Motorola Mobility, Inc. v. Apple, Inc.

Filing 94

NOTICE by Motorola Mobility, Inc. of Filing Brief on Claim Construction (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit, # 23 Exhibit, # 24 Exhibit, # 25 Exhibit, # 26 Exhibit, # 27 Exhibit, # 28 Exhibit, # 29 Exhibit, # 30 Exhibit, # 31 Affidavit)(Giuliano, Douglas)

Exhibit 27
to Motorola’s Opening Claim Construction Brief
July 28, 2011

Patent
Attorney's Docket No. P2232-460

44i#

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
i
1

In re Patent Application of

)
)
) Group Art Unit: 2787
)
) Examiner: R.-Hartman...Ir.
) ..-%
)

Ian HENDRY et al.
Application No.: 091074,300
.Filed; MaY 8, 1998
For;

SYSTEM FOR REAL-TIME
ADAPTATION TO CHANGES IN
DISPLAY CONFIGURATION

)
)
)
)
)

a
a
1-

AMENDMENT
Assistant Commissioner for Patents
Washington, D.C. 20231
Sir:
In response to the Office Action dated October 28, 1999, kindly amend the aboveidentified application as follows:

TN TUE CLAIMS:

1.

(Amended) A method for reconfiguring a computer system to accommodate

changes in a display environment, comprising the steps of:
detecting the addition or removal of an input/output device in the computer
83

system;
determining whether an input/output device which has been added or

rt.

removed is a video device, in response to said detection;
providing a notification to a display manager when_a_determinionisinade

that a video device has been added or removed; and

ExHIBIL2,0
PAGE21-

I

v.•.i3

11

Application No. 091074,300
Attorney's Docket No. P2232 - 460

modifying the allocation of display space to display devices via said display

manager, in accordance with the addition or removal of a video device.

10.

(Amended) A system which provides hot-plugging capabilities for display

devices, comprising:

r/

a video device including a frame buffer for storing data that defines an image
to be displayed on an associated display device;
a display manager which defines a display space and assigns a portion of said
display space to said frame buffer, and which provides data for images to be displayed to
said frame buffer; and
a device manager which detects the addition or removal of [the video] a
device [to]

in a computer system, determines villether a device which has been added or

removed is a video device, and provides . a notification of such addition or removal to the
display manager when a video device is determined to have_beu added or removed, to
cause the assignment of a portion of the display space to be modified in accordance with a
detected addition or removal.

13.

t4)

(Amended) A system which provides hot-plugging capabilities for display

devices, comprising:
at least one display for displaying images;

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EXHIBIT 27
PAGE 2

Application No. 091074.30Q
Attorney's Docket No. P2232-46Q

a display manager which defines a display space and assigns a portion of said
display space to a display device, and which provides data for images to be displayed on
said display device; and
a device manager which detects the addition or removal of a [display] device
in a computer system, determines whether a device which has been added or removed is A
display device., and provides a notification of such addition or removal to the display
manager when a display device is determined to have been added or removed, to cause the
assignment of a portion of the display space to be modified in accordance with a detected
addition or removal.

Please add the following claims 22-37:
--22. The method of claim 3, wherein said preference file stores the video devices
which make up the configuration of the computer, and the locations of objects displayed on
said video devices.

23.

The method of claim 22, wherein said preferences file also stores operating

parameters for said devices.

1.

A method for reconfigurin a computer system to ac

changes, in a

display environment, comprising the
storing
to a

titles the status of displayed objects prior

rences

in the configuration of a computer;

-3,

EXHIBIT 27
PAGE 3

Application No. 09/074.300
Attorney's Docket No. P2232-460

detecdng the addition of a video device in the computer system;
providing a notificaticin to a display manager that

eo device has been

added;
Modifying the allocation
manager, in accordance w;
re
iii sai

'splay s e to display devices via said display

e addition of a video device; and

oning objectS in said display space, in accordance with a status stored

ferences file.

25.

The method of claim 24, wher n aid preference f e.-steres-th -e video

devices which make up the configuration . 1
displayed on said vid

26.

com uter, and the locations of objects

ces.

The method of claim 25, w

re

also stores opetating

parameters for said device

27.

A method for reconfiguring a comput r system to accommodate changes in a

display environment, comprising the steps of:
detecting the addition or removal of video device in the computer system;
providing a notification to a displa manager that a video device has been
added or removed;
mOdifying the allocation of disp y space to display devices via said display
manager, in accordance with the addition or r moval of a video device; and

EXHIBIT 27

Application No. 09/074 300
Attorney's Docket No. P2232-46Q
,

located in the drie po ny sp ace . a computer resource to c rrespond to the status of objects
sc la fig u r ing

28.

The method of claim .27 whe

computer resource is a color look-up

table.

A system which provides hot-plugging capabilities for display devices,

i

ktk

comprising:
a video device including a frame buffer for storing data that defines an image
to be displayed on an associated display device;
a display manager which defines a display space and assigns a portion of said
display space to said frame buffer, and which provides data for images to be displayed to
said frame buffer;
a device manager which detects the addition or removal of the video device
to a computer system, and provides a notification of such addition or removal to the display
manager to cause the assignment of a portion of the display space to be modified in
accordance with a detected addition or removal; and
means responsive to the removal of a video device for storing a preference
file in memory which indicates the status of objects being displayed.

The system of claim 2 wherein said display manager is responsive to the
,
addition or removal of a video device to restore displayed objects to a status stored in said

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EXHIBIT 27
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Application No. 09/074.300
Attorney's Docket No. P2232-460

preference file which corresponds to the configuration of the computer system after the
video device is added or removed.

The system of claim , wherein said preference file stores the video devices
which make up the configuration of the computer, and the locations of objects displayed on
said video devices.

A

The system of claimXj, wherein said preferences file also stores operating

parameters for said devices.

A computer-readable medium containing a device manager program and a
display manager program, wherein said device manager program performs the steps of:
detecting the addition or removal of a video device in a computer system,
and
providing a notification to the display manager program when a video device
is added or removed;
and wherein said display manager performs the steps of:
modifying the allocation of display space to display devices in response to
said notification from the device manager, and
storing a preference file relating to the status of objects appearing on a
display device, and restoring objects to the status stored in the preferences file when a
video device is added.

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EXHIBIT 27
. . -PAGE 6.

Application No. 09/074 300
Attorney's Docket No. P2232 46Q
-

The computer-readable medium of clairn , wherein said preference file
stores the video devices which make up the configuration of the computer, and the locations
of objects displayed on said video devices.

The computer-readable medium of claim

wherein said preferences file

also stores operating parameters for said devices.

A computer-readable medium containing a device manager program and a
display manager program, wherein said device manager program performs the steps of:
detecting the addition or removal of a video device in a computer system,
and
providing a notification to the display manager program when a video device
is added or removed;
and wherein said display manager performs the step of:
modifying the allocation of display space to display devices in response to
said notification from the device manager, and
reconfiguring at least one computer resource in accordance with the
modification of the display space allocation.

The computer-readable medium of claim 36whercin said computer resource
,

is a color look-up table.

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EXHIBIT 27
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Application No. 096011290
Attorney's Docket No. Pa232-460

REMARK5
In response to the Office Action dated October 28, 1999, Applicants respectfully
•i
request reconsideration and withdrawal of the rejections of the claims.
Claim I was rejected under 35 U.S.C. § 102 as being unpatentable over the Hendry
et al. patent (U.S. Patent No. 5,682,529). and claims 2-21 were rejected as being
unpatentable over the Hendry et at. patent in view of the Kimura patent (U.S. Patent No.
5,469,223). It is respectfully submitted, however, that the Hendry patent neither
anticipates, nor otherwise suggests, the subject matter of the present invention, whether
considered by itself or in combination with the Kimura patent.
As discussed in the Background portion of the present application. the Hendry et al.
patent discloses a system for dynamically accommodating changes in the display
configuration of a computer, without the need to restart the computer. For example, if the
computer is in a sleep mode, and changes are made to the display configuration of the
computer, these changes are immediately recognized upon the resumption of normal
operation, when the computer is awakened from its sleep mode, without the need to restart
the computer. The present invention builds upon this system, by adding hot-plugging
capabilities. For example, the user might add a video card which is embodied within a PC
Card, while the computer is running. In accordance with the invention, a device manager
detects the insertion of the PC Card, and determines whether the PC Card is a video device.
If it is, notification is provided to a display manager, which then reconfigures the display
configuration to accommodate the newly added video card. In a similar manner, when a
device is removed from the computer system, the device manager determines whether the

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EXHIBIT 27
PAGE 8

--r

Application No. 091074 300
Attorney's Docket No. P2232-460

removed device performs a video operation, and if so notifies the display manager so that
the display configuration can be appropriately updated,
In accordance with one aspect thereof, the present invention adds to the system of
the Hendry et aL patent by utilizing a device manager to proAde hot-plugging capabilities.
More particularly, the device manager detects the addition or removal of any type of
input/output device in the computer system. Upon detecting 'the addition or removal of a
device, the device manager then determines whether that input/output device is a video
device. As illustrated in Figure 5, if the device which as been added or removed is not a
video device, the device manager continues on with its normal operations associated with
the addition or removal of a device. If, however, the added or removed device is a video
device, the device manager informs the display manager of the addition or removal. In
response to this notification, the display manager then modifies the allocation of display
space accordingly.
It is respectfully submitted that the distinctions between the present invention and
the Hendry et aL patent are brought out in each of the rejected claims. For example, claim
I recites the steps of detecting the addition or removal of an input/output device, and
"determining whether an input/output device which has been added or removed is a video
device, in response to said detection." It is respectfully submitted that the Hendry et al.
patent does not disclose this step of determining whether an input/output device that is
added or removed in a computer system is a video device. Further, it is noted that the
rejection of claim I does not address this particular element of the claim. For at least this

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EXHIBIT 27
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Application No. 09/074.310
Attorney's Docket No. P2232-460

reason, therefore, it is respectfully submitted that the subject matter of claim 1 is not
anticipated by the Hendry et al. patent.
Claim 10 recites a system which provides hot-plugging capabilities for display
devices, comprising a video device, a display manager, and a device manager. The device
manager detects the additiOn or removal of a device in a computer system, and provides a
notification of such addition or removal to the display manager, Claim 13 also recites a
system which provides hot-plugging capabilities, that includes a display, a display manager
and a device manager. In a similar fashion, claim 16 recites a computer-readable medium
containing a device manager program and a display manager program.
It is respectfully submitted that the Hendry et al, patent does.not disclose a device
manager as recited in each of these claims. Furthermore, it is noted that the rejection of
each of these claims does not address this claimed subject matter. If the rejection of any of
the claims is repeated, the Examiner is respectfully requested to explain the manner in
which the Hendry et al. patent is being interpreted relative to the claimed device manager.
In addition to the foregoing distinctions, other features of the invention are likewise
not disclosed in the prior art. For instance, claims 3, 12, 15 and 17 recite the concept of
storing a preference file that identifies the status of displayed objects prior to a change in
the configuration of a computer. This feature is also recited in newly added claims. 24-26
and 29-34. With respect to this claimed subject matter, the Office Action states that the
Hendry et al. patent does not specifically disclose storing a preference file, but goes on to
conclude that it is suggested within the disclosure of the patent, by the presence of a frame
buffer. However, as acknowledged in the Office Action, a frame buffer stores the come=

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EXHIBIT 27
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Application No. 09/074 300
Attorney's Docket No. P2232-460

of a screen image, i.e. the data which is displayed, per se. In contrast, a preference file
stores information about the status of displayed objects. For instance, in a configuration
which ccintains multiple display monitors, the preference file indicates where the system'S
main menu is to be displayed upon the multiple monitors. Whenever the computer system
is restored to that configuration, the main menu is moved to the appropriate monitor, as
indicated by the preference file. As described on page 12 of the application, the preference
file can store additional information about the configuration, such as operating parameters
for the monitor, and the like. A frame buffer merely stores the contents of the image
displayed on one of the monitors. It is respectfully submitted that the frame buffer does not
suggest a preference file of the type provided by the present invention, which stores
information relating to the configuration of the display system.
Another feature of the present invention is the reconfiguration of computer
resources, such as a color lookup table, to correspond to the status of objects located in the
display space. This feature is recited in claims 7, 8, 20 and 2.1, as well as newly added
claims 27, 28, 35 and 36. In connection with this subject matter, the Office Action notes
that the Hendry et al. patent discloses the use of a lookup table, and concludes that it would
be obvious to employ a color lookup table therein. It is respectfully submitted, however,
that the lookup table described in the Hendry et al. patent is quite distinct from the subject
mater of the claims identified above. The noted portion of the Hendry et al. patent (column
4, lines 10-14) pertains to the situation in which some monitors are able to directly
communicate information about their operating states to display drivers, whereas other
(typically older) monitors do not have such functionality. For this latter case, the Hendry

EXHIBIT 27
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Application No. 09/074.300
Attorney's Docket No. P2232-460

et aI. patent discloses that the display driver can obtain information about a particular
monitor's capabilities by means of a lookup table that is stored within the computer system.
In other words, this lookup table stores inforination about the operating parameters of a
plurality of different types of monitors. The display drivers can refer to this stored
information to determine the operating parameters for a given monitor that is connected to
the system.
It is respectfully submitted that this disclosure does not anticipate, nor otherwise
suggest, the subject matter of claims 7, 8 and the like. Claim 7 recites that the display
manager carries out the step of

reconfiguring

a computer resource to correspond to the

status of objects located in the display space. In the particular example given at the top of
page 13 of the application, one such resource is a color lookup table. ln accordance with
the invention, if a second monitor is added to the display system, and certain windows or
other objects are moved to that monitor's display space, then the color lookup table for that
monitor is reconfigured in accordance with the application programs that own the moved
objects. It is respectfully submitted that the disclosure of the Hendry et al. patent relating
to the use of a lookup table for display monitor capabilities, is not the same as, nor
otherwise suggestive of, this claimed subject matter.

EXHIBIT 27
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Application No. 09/074 300
Attorney's Docket No. P2232-460

For the foregoing reasons, it is respectfully submitted that all pending claims are
patentable over the prior art of record. Reconsideration and withdrawal of the rejections
are therefore respectfully submitted.
Respectfully submitted,
BURNS, DOANE, SAVECKER & MATHIS, L.L.P.

By:
James A. LaBarre
Registration No. 28,632
P.O. Box 1404
Alexandria, Virginia 22313-1404
[phone]
Date: March 28, 2000

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