Personal Audio, LLC v. Samsung Electronics Co., Ltd. et al

Filing 1

COMPLAINT against All Defendants ( Filing fee $ 350 receipt number 0540-3217134.), filed by Personal Audio, LLC. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13)(Goehringer, Charles)

EXHIBIT 13

Exhibit 13
Personal Audio Exemplary Infringement Contentions for U.S. Patent No. 6,199,076
LG Revolution
Claim1
1

A player for reproducing
selected audio program
segments comprising, in
combination:

Exemplary Infringement Support
The LG Revolution smart phone has a music player application, making it a player for
reproducing selected audio program segments. A song is an example of an audio program
segment.

LG Revolution User Guide at 13

1

Claims are construed in view of the claim construction orders issued in the Personal Audio LLC v. Apple Inc. action, Civil Action No. 9:09CV111, dated
December 21, 2010 (ECF No. 258), January 31, 2011 (ECF No. 292), and May 18, 2011 (ECF No. 358).

LG Revolution User Guide at 151

LG Revolution User Guide at 154

LG Revolution User Guide at 151.
1.a

2

means for storing a plurality of
program segments, each of said
program segments having a
beginning and an end,

The Revolution has a means for storing a plurality of program segments, each of said program
segments having a beginning and an end. This limitation is governed by 35 U.S.C. § 112, para.
6. The Revolution literally performs the identical function with identical, or at least equivalent,
structure.

The “storing” structure in the Revolution is internal memory replaceable media. The
replaceable media is a microSD card. A microSD card is sold with the Revolution and comes
in the box.
The Revolution stores audio files on the microSD card.

LG Revolution User Guide at 149.

LG Revolution User Guide at 219.

1.b

means for receiving and storing
a file of data establishing a
sequence in which said program
segments are scheduled to be
reproduced by said player,

The Revolution has a means for receiving and storing a file of data establishing a sequence in
which said program segments are scheduled to be reproduced by the player. This limitation is
governed by 35 U.S.C. § 112, para. 6. The Revolution literally performs the identical function
with identical and equivalent structure.
The “receiving” structure in the Revolution is the micro USB port on the side of the device.
The structure is equivalent to the construed IR structure.

3

LG Revolution User Guide at 15.
The “storing” structure in the Revolution is internal memory and replaceable media. The
replacable media is a microSD card. A microSD card is sold with the Revolution and comes in
the box.

LG Revolution User Guide at 149.
The file of data establishing a sequence in which the program segments are scheduled to be
reproduced by the Revolution is the playlist file.

4

1.c

means for accepting control
commands from a user of said
player,

The Revolution has a means for accepting control commands from a user of said player. This
limitation is governed by 35 U.S.C. § 112, para. 6. The Revolution literally performs the
identical function with equivalent structure.
The “accepting” structure on the Revolution is the touch screen.

LG Revolution User Guide at 14.

LG Revolution User Guide at 152.
1.d

5

means for continuously
reproducing said program

The Revolution has a means for continuously reproducing said program segments in the order
establish by said sequence in the absence of a control command. This limitation is governed by

segments in the order
established by said sequence in
the absence of a control
command,

35 U.S.C. § 112, para. 6. The Revolution performs the identical function using equivalent
structure.
The “continuously reproducing” structure in the Revolution comprises hardware and software
components programmed to continuously reproduce program segments in the absence of a
control command.
Hardware components are the Revolution’s general purpose computer circuitry (processor,
RAM, power supply, and bus), audio codec, and speaker.

LG Revolution Data Sheet at 2.

LG Revolution Data sheet at 2.

6

LG Revolution User Guide at 16
The Revolution has an audio codec as show by the Revolution’s capability to play digitally
compressed audio files.

7

LG Revolution Data sheet at 2.

LG Revolution User Guide at 151
Once a user has started listening to a playlist on the Revolution, the device automatically plays
the audio file next in the playlist sequence after the previous audio file ends. The Revolution
reproduces the audio file in the order established by the playlist without the need for the user to
entering a control command. Once a playlist has been selected, no further control command is
required for continuously reproducing said program segments in the order establish by said
playlist sequence.
The Revolution can be set to play songs in order and repeat songs.

8

LG Revolution User Guide at 152.
1.e

means for detecting a first
command indicative of a
request to skip forward, and

The Revolution has a means for detecting a first command indicative of a request to skip
forward. This limitation is governed by 35 U.S.C. § 112, para. 6. The Revolution performs the
identical function using identical, or at least equivalent, structure.
The “detecting” structure in the Revolution comprises hardware and software components
programmed to detect a first command indicative of a request to skip forward.
The hardware component is the general purpose computer circuitry, identified in row 1.d
above.
Once a user presses the “next” key the Revolution responds to the selected command by
discontinuing playback of the current audio file and begins playing the next audio file in the
playlist. This operation shows there is software that detects the skip forward command.

LG Revolution User Guide at 152.

9

1.f

means responsive to said first
command for discontinuing the
reproduction of the currently
playing program segment and
instead continuing the
reproduction at the beginning of
a program segment which
follows said currently playing
program in said sequence.

The Revolution has a means responsive to said first command for discontinuing the
reproduction of the currently playing program segment and instead continuing the reproduction
at the beginning of a program segment which follows said currently playing program in said
sequence. This limitation is governed by 35 U.S.C. § 112, para. 6. The Revolution performs the
identical function using identical, or at least equivalent, structure.
The “responsive” structure in the Revolution comprises hardware and software components
programmed to detect a first command indicative of a request to skip forward.
The hardware component is the general purpose computer circuitry, identified in row 1.d
above.
Once a user presses the “next” key the Revolution discontinues playing the current audio file
and skips ahead and begins playing the next audio file in the playlist.

10

LG Revolution User Guide at 152.
2

A player as set forth in claim 1
further comprising

Every claim limitation of claim 1 is present in the Revolution as described above.

2a

means for detecting a second
command indicative of a
request to skip backward, and

The Revolution has a means for detecting a second command indicative of a request to skip
backward. This limitation is governed by 35 U.S.C. § 112, para. 6. The Revolution performs
the identical function using identical, or at least equivalent, structure.
The “detecting” structure in the Revolution comprises hardware and software components
programmed to detect a second command indicative of a request to skip backward.
The hardware component is the general purpose computer circuitry, identified in row 1.d
above.
Once a user presses the “previous” key the Revolution responds to the selected command by
discontinuing playback of the current audio file and begins playing the same audio file in the
playlist at its beginning. This operation shows there is software that detects the skip backward
command.

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LG Revolution User Guide at 152
2.b

means responsive to a single
one of said second commands
for discontinuing the
reproduction of the currently
playing program segment and
instead continuing the
reproduction at the beginning of
said currently playing program

The Revolution has a means responsive to a single one of said second commands for
discontinuing the reproduction of the currently playing program segment and instead
continuing the reproduction at the beginning of the currently playing program. This limitation
is governed by 35 U.S.C. § 112, para. 6. The Revolution performs the identical function using
identical, or at least equivalent, structure.
The “responsive” structure in the Revolution comprises hardware and software components
programmed to detect a first command indicative of a request to skip forward.
The hardware component is the general purpose computer circuitry, identified in row 1.d
above.
Once a user presses the “previous” key the Revolution discontinues playing the current audio

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file and begins playing the current audio file from the beginning.

LG Revolution User Guide at 152.
3

A player as set forth in claim 2
further comprising

Every claim limitation of claim 2 is present in the Revolution as described above.

3a

means responsive to the
detection of two consecutive
ones of said second commands
for discontinuing the
reproduction of the currently
playing program segment and
instead continuing the
reproduction at the beginning of
a program segment which

The Revolution has a means responsive to the detection of two consecutive ones of said second
commands for discontinuing the reproduction of the currently playing program segment and
instead continuing the reproduction at the beginning of a program segment which precedes the
currently playing program. This limitation is governed by 35 U.S.C. § 112, para. 6. The
Revolution performs the identical function using identical, or at least equivalent, structure.

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The “responsive” structure in the Revolution comprises hardware and software components
programmed to detect a first command indicative of a request to skip forward.

precedes the currently playing
program segment.

The hardware component is the general purpose computer circuitry, identified in row 1.d
above.
Once a user presses the “previous” key twice the Revolution discontinues playing the current
audio file and begins playing the previous audio file in the playlist.

LG Revolution User Guide at 152.
4

A player as set forth in claim 1

Every claim limitation of claim 1 is present in the Revolution as described above.

4.a

wherein said sequence
established circular sequence of
program segments

In the Revolution the sequence established by said data forms an endless circular sequence of
audio files.
Once a user selects Repeat All mode the playlist plays in an endless circular sequence.

14

LG Revolution User Guide at 152.
82449974.4

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