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 F

EXHIBIT F
UNITED STATES PATENT NO. 6,377,161
PRELIMINARY INFRINGEMENT CONTENTIONS1
Accused Apple Products:

Apple iPhone 3G, Apple iPhone 3GS, Apple iPhone 4, Apple iPhone 4S, Apple iPhone 52 (collectively,
“Apple iPhones”), 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 iPads and iPods),
Apple Mac Pro, Apple iMac, new Apple iMac6, Apple Mac mini, new Apple Mac mini7, 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 F
MacBook, Apple MacBook Pro, 15-inch Apple MacBook Pro with Retina Display, 13-inch Apple
MacBook Pro with Retina Display8, Apple MacBook, Apple MacBook Air("Apple Computers"),
MobileMe, and iCloud.
Apple directly infringes the ‘161 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 ‘161 patent through its development, testing, use, distribution and sale of its
products and services, Apple also indirectly infringes the ‘161 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 ‘161 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 161 Patent. Moreover, Apple has known of the ‘161 patent since at least October 6, 2010, when Motorola filed
its Complaint, attaching the ‘161 patent as an exhibit. Despite knowing of the ‘161 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.
’161 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. In this claim chart, "Apple Phone" refers to
Apple iPhone 3G S, Apple iPhone 3G, Apple iPhone 4, Apple iPhone 4S, Apple iPhone 5, 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 iPad, 4th Generation
Apple iPad [with cellular], Apple iPad mini, 3rd Generation Apple iPod Touch, 4th Generation Apple iPod Touch, and 5th Generation
2

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

1. A method in a
wireless messaging
system for facilitating
an exchange of address
information between
first and second
portable messaging
units, the method
comprising the steps of:

Upon information and belief, the Accused Apple Products perform each and every step of this claim in the
course of their normal use. Additionally, a user of the Accused Apple Products performs each and every
step of this claim in the course of such use.
In a wireless messaging system, the Accused Apple Products facilitate the exchange of address
information between first and second portable messaging units. For example,
(1) Using a wireless messaging system (e.g., MobileMe, iCloud, Exchange, Gmail, Yahoo, AOL, SMS,
cellular telephone network, etc.), Apple iPhones, Apple iPads and iPods, and Apple Computers can
facilitate an exchange of email address information (address information) between, e.g., an Apple iPhone
(first portable messaging unit) and, e.g., another Apple iPhone (second portable messaging unit).

iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688.
See also id. at MOTO-APPLE-0006037953_126751:

Apple iPod Touch; "Apple Computer" refers to Apple MacBook, Apple MacBook Pro, 15-inch Apple MacBook Pro with Retina
Display, 13-inch Apple MacBook Pro with Retina Display, Apple MacBook Air, Apple iMac, new Apple iMac, Apple Mac Mini, new
Apple Mac Mini, and Apple Mac Pro. Upon information and belief, the analysis set forth in this chart for "Apple Phone" applies
equally to all Apple Phones; and, upon information and belief, the analysis set forth in this chart for "Apple Computer" applies equally
to all Apple Computers.
3

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Reading mail”), p. 51
(http://manuals.info.apple.com/en/iphone_user_guide.pdf) accessed on 11/06/2012, MOTO-SDFL0000016183:

See also, (http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, at MOTOAPPLE-0006037953_126647:

4

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

(2) In addition, over a cellular telephone network (wireless messaging system, Apple iPhones facilitate the
exchange of text message address information (address information) between, e.g., an Apple iPhone (first
portable messaging unit) and, e.g., another Apple iPhone (second portable messaging unit) ):

5

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126780.
See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Messages”), p. 65
(http://manuals.info.apple.com/en/iphone_user_guide.pdf) accessed on 11/06/2012, MOTO-SDFL0000016197 (emphasis added):

6

EXHIBIT F

’161 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 induced users of the Accused Apple Products to infringe the '161 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 '161 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
e.g., iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688:

Id. at MOTO-APPLE-0006037953_126751:

See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Reading mail”), p. 51
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016183:

7

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

(http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, at MOTO-APPLE0006037953_126647:

Apple also knew that offering to sell or selling the Accused Apple Products would contribute to direct
infringement of the '161 Patent. As indicated above, at least as early as 2007, Apple knew that offering to
8

EXHIBIT F

’161 Patent Claim

sending the address
information from the
first portable
messaging unit to the
second portable
messaging unit
through the wireless
messaging system;

Accused Apple Products9
sell or selling the Accused Apple Products would contribute to direct infringement of the '161 Patent.
Apple knew that the Accused Apple Products contain a specific software component for facilitating the
exchange of address information, a component with no substantial non-infringing use, which could be
combined with Apple's MobileMe / iCloud service, and that this combination, for which the component
was especially made, was both patented and infringing. Moreover, users of the Accused Apple Products
have, in fact, combined these components into an infringing method. 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., MOTOAPPLE-0006037953_126688, MOTO-APPLE-0006037953_126751, and MOTO-APPLE0006037953_126647, above.
Upon information and belief, Apple iPhones, Apple iPads and iPods, and Apple Computers send the
address information to another portable messaging unit through the wireless messaging system. For
example,
(1) Through a wireless messaging system, a first Accused Apple Product (first portable messaging unit)
can send email address information (address information) to, e.g., a second Accused Apple Product
(second portable messaging unit) :

iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688.
See also, (http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, at MOTOAPPLE-0006037953_126647:

9

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

(2) In addition, through a cellular telephone network, a first Apple iPhone (first portable messaging unit)
can send text address information (address information) to, e.g., a second Apple iPhone (second portable
messaging unit) .

10

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

iPhone User Guide for iOS 4.2 and 4.3 Software, MOTO-APPLE-0006037953_126780.
See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Messages”), p. 65
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016197 (emphasis added).

receiving the address

Upon information and belief, the email or text address information is received by the second Accused
11

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

information by the
second portable
messaging unit;

Apple Product. For example,
(1) a second Accused Apple Product (second portable messaging unit) can receive email address
information (address information) transmitted by a first Accused Apple Product (first portable messaging
unit):

iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688.
See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Reading mail”), p. 51
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016183:

See also, (http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, at MOTOAPPLE-0006037953_126647:

12

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

(2) Also, a second Apple iPhone (second portable messaging unit) can receive text message address
information (address information) transmitted by a first Apple iPhone (first portable messaging unit):

13

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

iPhone User Guide for iOS 4.2 and 4.3 Software, MOTO-APPLE-0006037953_126780.
See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Messages”), p. 65
(http://manuals.info.apple.com/en/iphone_user_guide.pdf) accessed on 11/06/2012, MOTO-SDFL0000016197 (emphasis added).

14

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

Screenshots of the iPhone 5(receiving the address information by email/text message), taken 11/06/2012,
accessed on 11/06/2012, MOTO-SDFL-0000018687; 18692.
checking, by the second Upon information and belief, the second Accused Apple Product checks, in response to the receiving step,
portable messaging unit whether information identical to the email or text address information is stored in its address book. For
15

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

in response to the
receiving step, whether
information identical to
the address information
is stored in an address
book of the second
portable messaging
unit; and

example,
(1) Where the second portable messaging unit is an Apple iPhone, iPad, or iPod Touch, after receiving an
email's address information (address information), the user of the second portable messaging unit can
check to determine whether information identical to the email address information is stored in the Contacts
App (the address book) of that Apple iPhone, iPad, or iPod Touch. If not, the Apple iPhone, iPad, or iPod
Touch creates a prompt screen upon user selection of the email address, which allows the user to select the
email address and either create a new contact or add it to an existing contact:

Id. at MOTO-APPLE-0006037953_126751.
See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Reading mail”), p. 51
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016183:

16

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

17

EXHIBIT F

’161 Patent Claim

Accused Apple Products9
Screenshots of the iPhone 5(checking whether the address information in an email is already stored; the
address information can be stored if previously not stored), taken 11/06/2012, MOTO-SDFL-0000018688;
18689.
2) Where the second portable messaging unit is an Apple Computer, after receiving an email's address
information (address information), the user of the second portable messaging unit can check to determine
whether information identical to the email address information is stored in the Address Book Application
(the address book) of that Apple Computer. If not, the Apple Computer creates a drop-down list upon user
selection of the email address, from which the user can create a new contact or add it to an existing
contact:

18

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

Screenshot of Apple Computer Screen, taken May 9, 2011, MOTO-APPLE-0006037953_126641.
See also, Apple Computer run on OS X Mountain Lion (the latest version of OS X)–“Mail (Mountain
Lion): Add Information to Contacts,” (http://support.apple.com/kb/PH11767), accessed on 11/06/2012,
MOTO-SDFL-0000018741 (boxes added):

19

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

(2) Where a text message containing address information (address information) is received by a second
Apple iPhone (second messaging unit), the user of the second portable messaging unit can check to
determine whether information identical to the email address information is stored in the Contacts App (the
address book) of that Apple iPhone. If not, the Apple iPhone creates a prompt screen upon user selection
of the email address, which allows the user to select the email address and either create a new contact or
add it to an existing contact:

20

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126643 (arrows and labels
added).
See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Messages”), p. 65
(http://manuals.info.apple.com/en/iphone_user_guide.pdf) accessed on 11/06/2012, MOTO-SDFL0000016197.

21

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

22

EXHIBIT F

’161 Patent Claim

Accused Apple Products9
Screenshots of the iPhone 5(checking whether the address information in a text message is already stored;
the address information can be stored if previously not stored), taken 11/06/2012, MOTO-SDFL0000018693-94.

processing the address
information, by the
second portable
messaging unit, in a
predetermined manner
selected in response to
the checking step.

Upon information and belief, as the second portable messaging unit, all Accused Apple Products process
the address information in a predetermined manner selected in response to whether information identical to
the second address information is stored in the address book. For example,
(1) Where the second portable messaging unit is an Apple iPhone, iPad, or iPod Touch (second portable
messaging unit) that device checks to determine whether information identical to the email address
information is stored in the Contacts App (the address book) of the second portable messaging unit. If not,
the second portable messaging unit creates a prompt screen upon user selection of the email address, which
allows the user to either create a new contact or add it to an existing contact:
Where email address information is not in the Second iPhone's Contacts

23

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

24

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126645-46 (arrows and
labels added).
See also iPhone User Guide for iOS 4.2 and 4.3 Software at MOTO-APPLE-0006037953_126751:

25

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Reading mail”), p. 51
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016183:

26

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

Screenshot of the iPhone 5(the identical address information is already stored), taken 11/06/2012, MOTOSDFL-0000018691.
Where the second portable messaging unit is an Apple Computer, that device checks to determine whether
information identical to the email address information is stored in the Address Book Application (the
27

EXHIBIT F

’161 Patent Claim

Accused Apple Products9
address book) of the second portable messaging unit. If not, the Apple Computer creates a drop-down list
upon user selection of the email address, from which the user can create a new contact or add it to an
existing contact:

Apple Computer Screenshots, taken May 9, 2011, MOTO-APPLE-0006037953_126641.
See also, Apple Computer run on OS X Mountain Lion (the latest version of OS X)–“Mail (Mountain
Lion): Add Information to Contacts,” (http://support.apple.com/kb/PH11767), accessed on 11/06/2012,
MOTO-SDFL-0000018741 (boxes added):
28

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

(2) Also, when a text message containing address information (address information) is received by a
second Apple iPhone (second messaging unit), that device checks to determine whether information
identical to the text address information is stored in the address book of the second Apple iPhone. If not,
the second Apple iPhone creates a prompt button upon user selection of the text message, which allows the
user to select the email address and either create a new contact or add it to an existing contact:

29

EXHIBIT F

’161 Patent Claim

Accused Apple Products9
Where text address information is not in the Second iPhone's Contacts

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126643 (arrows and labels
added).

If identical information is stored in the address book, the contact’s name is displayed at the top of the
30

EXHIBIT F

’161 Patent Claim

Accused Apple Products9
screen and a “Contact Info” prompt is added:

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126644 (arrows and labels
added).
See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Messages”), p. 65
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016197 (emphasis added):

31

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

32

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

Screenshot of the iPhone 5(the identical address information is already stored), taken 11/06/2012, MOTOSDFL-0000018696.
33

EXHIBIT F

’161 Patent Claim

Accused Apple Products9
See also Additional Photo of Apple Computer Screen where address information is already in the Apple
Computer's address book and no option to "Add to Address Book" is available, taken May 9, 2011,
MOTO-APPLE-0006037953_126642:

See also, Apple Computer run on OS X Mountain Lion (the latest version of OS X)–“Mail (Mountain
Lion): Add Information to Contacts,” (http://support.apple.com/kb/PH11767), accessed on 11/06/2012,
MOTO-SDFL-0000018741(boxes added):
34

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

2. The method of claim
1, wherein the
processing step
comprises the step of
storing the address
information in the

Upon information and belief, the Accused Apple Products perform each and every step of this claim in the
course of their normal use. Additionally, a user of the Accused Apple Products 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 Apple Products and providing directions for their use. The Accused Apple Products perform the
method of Claim 1, wherein the processing step comprises the step of storing the address information in
35

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

address book, when no the address book, when no information identical to the address information is stored in the address book.
information identical to See Claim 1 contentions above. See, e.g.,
the address information
is stored in the address
book.

iPhone 4 Screenshot, taken January 3, 2011, MOTO-APPLE-0006037953_126645 (arrows and labels
added). Upon information and belief, Apple devices that now run on the newly released iOS 6.0 (the same
operating system that ships with the iPhone 5) operate in substantially the same way as described above.

36

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

Screenshots of the iPhone 5(checking whether the address information in an email is already stored; the
address information can be stored if previously not stored), taken 11/06/2012, MOTO-SDFL-0000018688;
18689.
37

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

Screenshots of the iPhone 5(checking whether the address information in a text message is already stored;
the address information can be stored if previously not stored), taken 11/06/2012, MOTO-SDFL38

EXHIBIT F

’161 Patent Claim

Accused Apple Products9
0000018693-94.
As discussed above, Apple Computers generate a drop-down list that prompts the user, if he so wishes, to
store the option of adding the address information , when no information identical to the address
information is stored in the Apple Computer's Address Book application. See Claim 1 contentions above.
See, e.g., Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126641:
See also, Apple Computer run on OS X Mountain Lion (the latest version of OS X)–“Mail (Mountain
Lion): Add Information to Contacts,” (http://support.apple.com/kb/PH11767), accessed on 11/06/2012,
MOTO-SDFL-0000018741 (boxes added):

39

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

3. The method of claim
1, wherein the
processing step
comprises the steps of:
generating a prompt
inquiring whether a
user of the second
portable messaging unit
wishes to store the
address information,

Upon information and belief, the Accused Apple Products perform each and every step of this claim in the
course of their normal use. Additionally, a user of the Accused Apple Products 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 Apple Products and providing directions for their use. The Accused Apple Products perform the
method of Claim 1,wherein the processing step generates a prompt screen inquiring whether the user
wishes to store the address information, when no information identical to the address information is stored
in the second portable messaging unit's Contacts App (address book). See Claim 1 contentions above.
See, e.g.,

40

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

when no information
identical to the address
information is stored in
the address book; and

iPhone 4 Screenshot, taken January 3, 2011, MOTO-APPLE-0006037953_126645 (arrows and labels
added). Upon information and belief, Apple devices that now run on the newly released iOS 6.0 (the same
operating system that ships with the iPhone 5) operate in substantially the same way as described above.

41

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

Screenshots of the iPhone 5, taken 11/06/2012, MOTO-SDFL-0000018688; 18693.
As discussed above, Apple Computers generate a drop-down list that prompts the user, if he so wishes, to
42

EXHIBIT F

’161 Patent Claim

Accused Apple Products9
store the option of adding the address information , when no information identical to the address
information is stored in the Apple Computer's Address Book application. See Claim 1 contentions above.
See, e.g., Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126641:

See also, Apple Computer run on OS X Mountain Lion (the latest version of OS X)–“Mail (Mountain
Lion): Add Information to Contacts,” (http://support.apple.com/kb/PH11767), accessed on 11/06/2012,
MOTO-SDFL-0000018741 (boxes added):

43

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

storing the address
information in the
address book, in
response to an
affirmative response to
the prompt by the
user.

Upon information and belief, as discussed above, Apple iPhones, Apple iPads and iPods store the address
information in the Contacts App (address book) in response to an affirmative response to the prompt by
the user. See Claim 1 contentions above. See, e.g.,

44

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

iPhone 4 Screenshot, taken January 3, 2011, MOTO-APPLE-0006037953_126646 (arrows and labels
added). Upon information and belief, Apple devices that now run on the newly released iOS 6.0 (the same
operating system that ships with the iPhone 5) operate in substantially the same way as described above.

45

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

Screenshots of the iPhone 5, taken 11/06/2012, MOTO-SDFL-0000018688; 18694.
As discussed above, Apple Computers store the address information in the Address Book Application
(address book) in response to an affirmative response to the prompt by the user. See Claim 1 contentions
46

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Accused Apple Products9
above. See, e.g., Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126641:

See also, Apple Computer run on OS X Mountain Lion (the latest version of OS X)–“Mail (Mountain
Lion): Add Information to Contacts,” (http://support.apple.com/kb/PH11767), accessed on 11/06/2012,
MOTO-SDFL-0000018741 (boxes added):

47

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Accused Apple Products9

5. The method of claim
1, wherein the address
information includes a
unique user identifier
identifying a user of the
first portable messaging
unit, and

Upon information and belief the Accused Apple Products perform each and every step of this claim in the
course of their normal use. Additionally, a user of the Accused Apple Products 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 Apple Products and providing directions for their use. The Accused Apple Products perform the
method of Claim 1, wherein the address information discussed above in claim 1 includes a unique user
identifier identifying a user of the first portable messaging unit.
For example, the address information received can include a cellular telephone number, a user name, or an
email address. See Claim 1 contentions above.
48

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wherein the checking
step comprises the step
of checking
whether the unique user
identifier is stored in
the address book.

Upon information and belief, where an Apple iPhone, Apple iPad, or iPod is the second portable
messaging unit, that device will check whether the unique user identifier is stored in the that device's
Contacts App (the address book). Where an Apple Computer is the second portable messaging unit, that
device will check whether the unique user identifier is stored in the that device's Address Book application
(the address book). See Claim 1 contentions above.

9. The method of claim
1, wherein the sending
step comprises the step
of sending to the
second portable
messaging unit a return
address for routing a
message to the first
portable messaging
unit.

Upon information and belief, the Accused Apple Products perform each and every step of this claim in the
course of their normal use. Additionally, a user of the Accused Apple Products 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 Apple Products and providing directions for their use. The Accused Apple Products perform the
method of Claim 1, wherein the sending step comprises the step of an Apple Accused Product (first
portable messaging unit) sending a return address for routing a message to the first portable messaging
unit to the second portable messaging unit.
For example, a first iPhone 4 (first portable messaging unit) can send to a second iPhone 4 (second
portable messaging unit) a telephone number or an email address associated with the first iPhone 4 (return
address). See Claim 1 contentions above.
Upon information and belief, Apple manufactures, sells, offers for sale, imports, and uses the Accused
Apple Products, which are portable messaging units in a wireless messaging system for facilitating the
exchange of address information.

12. A portable
messaging unit in a
wireless messaging
system for facilitating
an exchange of address For example:
information, the
portable messaging unit (1) In a wireless messaging system (e.g., MobileMe, iCloud, Exchange, Gmail, Yahoo, AOL, etc.), any
comprising
Accused Apple Product facilitates an exchange of email address information (address information):

49

EXHIBIT F

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Accused Apple Products9

See iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688.
See also id. at MOTO-APPLE-0006037953_126751:

See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Reading mail”), p. 51
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016183:

See also, (http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, MOTOAPPLE-0006037953_126647:

50

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Accused Apple Products9

See also, (http://www.apple.com/why-mac/better-hardware/), accessed on May 14, 2011, MOTO-APPLE0006037953_126649:

51

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(2) In a cellular telephone network (wireless messaging system), Apple iPhones facilitate the exchange of
text address information (address information):

52

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Accused Apple Products9

iPhone User Guide for iOS 4.2 and 4.3 Software, MOTO-APPLE-0006037953_126780.
See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Messages”), p. 65
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016197 (emphasis added).

53

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In addition, Apple has performed each and every step of this claim and through its design of the Accused
Apple Products, Apple also induced users of the Accused Apple Products to infringe the '161 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 '161 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
e.g., iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126688:

Id. at MOTO-APPLE-0006037953_126751:

See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Reading mail”), p. 51
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016183:

54

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(http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14, 2011, at MOTO-APPLE0006037953_126647:

Apple also knew that offering to sell or selling the Accused Apple Products would contribute to direct
infringement of the '161 Patent. As indicated above, at least as early as 2007, Apple knew that offering to
55

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Accused Apple Products9
sell or selling the Accused Apple Products would contribute to direct infringement of the '161 Patent.
Apple knew that the Accused Apple Products contain a specific software component for facilitating the
exchange of address information, a component with no substantial non-infringing use, which could be
combined with Apple's MobileMe / iCloud service, and that this combination, for which the component
was especially made, was both patented and infringing. Moreover, users of the Accused Apple Products
have, in fact, combined these components into an infringing method. 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., MOTOAPPLE-0006037953_126688, MOTO-APPLE-0006037953_126751, and MOTO-APPLE0006037953_126647, above.

a transmitter for
sending address
information to another
portable messaging unit
through the wireless
messaging system

Upon information and belief, all Accused Apple Products have a transmitter for sending address
information to another portable messaging unit (e.g., another Accused Apple Product) through the wireless
messaging system. For example:
1) Apple iPhones and Apple iPads with 3G contain cellular hardware and software (transmitter) for
sending text message and/or email address information to another portable messaging unit, e.g., an Apple
iPhone through a cellular telephone network (wireless messaging system):

56

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

iPhone 4 Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed on May 12, 2011,
MOTO-APPLE-0006037953_126659.
See also, iPhone 5 Technical Specifications, (http://www.apple.com/iphone/specs.html), accessed on
11/06/2012, MOTO-SDFL-0000016104:

See also iPhone User Guide for iOS 4.2 and 4.3 Software, MOTO-APPLE-0006037953_126780.

57

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See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Messages”), p. 65
(http://manuals.info.apple.com/en/iphone_user_guide.pdf—accessed on 10/28/2012), accessed on
11/06/2012, MOTO-SDFL-0000016197 (emphasis added).

2) All Accused Apple Products contain wireless hardware (transmitter) allowing it to send, e.g., email
address information to another portable messaging unit (e.g., another Accused Apple Product) though a
wireless messaging system (MobileMe, iCloud, Exchange, Gmail, Yahoo, AOL, etc.):
58

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Accused Apple Products9

MobileMe Features, (http://www.apple.com/mobileme/features/), accessed on May 13, 2011, MOTOAPPLE-0006037953_127187.
See iPad Features, (http://www.apple.com/ipad/features/), accessed on May 14, 2011, MOTO-APPLE0006037953_127244-45:

59

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Accused Apple Products9

See also iPad Built-in-Apps, (http://www.apple.com/ipad/built-in-apps/mail.html), accessed on May 14,
2011, MOTO-APPLE-0006037953_126647:

60

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Accused Apple Products9

See also iPhone Features, (http://www.apple.com/iphone/features/mail.html), accessed on May 14, 2011,
MOTO-APPLE-0006037953_126648:

61

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Accused Apple Products9

See also, (http://www.apple.com/why-mac/better-hardware/), accessed on May 14, 2011, MOTO-APPLE0006037953_126649:

62

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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 11/06/2012, MOTO-SDFL0000016160.

63

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a receiver coupled to
the processing system
for receiving second
address information
from another portable
messaging unit

Upon information and belief, the Accused Apple Products each have a receiver coupled to the processing
system for receiving second address information from another portable messaging unit.
For example, the Apple iPhone contains a logic board with receiver circuitry (receiver coupled to the
processing system) that allows the Apple iPhone to receive, e.g., email and text message address
information from another Apple iPhone (another portable messaging unit).
See, e.g., iPhone 3G Teardown, (http://www.ifixit.com/Teardown/iPhone-4-Teardown/3130/2), accessed
on May 13, 2011, MOTO-APPLE-0006037953_127192-95 (arrows and labels added):

64

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Accused Apple Products9

65

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

66

EXHIBIT F

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Accused Apple Products9

67

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Accused Apple Products9
See also, iPhone 5 Teardown, (http://www.ifixit.com/Teardown/iPhone+5+Teardown/10525/2), accessed
on 11/06/2012, MOTO-SDFL-0000018703:

68

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Accused Apple Products9

For example, the Apple iPad contains a logic board with receiver circuitry (receiver coupled to the
processing system) that allows the Apple iPad to receive, e.g., email address information from another
Accused Apple Product (another portable messaging unit).
See also, e.g., iPad 3G Teardown, (http://www.ifixit.com/Teardown/iPad-3G-Teardown/2374/2), accessed
on May 14, 2011, MOTO-APPLE-0006037953_127230-31:

69

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Accused Apple Products9

70

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For example, the Apple Computer contains a logic board with receiver circuitry (receiver coupled to the
processing system) that allows the Apple Computer to receive, e.g., email address information from
another Accused Apple Product (another portable messaging unit).
See, e.g., MacBook Pro 15" Core 2 Duo Model A1211 Teardown,
(http://www.ifixit.com/Teardown/MacBook-Pro-15-Inch-Core-2-Duo-Model-A1211-Teardown/593/1),
accessed on May 14, 2011, MOTO-APPLE-0006037953_127250:

71

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where the processing
system is programmed
to: check in response
to receiving the second
address information,
whether information
identical to the second
address information is
stored in an address
book of the portable
messaging unit; and

Upon information and belief, the processing system in any Accused Apple Devices is programmed to
check in response to receiving the second address information whether information identical to the second
address information is stored in its address book. For example:
(1) where the portable messaging unit is an Apple iPhone, iPad, or iPod Touch that has received the second
address information, it will check whether information identical to the address information contained in the
email is stored in the Contacts App (address book) of the second Apple iPhone. If not, a prompt screen is
displayed upon user selection of the email address, and the user can then either create a new contact or add
it to an existing contact:

72

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Accused Apple Products9

73

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Accused Apple Products9

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126645-46 (arrows and
labels added).
See also iPhone User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126751.
74

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Accused Apple Products9

See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Reading mail”), p. 51
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016183:

75

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

Screenshots of the iPhone 5(checking whether the address information in an email is already stored; the
address information can be stored if previously not stored), taken 11/06/2012, MOTO-SDFL-0000018688;
18689.
76

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Accused Apple Products9
.
Where the second portable messaging unit is an Apple Computer that has received the second address
information, it will check whether information identical to the address information contained in the email
is stored in the Address Book Application (address book) of the second portable messaging unit. If not, the
Apple Computers generates a drop-down list that prompts the user, if he so wishes, to store the option of
adding the address information.

77

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Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126641.
See also, Apple Computer run on OS X Mountain Lion (the latest version of OS X)–“Mail (Mountain
Lion): Add Information to Contacts,” (http://support.apple.com/kb/PH11767), accessed on 11/06/2012,
MOTO-SDFL-0000018741 (boxes added):

(2) Where a text message containing address information (address information) is received, a second Apple
iPhone (second messaging unit) checks to determine whether information identical to the address
78

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Accused Apple Products9
information contained in the text message is stored in the address book of the second Apple iPhone. If not,
the second Apple iPhone creates a prompt button upon user selection of the text message, which allows the
user to select the email address and either create a new contact or add it to an existing contact:

See iPhone 4 Screen, taken January 3, 2011, MOTO-APPLE-0006037953_126643 (arrows and labels
added).
See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Messages”), p. 65
79

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’161 Patent Claim

Accused Apple Products9
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016197.

Screenshots of the iPhone 5(checking whether the address information in a text message is already stored;
80

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Accused Apple Products9
the address information can be stored if previously not stored), taken 11/06/2012, MOTO-SDFL0000018693-94..

process the second
address information in
a predetermined
manner selected in
response to whether
information identical to
the second address
information is stored in
the address book.

Upon information and belief, the Accused Apple Products process the address information in a
predetermined manner selected in response to whether information identical to the second address
information is stored in the address book. For example,
(1) Where an email message containing address information (address information) is received, a second
Apple iPhone (second messaging unit) checks to determine whether information identical to the address
information contained in the email is stored in the address book of the second Apple iPhone. If not, the
second Apple iPhone creates a prompt screen upon user selection of the email address, which allows the
user to select the email address and either create a new contact or add it to an existing contact:

81

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Accused Apple Products9

82

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Accused Apple Products9

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126645-46 (arrows and
labels added).
See also User Guide for iOS 4.2 and 4.3 Software, at MOTO-APPLE-0006037953_126751:
83

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’161 Patent Claim

Accused Apple Products9

See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Reading mail”), p. 51
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016183:

84

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Accused Apple Products9

Screenshot of the iPhone 5(the identical address information is already stored), taken 11/06/2012, MOTOSDFL-0000018691.
Where an email message containing address information (address information) is received, a second Apple
85

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Accused Apple Products9
Computer (second messaging unit) checks to determine whether information identical to the address
information contained in the email is stored in the address book of the second Apple Computer. If not, the
Apple Computers generates a drop-down list that prompts the user, if he so wishes, to store the option of
adding the address information.

See Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126641.
See also, Apple Computer run on OS X Mountain Lion (the latest version of OS X)–“Mail (Mountain
86

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Accused Apple Products9
Lion): Add Information to Contacts,” (http://support.apple.com/kb/PH11767), accessed on 11/06/2012,
MOTO-SDFL-0000018741 (boxes added):

(2) Where a text message containing address information (address information) is received, a second Apple
iPhone (second messaging unit) checks to determine whether information identical to the address
information contained in the text message is stored in the address book of the second Apple iPhone. If not,
the second Apple iPhone creates a prompt button upon user selection of the text message, which allows the
user to select the email address and either create a new contact or add it to an existing contact:

87

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See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126643 (arrows and labels
added).

If identical information is stored in the address book, the contact’s name is displayed at the top of the
screen and a “Contact Info” prompt is added:
88

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Accused Apple Products9

See iPhone 4 Screenshots, taken January 3, 2011, MOTO-APPLE-0006037953_126644 (arrows and labels
added).
See also, Apple devices with iOS 6 – iPhone User Guide For iOS 6 Software (“Messages”), p. 65
(http://manuals.info.apple.com/en/iphone_user_guide.pdf), accessed on 11/06/2012, MOTO-SDFL0000016197 (emphasis added):

89

EXHIBIT F

’161 Patent Claim

Accused Apple Products9

90

EXHIBIT F

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Accused Apple Products9

Screenshot of the iPhone 5(the identical address information is already stored), taken 11/06/2012, MOTOSDFL-0000018696.
91

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’161 Patent Claim

Accused Apple Products9
.
See also Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126642:

See also, Apple Computer run on OS X Mountain Lion (the latest version of OS X)–“Mail (Mountain
Lion): Add Information to Contacts,” (http://support.apple.com/kb/PH11767), accessed on 11/06/2012,
MOTO-SDFL-0000018741(boxes added):

92

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Accused Apple Products9

13. The method of
claim 12, wherein the
processing system is
further programmed to
store the second
address information in
the address book, when
no information
identical to the second

Upon information and belief, Apple manufactures, sells, offers for sale, imports, and uses the Accused
Apple Products, which are portable messaging units according to claim 12, wherein the processing system
of the Accused Apple Products are programmed to store the second address information in the address
book, when no information identical to the second address information is stored in the address book. See,
e.g.,

93

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Accused Apple Products9

address information is
stored in the address
book.

iPhone 4 Screenshot, taken January 3, 2011, MOTO-APPLE-0006037953_126645 (arrows and labels
added). Upon information and belief, Apple devices that now run on the newly released iOS 6.0 (the same
operating system that ships with the iPhone 5) operate in substantially the same way as described above.

94

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Accused Apple Products9

Screenshots of the iPhone 5(checking whether the address information in an email is already stored; the
address information can be stored if previously not stored), taken 11/06/2012, MOTO-SDFL-0000018688;
18689.
95

EXHIBIT F

’161 Patent Claim

Accused Apple Products9
.

Screenshots of the iPhone 5(checking whether the address information in a text message is already stored;
the address information can be stored if previously not stored), taken 11/06/2012, MOTO-SDFL96

EXHIBIT F

’161 Patent Claim

Accused Apple Products9
0000018693-94.
As discussed above, Apple Computers generate a drop-down list that prompts the user, if he so wishes, to
store the option of adding the address information , when no information identical to the address
information is stored in the Apple Computer's Address Book application. See Claim 12 contentions above.
See, e.g., Apple Computer Screenshot, taken May 9, 2011, MOTO-APPLE-0006037953_126641:
See also, Apple Computer run on OS X Mountain Lion (the latest version of OS X)–“Mail (Mountain
Lion): Add Information to Contacts,” (http://support.apple.com/kb/PH11767), accessed on 11/06/2012,
MOTO-SDFL-0000018741 (boxes added):

97

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Accused Apple Products9

14. The portable
messaging unit of claim
12, wherein the
processing system is
further programmed to
generate a prompt
inquiring whether a
user of the portable
messaging unit wishes

Upon information and belief, Apple manufactures, sells, offers for sale, imports, and uses the Accused
Apple Products, which are portable messaging units according to claim 12, wherein the processing system
of the Accused Apple Products are programmed to generate a prompt inquiring whether a user wishes to
store address information, when no information identical to the second address information is stored in the
address book. See Claim 12 contentions above.

98

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to store the address
information, when no
information identical to
the second address
information is stored in
the address book; and
store the second
Upon information and belief, the Accused Apple Products store the second address information in the
address information in address book, in response to an affirmative response to the prompt by the user. See Claim 12 contentions
the address book, in
above.
response to an
affirmative response to
the prompt by the user.

99