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)

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA

MOTOROLA MOBILITY, INC.,
Plaintiff / Counterclaim Defendant,
v.
APPLE INC.,
Defendant / Counterclaim Plaintiff.

) CASE NO. 1:10cv023580-Civ-UU
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DECLARATION OF MATTHEW 0. KORHONEN
I, Matthew 0. Korhonen, declare as follows:
1.

I am a member of the bar of the State of California and an associate at Quinn

Emanuel Urquhart & Sullivan, LLP, attorneys for Motorola Mobility, Inc. ("Motorola"). I make
this declaration of personal, firsthand knowledge and, if called and sworn as a witness, I could
and would testify competently thereto.
2.

Attached hereto as Exhibit 1 is a true and correct copy of U.S. Patent No.

_7,657,849.
3.

Attached hereto as Exhibit 2 is a true and correct copy of an excerpt of the 1994

IBM Dictionary of Computing.
4.

Attached hereto as Exhibit 3 is a true and correct copy of an excerpt of the 1992

Academic Press Dictionary of Science and Technology.
5.

Attached hereto as Exhibit 4 is a true and correct copy of Exhibit F of Apple,

Inc.'s Infringement Contention in this Action.
6.

Attached hereto as Exhibit 5 is a true and correct copy of an excerpt of the 2005

American Heritage desk dictionary and thesaurus.

7.

Attached hereto as Exhibit 6 is a true and correct copy of U.S. Patent No.

6,282,646.
8.

Attached hereto as Exhibit 7 is a true and correct copy of U.S. Patent No.

7,380,116.
9.

Attached hereto as Exhibit 8 is a true and correct copy of the September 14, 1999

Office Action Summary for Application No. 09/074,300.
10.

Attached hereto as Exhibit 9 is a true and correct copy of an excerpt of Patent

Application No. 09/074,300.
11.

Attached hereto as Exhibit 10 is a true and correct copy of U.S. Patent No.

5,583,560.
12.

Attached hereto as Exhibit 11 is a true and correct copy of U.S. Patent No.

5,594,509.
13.

Attached hereto as Exhibit 12 is a true and correct copy of U.S. Patent No.

5,621,456.
14.

Attached hereto as Exhibit 13 is a true and correct copy of U.S. Patent No.

5,958,006.
15.

Attached hereto as Exhibit 14 is a true and correct copy of U.S. Patent No.

6,101,531.
16.

Attached hereto as Exhibit 15 is a true and correct copy of an excerpt of the 1994

Microsoft Press Computer Dictionary, Second Edition.
17.

Attached hereto as Exhibit 16 is a true and correct copy of an excerpt of the 1994

Microsoft Press Computer Dictionary, Second Edition.

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18.

Attached hereto as Exhibit 17 is a true and correct copy of U.S. Patent No.

5,754,119.
19.

Attached hereto as Exhibit 18 is a true and correct copy of an excerpt of the 1986

Oxford University Press Dictionary of Computing, Second Edition.
20.

Attached hereto as Exhibit 19 is a true and correct copy of an excerpt of the 1993

Webster's Third New International Dictionary of The English Language Unabridged.
21.

Attached hereto as Exhibit 20 is a true and correct copy of an excerpt of the 1995

Webster's II New College Dictionary.
22.

Attached hereto as Exhibit 21 is a true and correct copy of an excerpt of the 1991

Microsoft Press Computer Dictionary.
23.

Attached hereto as Exhibit 22 is a true and correct copy of U.S. Patent No.

5,710,987.
24.

Attached hereto as Exhibit 23 is a true and correct copy of U.S. Patent No.

6,008,737.
25.

Attached hereto as Exhibit 24 is a true and correct copy of an excerpt of the 1985

Dictionary of Data Communications, Second Edition.
26.

Attached hereto as Exhibit 25 is a true and correct copy of an excerpt of the 1993

New IEEE Standard Dictionary of Electrical and Electronics Terms [Including Abstracts of All
Current IEEE Standards], Fifth Edition.
27.

Attached hereto as Exhibit 26 is a true and correct copy of an excerpt of the 1995

Dictionary of Communications Technology, Second Edition.
28.

Attached hereto as Exhibit 27 is a true and correct copy of the March 28, 2000

amendment from the prosecution history of Application No. 09/074,300.

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29.

Attached hereto as Exhibit 28 is a true and correct copy of an excerpt of the 1994

Microsoft Press Computer Dictionary, Second Edition.
30.

Attached hereto as Exhibit 29 is a true and correct copy of an excerpt of the 2001

Microsoft Encarta College Dictionary.
31.

Attached hereto as Exhibit 30 is a demonstrative containing a list of the disputed

phrases, Motorola's proposed constructions, and Apple's proposed constructions.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Executed July 28, 2011, at Los Angeles, California.
/
Matthew 0. Korhonen

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