160. 9 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 [1d] [a routine stored in the computerreadable medium and configured for execution by the processor, the routine comprising:] a second routine that analyzes the message to determine a size thereof, and further analyzes the message to determine from type identifying data transmitted with the message whether the message is of a message type for which a third Upon information and belief, the Apple iOS Device includes a computer-readable medium storing a second routine that analyzes the message to determine a size thereof, and further analyzes the message to determine from type identifying data transmitted with the message whether the message is of a message type for which the generating step is executed, wherein the criteria determining the type of message is different than a criteria based on the size of the message. Upon information and belief, the Apple iOS Device includes the iOS notification center. The Apple iOS Device generates a message for display in the iOS notification center when a certain type of message is received, but not when certain other types of message are 10 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 routine is executed, wherein the criteria for determining the type of message is different than a criteria based on the size of the message; and received. Whether a message for display is generated for a particular type of message may be based on notification settings. Upon information and belief, the Apple iOS Device analyzes the received message to determine from type identifying data transmitted with the message whether the message is of a message type for which the generating step is executed. See, e.g., iPhone User Guide, p. 159-60 (http://manuals.info.apple.com/en_US/iphone_user_guide.pdf), accessed October 31, 2012, MOTO-SDFL-0000006566-67. 11 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also, iPhone User Guide For iOS 6 Software, p. 28 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on October 28, 2012, MOTO-SDFL-0000016160. Upon information and belief, a third routine is run if a second routine determines that the message type is one for which a third routine should be executed. Upon information and belief, the third routine generates a display item for received messages of a certain type. Upon information and belief, the types of message for which a display item is generated may be set in iOS settings for the notification center. See, e.g., iPhone 4S – Always know what's up in Notification Center, (http://www.apple.com/iphone/features/notificationcenter.html), accessed September 5, 2012, MOTO-SDFL-0000006330 (emphasis added). 12 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See, e.g., iPhone 4S – Always know what's up in the Notification Center, (http://www.apple.com/iphone/features/notification-center.html), accessed September 5, 2012, MOTO-SDFL-0000006328 (emphasis added). 13 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also, e.g., iOS 5 – See new features included in iOS 5, 14 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 (http://www.apple.com/ios/features.html), accessed August 30, 2012, MOTO-SDFL0000006245-46 (emphasis added). Upon information and belief, in order to determine whether the full message or merely a portion thereof will be displayed, the Apple iOS Device analyzes the message to determine a size thereof. Upon information and belief, if the received message is determined to be smaller than a certain size and of a type where a display item is generated, its content will be displayed in full. Upon information and belief, if the received message is determined to 15 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 be larger than a predetermined size and of a type where a display item is generated, its content will be abbreviated upon display in the notification center. See, e.g., iPhone 4S – Always know what's up in the Notification Center, (http://www.apple.com/iphone/features/notification-center.html), accessed September 5, 2012, MOTO-SDFL-0000006330 (emphasis added); see, also, iOS 5 – See new features included in iOS 5, (http://www.apple.com/ios/features.html), accessed August 30, 2012, MOTO-SDFL-0000006245-46 (emphasis and notations added). See also Screenshots of iPhone 5 (emphasis added; phone numbers redacted). 16 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 17 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 Upon information and belief, the Apple iOS Device determines a size of the message, and for messages below a certain size, it reproduces the entire message, and for messages above that size, it reproduces only a portion of the message. Upon information and belief, the second routine is stored in the memory of the Apple iOS Device. Upon information and belief, this second routine is part of a larger routine configured for execution by the processor of the Apple iOS Device. [1e] wherein the third routine generates a display item for the message in accordance with the size thereof, if the message is of the type for which the Upon information and belief, the Apple iOS Device stores in a computer-readable medium a third routine, wherein the third routine generates a display item for the message in accordance with the size thereof, if the message is the type for which the third routine is executed. 18 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 generating step is executed. Upon information and belief, if a message received by the Apple iOS Device is determined to be a message type for which a display item should be generated, then a third routine is run that creates a display item for the message on the display screen in accordance with the size of the message. Upon information and belief, this generating step is executed by a third routine stored in the memory of the Apple iOS Device. Upon information and belief, if the Apple iOS Device is locked, the display item for the message is displayed on the unlock screen. See, e.g., iOS 5 – See new features included in iOS 5, (http://www.apple.com/ios/features.html), accessed August 30, 2012, MOTOSDFL-0000006245 (emphasis added). 19 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also Screenshots of iPhone 5 (phone numbers redacted). 20 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 Upon information and belief, if the Apple iOS Device is unlocked, the display item for the message is displayed for a predetermined time on the display screen, and after that predetermined time it may be displayed after a user selects a pulldown notification bar. See, e.g., iPhone 4S – Always know what's up in the Notification Center, (http://www.apple.com/iphone/features/notification-center.html), accessed September 5, 2012, MOTO-SDFL-0000006328 (emphasis added); iPhone User Guide (http://manuals.info.apple.com/en_US/iphone_user_guide.pdf) at 31, accessed August 30, 2012, MOTO-SDFL-0000006438 (emphasis added). 21 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 iPhone User Guide For iOS 6 Software, p. 28 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on October 28, 2012, MOTO-SDFL-0000016160 (emphasis added). 22 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also Screenshots of iPhone 5 (emphasis added; phone numbers redacted). 23 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 [3] The message alert system of claim 1, wherein the generated display item comprises a reproduction of the message when the second routine determines that the size of the message is less than a predetermined size. Upon information and belief, the Apple iOS Device comprises the message alert system of claim 1, wherein the generated display item comprises a reproduction of the message when the second routine determines that the size of the message is less than a predetermined size. See, e.g., iOS 5 – See new features included in iOS 5, (http://www.apple.com/ios/features.html), accessed August 30, 2012, MOTO-SDFL0000006245-46 (emphasis and notations added). 24 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also Screenshots of iPhone 5 (emphasis added; phone numbers redacted). 25 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 26 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 Upon information and belief, the Apple iOS Device determines the size of the message, and for messages below a certain size, it reproduces the entire message, and for messages above that predetermined size, it reproduces only a portion of the message. [6] The software system of claim 1, Upon information and belief, the Apple iOS Device comprises the software system of wherein: claim 1, wherein the message is transmitted to the communication device via a network, the message is transmitted to the and the network is a broadcast network. Upon information and belief, the Apple iOS communication device via a network; and Device receives messages transmitted over a broadcast network, such as, for example, the the network is a broadcast network. 802.11 wireless network. See, e.g., iPhone 4S – Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed August 30, 2012, MOTO-SDFL0000006340. 27 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also, iPhone 5 Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed November 6, 2012, MOTO-SDFL-0000016104. [7a] A method in a communication device having a display for displaying information, the method comprising the steps of: Upon information and belief, an Apple iOS Device performs each and every step of this claim in the course of normal use. An Apple iOS Device practices a method in a communication device having a display for displaying information. See, e.g., iPhone 4S – See all the amazing new things iPhone can do, (http://www.apple.com/iphone/features/#performance), accessed September 5, 2012, MOTO-SDFL-0000006284. 28 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See, e.g., Apple – iPhone 5, (http://www.apple.com/iphone/features/), accessed October 31, 2012, MOTO-SDFL-0000016093. 29 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 [7b] receiving by the communication device a message intended for receipt by the communication device, the message comprising the information; Upon information and belief, an Apple iOS Device receives by the communication device a message intended for receipt by the communication device, the message comprising the information. An Apple iOS Device is a communication device that receives messages intended for receipt by the communication device, including but not limited to, for example, SMS text messages, iMessages, email, Facebook messages, and Twitter messages. These messages comprise information that can be displayed on the Apple iOS Device display by the iOS notification center. See, e.g., iPhone 4S – See all the amazing new things iPhone can do, (http://www.apple.com/iphone/features/#ios), accessed September 5, 2012, MOTO-SDFL0000006286. 30 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also, iPhone Notification Center, iOS6—iPhone User Guide For iOS 6 Software, p. 28 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed October 28, 2012, MOTO-SDFL-0000016160. 31 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 [7c] analyzing the message to determine a size thereof, and further analyzing the message to determine from type identifying data transmitted with the message whether the message is of a message type for which the generating step is executed, wherein the criteria for determining the type of message is different than a criteria based on the size of the message; and Upon information and belief, an Apple iOS Device analyzes the message to determine a size thereof, and further analyzes the message to determine from type identifying data transmitted with the message whether the message is of a message type for which the generating step is executed, wherein the criteria determining the type of message is different than a criteria based on the size of the message. Upon information and belief, an Apple iOS Device includes the iOS notification center. iOS generates a message for display when a certain type of message is received, but not when certain other types of message are received based on notification settings. In order to implement the notification settings, an Apple iOS Device analyzes the received message to 32 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 determine from type identifying data transmitted with the message whether the message is of a message type for which the generating step is executed. See, e.g., iPhone User Guide, p. 159 (http://manuals.info.apple.com/en_US/iphone_user_guide.pdf), accessed August 30, 2012, MOTO-SDFL-0000006566-67. See also, iPhone Notification Center, iOS6—iPhone User Guide For iOS 6 Software, p. 28 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed October 28, 2012, MOTO-SDFL-0000016160. Upon information and belief, in order to determine whether the full message or merely a portion thereof will be displayed, the Apple iOS Device analyzes the message to determine a size thereof. Upon information and belief, if the received message is determined to be 33 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 smaller than a certain size and of a type where a display item is generated, its content will be displayed in full. Upon information and belief, if the received message is determined to be larger than a predetermined size and of a type where a display item is generated, its content will be abbreviated upon display in the notification center. See, e.g., iOS 5 – See new features included in iOS 5, (http://www.apple.com/ios/features.html), accessed August 30, 2012, MOTO-SDFL-0000006245-46 (emphasis and notations added). See also Screenshots of iPhone 5 (emphasis added; phone numbers redacted). 34 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 35 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 Upon information and belief, the Apple iOS Device determines a size of the message, and for messages below a certain size, it reproduces the entire message, and for messages above that size, it reproduces only a portion of the message. 36 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also, e.g., iOS 5 – See new features included in iOS 5, 37 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 (http://www.apple.com/ios/features.html), accessed September 5, 2012, MOTO-SDFL0000006328 (emphasis added). See also, iPhone User Guide For iOS 6 Software, p. 28 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed October 28, 2012, MOTO-SDFL-0000016160 (emphasis added). 38 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also Screenshots of iPhone 5 (emphasis added and phone numbers redacted). 39 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 40 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 [7d] generating on the display a display item for the message in accordance with the size thereof, if the message is of the type for which the generating step is executed. Upon information and belief, an Apple iOS Device generates on the display a display item for the message in accordance with the size thereof, if the message is the type for which the generating step is executed. Upon information and belief, when a message is received by the Apple iOS Device, the Apple iOS Device determines whether that message is of a type that should be displayed in accordance with the notification settings. If that message is of a type that should be displayed, it is displayed on the display screen. Upon information and belief, for example, if the Apple iOS Device is locked, the message is displayed on the unlock screen. See, e.g., iOS 5 – See new features included in iOS 5, (http://www.apple.com/ios/features.html), accessed August 30, 2012, MOTO-SDFL41 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 0000006245 (emphasis added). See also Screenshots of iPhone 5 (phone numbers redacted). 42 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 Upon information and belief, for example, if the Apple iOS Device is in use, the message is displayed for a predetermined time on the display screen, and after that predetermined time it is displayed in a pulldown notification bar. See, e.g., iPhone 4S – Always know what's up in the Notification Center, (http://www.apple.com/iphone/features/notificationcenter.html), accessed September 5, 2012, MOTO-SDFL-0000006328 (emphasis added); iPhone User Guide (http://manuals.info.apple.com/en_US/iphone_user_guide.pdf) at 31, accessed August 30, 2012, MOTO-SDFL-0000006438 (emphasis added). 43 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See iPhone User Guide For iOS 6 Software, p. 28 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed October 28, 2012, MOTO-SDFL-0000016160 (emphasis added). 44 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also Screenshots of iPhone 5 (emphasis added and phone numbers redacted). 45 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 [9] The method of claim 7, wherein the generated display item comprises a reproduction of the message when the analyzing step determines that the size of the message is less than a predetermined size. Upon information and belief, an Apple iOS Device practices the method of claim 7, wherein the generated display item comprises a reproduction of the message when the analyzing step determines that the size of the message is less than a predetermined size. See, e.g., iOS 5 – See new features included in iOS 5, (http://www.apple.com/ios/features.html), accessed August 30, 2012, MOTO-SDFL0000006245-46 (emphasis and notations added). 46 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 See also Screenshot of iPhone 5 (emphasis added and phone numbers redacted). 47 EXHIBIT L '148 Patent Claim Representative Apple Products: Apple iOS Device6 48

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