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 B EXHIBIT B UNITED STATES PATENT NO. 5,754,119 PRELIMINARY INFRINGEMENT CONTENTIONS1 Accused Apple Products: Apple iPhone 3G, 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 Apple iPad, 3rd Generation Apple iPad + 4G, 4th Generation Apple iPad3, 4th Generation Apple iPad [with cellular], Apple iPad mini4, Apple iPad mini [with cellular], 3rd Generation Apple iPod Touch, 4th Generation Apple iPod Touch, 5th Generation Apple iPod Touch5, MobileMe, and iCloud. Apple directly infringes the ‘119 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 ‘119 patent through its development, testing, use, distribution and sale of its products and services, Apple also indirectly infringes the ‘119 patent pursuant to 35 U.S.C. § 271(b) and (c). End-users and others in the distribution channel of the Accused Apple Products directly infringe this claim by using, selling, offering for sale, and/or importing these devices into the United States. Apple contributes to and induces infringement through its promotion and provision of marketing, 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 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. 4 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. 5 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. 1 EXHIBIT B 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 ‘119 patent and did so with specific intent to encourage direct infringement, at least as of 2007, when Apple and Motorola participated in talks regarding the licensing of Motorola's patent portfolio. On information and belief, in connection with those negotiations, Apple has reviewed said portfolio, including Motorola's ‘119 Patent. Moreover, Apple has known of the ‘119 patent since at least October 6, 2012, when Motorola filed its Complaint, attaching the ‘119 patent as an exhibit. Despite knowing of the ‘119 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. ‘119 Patent Claim 1. A method of synchronizing message information among a plurality of transceivers comprising the steps of: Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 Upon information and belief, the Accused Apple Products perform each and every step of this claim in the course of normal use. Additionally, a user of an Accused Apple Product performs each and every step of this claim in the course of such use. Furthermore, Apple has performed each and every step of this claim. Apple’s MobileMe / iCloud service with an Apple iOS Device practices a method of synchronizing message information among a plurality of transceivers: 6 This chart provides Motorola’s infringement analysis for the MobileMe and/or iCloud service communicating with the Accused Apple Products. In this claim chart, "Apple iOS Device" refers to the Apple iPhone 3G, Apple iPhone 3GS, Apple iPhone 4, Apple iPhone 4S, Apple iPhone 5, Apple iPad, Apple iPad + 3G, Apple iPad 2, Apple iPad 2 with 3G, 3rd Generation Apple iPad, 3rd Generation Apple iPad + 4G, 4th Generation Apple iPad6, 4th Generation Apple iPad [with cellular], Apple iPad mini6, Apple iPad mini [with cellular], 3rd Generation Apple iPod Touch, 4th Generation Apple iPod Touch, and 5th Generation Apple iPod Touch. Upon information and belief, the analysis set forth in this chart for "Apple iOS Device" applies equally to each such device. Because, upon information and belief, the analysis set forth in this chart applies equally to both MobileMe and iCloud, they are referred to together herein as “MobileMe / iCloud.” 2 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 MobileMe Features, (http://www.apple.com/mobileme/features/), accessed on May 13, 2011, MOTOAPPLE-0006037953_127187. See also iPhone User Guide for iPhone 0S 3.1 Software, at MOTO-APPLE-0006037953_126971: 3 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also MobileMe Help: How MobileMe synching works, (http://docs.info.apple.com/article.html?path=MobileMe/Help/en/mm5b08c671.html), accessed on May 17, 2011, MOTO-APPLE-0006037953_127252-53: See also MobileMe on you iPhone or iPod touch, (http://www.apple.com/mobileme/features/iphone.html), accessed on May 16, 2011, MOTO-APPLE0006037953_126654: 4 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also What is IMAP and Why Do We Use It, (http://www.apple.com/mobileme/news/2008/11/what-is-imap-and-why-do-we-use-it.html), accessed on May 5, 2011, MOTO-APPLE-0006037953_126657: 5 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also, iCloud - Calendar, Mail, and Contacts, http://www.apple.com/icloud/features/calendar-mailcontacts.html, accessed on October 27, 2011: 6 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software, p. 15 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016147: In addition, through its design of the Accused Apple Products, Apple also induced users of the Accused Apple Products to infringe the '119 patent. Apple and Motorola have been in talks since 2007 regarding the licensing of Motorola's patent portfolio, and, on information and belief, in accordance with those negotiations, Apple has reviewed said portfolio, including Motorola's '119 Patent. Thus, at least as early as 2007, Apple knew or should have known its actions would induce actual infringement and possessed specific intent to encourage its customers' direct infringement through the design of the Accused Apple products. In addition, Apple instructs the users of the Accused Apple Products to use them in an infringing manner, including but not limited to by 7 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 describing infringing uses in its advertisements, promotional materials, labels, and user manuals. See e.g. MobileMe Features, (http://www.apple.com/mobileme/features/), accessed on May 13, 2011, MOTO-APPLE-0006037953_127187. See also, e.g. MobileMe Help: How MobileMe synching works, (http://docs.info.apple.com/article.html?path=MobileMe/Help/en/mm5b08c671.html), accessed on May 17, 2011, MOTO-APPLE-0006037953_127252-53: 8 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also, iCloud - Calendar, Mail, and Contacts, http://www.apple.com/icloud/features/calendar-mailcontacts.html, accessed on October 27, 2011: See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software, p. 15 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL- 9 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 0000016147: Moreover, Apple also contributes to the infringement of the '119 patent by users of the device. As indicated above, at least as early as 2007, Apple knew that offering to sell or selling the Accused Apple Products would contribute to direct infringement of the '119 Patent. Apple knew that the Accused Apple Products contain a specific synchronization software component, a component with no substantial non-infringing use, that could be combined with Apple's MobileMe / iCloud service, and that this combination, for which the two components were especially made, was both patented and infringing. Moreover, Accused Apple Products users have, in fact, combined these components into an infringing device. Apple further contributes to the direct infringement of the users of the Accused Apple Products, including but not limited to by describing infringing combinations in its advertisements, promotional materials, and user manuals. See e.g. MobileMe Features, (http://www.apple.com/mobileme/features/), accessed on May 13, 2011, MOTO-APPLE0006037953_127187. 10 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also, e.g. MobileMe Help: How MobileMe synching works, (http://docs.info.apple.com/article.html?path=MobileMe/Help/en/mm5b08c671.html), accessed on May 17, 2011, MOTO-APPLE-0006037953_127252-53: 11 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also, iCloud - Calendar, Mail, and Contacts, http://www.apple.com/icloud/features/calendar-mailcontacts.html, accessed on October 27, 2011: See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software, p. 15 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL12 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 0000016147: transmitting by a wireless messaging infrastructure a first message having a first status; Upon information and belief, MobileMe/iCloud transmits by a wireless messaging structure a first message having a first status. For example, this first message could be an email (a first message) that has a status of the email being "Unread" (a first status). This first message could also be a calendar event, or contact information. iPhone User Guide for iOS 4.2 and 4.3 Software, "Checking and Reading Email," MOTO-APPLE0006037953_126750: "When you open a mailbox, Mail retrieves and displays the most recent messages, and shows the number of unread messages at the top of the screen. Unread messages have a blue dot next to them . . . . If you organize messages by thread, related messages appear as a single entry in the mailbox. Message threads have a number next to the right arrow, showing the number of messages in the thread. A blue dot indicates that one or more messages in the thread are unread." 13 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See MobileMe Features, (http://www.apple.com/mobileme/features/), accessed on May 13, 2011, MOTO-APPLE-0006037953_127188: 14 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also, iCloud email service—http://support.apple.com/kb/TS4083, accessed on 11/06/2012, MOTO-SDFL-0000018786: See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software, pp. 51, 65 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL- 15 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 0000016183, 16197 (circles added): in one transceiver of the plurality of transceivers, changing the first status of the first message to a second status responsive to an input Upon information and belief, in an Apple iOS Device, (one transceiver of the plurality of transceivers), the first status of the first message is changed to a second status responsive to an input to the one transceiver, and a second message is transmitted indicative of the second status. The first message could be an email, calendar appointment, or a contact. 16 EXHIBIT B ‘119 Patent Claim to the one transceiver, and transmitting a second message indicative of the second status; Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 For example, in an Apple iOS Device, if the first message was an email, the status of the email changes from “Unread” (the first status) to “Read” in response to the user selecting the email in the Mail of iOS (an input to the one transceiver), and a second message is transmitted indicative of the email's status of “Unread” (the second status). Additionally, in an Apple iOS Device (one transceiver of the plurality of transceivers), the status of the email changes from “Unread” (the first status) to “Deleted” in response to the user deleting the email in the Mail of iOS (an input to the one transceiver), and a second message is transmitted indicative of the email's status of “Deleted” (the second status): See MobileMe Features, (http://www.apple.com/mobileme/features/), accessed on May 13, 2011, MOTO-APPLE-0006037953_127188. 17 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also What is IMAP and Why Do We Use It, (http://www.apple.com/mobileme/news/2008/11/what-is-imap-and-why-do-we-use-it.html), accessed on May 5, 2011, MOTO-APPLE-0006037953_126657: See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software, pp. 51, 65 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016183, 16197, (circles added): 18 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also, iCloud email service—http://support.apple.com/kb/TS4083, accessed on 11/06/2012, MOTO-SDFL-0000018786: See also, iCloud mail overview—http://support.apple.com/kb/PH2618, accessed on 11/06/2012, 19 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 MOTO-SDFL-0000018647: in the wireless messaging infrastructure, receiving the second message, and responsive to receiving the second message, transmitting a third message indicative of the second status; and Upon information and belief, MobileMe’s / iCloud's wireless messaging infrastructure receives the second message, and responsive to the second message, transmits a third message indicative of the second status. For example, where the first message was an email, MobileMe’s IMAP server (the wireless messaging infrastructure) receives the second message. In response to the receipt of the second message, the IMAP server transmits a third message indicative of the email's status of "Unread" or "Deleted" (the second status). Indeed, but for the receipt of the second message, the third message would not have been sent. See, e.g., Apple's Markman slides for '119 patent at 45-49; Markman Transcript 443:20445:9. 20 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See MobileMe Features, (http://www.apple.com/mobileme/features/), accessed on May 13, 2011, MOTO-APPLE-0006037953_127188. See also MobileMe on your iPhone or iPod touch, (http://www.apple.com/mobileme/features/iphone.html), accessed on May 16, 2011, MOTO-APPLE0006037953_126654: 21 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also iPhone User Guide for iPhone 0S 3.1 Software, at MOTO-APPLE-0006037953_126971: See also MobileMe Features, (http://www.apple.com/mobileme/features/), accessed on May 13, 2011, MOTO-APPLE-0006037953_127187: 22 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also What is IMAP and Why Do We Use It, (http://www.apple.com/mobileme/news/2008/11/what-is-imap-and-why-do-we-use-it.html), accessed on May 5, 2011, MOTO-APPLE-0006037953_126657: 23 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also, iCloud - Calendar, Mail, and Contacts, http://www.apple.com/icloud/features/calendar-mailcontacts.html, accessed on October 27, 2011: 24 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also, iCloud email service—http://support.apple.com/kb/TS4083, accessed on 11/06/2012, MOTO-SDFL-0000018786: See also, iCloud mail overview—http://support.apple.com/kb/PH2618, accessed on 11/06/2012, MOTO-SDFL-0000018647: in at least one other transceiver of the plurality of transceivers, receiving the third message, and responsive to receiving the third message, changing the first status of the first message to the second status. Upon information and belief, at least one other Apple iOS Device receives the third message, and responsive to receiving the third message, changes the first status of the first message to the second status. For example, where the first message was an email, the first status of the email changes from "Unread" to "Read" or "Deleted" (the second status): 25 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See MobileMe Features, (http://www.apple.com/mobileme/features/), accessed on May 13, 2011, MOTO-APPLE-0006037953_127188. See also MobileMe on you iPhone or iPod touch, (http://www.apple.com/mobileme/features/iphone.html), accessed on May 16, 2011, MOTO-APPLE0006037953_126654: 26 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also MobileMe Help: How MobileMe synching works, (http://docs.info.apple.com/article.html?path=MobileMe/Help/en/mm5b08c671.html), accessed on May 17, 2011, MOTO-APPLE-0006037953_127252-53: 27 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also Exhibit MobileMe Features, (http://www.apple.com/mobileme/features/), accessed on May 13, 2011, MOTO-APPLE-0006037953_127187: See also What is IMAP and Why Do We Use It, (http://www.apple.com/mobileme/news/2008/11/what-is-imap-and-why-do-we-use-it.html), accessed 28 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 on May 5, 2011, MOTO-APPLE-0006037953_126657: See also, iCloud - Calendar, Mail, and Contacts, http://www.apple.com/icloud/features/calendar-mailcontacts.html, accessed on October 27, 2011: 29 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 See also, iCloud email service—http://support.apple.com/kb/TS4083, accessed on 11/06/2012, MOTO-SDFL-0000018786: See also, iCloud mail overview—http://support.apple.com/kb/PH2618, accessed on 11/06/2012, MOTO-SDFL-0000018647: 2. The method according to claim 1 wherein the first status is an unread status and the second status is includes read, deleted, or protected status. Upon information and belief, the Accused Apple Products perform each and every step of this claim in the course of normal use. Additionally, a user of an Accused Apple Product performs each and every step of this claim in the course of such use. Furthermore, Apple has performed each and every step of this claim, has actively induced users to perform such steps, and has contributed to such use by selling the accused products and providing directions for their use. Apple’s MobileMe / iCloud service with an Apple iOS Device practice a method according to claim 1 wherein the first status is an unread status and the second status is includes read, deleted, or protected status. As discussed above in Claim 1, MobileMe / iCloud will transmit to an Apple iOS Device an email that 30 EXHIBIT B ‘119 Patent Claim Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 has a first status of "Unread." When a user of an Apple iOS Device selects or deletes a message in the Mail of iOS, the email's status changes to a second status of "Read" or "Deleted."See Claim 1 contentions above. See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software, pp. 51, 65 (http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016183, 16197 (circles added): 31 EXHIBIT B ‘119 Patent Claim 5. A method of synchronizing a status of a plurality of transceivers comprising the steps of: Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 Upon information and belief, the Accused Apple Products perform each and every step of this claim in the course of normal use. Additionally, a user of an Accused Apple Product performs each and every step of this claim in the course of such use. Furthermore, Apple has performed each and every step of this claim. Apple’s MobileMe / iCloud service with an Apple iOS Device practice a method of synchronizing message information among a plurality of transceivers. See Claim 1 contentions above. In addition, through its design of the Accused Apple Products, Apple also induced users of the Accused Apple Products to infringe the '119 patent. Apple and Motorola have been in talks since 2007 regarding the licensing of Motorola's patent portfolio, and, on information and belief, in accordance with those negotiations, Apple has reviewed said portfolio, including Motorola's '119 Patent. Thus, at least as early as 2007, Apple knew or should have known its actions would induce actual infringement and possessed specific intent to encourage its customers' direct infringement through the design of the Accused Apple products. In addition, Apple instructs the users of the Accused Apple Products to use them in an infringing manner, including but not limited to by describing infringing uses in its advertisements, promotional materials, labels, and user manuals. See Claim 1 contentions above. Moreover, Apple also contributes to the infringement of the '119 patent by users of the device. As indicated above, at least as early as 2007, Apple knew that offering to sell or selling the Accused Apple Products would contribute to direct infringement of the '119 Patent. Apple knew that the Accused Apple Products contain a specific synchronization software component, a component with no substantial non-infringing use, that could be combined with Apple's MobileMe / iCloud service, and that this combination, for which the two components were especially made, was both patented and infringing. Moreover, Accused Apple Products users have, in fact, combined these components into an infringing device. Apple further contributes to the direct infringement of the users of the Accused Apple Products, including but not limited to by describing infringing combinations in its advertisements, promotional materials, and user manuals. See Claim 1 contentions above. in a first transceiver, changing the status of the first transceiver from a first Upon information and belief, in a first transceiver connected to the MobileMe / iCloud network the status of the first transceiver changes from a first status to a second status as a result of an input from a user, and transmits a first message indicative of the second status. 32 EXHIBIT B ‘119 Patent Claim status to a second status as a result of an input from a user, and transmitting a first message indicative of the second status; in a wireless messaging infrastructure, receiving the first message, and transmitting a second message indicative of the second status; and in a second transceiver, receiving the second message, and changing a status of the second transceiver to the second status in response thereto. Representative Apple Product: Apple MobileMe / iCloud communicating with an Apple iOS Device6 For example, an Apple iOS Device, (first transceiver) can, as a result of input from a user, change the status of email, calendar, or contact information (first status) to reflect, e.g., email deletions, new calendar appointments, and/or new contacts (second status) and transmit a first message indicative of the second status to the MobileMe / iCloud communication server. See Claim 1 contentions above. Upon information and belief, MobileMe / iCloud's wireless messaging infrastructure, receives the first message, and transmits a second message indicative of the second status. To continue the above example, the MobileMe / iCloud's IMAP server (the wireless messaging infrastructure) receives the first message. In response to the receipt of the first message, the IMAP server transmits a second message indicative of the second status, e.g., any email deletions, new calendar appointments, and/or new contacts (second status). Indeed, but for the receipt of the first message, the second message would not have been sent. See, e.g., Apple's Markman slides for '119 patent at 45-49; Markman Transcript 443:20-445:9. See Claim 1 contentions above. Upon information and belief, a second transceiver connected to the MobileMe / iCloud network receives the second message, and changes a status of the second transceiver to the second status in response thereto. To continue the above example, a second Apple iOS Device receives the second message transmitted by the MobileMe / iCloud IMAP server, and in response thereto, changes the status of, e.g., any email, calendar, or contact information to reflect any email deletions, new calendar appointments, and/or new contacts (second status). See Claim 1 contentions above. 33

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