Motorola Mobility, Inc. v. Microsoft Corporation

Filing 129

MOTION in Limine Nos. 1-9 and Brief in Support Thereof by Motorola Mobility, Inc.. (Attachments: #1 Affidavit, #2 Exhibit A to Affidavit in Support, #3 Exhibit B to Affidavit in Support, #4 Exhibit C to Affidavit in Support, #5 Exhibit D to Affidavit in Support, #6 Exhibit E to Affidavit in Support, #7 Exhibit F to Affidavit in Support, #8 Exhibit G to Affidavit in Support, #9 Exhibit H to Affidavit in Support, #10 Exhibit I to Affidavit in Support, #11 Exhibit J to Affidavit in Support, #12 Exhibit K to Affidavit in Support, #13 Exhibit L to Affidavit in Support, #14 Exhibit M to Affidavit in Support)(Mullins, Edward)

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‘214 Patent Infringement Contentions
Motorola’s infringing products (“Accused Devices”) include mobile devices, such as
smartphones, associated software, and components thereof. The Accused Devices include
Motorola’s Android based phones which include, but are not limited to, the Motorola Droid X,
Droid 2, Droid 2 Global, Cliq 2, Defy, Bravo, Droid Pro, Droid 2 R2-D2, Droid X 2, Charm,
Droid, Flipside, Flipout, Atrix, Droid Bionic, Xoom, Devour A555, Backflip, Cliq/Dext, Cliq
XT/Quench, Citrus, Spice, i1 and other Motorola Android based phones incorporating hardware
and/or software that is substantially similar. The figures and illustrations in the infringement
chart below display exemplary devices.

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

1. In a network that includes a
first computer system having a
first data store and second
computer system having a
second data store, a method
for synchronizing the first and
second data stores in a flexible
manner considering the
circumstances that exist at the
time of synchronization, the
method comprising the
following:

Each Accused Device, such as, for example, the DROID 2 or
DROID X model, is a first computer system, that operates in
a network. Such network includes at least each Accused
Device and a second computer system, which can be, for
example, an email or calendar server. Such email or
calendar server can be, for example, a Microsoft Exchange
Server, Gmail server, or Google calendar server.
Each Accused Device has a first data store, which can be onboard memory (e.g., 8 GB in DROID 2 and DROID X), SD
memory (e.g., 8 GB in DROID 2, or 2 GB in DROID X),
SIM card, and/or other memory (e.g., removable memory)
for storing data items such as email, calendar data and
contact information. See, e.g., DROID 2 by Motorola –
Android Phone – Tech Specs,
http://www.motorola.com/Consumers/US-EN/ConsumerProduct-and-Services/Mobile-Phones/ci.Motorola-DROID2-US-EN.alt (visited Feb. 16, 2011):

1

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also DROID X by Motorola – Android phone – HD
phone – Tech Specs,
http://www.motorola.com/Consumers/US-EN/ConsumerProduct-and-Services/Mobile-Phones/ci.Motorola-DROIDX-US-EN.alt (visited Feb. 16, 2011):

See also DROID 2 User Guide at 59,
http://www.motorola.com/staticfiles/Support/USEN/Mobile%20Phones/DROID2/USEN/_Documents/Static_Files/DROID2_VZW_USEN_UG_68000202881b.pdf (visited Feb. 16, 2011):

2

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

The second computer system (which can be, for example, an
email or calendar server) has a second data store for storing
data items such as email, calendar data and contact
information.
As set forth below, each Accused Device comprises a
method for synchronizing the calendar, email, and contact
information of the first data store of each Accused Device
and second data store of the second computer system. See,
e.g., DROID 2 by Motorola – Android Phone – Tech Specs:

See also DROID X by Motorola – Android phone – HD
phone – Tech Specs:

3

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As set forth below, this synchronization of the first and
second data stores is accomplished in a flexible manner
considering the circumstances existing at the time of
synchronization.
an act of the first computer
system determining that a data
item is to be synchronized;

Each Accused Device determines that a data item (e.g.,
email, calendar data and contact information) is to be
synchronized. See, e.g., DROID 2 User Guide at 10;
Screenshot 1.1:

4

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

Screenshot 1.1: status icon indicates a synchronization is
active – each Accused Device determined that a data item
was to be synchronized
Furthermore, each Accused Device can determine that a data
item is to be synchronized by either "pushing " data or
"fetching" data on a predetermined schedule.
Also, each Accused Device will immediately determine that
a data item is to be synchronized when a new item is created
or an old item is edited.
an act of the first computer
system identifying which of a
plurality of synchronization
mechanisms, including one or
more hardwired or wireless
communication connections,
are available to use for
synchronization;

Each Accused Device identifies which of a plurality
synchronization mechanisms, including one or more
hardwired or wireless communication connections, are
available to use for synchronization.
Such wireless communication connections for
synchronization can be, for example, 3G, Wi-Fi, and
Bluetooth connections. See, e.g., DROID 2 User Guide at
10:

5

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices
The hardwired communication connection can be, for
example, a USB connection. See, e.g., DROID 2 User Guide
at 48:

Other synchronization mechanisms can be “push” or “fetch.”
For the former, the second computer system (for example, an
email or calendar server, e.g., Microsoft Exchange Server,
Gmail server, or Google calendar server) can “push” a data
item (e.g., email, calendar data and contact information) to
each Accused Device. For the latter, each Accused Device
fetches a data item from the second computer system.
Another synchronization mechanism can be a Virtual Private
Network (VPN). See, e.g., Add a Virtual Private Network –
Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

an act of the first computer
system consulting a set of one
or more flexible selection
rules to select a
synchronization mechanism,
the set of one or more flexible
rules taking into consideration

Each Accused Device consults a set of one or more flexible
selection rules to select a synchronization mechanism (e.g.,
wireless 3G or Wi-Fi; hardwired USB; fetch or pull
synchronization).
Each Accused Device can be flexibly configured such that,
for example, it synchronizes emails by fetch or push

6

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

value, from having access to
synchronized data, relative to
at least one of (i) an economic
cost for synchronization using
each available synchronization
mechanism, (ii) network
security for each available
synchronization mechanism,
(iii) security of the second
computer system, or (iv) value
of data being synchronized
and thereby selecting an
available synchronization
mechanism appropriate for the
data item given the one or
more flexible selection rules;
and

synchronization, whereas it synchronizes social applications
only via Wi-Fi.
See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

The set of one or more flexible rules takes into consideration
value, from having access to synchronized data (e.g., email,
calendar data and contact information), relative to at least
one of (i) an economic cost for synchronization using each
available synchronization mechanism (e.g., wireless 3G or
Wi-Fi; hardwired USB; fetch or pull synchronization), (ii)
network security for each available synchronization
mechanism, (iii) security of the second computer system (for
example, an email or calendar server, e.g., Microsoft
Exchange Server, Gmail server, or Google calendar server),
or (iv) value of data being synchronized and thereby
selecting an available synchronization mechanism
appropriate for the data item given the one or more flexible
selection rules.
For example, each Accused Device can fetch data on a predetermined schedule, or the second computer system can
automatically push data to each Accused Device, or. This is
a flexible choice that takes into account at least the value of
the data.

7

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices
As another example, each Accused Device can be flexibly
configured to synchronize social applications only via a WiFi mechanism, while email is set to be synchronized via
"push" synchronization. Such flexible rule takes into
account at least the value of the data and cost of
synchronizing using the various synchronization
mechanisms.
See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

As yet another example, each Accused Device can be
flexibly configured to use a secure connection when
synchronizing email. This flexible rule takes into account
the security of the synchronization mechanism.
See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

8

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As another example, each Accused Device can be flexibly
configured to use a Virtual Private Network (VPN).
Choosing to use a Virtual Private Network for
synchronization is a rule that considers the security of the
synchronization mechanism.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

9

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As still another example, each Accused Device can be
flexibly configured to choose between a Wi-Fi mechanism
and a 3G mechanism when synchronizing data. Each
Accused Device uses a 3G mechanism until it is flexibly
authorized to use a particular Wi-Fi mechanism. This rule
considers the network security of unauthorized Wi-Fi
mechanisms. Once one or more available Wi-Fi
mechanisms have been authorized, each Accused Device
prefers user-authorized Wi-Fi mechanisms to a 3G
mechanism. This rule considers the economic cost due to
the fact that using a Wi-Fi mechanism is less likely lead to
additional user fees.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

Each Accused Device can be flexibly configured to remove a
particular Wi-Fi mechanism from the list of authorized Wi-

10

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices
Fi mechanisms, and each Accused Device will thereafter
prefer a 3G mechanism to the de-authorized Wi-Fi
mechanism. This can be done by selecting "Forget network"
from the "Manage Networks" settings screen.
See, e.g., Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

Alternatively, each Accused Device can flexibly override the
preference for all user-authorized Wi-Fi mechanisms by
clearing the "Wi-Fi" checkbox on the "Wireless and network
settings" screen. This will result in each Accused Device
preferring a 3G mechanism to all Wi-Fi mechanisms,
including user-authorized Wi-Fi mechanisms.
See, e.g., WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

11

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As another example, each Accused Device can be flexibly
configured to allow "roaming," or alternatively to allow
synchronizations only using the "home" carrier's
synchronization mechanisms. This flexible rule considers
the cost of synchronizing using the various synchronization
mechanisms.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

12

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('214 Patent)

Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

13

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('214 Patent)

an act of the first computer
system using the selected
synchronization mechanism to
synchronize the data item with
the second computer.

Accused Devices

Each Accused Device uses the selected synchronization
mechanism to synchronize data with the second computer.
See, e.g., DROID 2 User Guide at 10; Screenshot 1.2;
Screenshot 1.3, which show a successful synchronization
using first a Wi-Fi synchronization mechanism and then a
3G synchronization mechanism.

14

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Accused Devices

Screenshot 1.2: synchronization taking place using a Wi-Fi
synchronization mechanism

Screenshot 1.3: synchronization taking place using a 3G
synchronization mechanism
3. A method in accordance
with claim 1, wherein the first
computer system is a mobile
device, and the second
computer system is a
synchronization server.

Each Accused Device, such as, for example, the DROID 2 or
DROID X model, is a mobile device and operates in a
network in which the second computer system is a
synchronization server, such as, for example a Microsoft
Exchange Server, Gmail server, or Google calendar server.

4. A method in accordance
with claim 3, wherein the act
of the first computer system
determining that a data item is
to be synchronized comprises
the following: an act of the
mobile device determining on
its own that the data item is to

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can each determine on its down that a
data item is to be synchronized.
For example, each Accused Device can determine that a data
item is to be synchronized by "fetching" data on a
predetermined schedule.
Also, each Accused Device will immediately determine that

15

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('214 Patent)

Accused Devices

be synchronized.

a data item is to be synchronized when a new item is created
or an old item is edited.

5. A method in accordance
with claim 3, wherein the act
of the first computer system
determining that a data item is
to be synchronized comprises
the following: an act of the
mobile device receiving a
user-issued instruction to
synchronize the data item.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can each determine that a data item is
to be synchronized by receiving a user-issued instruction to
synchronize the data item.
For example, each Accused Device can receive a user-issued
instruction to "sync now." See, e.g. Google Synchronization,
https://motorola-globalportal.custhelp.com/app/answers/detail/a_id/51167/~/droid2---google-synchronization (visited March 24, 2011); Gmail
Synchronization – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited March 25, 2011):

16

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('214 Patent)

Accused Devices

6. A method in accordance
with claim 3, wherein the act
of the first computer system
determining that a data item is
to be synchronized comprises
the following: an act of the
mobile device receiving a
signal from the
synchronization server that
represents to the mobile
device that the data item is to
be synchronized.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can each determine that a data item is
to be synchronized by receiving a signal from the
synchronization server that represents to the mobile device
that the data item is to be synchronized.
For example, each Accused Device can determine that a data
item is to be synchronized by receiving a signal from the
synchronization server comprising a data "push" operation.

17

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('214 Patent)

Accused Devices

10. A method in accordance
with claim 3, wherein the
mobile device comprises a
mobile telephone.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, each comprise a mobile telephone.

14. A method in accordance
with claim 1, wherein the
plurality or synchronization
mechanisms comprises at least
one wireless synchronization
mechanism.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can synchronize using a plurality of
synchronization mechanisms comprising at least one
wireless synchronization mechanism.

17. A method in accordance
with claim 14, wherein the at
least one wireless
synchronization mechanism
uses an 802.11b network.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can synchronize using a wireless
synchronization mechanism that uses an 802.11b network.
Such wireless synchronization mechanism includes, for
example, Wi-Fi.

19. A method in accordance
with claim 14, wherein the at
least one wireless
synchronization mechanism
uses a cellular network.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can synchronize using a wireless
synchronization mechanism that uses a cellular network.
Such wireless synchronization mechanism includes, for
example, 3G.

22. A method in accordance
with claim 1, further
comprising the following: an
act of receiving instructions to
change the set of flexible
selection rules; and an act of
changing the set or selection
rules in response to the

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can receive instructions to change the
set of flexible rules and can change the set of flexible rules in
response to the instruction.

Such wireless synchronization mechanisms include, for
example, 3G, Wi-Fi, and Bluetooth mechanisms. See, e.g.,
DROID 2 User Guide at 10:

For example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that emails are only synchronized if they are more recent
18

U.S. Patent No. 7,024,214
('214 Patent)
instruction.

Accused Devices
than one day, two days, three days, one week, two weeks, or
one month old; or so that emails are synchronized without
such a restraint. Each Accused Device can change the set of
selection rules in response to such instruction. See
Screenshot 22.1.

Screenshot 22.1: receiving an instruction to change the
flexible rule that dictates the age of emails that are
synchronized
As another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that social applications synchronize only via a Wi-Fi
mechanism, while email is set to be synchronized via "push"
synchronization. Alternatively, each Accused Device can
receive an instruction to change the set of flexible selection
rules such that social applications are not restricted in this

19

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Accused Devices
way. Either way, each Accused Device can change the set of
selection rules in response to the instruction.
See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use, a secure connection
when synchronizing email, and can change the set of flexible
selection rules in response to the instruction.
See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

20

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use a Virtual Private
Network (VPN), and can change the set of selection rules in
response to the instruction.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

21

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As still another example, each Accused Device can receive
an instruction to change the set of flexible selection rules
such that the device uses, or does not use Wi-Fi
synchronization mechanisms and can change the set of
selection rules in response to the instruction.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

See also, Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

22

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also, WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

23

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device allows, or does not allow, "roaming," or
alternatively to allow, or not allow, synchronizations only
using the "home" carrier's synchronization mechanisms.
Each Accused Device can change the set of selection rules in
response to the instruction.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

24

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

25

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Accused Devices

23. A method in accordance
with claim 22, wherein the act
of receiving instructions to
change the set of flexible
selection rules comprises the
following: an act of receiving
instructions to change the set
of flexible selection rules from
a user of the first computer
system.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can receive instructions to change the
set of flexible rules from a user of the first computer system
(i.e. each Accused Device) and can change the set of flexible
rules in response to the instruction.
For example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that emails are only synchronized if they are more recent
than one day, two days, three days, one week, two weeks, or
one month old; or so that emails are synchronized without
such a restraint. Each Accused Device can change the set of
selection rules in response to such instruction. See
Screenshot 23.1.

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Accused Devices

Screenshot 23.1: receiving an instruction to change the
flexible rule that dictates the age of emails that are
synchronized
As another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that social applications synchronize only via a Wi-Fi
mechanism, while email is set to be synchronized via "push"
synchronization. Alternatively, each Accused Device can
receive an instruction to change the set of flexible selection
rules such that social applications are not restricted in this
way. Either way, each Accused Device can change the set of
selection rules in response to the instruction.

See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

27

U.S. Patent No. 7,024,214
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Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use, a secure connection
when synchronizing email, and can change the set of flexible
selection rules in response to the instruction.
See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

28

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use a Virtual Private
Network (VPN), and can change the set of selection rules in
response to the instruction.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

29

U.S. Patent No. 7,024,214
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Accused Devices

As still another example, each Accused Device can receive
an instruction to change the set of flexible selection rules
such that the device uses, or does not use Wi-Fi
synchronization mechanisms and can change the set of
selection rules in response to the instruction.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

See also, Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

30

U.S. Patent No. 7,024,214
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Accused Devices

See also, WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

31

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device allows, or does not allow, "roaming," or
alternatively to allow, or not allow, synchronizations only
using the "home" carrier's synchronization mechanisms.
Each Accused Device can change the set of selection rules in
response to the instruction.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

32

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

33

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Accused Devices

24. A method in accordance
with claim 22, wherein the act
of receiving instructions to
change the set of flexible
selection rules comprises the
following: an act of receiving
instructions to change the set
of flexible selection rules from
an agent of the second
computer system.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can receive instructions to change the
set of flexible rules from a an agent of the second computer
system and can change the set of flexible rules in response to
the instruction.
For example, each Accused Device can receive an
instruction from an agent of the second computer system to
change the set of flexible selection rules such that calendar
items are only synchronized if they are newer than two
weeks old. Each Accused Device can change the set of
selection rules in response to such an instruction.
As another example, each Accused Device can receive an
instruction from an agent of the second computer system to
change the set of flexible selection rules such that emails are
only synchronized if they are more recent than one day, two
days, three days, one week, two weeks, or one month old; or
so that emails are synchronized without such a restraint.
Each Accused Device can change the set of selection rules in

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U.S. Patent No. 7,024,214
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Accused Devices
response to such instruction.
As a further example, each Accused Device can receive an
instruction from an agent of the second computer system to
change the set of flexible selection rules such that
attachments to emails are not synchronized, or are only
synchronized if they are smaller than a given size. Each
Accused Device can change the set of selection rules in
response to such instruction.
See, e.g., http://www.sysadminlab.net/activesync/android-22-and-activesync-policies-a-complete-guide-what-works
(accessed April 12, 2011)

25. A method in accordance
with claim 24, wherein the act
of receiving instructions to
change the set of flexible
selection rules from an agent
of the second computer system
comprises the following: an
act of receiving instructions to
change the set of flexible
selection rules from a network
administrator of a network that
includes the second computer
system.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can receive instructions to change the
set of flexible rules from a network administrator of a
network that includes the second computer system and can
change the set of flexible rules in response to the instruction.
For example, each Accused Device can receive an
instruction from a network administrator of a network that
includes the second computer system to change the set of
flexible selection rules such that calendar items are only
synchronized if they are newer than two weeks old. Each
Accused Device can change the set of selection rules in
response to such an instruction.
As another example, each Accused Device can receive an
instruction from a network administrator of a network that
includes the second computer system to change the set of
flexible selection rules such that emails are only
synchronized if they are more recent than one day, two days,
three days, one week, two weeks, or one month old; or so
that emails are synchronized without such a restraint. Each
Accused Device can change the set of selection rules in
response to such instruction.
As a further example, each Accused Device can receive an
instruction from a network administrator of a network that
includes the second computer system to change the set of
flexible selection rules such that attachments to emails are
not synchronized, or are only synchronized if they are
smaller than a given size. Each Accused Device can change
35

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices
the set of selection rules in response to such instruction.
See, e.g., http://www.sysadminlab.net/activesync/android-22-and-activesync-policies-a-complete-guide-what-works
(accessed April 12, 2011)

26. A method in accordance
with claim 25, further
comprising the following: an
act of receiving instructions to
change the set of flexible
selection rules from a user.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can receive instructions to change the
set of flexible rules from a user of the first computer system
(i.e. each Accused Device) and can change the set of flexible
rules in response to the instruction.
For example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that emails are only synchronized if they are more recent
than one day, two days, three days, one week, two weeks, or
one month old; or so that emails are synchronized without
such a restraint. Each Accused Device can change the set of
selection rules in response to such instruction. See
Screenshot 23.1.

36

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

Screenshot 23.1: receiving an instruction to change the
flexible rule that dictates the age of emails that are
synchronized
As another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that social applications synchronize only via a Wi-Fi
mechanism, while email is set to be synchronized via "push"
synchronization. Alternatively, each Accused Device can
receive an instruction to change the set of flexible selection
rules such that social applications are not restricted in this
way. Either way, each Accused Device can change the set of
selection rules in response to the instruction.

See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

37

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use, a secure connection
when synchronizing email, and can change the set of flexible
selection rules in response to the instruction.
See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

38

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use a Virtual Private
Network (VPN), and can change the set of selection rules in
response to the instruction.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

39

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As still another example, each Accused Device can receive
an instruction to change the set of flexible selection rules
such that the device uses, or does not use Wi-Fi
synchronization mechanisms and can change the set of
selection rules in response to the instruction.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

See also, Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

40

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also, WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

41

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device allows, or does not allow, "roaming," or
alternatively to allow, or not allow, synchronizations only
using the "home" carrier's synchronization mechanisms.
Each Accused Device can change the set of selection rules in
response to the instruction.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

42

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

43

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

27. A method in accordance
with claim 26, wherein the act
of changing the set of
selection rules in response to
the instruction, comprises the
following: an act of fulfilling
the instructions received from
the network administrator of
the second computer system to
the extent that there is a
conflict between the
instructions received from the
network administrator of the
second computer system and
the instructions received from
the user of the first computer
system.

Each Accused Device fulfils the instructions received from
the network administrator of the second computer system to
the extent that there is a conflict between the instructions
received from the network administrator of the second
computer system and the instructions received from the user
of the first computer system.
For example, if each Accused Device receives an instruction
from the network administrator to disable synchronization of
email attachments, and the user gives an instruction to
synchronize an email attachment by clicking on an
attachment to an email message, each Accused Device will
not allow the attachment synchronization.
As a further example, if each Accused Device receives an
instruction from the network administrator to disable
synchronization of email attachments greater than a certain
size, and the user gives an instruction to synchronize an
email attachment that exceeds that size by clicking on an
attachment to an email message, each Accused Device will

44

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices
not allow the attachment synchronization.
As a further example, if each Accused Device receives an
instruction from the network administrator to synchronize
only email items received more recently than a certain age,
each Accused Device will not allow the user to synchronize
older email items.
As a further example, if each Accused Device receives an
instruction from the network administrator to synchronize
only calendar items more recent than a certain age, each
Accused Device will not allow the user to synchronize older
calendar items.
See, e.g., http://www.sysadminlab.net/activesync/android-22-and-activesync-policies-a-complete-guide-what-works
(accessed April 12, 2011)

28. A method in accordance
with claim 1, wherein the act
of the first computer system
consulting a set of flexible
selection rules comprises the
following: an act of the first
computer system selecting one
of the available
synchronization mechanisms
without synchronous
intervention from a user of the
first computer system.

Each Accused Device can consult the set of flexible
selection rules by selecting one of the available
synchronization mechanisms without synchronous
intervention from a user of the first computer system (i.e.
each Accused Device).
For example, without synchronous intervention from a user,
each Accused Device can synchronize emails by fetch or
push synchronization.
See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

45

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, without synchronous intervention
by a user, each Accused Device can use a secure connection
when synchronizing email.
See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

46

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As another example, without synchronous intervention by a
user, each Accused Device use a Virtual Private Network
(VPN).
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

47

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As still another example, without synchronous user
invention, each Accused Device can use either a Wi-Fi
mechanism or a 3G mechanism when synchronizing data.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

See also, Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

48

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also, WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

49

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As another example, without synchronous user intervention,
each Accused Device can "roam" or alternatively only use
the "home" carrier's synchronization mechanisms.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

50

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

51

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

29. A method in accordance
with claim 1, wherein the act
of determining that a data item
is to be synchronized
comprises the following: an
act of the first computer
system receiving a notification
from the second computer
system that a data item is
available to synchronize; an
act of the first computer
system notifying the user of
the availability of the data
item; and an act of receiving a
user-instruction to synchronize
the data item.

Each Accused Device can determine that a data item is to be
synchronized by receiving a notification from the second
computer system that a data item is available to synchronize,
notifying the user of the availability of the data item, and
receiving a user-instruction to synchronize the data item.

32. A method in accordance
with claim 1, wherein the act
of consulting a set of flexible
selection rules to select one of
the available synchronization

Each Accused Device can select the synchronization
mechanism at least based on the value of the data.

See, e.g., DROID 2 User Guide at 50:

For example, each Accused Device can fetch data on a predetermined schedule, or the second computer system can
automatically push data to each Accused Device, or. This is
52

U.S. Patent No. 7,024,214
('214 Patent)
mechanisms comprises the
following: an act of selecting
the synchronization
mechanism at least based on
the value of the data.

Accused Devices
a flexible choice that takes into account at least the value of
the data.
As another example, each Accused Device can be flexibly
configured to synchronize social applications only via a WiFi mechanism, while email is set to be synchronized via
"push" synchronization. Such flexible rule takes into
account at least the value of the data and cost of
synchronizing using the various synchronization
mechanisms.
See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

33. A method in accordance
with claim 1, wherein the act
of consulting a set of flexible
selection rules to select one of
the available synchronization
mechanisms comprises the
following: an act of selecting
the synchronization
mechanism at least based on
the economic cost of using a
network associated with the

Each Accused Device can select the synchronization
mechanism at least based on the economic cost of using a
network associated with the synchronization mechanism.
For example, each Accused Device can be flexibly
configured to synchronize social applications only via a WiFi mechanism, while email is set to be synchronized via
"push" synchronization. Such flexible rule takes into
account at least the value of the data and economic cost of
using a network associated with the synchronization

53

U.S. Patent No. 7,024,214
('214 Patent)
synchronization mechanism.

Accused Devices
mechanism.
See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

As another example, each Accused Device can be flexibly
configured to choose between a Wi-Fi mechanism and a 3G
mechanism when synchronizing data. Each Accused Device
uses a 3G mechanism until it is flexibly authorized to use a
particular Wi-Fi mechanism. Once one or more available
Wi-Fi mechanisms have been authorized, each Accused
Device prefers user-authorized Wi-Fi mechanisms to a 3G
mechanism. This rule considers the economic cost of using
a network associated with the synchronization mechanism
due to the fact that using a Wi-Fi mechanism is less likely to
lead to additional user fees.
See, e.g., DROID 2 User Guide at 35-36:

54

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('214 Patent)

Accused Devices

See also DROID 2 User Guide at 46:

As another example, each Accused Device can be flexibly
configured to allow "roaming," or alternatively to allow
synchronizations only using the "home" carrier's
synchronization mechanisms. This flexible rule considers
the economic cost of using a network associated with the
synchronization mechanism.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

55

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

56

U.S. Patent No. 7,024,214
('214 Patent)

34. A method in accordance
with claim 1, wherein the act
of consulting a set of flexible
selection rules to select one of
the available synchronization
mechanisms comprises the
following: an act of selecting
the synchronization
mechanism at least based on
the security of a network
associated with the
synchronization mechanism.

Accused Devices

Each Accused Device can select the synchronization
mechanism at least based on the security of a network
associated with the synchronization mechanism.
As yet another example, each Accused Device can be
flexibly configured to use a secure connection when
synchronizing email. This flexible rule takes into account
the security of a network associated with the synchronization
mechanism.
See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

57

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As another example, each Accused Device can be flexibly
configured to use a Virtual Private Network (VPN).
Choosing to use a Virtual Private Network for
synchronization is a rule that considers the security of a
network associated with the synchronization mechanism.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

58

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Accused Devices

As still another example, each Accused Device can be
flexibly configured to choose between a Wi-Fi mechanism
and a 3G mechanism when synchronizing data. Each
Accused Device uses a 3G mechanism until it is flexibly
authorized to use a particular Wi-Fi mechanism. This rule
considers the security of a network associated with the
synchronization mechanism (e.g.. an authorized Wi-Fi
network).
38. A method in accordance
with claim 1, wherein the act
of consulting a set of flexible
selection rules to select one of
the available synchronization
mechanisms comprises the
following: an act of selecting
the synchronization
mechanism at least based on
the location of the user of the
first computer system.

Each Accused Device can select the synchronization
mechanism at least based on the location of the first
computer system.
As an example, each Accused Device can be flexibly
configured to choose between a Wi-Fi mechanism and a 3G
mechanism when synchronizing data. Each Accused Device
uses a 3G mechanism until it is flexibly authorized to use a
particular Wi-Fi mechanism. Once one or more available
Wi-Fi mechanisms have been authorized, each Accused
Device prefers user-authorized Wi-Fi mechanisms to a 3G
mechanism when the first computer system is located within
range of the Wi-Fi mechanism. This rule considers the
location of the first computer system.
See, e.g., DROID 2 User Guide at 35-36:

59

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also DROID 2 User Guide at 46:

As another example, each Accused Device can be flexibly
configured to allow "roaming," or alternatively to allow
synchronizations only using the "home" carrier's
synchronization mechanisms. This rule considers the
location of the first computer system.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

60

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Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

61

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Accused Devices

39. A method in accordance
with claim 1, wherein the act
of consulting a set of flexible
selection rules to select one of
the available synchronization
mechanisms comprises the
following: an act of
determining that there are no
current synchronization
mechanisms that are selectable
based on the flexible set of
rules; an act of reevaluating
the flexible selection rules at a
later time; and an act of
repeating the reevaluation
until at least one of the
available synchronization
mechanisms is selectable
based on the flexible selection
rules.

Each Accused Device can determine that there are no current
synchronization mechanisms that are selectable based on the
flexible set of rules, reevaluate the flexible selection rules at
a later time, and repeat the reevaluation until at least one of
the available synchronization mechanisms is selectable based
on the flexible selection rules.

41. A method in accordance

Each Accused Device can determine that a data item is to be

For example, each Accused Device can be flexibly
configured to synchronize social applications only via a WiFi mechanism, while email is set to be synchronized via
"push" synchronization. In such situation, if a social
application data item is to be synchronized, but a Wi-Fi
connection is not available, each Accused Device will
determine that there are no current synchronization
mechanisms that are selectable based on the flexible set of
rules. Each Accused Device will reevaluate the flexible
selection rules at a later time and repeat the reevaluation
until at least one of the available synchronization
mechanisms is selectable based on the flexible selection
rules (for example, until the rule that social applications are
synchronized only via Wi-Fi changes, or until a Wi-Fi
connection becomes available).

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Accused Devices

with claim 1, wherein the act
of the first computer system
determining that a data item is
to be synchronized comprises
the following: an act of the
first computer system
determining whether to
synchronize a data item by
consulting a set of flexible
selection rules; and an act of
the first computer system
synchronize the data item with
the second computer if the
first computer system
determines that the data item
is to be synchronized.

synchronized by consulting a flexible set of selection rules
and synchronizing the data item with the second computer if
the first computer (i.e. each Accused Device) determines that
the data item is to be synchronized.
For example, each Accused Device can determine that a data
item is to be synchronized by consulting a flexible set of
selection rules that dictate that emails are only synchronized
if they are more recent than one day, two days, three days,
one week, two weeks, or one month old; or that emails are
synchronized without such a restraint. Each Accused Device
will synchronize emails if it determines that the data item is
to be synchronized. See Screenshot 41.1.

Screenshot 41.1: determining that a data item is to be
synchronized by consulting a flexible rule that specifies the
age of emails that are synchronized

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Accused Devices

42. A computer program
product for use in a network
that includes a first computer
system having a first data
store and second computer
system having a second data
store, the computer program
product for implementing a
method for synchronizing the
first and second data stores in
a flexible manner considering
the circumstances that exist at
the time of synchronization,
the computer program product
comprising one or more
computer-readable media
having stored thereon the
following:

Each Accused Device, such as, for example, the DROID 2 or
DROID X model, is a first computer system and includes a
computer program product (which may include or be part of,
but is not limited to), the Android operating system) for use
in a network. Such network includes at least each Accused
Device and a second computer system, which can be, for
example, an email or calendar server. Such email or
calendar server can be, for example, a Microsoft Exchange
Server, Gmail server, or Google calendar server.
Each Accused Device has a first data store, which can be onboard memory (e.g., 8 GB in DROID 2 and DROID X), SD
memory (e.g., 8 GB in DROID 2, or 2 GB in DROID X),
SIM card, and/or other memory (e.g., removable memory)
for storing data items such as email, calendar data and
contact information.
See, e.g., DROID 2 by Motorola – Android Phone – Tech
Specs, http://www.motorola.com/Consumers/USEN/Consumer-Product-and-Services/MobilePhones/ci.Motorola-DROID-2-US-EN.alt (visited Feb. 16,
2011):

See also DROID X by Motorola – Android phone – HD
phone – Tech Specs,
http://www.motorola.com/Consumers/US-EN/ConsumerProduct-and-Services/Mobile-Phones/ci.Motorola-DROID-

64

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Accused Devices
X-US-EN.alt (visited Feb. 16, 2011):

See also DROID 2 User Guide at 59,
http://www.motorola.com/staticfiles/Support/USEN/Mobile%20Phones/DROID2/USEN/_Documents/Static_Files/DROID2_VZW_USEN_UG_68000202881b.pdf (visited Feb. 16, 2011):

The second computer system (which can be, for example, an
email or calendar server) has a second data store for storing
data items such as email, calendar data and contact
information.
Each Accused Device implements a method for
synchronizing the calendar, email, and contact information
of the first data store of each Accused Device and second
data store of the second computer system. See, e.g., DROID
2 by Motorola – Android Phone – Tech Specs:

65

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('214 Patent)

Accused Devices

See also DROID X by Motorola – Android phone – HD
phone – Tech Specs:

66

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Accused Devices

As set forth below, this synchronization of the first and
second data stores is accomplished in a flexible manner
considering the circumstances existing at the time of
synchronization.

Each Accused Device comprises one or more computerreadable media, which can be on-board memory (e.g., 8 GB
in DROID 2 and DROID X), SD memory (e.g., 8 GB in
DROID 2, or 2 GB in DROID X), SIM card, and/or other
memory (e.g., removable memory). This computer-readable
media has computer-executable instructions (including, but
not limited to, the Android operating system), as set forth
below.
computer-executable
instructions for determining
that a data item is to be
synchronized;

Certain computer-executable instructions (which may be part
of, but not limited to, the Android operating system) on each
Accused Device are for determining that a data item (e.g.,
email, calendar data and contact information) is to be
synchronized. See, e.g., DROID 2 User Guide at 10;
Screenshot 42.1:

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Accused Devices

Screenshot 42.1: status icon indicates a synchronization is
active – each Accused Device determined that a data item
was to be synchronized
Furthermore, each Accused Device can determine that a data
item is to be synchronized by either "pushing " data or
"fetching" data on a predetermined schedule.
Also, each Accused Device will immediately determine that
a data item is to be synchronized when a new item is created
or an old item is edited.
computer-executable
instructions for identifying
which of a plurality of
synchronization mechanisms,
including one or more
hardwired or wireless
communication connections,
are available to use for
synchronization;

Certain computer-executable instructions (which may
include or be part of, but is not limited to, the Android
operating system) on each Accused Device are for
identifying which of a plurality synchronization
mechanisms, including one or more hardwired or wireless
communication connections, are available to use for
synchronization.
Such wireless communication connections for
synchronization can be, for example, 3G, Wi-Fi, and
Bluetooth connections. See, e.g., DROID 2 User Guide at
10:

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Accused Devices

The hardwired communication connection can be, for
example, a USB connection. See, e.g., DROID 2 User Guide
at 48:

Other synchronization mechanisms can be “push” or “fetch.”
For the former, the second computer system (for example, an
email or calendar server, e.g., Microsoft Exchange Server,
Gmail server, or Google calendar server) can “push” a data
item (e.g., email, calendar data and contact information) to
each Accused Device. For the latter, each Accused Device
fetches a data item from the second computer system.
Another synchronization mechanism can be a Virtual Private
Network (VPN). See, e.g., Add a Virtual Private Network –
Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

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Accused Devices

computer-executable
instructions for consulting a
set of one or more flexible
selection rules to select a
synchronization mechanism,
the set of one or more flexible
rules taking into consideration
value, from having access to
synchronized data, relative to
at least one of (i) an economic
cost for synchronization using
each available synchronization
mechanism, (ii) network
security for each available
synchronization mechanism,
or (iii) security of the second
computer system, or (iv) value
of data being synchronized,
and thereby selecting an
available synchronization
mechanism appropriate for the
data item given the one or
more flexible selection rules;
and

Certain computer-executable instructions (which may
include or be part of, but is not limited to, the Android
operating system) on each Accused Device are for consulting
a set of one or more flexible selection rules to select a
synchronization mechanism (e.g., wireless 3G or Wi-Fi;
hardwired USB; fetch or pull synchronization).
Each Accused Device can be flexibly configured such that,
for example, it synchronizes emails by fetch or push
synchronization, whereas it synchronizes social applications
only via Wi-Fi.
See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

70

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Accused Devices

The set of one or more flexible rules takes into consideration
value, from having access to synchronized data (e.g., email,
calendar data and contact information), relative to at least
one of (i) an economic cost for synchronization using each
available synchronization mechanism (e.g., wireless 3G or
Wi-Fi; hardwired USB; fetch or pull synchronization), (ii)
network security for each available synchronization
mechanism, (iii) security of the second computer system (for
example, an email or calendar server, e.g., Microsoft
Exchange Server, Gmail server, or Google calendar server),
or (iv) value of data being synchronized and thereby
selecting an available synchronization mechanism
appropriate for the data item given the one or more flexible
selection rules.
For example, each Accused Device can fetch data on a predetermined schedule, or the second computer system can
automatically push data to each Accused Device, or. This is
a flexible choice that takes into account at least the value of
the data.
As another example, each Accused Device can be flexibly
configured to synchronize social applications only via a WiFi mechanism, while email is set to be synchronized via
"push" synchronization. Such flexible rule takes into
account at least the value of the data and cost of
synchronizing using the various synchronization

71

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Accused Devices
mechanisms.
See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

As yet another example, each Accused Device can be
flexibly configured to use a secure connection when
synchronizing email. This flexible rule takes into account
the security of the synchronization mechanism.
See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

72

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Accused Devices

As another example, each Accused Device can be flexibly
configured to use a Virtual Private Network (VPN).
Choosing to use a Virtual Private Network for
synchronization is a rule that considers the security of the
synchronization mechanism.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

73

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Accused Devices

As still another example, each Accused Device can be
flexibly configured to choose between a Wi-Fi mechanism
and a 3G mechanism when synchronizing data. Each
Accused Device uses a 3G mechanism until it is flexibly
authorized to use a particular Wi-Fi mechanism. This rule
considers the network security of unauthorized Wi-Fi
mechanisms. Once one or more available Wi-Fi
mechanisms have been authorized, each Accused Device
prefers user-authorized Wi-Fi mechanisms to a 3G
mechanism. This rule considers the economic cost due to
the fact that using a Wi-Fi mechanism is less likely lead to
additional user fees.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

Each Accused Device can be flexibly configured to remove a
particular Wi-Fi mechanism from the list of authorized Wi-

74

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Accused Devices
Fi mechanisms, and each Accused Device will thereafter
prefer a 3G mechanism to the de-authorized Wi-Fi
mechanism. This can be done by selecting "Forget network"
from the "Manage Networks" settings screen.
See, e.g., Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

Alternatively, each Accused Device can flexibly override the
preference for all user-authorized Wi-Fi mechanisms by
clearing the "Wi-Fi" checkbox on the "Wireless and network
settings" screen. This will result in each Accused Device
preferring a 3G mechanism to all Wi-Fi mechanisms,
including user-authorized Wi-Fi mechanisms.
See, e.g., WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

75

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Accused Devices

As another example, each Accused Device can be flexibly
configured to allow "roaming," or alternatively to allow
synchronizations only using the "home" carrier's
synchronization mechanisms. This flexible rule considers
the cost of synchronizing using the various synchronization
mechanisms.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

76

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

77

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('214 Patent)

Accused Devices

computer-executable
instructions for using the
selected synchronization
mechanism to synchronize the
data item with the second
computer.

Certain computer-executable instructions (which may
include or be part of, but is not limited to, the Android
operating system) on each Accused Device are for using the
selected synchronization mechanism to synchronize the data
item with the second computer.
See, e.g., DROID 2 User Guide at 10; Screenshot 42.2;
Screenshot 42.3, which show a successful synchronization
using first a Wi-Fi synchronization mechanism and then a
3G synchronization mechanism.

78

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Accused Devices

Screenshot 42.2: synchronization taking place using a Wi-Fi
synchronization mechanism

Screenshot 42.3: synchronization taking place using a 3G
synchronization mechanism
43. A computer program
product in accordance with
claim 42, wherein the one or
more computer-readable
media are physical storage
media.

The computer-readable media in each Accused Device
comprise physical storage media, which can be on-board
memory (e.g., 8 GB in DROID 2 and DROID X), SD
memory (e.g., 8 GB in DROID 2, or 2 GB in DROID X),
SIM card, and/or other memory (e.g., removable memory).

44. In a network that includes
a first computer system having
a first data store and second
computer system having a
second data store, a method
for synchronizing the first and
second data stores in a flexible
manner considering the
circumstances that exist at the

Each Accused Device, such as, for example, the DROID 2 or
DROID X model, is a first computer system that operates in
a network. Such network includes at least each Accused
Device and a second computer system, which can be, for
example, an email or calendar server. Such email or
calendar server can be, for example, a Microsoft Exchange
server, Gmail server, or Google calendar server.

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time of synchronization, the
method comprising the
following:

Accused Devices

Each Accused Device has a first data store, which can be onboard memory (e.g., 8 GB in DROID 2 and DROID X), SD
memory (e.g., 8 GB in DROID 2, or 2 GB in DROID X),
SIM card, and/or other memory (e.g., removable memory)
for storing data items such as email, calendar data and
contact information.

See, e.g., DROID 2 by Motorola – Android Phone – Tech
Specs, http://www.motorola.com/Consumers/USEN/Consumer-Product-and-Services/MobilePhones/ci.Motorola-DROID-2-US-EN.alt (visited Feb. 16,
2011):

See also DROID X by Motorola – Android phone – HD
phone – Tech Specs,
http://www.motorola.com/Consumers/US-EN/ConsumerProduct-and-Services/Mobile-Phones/ci.Motorola-DROIDX-US-EN.alt (visited Feb. 16, 2011):

80

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Accused Devices

See also DROID 2 User Guide at 59,
http://www.motorola.com/staticfiles/Support/USEN/Mobile%20Phones/DROID2/USEN/_Documents/Static_Files/DROID2_VZW_USEN_UG_68000202881b.pdf (visited Feb. 16, 2011):

The second computer system (which can be, for example, an
email or calendar server) has a second data store for storing
data items such as email, calendar data and contact
information.

As set forth below, each Accused Device comprises a
method for synchronizing the calendar, email, and contact
information of the first data store of each Accused Device
and second data store of the second computer system. See,
81

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Accused Devices
e.g., DROID 2 by Motorola – Android Phone – Tech Specs:

See also DROID X by Motorola – Android phone – HD
phone – Tech Specs:

82

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('214 Patent)

Accused Devices

As set forth below, this synchronization of the first and
second data stores is accomplished in a flexible manner
considering the circumstances existing at the time of
synchronization.
an act of the first computer
system determining whether to
synchronize a data item by
consulting a set of one or more
flexible selection rules, the set
of one or more flexible rules
taking into consideration
value, from having access to
synchronized data, relative to
at least one of (i) an economic
cost for synchronization using
each available synchronization
mechanism, (ii) network
security for each available
synchronization mechanism,
or (iii) security of the second

Each Accused Device determines whether to synchronize a
data item (e.g., email, calendar data and contact information)
by consulting a set of one or more flexible selection rules.

For example, each Accused Device consults a flexible
selection rule to determine whether to synchronize an email
message based on the age of the email. See Screenshots
44.1-44.3.

83

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Accused Devices

computer system,or (iv) value
of data being synchronized,
and thereby also determining
an available synchronization
mechanism appropriate for the
data item given the one or
more flexible selection rules;
and

Screenshot 44.1: a flexible rule dictates that only emails
from the past month should be synchronized

Screenshot 44.2: the second data store contains 7 emails,
84

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('214 Patent)

Accused Devices
but only 3 are from the past month

Screenshot 44.3: only the 3 emails from the past month are
synchronized to each Accused Device's first data store

Various synchronization mechanisms may be available to
use for synchronization by each Accused Device. Such
synchronization mechanisms can include wireless and
hardwired communication connections.

Wireless communication connections for synchronization
can be, for example, 3G, Wi-Fi, and Bluetooth connections.
See, e.g., DROID 2 User Guide at 10:

85

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Accused Devices

The hardwired communication connection can be, for
example, a USB connection. See, e.g., DROID 2 User Guide
at 48:

Other synchronization mechanisms can be “push” or “fetch.”
For the former, the second computer system (for example, an
email or calendar server, e.g., Microsoft Exchange Server,
Gmail server, or Google calendar server) can “push” a data
item (e.g., email, calendar data and contact information) to
each Accused Device. For the latter, each Accused Device
fetches a data item from the second computer system.

Another synchronization mechanism can be a Virtual Private
Network (VPN). See, e.g., Add a Virtual Private Network –
Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

86

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Accused Devices

The set of one or more flexible rules takes into consideration
value, from having access to synchronized data (e.g., email,
calendar data and contact information), relative to at least
one of (i) an economic cost for synchronization using each
available synchronization mechanism (e.g., wireless 3G or
Wi-Fi; hardwired USB; fetch or pull synchronization), (ii)
network security for each available synchronization
mechanism, (iii) security of the second computer system (for
example, an email or calendar server, e.g., Microsoft
Exchange Server, Gmail server, or Google calendar server),
or (iv) value of data being synchronized and thereby
selecting an available synchronization mechanism
appropriate for the data item given the one or more flexible
selection rules.

For example, each Accused Device can fetch data on a predetermined schedule, or the second computer system can
automatically push data to each Accused Device. This is a
flexible choice that takes into account at least the value of
the data.

As another example, each Accused Device can be flexibly
configured to synchronize social applications only via a Wi87

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices
Fi mechanism, while email is set to be synchronized via
"push" synchronization. Such flexible rule takes into
account at least the value of the data and cost of
synchronizing using the various synchronization
mechanisms.

See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

As yet another example, each Accused Device can be
flexibly configured to use a secure connection when
synchronizing email. This flexible rule takes into account
the security of the synchronization mechanism.

See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

88

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As another example, each Accused Device can be flexibly
configured to use a Virtual Private Network (VPN).
Choosing to use a Virtual Private Network for
synchronization is a rule that considers the security of the
synchronization mechanism.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

89

U.S. Patent No. 7,024,214
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Accused Devices

As still another example, each Accused Device can be
flexibly configured to choose between a Wi-Fi mechanism
and a 3G mechanism when synchronizing data. Each
Accused Device uses a 3G mechanism until it is flexibly
authorized to use a particular Wi-Fi mechanism. This rule
considers the network security of unauthorized Wi-Fi
mechanisms. Once one or more available Wi-Fi
mechanisms have been authorized, each Accused Device
prefers user-authorized Wi-Fi mechanisms to a 3G
mechanism. This rule considers the economic cost due to
the fact that using a Wi-Fi mechanism is less likely lead to
additional user fees.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

Each Accused Device can be flexibly configured to remove a
particular Wi-Fi mechanism from the list of authorized Wi-

90

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices
Fi mechanisms, and each Accused Device will thereafter
prefer a 3G mechanism to the de-authorized Wi-Fi
mechanism. This can be done by selecting "Forget network"
from the "Manage Networks" settings screen.
See, e.g., Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

Alternatively, each Accused Device can flexibly override the
preference for all user-authorized Wi-Fi mechanisms by
clearing the "Wi-Fi" checkbox on the "Wireless and network
settings" screen. This will result in each Accused Device
preferring a 3G mechanism to all Wi-Fi mechanisms,
including user-authorized Wi-Fi mechanisms.
See, e.g., WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

91

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As another example, each Accused Device can be flexibly
configured to allow "roaming," or alternatively to allow
synchronizations only using the "home" carrier's
synchronization mechanisms. This flexible rule considers
the cost of synchronizing using the various synchronization
mechanisms.

See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

92

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Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

93

U.S. Patent No. 7,024,214
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Accused Devices

an act of the first computer
system synchronizing the data
item with the second computer
if the first computer system
determines that the data item
is to be synchronized based on
the one or more flexible
selection rules and each
available synchronization
mechanism, including one or
more hardwired or wireless
communication connections.

Each Accused Device synchronizes the data item (e.g.,
email, calendar data and contact information) with the
second computer (for example, an email or calendar server,
e.g., Microsoft Exchange Server, Gmail server, or Google
calendar server) if the first computer system (e.g., Accused
Device) determines that the data item is to be synchronized
based on the one or more flexible selection rules and each
available synchronization mechanism, including one or more
hardwired or wireless communication connections.

The wireless communication connections for
synchronization can be, for example, 3G, Wi-Fi, and
Bluetooth connections. See, e.g., DROID 2 User Guide at
10:

94

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Accused Devices

The hardwired communication connection can be, for
example, a USB connection. See, e.g., DROID 2 User Guide
at 48:

The Android operating system on the Motorola Android
synchronizes the data item with the second computer if each
Accused Device determines that the data item is to be
synchronized. See, e.g., Screenshot 44.4; Screenshot 44.5,
which show a successful synchronization using first a Wi-Fi
synchronization mechanism and then a 3G synchronization
mechanism.

Screenshot 44.4: synchronization taking place using a Wi-Fi

95

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Accused Devices
synchronization mechanism

Screenshot 44.5: synchronization taking place using a 3G
synchronization mechanism
46. A method in accordance
with claim 44, wherein the
first computer system is a
mobile device, and the second
computer system is a
synchronization server.

Each Accused Device, such as, for example, the DROID 2 or
DROID X model, is a mobile device and operates in a
network in which the second computer system is a
synchronization server, such as, for example, a Microsoft
Exchange server, Gmail server, or Google calendar server.

47. A method in accordance
with claim 44, further
comprising the following: an
act of receiving instructions to
change the set of flexible
selection rules; and an act of
changing the set of flexible
selection rules in response to
the instruction.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can receive instructions to change the
set of flexible rules and can change the set of flexible rules in
response to the instruction.

For example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that emails are only synchronized if they are more recent
than one day, two days, three days, one week, two weeks, or
one month old; or so that emails are synchronized without
such a restraint. Each Accused Device can change the set of
selection rules in response to such instruction. See
Screenshot 47.1.

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Accused Devices

Screenshot 47.1: receiving an instruction to change the
flexible rule that dictates the age of emails that are
synchronized

As another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that social applications synchronize only via a Wi-Fi
mechanism, while email is set to be synchronized via "push"
synchronization. Alternatively, each Accused Device can
receive an instruction to change the set of flexible selection
rules such that social applications are not restricted in this
way. Either way, each Accused Device can change the set of
selection rules in response to the instruction.

See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
97

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices
=31337 (visited Feb. 16, 2011):

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use, a secure connection
when synchronizing email, and can change the set of flexible
selection rules in response to the instruction.

See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

98

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use a Virtual Private
Network (VPN), and can change the set of selection rules in
response to the instruction.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

99

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As still another example, each Accused Device can receive
an instruction to change the set of flexible selection rules
such that the device uses, or does not use Wi-Fi
synchronization mechanisms and can change the set of
selection rules in response to the instruction.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

See also, Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

100

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also, WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

101

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device allows, or does not allow, "roaming," or
alternatively to allow, or not allow, synchronizations only
using the "home" carrier's synchronization mechanisms.
Each Accused Device can change the set of selection rules in
response to the instruction.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

102

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

103

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Accused Devices

48. A method in accordance
with claim 47, wherein the act
of receiving instructions to
change the set or flexible
selection rules comprises the
following: an act of receiving
instructions to change the set
of flexible selection rules from
a user of the first computer
system.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can receive instructions to change the
set of flexible rules from a user of the first computer system
(i.e. each Accused Device) and can change the set of flexible
rules in response to the instruction.
For example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that emails are only synchronized if they are more recent
than one day, two days, three days, one week, two weeks, or
one month old; or so that emails are synchronized without
such a restraint. Each Accused Device can change the set of
selection rules in response to such instruction. See
Screenshot 48.1.

104

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Accused Devices

Screenshot 48.1: receiving an instruction to change the
flexible rule that dictates the age of emails that are
synchronized
As another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that social applications synchronize only via a Wi-Fi
mechanism, while email is set to be synchronized via "push"
synchronization. Alternatively, each Accused Device can
receive an instruction to change the set of flexible selection
rules such that social applications are not restricted in this
way. Either way, each Accused Device can change the set of
selection rules in response to the instruction.

See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

105

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use, a secure connection
when synchronizing email, and can change the set of flexible
selection rules in response to the instruction.
See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

106

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use a Virtual Private
Network (VPN), and can change the set of selection rules in
response to the instruction.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

107

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

As still another example, each Accused Device can receive
an instruction to change the set of flexible selection rules
such that the device uses, or does not use Wi-Fi
synchronization mechanisms and can change the set of
selection rules in response to the instruction.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

See also, Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

108

U.S. Patent No. 7,024,214
('214 Patent)

Accused Devices

See also, WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

109

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Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device allows, or does not allow, "roaming," or
alternatively to allow, or not allow, synchronizations only
using the "home" carrier's synchronization mechanisms.
Each Accused Device can change the set of selection rules in
response to the instruction.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

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See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

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49. A method in accordance
with claim 47, wherein the act
of receiving instructions to
change the set of flexible
selection rules comprises the
following: an act of receiving
instructions to change the set
of flexible selection rules from
an agent of the second
computer system.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can receive instructions to change the
set of flexible rules from a an agent of the second computer
system and can change the set of flexible rules in response to
the instruction.
For example, each Accused Device can receive an
instruction from an agent of the second computer system to
change the set of flexible selection rules such that calendar
items are only synchronized if they are newer than two
weeks old. Each Accused Device can change the set of
selection rules in response to such an instruction.
As another example, each Accused Device can receive an
instruction from an agent of the second computer system to
change the set of flexible selection rules such that emails are
only synchronized if they are more recent than one day, two
days, three days, one week, two weeks, or one month old; or
so that emails are synchronized without such a restraint.
Each Accused Device can change the set of selection rules in

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Accused Devices
response to such instruction.
As a further example, each Accused Device can receive an
instruction from an agent of the second computer system to
change the set of flexible selection rules such that
attachments to emails are not synchronized, or are only
synchronized if they are smaller than a given size. Each
Accused Device can change the set of selection rules in
response to such instruction.
See, e.g., http://www.sysadminlab.net/activesync/android-22-and-activesync-policies-a-complete-guide-what-works
(accessed April 12, 2011)

50. A method in accordance
with claim 49, wherein the act
of receiving instructions to
change the set of flexible
selection rules from an agent
of the second computer system
comprises the following: an
act of receiving instructions to
change the set of flexible
selection rules from a network
administrator of trusted
network that includes the
second computer system.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can receive instructions to change the
set of flexible rules from a network administrator of a
network that includes the second computer system and can
change the set of flexible rules in response to the instruction.
For example, each Accused Device can receive an
instruction from a network administrator of a network that
includes the second computer system to change the set of
flexible selection rules such that calendar items are only
synchronized if they are newer than two weeks old. Each
Accused Device can change the set of selection rules in
response to such an instruction.
As another example, each Accused Device can receive an
instruction from a network administrator of a network that
includes the second computer system to change the set of
flexible selection rules such that emails are only
synchronized if they are more recent than one day, two days,
three days, one week, two weeks, or one month old; or so
that emails are synchronized without such a restraint. Each
Accused Device can change the set of selection rules in
response to such instruction.
As a further example, each Accused Device can receive an
instruction from a network administrator of a network that
includes the second computer system to change the set of
flexible selection rules such that attachments to emails are
not synchronized, or are only synchronized if they are
smaller than a given size. Each Accused Device can change
113

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Accused Devices
the set of selection rules in response to such instruction.
See, e.g., http://www.sysadminlab.net/activesync/android-22-and-activesync-policies-a-complete-guide-what-works
(accessed April 12, 2011)

51. A method in accordance
with claim 50, further
comprising the following: an
act of receiving instructions to
change the set of flexible
selection rules from a user.

Each Accused Device, such as, for example, the DROID 2
and DROID X models, can receive instructions to change the
set of flexible rules from a user of the first computer system
(i.e. each Accused Device) and can change the set of flexible
rules in response to the instruction.
For example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that emails are only synchronized if they are more recent
than one day, two days, three days, one week, two weeks, or
one month old; or so that emails are synchronized without
such a restraint. Each Accused Device can change the set of
selection rules in response to such instruction. See
Screenshot 23.1.

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Accused Devices

Screenshot 23.1: receiving an instruction to change the
flexible rule that dictates the age of emails that are
synchronized
As another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that social applications synchronize only via a Wi-Fi
mechanism, while email is set to be synchronized via "push"
synchronization. Alternatively, each Accused Device can
receive an instruction to change the set of flexible selection
rules such that social applications are not restricted in this
way. Either way, each Accused Device can change the set of
selection rules in response to the instruction.

See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

115

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Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use, a secure connection
when synchronizing email, and can change the set of flexible
selection rules in response to the instruction.
See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

116

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('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device uses, or does not use a Virtual Private
Network (VPN), and can change the set of selection rules in
response to the instruction.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

117

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Accused Devices

As still another example, each Accused Device can receive
an instruction to change the set of flexible selection rules
such that the device uses, or does not use Wi-Fi
synchronization mechanisms and can change the set of
selection rules in response to the instruction.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

See also, Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

118

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('214 Patent)

Accused Devices

See also, WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

119

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('214 Patent)

Accused Devices

As yet another example, each Accused Device can receive an
instruction to change the set of flexible selection rules such
that the device allows, or does not allow, "roaming," or
alternatively to allow, or not allow, synchronizations only
using the "home" carrier's synchronization mechanisms.
Each Accused Device can change the set of selection rules in
response to the instruction.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

120

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Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

121

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Accused Devices

52. A method in accordance
with claim 51, wherein the act
of changing the set of flexible
selection rules in response to
the instruction, comprises the
following: an act of fulfilling
the instructions received from
the network administrator of
the second computer system to
the extent that there is a
conflict between the
instructions received from the
network administrator of the
second computer system and
the instructions received from
the user at the first computer
system.

Each Accused Device fulfils the instructions received from
the network administrator of the second computer system to
the extent that there is a conflict between the instructions
received from the network administrator of the second
computer system and the instructions received from the user
of the first computer system.
For example, if each Accused Device receives an instruction
from the network administrator to disable synchronization of
email attachments, and the user gives an instruction to
synchronize an email attachment by clicking on an
attachment to an email message, each Accused Device will
not allow the attachment synchronization.
As a further example, if each Accused Device receives an
instruction from the network administrator to disable
synchronization of email attachments greater than a certain
size, and the user gives an instruction to synchronize an
email attachment that exceeds that size by clicking on an
attachment to an email message, each Accused Device will

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Accused Devices
not allow the attachment synchronization.
As a further example, if each Accused Device receives an
instruction from the network administrator to synchronize
only email items received more recently than a certain age,
each Accused Device will not allow the user to synchronize
older email items.
As a further example, if each Accused Device receives an
instruction from the network administrator to synchronize
only calendar items more recent than a certain age, each
Accused Device will not allow the user to synchronize older
calendar items.
See, e.g., http://www.sysadminlab.net/activesync/android-22-and-activesync-policies-a-complete-guide-what-works
(accessed April 12, 2011)

54. A method in accordance
with claim 44, wherein the act
of the first computer system
synchronize the data item with
the second computer
comprises the following:

Each Accused Device comprises a method wherein the act of
the first computer system to synchronize the data item with
the second computer comprises the following:

an act of the first computer
system identifying which of a
plurality of synchronization
mechanisms are available to
use for synchronization;

Each Accused Device identifies which of a plurality of
synchronization mechanisms are available to use for
synchronization.

Such synchronization mechanisms can be, for example, 3G,
Wi-Fi, and Bluetooth connections. See, e.g., DROID 2 User
Guide at 10:

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Accused Devices

Such synchronization mechanisms can further be, for
example, a USB connection. See, e.g., DROID 2 User Guide
at 48:

Other synchronization mechanisms can be “push” or “fetch.”
For the former, the second computer system (for example, an
email or calendar server, e.g., Microsoft Exchange Server,
Gmail server, or Google calendar server) can “push” a data
item (e.g., email, calendar data and contact information) to
each Accused Device. For the latter, each Accused Device
fetches a data item from the second computer system.
Another synchronization mechanism can be a Virtual Private
Network (VPN). See, e.g., Add a Virtual Private Network –
Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

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an act of the first computer
system consulting a set of
flexible selection rules to
select one of the available
synchronization mechanisms;
and

Accused Devices

Each Accused Device consults a set of one or more flexible
selection rules to select a synchronization mechanism (e.g.,
wireless 3G or Wi-Fi; hardwired USB; fetch or pull
synchronization).

For example, each Accused Device can be flexibly
configured such that, for example, it synchronizes emails by
fetch or push synchronization, whereas it synchronizes social
applications only via Wi-Fi.
See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

125

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Accused Devices

The set of one or more flexible rules takes into consideration
value, from having access to synchronized data (e.g., email,
calendar data and contact information), relative to at least
one of (i) an economic cost for synchronization using each
available synchronization mechanism (e.g., wireless 3G or
Wi-Fi; hardwired USB; fetch or pull synchronization), (ii)
network security for each available synchronization
mechanism, (iii) security of the second computer system (for
example, an email or calendar server, e.g., Microsoft
Exchange Server, Gmail server, or Google calendar server),
or (iv) value of data being synchronized and thereby
selecting an available synchronization mechanism
appropriate for the data item given the one or more flexible
selection rules.
For example, each Accused Device can fetch data on a predetermined schedule, or the second computer system can
automatically push data to each Accused Device, or. This is
a flexible choice that takes into account at least the value of
the data.
As another example, each Accused Device can be flexibly
configured to synchronize social applications only via a WiFi mechanism, while email is set to be synchronized via
"push" synchronization. Such flexible rule takes into
account at least the value of the data and cost of
synchronizing using the various synchronization

126

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('214 Patent)

Accused Devices
mechanisms.
See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

As yet another example, each Accused Device can be
flexibly configured to use a secure connection when
synchronizing email. This flexible rule takes into account
the security of the synchronization mechanism.
See, e.g., Configure Corporate Email (Exchange ActiveSync)
– Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

127

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('214 Patent)

Accused Devices

As another example, each Accused Device can be flexibly
configured to use a Virtual Private Network (VPN).
Choosing to use a Virtual Private Network for
synchronization is a rule that considers the security of the
synchronization mechanism.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

128

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('214 Patent)

Accused Devices

As still another example, each Accused Device can be
flexibly configured to choose between a Wi-Fi mechanism
and a 3G mechanism when synchronizing data. Each
Accused Device uses a 3G mechanism until it is flexibly
authorized to use a particular Wi-Fi mechanism. This rule
considers the network security of unauthorized Wi-Fi
mechanisms. Once one or more available Wi-Fi
mechanisms have been authorized, each Accused Device
prefers user-authorized Wi-Fi mechanisms to a 3G
mechanism. This rule considers the economic cost due to
the fact that using a Wi-Fi mechanism is less likely lead to
additional user fees.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

Each Accused Device can be flexibly configured to remove a
particular Wi-Fi mechanism from the list of authorized Wi-

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Accused Devices
Fi mechanisms, and each Accused Device will thereafter
prefer a 3G mechanism to the de-authorized Wi-Fi
mechanism. This can be done by selecting "Forget network"
from the "Manage Networks" settings screen.
See, e.g., Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

Alternatively, each Accused Device can flexibly override the
preference for all user-authorized Wi-Fi mechanisms by
clearing the "Wi-Fi" checkbox on the "Wireless and network
settings" screen. This will result in each Accused Device
preferring a 3G mechanism to all Wi-Fi mechanisms,
including user-authorized Wi-Fi mechanisms.
See, e.g., WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

130

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('214 Patent)

Accused Devices

As another example, each Accused Device can be flexibly
configured to allow "roaming," or alternatively to allow
synchronizations only using the "home" carrier's
synchronization mechanisms. This flexible rule considers
the cost of synchronizing using the various synchronization
mechanisms.
See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

131

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('214 Patent)

Accused Devices

See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

132

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an act of the first computer
system using the selected
synchronization mechanism to
synchronize the data item with
the second computer.

Accused Devices

Each Accused Device uses the selected synchronization
mechanism to synchronize data with the second computer.

See, e.g., DROID 2 User Guide at 10; Screenshot 54.1;
Screenshot 54.2, which show a successful synchronization
using first a Wi-Fi synchronization mechanism and then a
3G synchronization mechanism.

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Accused Devices

Screenshot 54.1: synchronization taking place using a Wi-Fi
synchronization mechanism

Screenshot 54.2: synchronization taking place using a 3G
synchronization mechanism
55. A computer program
product for use in a network
that includes a first computer
system having a first data
store and second computer
system having a second data
store, the computer program
product for implementing a
method for synchronizing the
first and second data stores in
a flexible manner considering
the circumstances that exist at
the time of synchronization,
the computer program product
comprising one or more
computer-readable media

Each Accused Device, such as, for example, the DROID 2 or
DROID X model, is a first computer system and each
includes a computer program product (the Android operating
system) for use in a network. Such network includes at least
each Accused Device and a second computer system, which
can be, for example, an email or calendar server. Such email
or calendar server can be, for example, a Microsoft
Exchange server, Gmail server, or Google calendar server.

Each Accused Device has a first data store, which can be onboard memory (e.g., 8 GB in DROID 2 and DROID X), SD
memory (e.g., 8 GB in DROID 2, or 2 GB in DROID X),
SIM card, and/or other memory (e.g., removable memory)
for storing data items such as email, calendar data and

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having stored thereon the
following:

Accused Devices
contact information.

See, e.g., DROID 2 by Motorola – Android Phone – Tech
Specs, http://www.motorola.com/Consumers/USEN/Consumer-Product-and-Services/MobilePhones/ci.Motorola-DROID-2-US-EN.alt (visited Feb. 16,
2011):

See also DROID X by Motorola – Android phone – HD
phone – Tech Specs,
http://www.motorola.com/Consumers/US-EN/ConsumerProduct-and-Services/Mobile-Phones/ci.Motorola-DROIDX-US-EN.alt (visited Feb. 16, 2011):

135

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('214 Patent)

Accused Devices

See also DROID 2 User Guide at 59,
http://www.motorola.com/staticfiles/Support/USEN/Mobile%20Phones/DROID2/USEN/_Documents/Static_Files/DROID2_VZW_USEN_UG_68000202881b.pdf (visited Feb. 16, 2011):

The second computer system (which can be, for example, an
email or calendar server) has a second data store for storing
data items such as email, calendar data and contact
information.

Each Accused Device implements a method for
synchronizing the calendar, email, and contact information
of the first data store of each Accused Device and second
data store of the second computer system. See, e.g., DROID
136

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('214 Patent)

Accused Devices
2 by Motorola – Android Phone – Tech Specs:

See also DROID X by Motorola – Android phone – HD
phone – Tech Specs:

137

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('214 Patent)

Accused Devices

As set forth below, this synchronization of the first and
second data stores is accomplished in a flexible manner
considering the circumstances existing at the time of
synchronization.

Each Accused Device comprises one or more computerreadable media, which can be on-board memory (e.g., 8 GB
in DROID 2 and DROID X), SD memory (e.g., 8 GB in
DROID 2, or 2 GB in DROID X), SIM card, and/or other
memory (e.g., removable memory). This computer-readable
media has computer-executable instructions (including, but
not limited to, the Android operating system), as set forth
below.
computer-executable
instructions for determining
whether to synchronize a data
item by consulting a set of one

Certain computer-executable instructions (which may be part
of, but not limited to, the Android operating system) on each
Accused Device are for determining whether to synchronize
a data item (e.g., email, calendar data and contact

138

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or more flexible selection
rules, the set of one or more
flexible rules taking into
consideration value, from
having access to synchronized
data, relative to at least one of
(i) an economic cost for
synchronization using each
available synchronization
mechanism, (ii) network
security for each available
synchronization mechanism,
(iii) security of the second
computer system, or (iv) value
of data being synchronized,
and thereby also determining
an available synchronization
mechanism appropriate for the
data item given the one or
more flexible selection rules;
and

Accused Devices
information) by consulting a set of one or more flexible
selection rules.

For example, each Accused Device consults a flexible
selection rule to determine whether to synchronize an email
message based on the age of the email. See Screenshots
55.1-55.3.

Screenshot 55.1: a flexible rule dictates that only emails
from the past month should be synchronized

139

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('214 Patent)

Accused Devices

Screenshot 55.2: the second data store contains 7 emails, but
only 3 are from the past month

Screenshot 55.3: only the 3 emails from the past month are
synchronized to each Accused Device's first data store

Various synchronization mechanisms may be available to
use for synchronization by each Accused Device. Such
synchronization mechanisms can include wireless and

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('214 Patent)

Accused Devices
hardwired communication connections.

Wireless communication connections for synchronization
can be, for example, 3G, Wi-Fi, and Bluetooth connections.
See, e.g., DROID 2 User Guide at 10:

The hardwired communication connection can be, for
example, a USB connection. See, e.g., DROID 2 User Guide
at 48:

Other synchronization mechanisms can be “push” or “fetch.”
For the former, the second computer system (for example, an
email or calendar server, e.g., Microsoft Exchange Server,
Gmail server, or Google calendar server) can “push” a data
item (e.g., email, calendar data and contact information) to
each Accused Device. For the latter, each Accused Device
fetches a data item from the second computer system.

Another synchronization mechanism can be a Virtual Private
Network (VPN). See, e.g., Add a Virtual Private Network –

141

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('214 Patent)

Accused Devices
Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

The set of one or more flexible rules takes into consideration
value, from having access to synchronized data (e.g., email,
calendar data and contact information), relative to at least
one of (i) an economic cost for synchronization using each
available synchronization mechanism (e.g., wireless 3G or
Wi-Fi; hardwired USB; fetch or pull synchronization), (ii)
network security for each available synchronization
mechanism, (iii) security of the second computer system (for
example, an email or calendar server, e.g., Microsoft
Exchange Server, Gmail server, or Google calendar server),
or (iv) value of data being synchronized and thereby
selecting an available synchronization mechanism
appropriate for the data item given the one or more flexible
selection rules.

For example, each Accused Device can fetch data on a predetermined schedule, or the second computer system can
automatically push data to each Accused Device. This is a
flexible choice that takes into account at least the value of
the data.

142

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('214 Patent)

Accused Devices

As another example, each Accused Device can be flexibly
configured to synchronize social applications only via a WiFi mechanism, while email is set to be synchronized via
"push" synchronization. Such flexible rule takes into
account at least the value of the data and cost of
synchronizing using the various synchronization
mechanisms.

See, e.g., Gmail Synchronization – Motorola Droid 2,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31337 (visited Feb. 16, 2011):

As yet another example, each Accused Device can be
flexibly configured to use a secure connection when
synchronizing email. This flexible rule takes into account
the security of the synchronization mechanism.

See, e.g., Configure Corporate Email (Exchange
ActiveSync) – Motorola DROID X MB810,

143

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('214 Patent)

Accused Devices
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34193 (visited Feb. 16, 2011):

As another example, each Accused Device can be flexibly
configured to use a Virtual Private Network (VPN).
Choosing to use a Virtual Private Network for
synchronization is a rule that considers the security of the
synchronization mechanism.
See, e.g., Add a Virtual Private Network – Motorola DROID
X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34245 (visited Feb. 23, 2011):

144

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('214 Patent)

Accused Devices

As still another example, each Accused Device can be
flexibly configured to choose between a Wi-Fi mechanism
and a 3G mechanism when synchronizing data. Each
Accused Device uses a 3G mechanism until it is flexibly
authorized to use a particular Wi-Fi mechanism. This rule
considers the network security of unauthorized Wi-Fi
mechanisms. Once one or more available Wi-Fi
mechanisms have been authorized, each Accused Device
prefers user-authorized Wi-Fi mechanisms to a 3G
mechanism. This rule considers the economic cost due to
the fact that using a Wi-Fi mechanism is less likely lead to
additional user fees.
See, e.g., DROID 2 User Guide at 35-36:

See also DROID 2 User Guide at 46:

Each Accused Device can be flexibly configured to remove a

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particular Wi-Fi mechanism from the list of authorized WiFi mechanisms, and each Accused Device will thereafter
prefer a 3G mechanism to the de-authorized Wi-Fi
mechanism. This can be done by selecting "Forget network"
from the "Manage Networks" settings screen.
See, e.g., Remove WiFi Connection – Motorola Droid 2
(A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=34876 (visited Feb. 16, 2011):

Alternatively, each Accused Device can flexibly override the
preference for all user-authorized Wi-Fi mechanisms by
clearing the "Wi-Fi" checkbox on the "Wireless and network
settings" screen. This will result in each Accused Device
preferring a 3G mechanism to all Wi-Fi mechanisms,
including user-authorized Wi-Fi mechanisms.
See, e.g., WiFi On/Off – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31315 (visited Feb. 16, 2011):

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As another example, each Accused Device can be flexibly
configured to allow "roaming," or alternatively to allow
synchronizations only using the "home" carrier's
synchronization mechanisms. This flexible rule considers
the cost of synchronizing using the various synchronization
mechanisms.

See, e.g., Data Roaming – Motorola DROID X MB810,
http://support.vzw.com/clc/devices/knowledge_base.html?id
=33954 (visited Feb. 23, 2011):

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See also System Select – Motorola Droid 2 (A955),
http://support.vzw.com/clc/devices/knowledge_base.html?id
=31420 (visited Feb. 23, 2011):

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computer-executable
instructions for synchronizing
the data item with the second
computer if the first computer
system determines that the
data item is to be
synchronized based on the one
or more flexible selection
rules and each available
synchronization mechanism,
including one or more
hardwired or wireless
communication connections.

Certain computer-executable instructions (which may be part
of, but not limited to, the Android operating system) on each
Accused Device are for synchronizing the data item (e.g.,
email, calendar data and contact information) with the
second computer (for example, an email or calendar server,
e.g., Microsoft Exchange Server, Gmail server, or Google
calendar server) if the first computer system (e.g., Accused
Device) determines that the data item is to be synchronized
based on the one or more flexible selection rules and each
available synchronization mechanism, including one or more
hardwired or wireless communication connections.
The wireless communication connections for
synchronization can be, for example, 3G, Wi-Fi, and
Bluetooth connections. See, e.g., DROID 2 User Guide at
10:

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The hardwired communication connection can be, for
example, a USB connection. See, e.g., DROID 2 User Guide
at 48:

The Android operating system on the Motorola Android
synchronizes the data item with the second computer if each
Accused Device determines that the data item is to be
synchronized. See, e.g., Screenshot 55.4; Screenshot 55.5,
which show a successful synchronization using first a Wi-Fi
synchronization mechanism and then a 3G synchronization
mechanism.

Screenshot 55.4: synchronization taking place using a Wi-Fi

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synchronization mechanism

Screenshot 55.5: synchronization taking place using a 3G
synchronization mechanism
56. A computer program
product in accordance with
claim 55, wherein the one or
more computer-readable
media comprise physical
storage media.

The computer-readable media in each Accused Device
comprise physical storage media, which can be on-board
memory (e.g., 8 GB in DROID 2 and DROID X), SD
memory (e.g., 8 GB in DROID 2, or 2 GB in DROID X),
SIM card, and/or other memory (e.g., removable memory).

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