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 30
to Motorola’s Opening Claim Construction Brief
July 28, 2011

Disputed Claim Phrase
moving an unlock image

gesture

Determi[ning][es]
whether [a] device . . . is
a video device
Detect[ing][s] . . . a
display device

"modifying the
allocation of display
space"

“a portion of the display
space to be modified”

listing means / listing
interface means

Motorola's Proposed
Construction
“Translating the unlock image from
one portion of the coordinate space
of the touch-sensitive display to
another”

Apple Proposed
Construction
Ordinary meaning, or in the
alternative, “causing an
unlock image to change
position over time via
continuous contact with the
touch screen”
“A motion of the object /
Plain and ordinary meaning
appendage making contact with the applies, or in the alternative,
touch screen display”
“a motion of the object /
appendage making contact
with the touch-screen”
“Having the device manager, which Apple believes that these
is an operating system component
phrases should be construed
and not a device driver, specifically separately as follows:
determine that the device is a video Determin[ing][es]…
display device”
Plain and ordinary meaning
applies or, in the alternative:
“determine whether a device
is or is not capable of
displaying video”

“Changing the allotment of the
global coordinate space available
for use by display devices”

“An allotment of the global
coordinate space, available for use
by display devices, to be changed

Corresponding Function: Causing
the A/V display to selectively
display one level of the multiple
levels of information related to an
audio-visual program, that level
containing a list of information
(including at least

EXHIBIT 30
PAGE 1

Detect[ing][s]…
Plain and ordinary meaning
applies or, in the alternative:
“detecting a device capable of
displaying”
Plain and ordinary meaning
applies or, in the alternative:
“allocating or deallocating
display space”

Plain and ordinary meaning
applies or, in the alternative:
“a part of the display space to
be allocated or deallocated”
Apple believes that these
phrases should be construed
separately as follows:
’509
Under § 112 ¶ 6, the function
is “causing an A/V display to
selectively display a program

listing that contains listing
information related to A/V
programs viewable on the A/V
display.”
Corresponding Structure: A central The corresponding structure
is: a combination of the CPU
processing unit (CPU), a system
module 62, which receives the
bus; an A/V decoder; a wireless
control unit; a system memory unit; data stream of program
listings, the system memory
an A/V memory unit; a memory
and bus controller; an A/V encoder; 65, which stores the section of
the program listings most
a highspeed digital A/V bus; an
relevant to the user, A/V
A/V processor; one or more
processor 77, which is “used
tuners/demodulators, wherein one
to manipulate, process, render,
tuner/demodulator reads and
mix, and otherwise rearrange
displays a current program from
digital data into coherent
one of the channels received;
additional tuners/demodulators (or audio-visual displays,” and
A/V connect module 66,
the same tuner/demodulator, used
which “provides a graphic
in alternation) to read and display
data from the side-band channels in overlay function that
picture-in-picture (pip) windows; a superimposes an A/V signal
from the video encoder 78
remote control device including a
transmitter for transmitting signals against another A/V signal”
that allows “both signals to be
to the audio-visual system; and
software applications that generate simultaneously displayed on
the TV.”
picture-in-picture windows,
program listing information,
’456
program recording, and other
interactive functions.
Under § 112 ¶ 6, the function
is “causing an A/V display to
selectively display a program
listing.”
The corresponding structure
is: a combination of the CPU
module 62, which receives the
data stream of program
listings, the system memory
65, which stores the section of
the program listings most
relevant to the user, A/V
processor 77, which is “used
to manipulate, process, render,
mix, and otherwise rearrange
digital data into coherent
audio-visual displays,” and
A/V connect module 66,
channel numbers, channel names,
and titles) about the viewable
audio-visual programs

EXHIBIT 30
PAGE 2

Listing Interface

Controller in
communication with

Control means in
communication with

A software application executing
on the CPU causing the A/V
display to selectively display one
level of the multiple levels of
information related to an audiovisual program, that level
containing a list of information
(including at least channel
numbers, channel names, and/or
titles) about the viewable audiovisual programs
A hand-held remote control
containing a transmitter for
transmitting signals wirelessly to
the transceiver.

This element is subject to
U.S.C. § 112 ¶ 6.
Corresponding Structure: A handheld remote control containing a
transmitter.
See, e.g., Abstract; col. 8:42-46.
Corresponding Function:
transmitting signals wirelessly to
the transceiver

which “provides a graphic
overlay function that
superimposes an A/V signal
from the video encoder 78
against another A/V signal”
that allows “both signals to be
simultaneously displayed on
the TV.”
Plain and ordinary meaning
applies or, in the alternative:
“an interactive interface for
listing A/V program
information”

Apple believes that these
phrases should be construed
separately as follows:
’560
Plain and ordinary meaning
applies or, in the alternative:
“controller that sends
commands to”

’509
Under § 112 ¶ 6, the function
is “sending commands to the
transceiver to allow a user to
selectively display multiple
levels of information on an
A/V display.”
The corresponding structure
is: remote control 60 or
equivalent structure.
’456
Under § 112 ¶ 6, the function
is “sending commands to the
transceiver to allow a user to
display A/V programs on an

EXHIBIT 30
PAGE 3

“Data Units Not Being
Sent From The Host To
The Communications
Unit”

Ordinary meaning – the phrase
requires no construction.

“filtered data unit”

Plain meaning; or “a data unit that
has been filtered”

“wireless network”

Ordinary meaning – this term
requires no construction, but in the
alternative; “two or more devices
whose interconnection(s) is
implemented, at least in part,
without the use of wires”
Ordinary meaning – this phrase
requires no construction.

“responsive to receiving
the second message,
transmitting a third
message”
“indicative of the second
status”

“the antenna . . . is
disposed between an
outside surface of the
housing and the at least
a portion of the user
interface”
“address identifying the
portable communication
device”

Ordinary meaning – this phrase
requires no construction, but in the
alternative, "providing an indication
of the second status"
Ordinary meaning – this phrase
requires no construction, but in the
alternative, "the antenna . . . is
arranged between an exposed
surface of the housing and at least a
portion on the user interface"
“Ordinary meaning – this term
requires no construction, but in the
alternative, some reference
uniquely identifying the portable
communication device”

EXHIBIT 30
PAGE 4

A/V display.”
The corresponding structure
is: remote control 60 or
equivalent structure.
“data units present at the host
and not sent to the
communication unit”

“one of a subset of data units
at the host device that are
selected for download to the
client communication unit
based on having passed a
filter”
“a network in which the
communication server is
connected to both the host
device and the client
communication unit through a
completely wireless path”
"upon receiving the second
message, automatically
transmitting a third message”
“descriptive of the changed
status”

“the entire antenna is placed
between the outside surface
of the receiver’s case and the
portion of the user interface
surrounded by the antenna”
"a number used to direct
messages that uniquely
identifies a portable
communication device”