IP Innovation LLC et al v. Google, Inc.

Filing 1

COMPLAINT for Patent Infringement against Google, Inc. ( Filing fee $ 350 receipt number 1335423.), filed by IP Innovation LLC, Technology Licensing Corporation. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Civil Cover Sheet # 6)(Ward, Thomas)

EXHIBIT C

Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT 1. A method of operating a system that includes a display, a user input device, and a processor connected for receiving signals from the user input device and for presenting images on the display;
The set of signals provided by user input means can therefore include data indicating mouse operation and data indicating keyboard operation. (col. 5, ll. 60-62).

Google Earth is an example of a method of operating a system that includes a display, a user input device, and a processor connected for receiving signals from the user input device. Google Earth uses a display and a processor.

Source: http://earth.google.com/tour/thanks-win4.html Google Earth makes use of input devices such as a keyboard and mouse. As shown below, the user uses a keyboard to "type" "hollywood, ca" in the "Fly to" box and uses a mouse to "hit" the search button.

Source: Google Earth Version 4.1.7076.4458 (beta)

Source: http://earth.google.com/tour/ Page 1 of 14

Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT An example of images being presented on the display is the following screenshot of the Google Earth application as viewed on a standard monitor (display):

Source: Google Earth Version 4.1.7076.4458 (beta)

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Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT the user input device providing region indicating signals indicating regions within images presented and motion requesting signals requesting viewpoint motion; the method comprising steps of:
A signal from a user input An example of the user providing a region indicating signal is the user typing a location or point of device "indicates" a region of a interest (POI) into the "Fly to" box and using the mouse to hit the "Begin search" button.1 surface if the signal includes data from which the region can be identified. For example, if a signal includes data indicating a mouse pointer displacement, a system can find a point in the display plane based on the previous pointer position. This point can then be used to project a ray from the viewpoint into the three-dimensional workspace being presented, and the coordinates of display features can be used to find the nearest display feature intersected by the ray. The point or a set of points at the intersection can thus be identified as the region. (col. 6, ll. 67 ­ col. 7, ll. 10). Signals from user input means can request motion of the viewpoint and motion of the POI. If the user can request viewpoint and POI motion separately and can request both types of motion simultaneously, the user input means is structured so that the user can

Source: Google Earth Version 4.1.7076.4458 (beta)
1

Another example of a region indicating signal is the user using the mouse to double-click on a region or POI. In this example, the motion requesting signal would be the doubleclicking of the mouse since the image will pan in towards the region selected.

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Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT

request viewpoint motion and POI motion "independently." For example, the user can operate a mouse or other pointing device to request POI motion with one hand and can independently operate keys on a keyboard to request viewpoint motion with the other hand. (col. 8, ll. 5-14). "Viewpoint motion" or "viewpoint displacement" occurs when a sequence of images is presented that are perceptible as views of a threedimensional workspace from a moving or displaced viewpoint. This perception may result from perception of objects in the workspace as continuations. Viewpoint motion is "relative" to a point or other region of the image if the viewpoint is perceived as moving with respect to the point or other region. A "point of interest" or "POI" is a point indicated by the user and relative to which the viewpoint can move... (col. 7, ll. 41 ­ col. 8, ll. 4). ...an "object surface" or "surface" is a display feature that is perceptible as a surface of a display object; for example, the outer boundary of a threedimensional display object is a surface. A "region" on a surface is a bounded area of the surface; for example, a single point is the smallest possible region of any surface. A "shape" is a display object that has a distinguishable outline; for example, a circular display object is a shape. (col. 6, ll. 15-23).

An example of a motion requesting signal is the user using the zoom and tilt sliders and navigation compass.

Source: Google Earth Version 4.1.7076.4458 (beta)

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Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT

presenting a first image on the display;

The following image of Hollywood, CA is an example of a first image as seen on a standard monitor (display).

Source: Google Earth Version 4.1.7076.4458 (beta)

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Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT
A "display object" or "object" is The first image includes a first surface (i.e., the mountain range) which is shown in a three-dimensional a display feature that is perceptible as a coherent unity. workspace from a first viewpoint (direction is North, indicated by compass in the upper-right-hand side). An "object surface" or "surface" is a display feature that is perceptible as a surface of a display object; for example, the outer boundary of a threedimensional display object is a surface. A "region" on a surface is a bounded area of the surface; for example, a single point is the smallest possible region of any surface. A "shape" is a display object that has a distinguishable outline; for example, a circular display object is a shape. (col. 6, ll. 1423).

the first image including a first surface that is perceptible as viewed from a first viewpoint within a threedimensional workspace;

Source: Google Earth Version 4.1.7076.4458 (beta)

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Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT
In order to present a threeThe viewpoint coordinates along with the orientation and elevation are stored as a Placemark. dimensional workspace, a system may store data indicating "coordinates" of the position of an object, a viewpoint, or other display feature in the workspace. Data indicating coordinates of a display feature can then be used in presenting the display feature so that it is perceptible as positioned at the indicated coordinates. The "distance" between two display features is the perceptible distance between them, and can be determined from their coordinates if they are presented so that they appear to be positioned at their coordinates. (col. 6, ll. 56-66).

the step of presenting the first image comprising a substep of storing viewpoint coordinate data indicating a position of the first viewpoint in the threedimensional workspace;

Source: Google Earth Version 4.1.7076.4458 (beta)

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Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT

receiving a first region indicating signal and a first motion requesting signal from the user input device;

An example of a first region indicating signal is the user typing "griffith observatory" into the "Fly to" box and using the mouse to hit the "Begin search" button.

Source: Google Earth Version 4.1.7076.4458 (beta)

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Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT An example of a first motion requesting signal is the user using the zoom and tilt sliders and navigation compass to get a different view of Griffith Observatory.

Zooming In

Tilting Image

Using Compass

Source: Google Earth Version 4.1.7076.4458 (beta) Page 9 of 14

Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT the first region indicating signal indicating a first region on the first surface;
In response to a first signal An example of a first region on the first surface is Griffith Observatory shown on the mountain range. requesting viewpoint motion toward the POI, an image is presented showing object 50 from viewpoint 54, displaced from viewpoint 52 along the ray from viewpoint 52 through the POI. Viewpoint 54 can be displaced toward the POI by a distance that is a proportion of the distance from viewpoint 52 to the P01. Similarly, in response to second and third signals requesting further viewpoint motion toward the same POI, images can be presented from viewpoints 56 and 58, displaced along the ray toward the POI by the same proportion. Furthermore, in response to a fourth signal requesting viewpoint motion away from the POI, the viewpoint could be displaced from viewpoint 58 to viewpoint 56, retracing the path followed in approaching the POI. (Office Action, pg. 55).

Source: Google Earth Version 4.1.7076.4458 (beta)

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Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT the first motion requesting signal requesting viewpoint motion relative to the first region; An example that the motion requesting signal moves relative to the first region can be shown by zooming in and zooming out. In both cases, Griffith Observatory is centered in the field of view.

Source: Google Earth Version 4.1.7076.4458 (beta)

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Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT

and presenting a second image on the display;

Using the zoom and tilt sliders and navigation compass (shown previously) produces a second image.

Source: Google Earth Version 4.1.7076.4458 (beta)

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Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT the second image including a second surface that is perceptible as a continuation of the first surface viewed from a second viewpoint within the threedimensional workspace, A second display feature The second image includes a second surface (i.e., a portion of the mountain range) that the user precieves as a continuation of the first surface, as viewed from a second viewpoint (direction is Southwest, is perceptible as a indicated by compass in the upper-right-hand side). "continuation" of a first display feature when presentation of the second display feature follows presentation of the first display feature in such a way that the user perceives the first display Second feature as being continued Surface when the second display feature is presented. (col. 7, ll. 35-38).

Source: Google Earth Version 4.1.7076.4458 (beta)

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Claim Chart for US Patent 5276785 v Google Earth CONFIDENTIAL ­ SETTLEMENT DOCUMENT the second viewpoint being displaced from the position indicated by the stored viewpoint coordinate data relative to the first region on the first surface in accordance with the first motion requesting signal. The stored coordinate data of the first region on the first surface was Latitude: 34°6'56.76"N, Longitude: 118°20'18.26"W, Range: 9744m, Heading: 0. 000000°, Tilt: 27.000000° (as indicated with the Placemark shown previously). The second viewpoint is displaced from the first region in accordance with the first motion requesting signal with Latitude: 34° 7'7.01"N, Longitude: 118°16'20.41"W, Range: 740m, Heading: 62.000000° and Tilt: 44.000000°.

Source: Google Earth Version 4.1.7076.4458 (beta)

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