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 D

EXHIBIT D
UNITED STATES PATENT NO. 6,008,737
PRELIMINARY INFRINGEMENT CONTENTIONS1
Accused Apple Products:

Apple iPhone 3G, Apple iPhone 3GS, Apple iPhone 4, and Apple iPhone 4S, Apple iPhone 52, Apple
iPad, Apple iPad with 3G, Apple iPad 2, Apple iPad 2 with 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 (collectively, "Apple Phones"), Apple Mac Pro,
Apple iMac, new Apple iMac6, Apple Mac mini, new Apple Mac mini7, Apple MacBook, Apple

1

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

The term "Apple iPhone 5" means Apple's new iPhone announced by Apple on September 12, 2012. See
http://www.apple.com/pr/library/2012/09/12Apple-Introduces-iPhone-5.html.
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.
6

The term "new Apple iMac" means Apple's new iMac computers announced by Apple on October 23, 2012. See
http://www.apple.com/pr/library/2012/10/23All-New-iMac-Features-Stunning-Design-Brilliant-Display-Faster-Performance.html.
7

The term "new Apple Mac mini" means Apple's new Mac mini computers announced by Apple on October 23, 2012. See
http://www.apple.com/pr/library/2012/10/23All-New-iMac-Features-Stunning-Design-Brilliant-Display-Faster-Performance.html.
1

EXHIBIT D
MacBook Pro, 15-inch Apple MacBook Pro with Retina Display, 13-inch Apple MacBook Pro with
Retina Display8, Apple MacBook, and Apple MacBook Air (collectively, "Apple Computers").
Apple directly infringes the ‘737 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 ‘737 patent through its development, testing, use, distribution and sale of its
products and services, Apple also indirectly infringes the ‘737 patent pursuant to 35 U.S.C. § 271(b) and (c). End-users and others in
the distribution channel of the Accused Apple Products directly infringe this claim by using, selling, offering for sale, and/or
importing these devices into the United States. Apple contributes to and induces infringement through its promotion and provision of
marketing, sale and/or technical support of the Accused Apple Products and associated services in the United States, and through the
design, marketing, manufacture, sale, and/or technical support of the Accused Apple Products. Apple supplies Accused Apple
Products and actively encourages the use, sale, offer for sale, and importation of the same in the United States through the promotion
and provision of marketing literature, promotion, and user guides, which induces and results in direct infringement. Apple has known
or should have known that these actions would cause direct infringement of the ‘737 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 ‘737 Patent. Moreover, Apple has known of the ‘737 patent since at least October 6, 2010, when Motorola filed
its Complaint, attaching the ‘737 patent as an exhibit. Despite knowing of the ‘737 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.
‘737 Patent Claim

Accused Apple Products9

8

The term "13-inch Apple MacBook Pro with Retina Display" means Apple's new 13-inch MacBook Pro computer announced by
Apple on October 23, 2012. See http://www.apple.com/pr/library/2012/10/23Apple-Introduces-13-inch-MacBook-Pro-with-RetinaDisplay.html.
9

This chart provides Motorola’s infringement analysis for the Accused Apple Products. Upon information and belief, the analysis set
forth in this chart for applies equally to all of the Accused Apple Products.

2

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

9. A portable communication
device in a communication
system having a fixed portion,
the portable communication
device comprising:

Upon information and belief, Apple imports, manufactures, sells, offers to sell, and uses the Accused
Apple Products, which are portable communication devices. Moreover, the Accused Apple Products
operate in the normal course of use in a communication system having a fixed portion, which is the
authentication system used in one or more of Apple's iTunes, Apple's App Store, and Apple's
enterprise application system.
See, e.g., iPhone 4 Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed on
May 12, 2011, MOTO-APPLE-0006037953_126659:

3

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

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

4

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

See also e.g., Apple iPad Technical Specifications, (www.apple.com/ipad/specs), accessed on
April 12, 2011, MOTO-APPLE-0005383110_35376:

See also, e.g., MacBook Pro 15" Core 2 Duo Model A1211 Teardown,
(http://www.ifixit.com/Teardown/MacBook-Pro-15-Inch-Core-2-Duo-Model-A1211Teardown/593/1), accessed on May 14, 2011, MOTO-APPLE-0006037953_127250:

5

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

In addition, Apple has performed each and every step of this claim, and, through its design of the
Accused Apple Products, Apple also contributes to the infringement of the '737 patent by users of the
device. 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 '737 Patent. Thus, 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
'737 Patent. Apple knew that the Accused Apple Products contain two specific components for
sending and receiving authorization requests and responses. Apple knew that these components could
be combined and had no substantial non-infringing use, and that the 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., iPhone in Business: Security Overview, MOTO-APPLE-0006037953_126666.

See also iPhone in Business: Digital Certificates, MOTO-APPLE-0006037953_126669:

6

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

See also id.:

See also Distributing Enterprise Apps for iOS 4 Devices,
(http://developer.apple.com/library/ios/#featuredarticles/FA_Wireless_Enterprise_App_Distribution/
Introduction/Introduction.html), accessed on May 12, 2011, MOTO-APPLE-0006037953_126598:
"Certificate Validation. The first time an application is opened on a device, the
distribution certificate is validated by contacting Apple's OCSP server. Unless the
certificate has been revoked, the app is allowed to run. Inability to contact or get a
response from the OCSP server is not interpreted as a revocation. To verify the status,
the device must be able to reach ocsp.apple.com. See 'Network Configuration
Requirements.'

7

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9
The OCSP response is cached on the device for the period of time specified by the
OCSP server; currently between 3 and 7 days. The validity of the certificate will not be
checked again until the device has restarted and the cached response has expired. If a
revocation is received at that time, the app will be prevented from running. Note that
revoking a distribution certificate will invalidate all of the applications you have
distributed.
An app will not run if the distribution certificate has expired. Currently, distribution
certificates are valid for one year. A few weeks before your certificate expires request a
new distribution certificate from the Dev Center, use it create new distribution
provisioning profiles, then recompile and distribute the updated apps to your users. See
'Providing Updated Apps.'"
See also Developer Library—Authentication and Authorization,
(http://developer.apple.com/library/ios/#documentation/Security/Conceptual/Security_Overvie
w/AuthenticationAndAuthorization/AuthenticationAndAuthorization.html#//apple_ref/doc/uid
/TP30000976-CH2-SW1), accessed on 11/06/2012, MOTO-SDFL-0000018762:

8

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

a processor;

Upon information and belief, the Apple Phones contain a variety of different processors, such a an
Apple A4 processor, and Apple Computers contain a variety of different processors, such as the
2.4GHz Intel Core 2 Duo processor.
See, e.g., (http://www.apple.com/channel/iphone/iphone-4/best-buy/design.html), accessed May 12,
2011, MOTO-APPLE-0006037953_127201:

See also e.g., Apple iPad Technical Specifications, (www.apple.com/ipad/specs), accessed on
April 12, 2011, MOTO-APPLE-0005383110_35376:

See also, iPhone 5 teardown analysis –A6 processor (http://www.ifixit.com/Teardown/Apple-A6Teardown/10528/2), accessed on 11/06/2012, MOTO-SDFL-0000016113:

9

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

See also, e.g., MacBook Pro 15" Core 2 Duo Model A1211 Teardown,
(http://www.ifixit.com/Teardown/MacBook-Pro-15-Inch-Core-2-Duo-Model-A1211Teardown/593/1), accessed on May 14, 2011, MOTO-APPLE-0006037953_127248:

an authorization element
coupled to the processor for
obtaining usage authorization
for utilizing software in the

Upon information and belief, the Accused Apple Products contain an authorization element coupled to
the processor for obtaining usage authorization for utilizing software in the Apple product:

10

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

portable communication
device,

iPhone in Business: Security Overview, MOTO-APPLE-0006037953_126666.
See also iPhone in Business: Digital Certificates, MOTO-APPLE-0006037953_126669:

See also id.:

See also Distributing Enterprise Apps for iOS 4 Devices,
(http://developer.apple.com/library/ios/#featuredarticles/FA_Wireless_Enterprise_App_Distribution/I

11

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9
ntroduction/Introduction.html), accessed on May 12, 2011, MOTO-APPLE-0006037953_126598:
"Certificate Validation. The first time an application is opened on a device, the
distribution certificate is validated by contacting Apple's OCSP server. Unless the
certificate has been revoked, the app is allowed to run. Inability to contact or get a
response from the OCSP server is not interpreted as a revocation. To verify the status,
the device must be able to reach ocsp.apple.com. See 'Network Configuration
Requirements.'
The OCSP response is cached on the device for the period of time specified by the
OCSP server; currently between 3 and 7 days. The validity of the certificate will not be
checked again until the device has restarted and the cached response has expired. If a
revocation is received at that time, the app will be prevented from running. Note that
revoking a distribution certificate will invalidate all of the applications you have
distributed.
An app will not run if the distribution certificate has expired. Currently, distribution
certificates are valid for one year. A few weeks before your certificate expires request a
new distribution certificate from the Dev Center, use it create new distribution
provisioning profiles, then recompile and distribute the updated apps to your users. See
'Providing Updated Apps.'"
See also Developer Library—Authentication and Authorization,
(http://developer.apple.com/library/ios/#documentation/Security/Conceptual/Security_Overvie
w/AuthenticationAndAuthorization/AuthenticationAndAuthorization.html#//apple_ref/doc/uid
/TP30000976-CH2-SW1), accessed on 11/06/2012, MOTO-SDFL-0000018762 (emphasis
added):

12

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9
Communications with the Apple App store. In connection with a request to use or download software
onto an Accused Apple Product, an authorization element coupled to the processor of that Accused
Apple Product requests usage authorization for utilizing that software in the Accused Apple Product.
See also e.g., Email from Dallas De Atley, dated December 14, 2010, 745-Apple10360097-98:

See also e.g., iTunes Authentication Use Case Chart, 745-Apple5374978-81:

13

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

See also e.g., Email from Henri Lamiraux, dated December 13, 2010, 745-Apple10362501-32:

See also e.g. iPhone SDK, dated October 4, 2007, 745-Apple8563808-27;
http://support.apple.com/kb/HT1420; http://support.apple.com/kb/HT2204?viewlocale=en_US;

14

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9
http://support.apple.com/kb/HE37

in which the authorization
element generates an external
authorization request, and

Upon information and belief, the authorization element in the Accused Apple Products generates an
external authorization request sent to Apple's iTunes, Apple's App Store authentication servers and /
or Apple's enterprise application system. For example, the digital certificate is validated by contacting
an external OCSP server (external authorization request) upon initial opening, and by a runtime check
(external authorization request) at each time of use.
See Distributing Enterprise Apps for iOS 4 Devices,
(http://developer.apple.com/library/ios/#featuredarticles/FA_Wireless_Enterprise_App_Distribution/
Introduction/Introduction.html), accessed on May 12, 2011, MOTO-APPLE-0006037953_126598:
"Certificate Validation. The first time an application is opened on a device, the
distribution certificate is validated by contacting Apple's OCSP server. Unless the
certificate has been revoked, the app is allowed to run. Inability to contact or get a
response from the OCSP server is not interpreted as a revocation. To verify the status,
the device must be able to reach ocsp.apple.com. See 'Network Configuration
Requirements.'
The OCSP response is cached on the device for the period of time specified by the
OCSP server; currently between 3 and 7 days. The validity of the certificate will not be
checked again until the device has restarted and the cached response has expired. If a
revocation is received at that time, the app will be prevented from running. Note that
revoking a distribution certificate will invalidate all of the applications you have
distributed.
An app will not run if the distribution certificate has expired. Currently, distribution
certificates are valid for one year. A few weeks before your certificate expires request a
new distribution certificate from the Dev Center, use it create new distribution
provisioning profiles, then recompile and distribute the updated apps to your users. See
'Providing Updated Apps.'"
See also iPhone in Business: Security Overview, MOTO-APPLE-0006037953_126666:

15

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

See also iPhone in Business: Digital Certificates, MOTO-APPLE-0006037953_126669:

Communications with the Apple App store. In connection with a request to use software on or
download software onto an Accused Apple Product, an authorization element coupled to the processor
of that Accused Apple Product requests usage authorization for utilizing that software in the Accused
Apple Product. The authorization element within the Accused Apple Product generates an external
authorization request in order to secure this authorization.
See also e.g., Email from Dallas De Atley, dated December 14, 2010, 745-Apple10360097-98:

16

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

See also e.g., iTunes Authentication Use Case Chart, 745-Apple5374978-81:

17

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

See also e.g., Email from Henri Lamiraux, dated December 13, 2010, 745-Apple10362501-32:

See also e.g. iPhone SDK, dated October 4, 2007, 745-Apple8563808-27;
http://support.apple.com/kb/HT1420; http://support.apple.com/kb/HT2204?viewlocale=en_US;
http://support.apple.com/kb/HE37; 745-Apple5375102-04

18

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9
See also Developer Library—Authentication and Authorization,
(http://developer.apple.com/library/ios/#documentation/Security/Conceptual/Security_Overvie
w/AuthenticationAndAuthorization/AuthenticationAndAuthorization.html#//apple_ref/doc/uid
/TP30000976-CH2-SW1), accessed on 11/06/2012, MOTO-SDFL-0000018762 (emphasis
added):

in which the authorization
element communicates with
the fixed portion to obtain the
usage authorization in
response to the external
authorization request, and

Upon information and belief, the authorization element in the Accused Apple Products communicates
with the fixed portion (i.e., the authentication server for Apple's iTunes, Apple's App Store and / or
Apple's enterprise application system) to obtain the usage authorization in response to the external
authorization request. For example, the digital certificate (authorization element) is validated by
contacting an external OCSP server (communication to fixed portion to obtain usage authorization)
upon initial opening, and by a runtime check (external authorization request) at each time of use.
See, e.g., Distributing Enterprise Apps for iOS 4 Devices,
(http://developer.apple.com/library/ios/#featuredarticles/FA_Wireless_Enterprise_App_Distribution/
Introduction/Introduction.html), accessed on May 12, 2011, MOTO-APPLE-0006037953_126598:
"Certificate Validation. The first time an application is opened on a device, the
distribution certificate is validated by contacting Apple's OCSP server. Unless the
certificate has been revoked, the app is allowed to run. Inability to contact or get a

19

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9
response from the OCSP server is not interpreted as a revocation. To verify the status,
the device must be able to reach ocsp.apple.com. See 'Network Configuration
Requirements.'
The OCSP response is cached on the device for the period of time specified by the
OCSP server; currently between 3 and 7 days. The validity of the certificate will not be
checked again until the device has restarted and the cached response has expired. If a
revocation is received at that time, the app will be prevented from running. Note that
revoking a distribution certificate will invalidate all of the applications you have
distributed.
An app will not run if the distribution certificate has expired. Currently, distribution
certificates are valid for one year. A few weeks before your certificate expires request a
new distribution certificate from the Dev Center, use it create new distribution
provisioning profiles, then recompile and distribute the updated apps to your users. See
'Providing Updated Apps.'"
See also iPhone in Business: Security Overview, MOTO-APPLE-0006037953_126666:

See also iPhone in Business: Digital Certificates, MOTO-APPLE-0006037953_126669:

20

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

Communications with the Apple App store. In connection with a request to use software on or
download software onto an Accused Apple Product, an authorization element coupled to the processor
of that Accused Apple Product requests usage authorization for utilizing that software in the Accused
Apple Product. The authorization element within the Accused Apple Product generates an external
authorization request in order to secure this authorization. The authorization element communicates
with Apple servers to obtain the usage authorization in response to the external authorization request.
See also e.g., Email from Dallas De Atley, dated December 14, 2010, 745-Apple10360097-98:

21

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

See also e.g., iTunes Authentication Use Case Chart, 745-Apple5374978-81:

22

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9

See also e.g., Email from Henri Lamiraux, dated December 13, 2010, 745-Apple10362501-32

See also e.g. iPhone SDK, dated October 4, 2007, 745-Apple8563808-27;

23

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9
http://support.apple.com/kb/HT1420; http://support.apple.com/kb/HT2204?viewlocale=en_US;
http://support.apple.com/kb/HE37; 745-Apple5375102-04.
See also Developer Library—Authentication and Authorization,
(http://developer.apple.com/library/ios/#documentation/Security/Conceptual/Security_Overvie
w/AuthenticationAndAuthorization/AuthenticationAndAuthorization.html#//apple_ref/doc/uid
/TP30000976-CH2-SW1), accessed on 11/06/2012, MOTO-SDFL-0000018762 (emphasis
added):

in which the external
authorization request includes
at least one of: an address
identifying the portable
communication device, a
software name and a size of
the software; and

Upon information and belief, the external authorization request includes at least one of: an address
identifying the portable communication device, a software name and a size of the software.
For example, an X.509 digital certificate for an iPhone 4 “enforces a trust policy referred to as the
S/MIME policy, which specifies that in order to be trusted to verify a digitally signed email, a
certificate must contain an email address that matches the address of the sender of the email.” Security
Concepts,
(http://developer.apple.com/library/ios/#documentation/Security/Conceptual/Security_Overview/Conc
epts/Concepts.html), accessed on May 13, 2011, MOTO-APPLE-0006037953_126611.

24

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9
See id. at MOTO-APPLE-0006037953_126608:
"A digital certificate is a collection of data used to verify the identity of the holder or sender of the
certificate: For example, an X.509 certificate contains such information as:
•

Version

•

Serial number

•

Certificate issuer

•

Certificate holder

•

Validity period (the certificate is not valid before or after this period)

•

Attributes, known as certificate extension, that contain additional information such as
allowable uses for this certificate

•

Digital signature from the certification authority to ensure that the certificate has not been
altered and to indicate the identity of the issuer

•

Public key of the owner of the certificate

•

Message digest algorithm used to create the signature."

See also Distributing Enterprise Apps for iOS 4 Devices,
(http://developer.apple.com/library/ios/#featuredarticles/FA_Wireless_Enterprise_App_Distribution/I
ntroduction/Introduction.html), accessed on May 12, 2011, MOTO-APPLE-0006037953_126598:
"Certificate Validation. The first time an application is opened on a device, the
distribution certificate is validated by contacting Apple's OCSP server. Unless the
certificate has been revoked, the app is allowed to run. Inability to contact or get a
response from the OCSP server is not interpreted as a revocation. To verify the status,
the device must be able to reach ocsp.apple.com. See 'Network Configuration
Requirements.'
The OCSP response is cached on the device for the period of time specified by the
OCSP server; currently between 3 and 7 days. The validity of the certificate will not be
checked again until the device has restarted and the cached response has expired. If a
25

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9
revocation is received at that time, the app will be prevented from running. Note that
revoking a distribution certificate will invalidate all of the applications you have
distributed.
An app will not run if the distribution certificate has expired. Currently, distribution
certificates are valid for one year. A few weeks before your certificate expires request a
new distribution certificate from the Dev Center, use it create new distribution
provisioning profiles, then recompile and distribute the updated apps to your users. See
'Providing Updated Apps.'"

second authorization element
coupled to the processor for
allowing utilization of the
software, in response to usage
authorization being obtained
from the fixed portion.

Upon information and belief, the Accused Apple Products contain a second authorization element
coupled to the processor for allowing utilization of the software, in response to an authorization being
obtained from the fixed portion.
For example, the iPhone 4 software application is allowed to run (second authorization element) once
the digital certificate is authorized (usage authorization obtained from fixed portion.
See, e.g., Distributing Enterprise Apps for iOS 4 Devices,
(http://developer.apple.com/library/ios/#featuredarticles/FA_Wireless_Enterprise_App_Distribution/I
ntroduction/Introduction.html), accessed on May 12, 2011, MOTO-APPLE-0006037953_126598:
"Certificate Validation. The first time an application is opened on a device, the
distribution certificate is validated by contacting Apple's OCSP server. Unless the
certificate has been revoked, the app is allowed to run. Inability to contact or get a
response from the OCSP server is not interpreted as a revocation. To verify the status,
the device must be able to reach ocsp.apple.com. See 'Network Configuration
Requirements.'
The OCSP response is cached on the device for the period of time specified by the
OCSP server; currently between 3 and 7 days. The validity of the certificate will not be
checked again until the device has restarted and the cached response has expired. If a
revocation is received at that time, the app will be prevented from running. Note that
revoking a distribution certificate will invalidate all of the applications you have

26

EXHIBIT D
‘737 Patent Claim

Accused Apple Products9
distributed.
An app will not run if the distribution certificate has expired. Currently, distribution
certificates are valid for one year. A few weeks before your certificate expires request a
new distribution certificate from the Dev Center, use it create new distribution
provisioning profiles, then recompile and distribute the updated apps to your users. See
'Providing Updated Apps.'"

27