Vertical Computer Systems, Inc. v. Interwoven, Inc. et al
Filing
87
RESPONSE in Opposition re 84 SEALED MOTION to Sever and Transfer Claims filed by Vertical Computer Systems Inc. (Attachments: # 1 Exhibit Declaration of Luiz Claudio Valdetaro (signed), # 2 Exhibit A - Google Information on LG Electronics, # 3 Exhibit B - Complaint (Vertical Computer Systems, Inc. v. Interwoven, Inc., et al; Civil Action No. 210-cv-490), # 4 Exhibit C - Samsung's Claim Charts, # 5 Exhibit D - LG's Claim Charts, # 6 Exhibit E - U.S. Court of Appeals for the Federal Circuit - Brief of Petitioner - Vertical Computer Systems, Inc, # 7 Exhibit F - U.S. Court of Appeals for the Federal Circuit - Petition on Writ of Mandamus Order, # 8 Exhibit G - U.S. District Court for the Northern District of California - Claims Construction Order, # 9 Exhibit H - Declaration of Seo Won Kwon, # 10 Exhibit I - LexisNexis Documents, # 11 Exhibit J - LexisNexis Documents, # 12 Text of Proposed Order)(Davis, William)
EXHIBIT D
Infringement of United States Patent number 7,726,629 by
LG’s Android‐Powered Smartphones
FIGURE 1 (LG.COM Website)
1
Infringement of United States Patent number 7,726,629 by
LG’s Android‐Powered Smartphones
LG’s Infringing Android‐Powered Smartphones
LG Ally/Apex/Axis
LG DoublePlay
LG Enlighten/Optimus Slider
LG Esteem
LG G2x/Optimus 2x
LG Genesis
LG Marquee
LG my Touch Q
LG my Touch
LG Optimus M/Optimus C
LG Optimus S/Optimus U/
Optimus V
LG Optimus T
LG Revolution
LG Thrill 4 G/Optimus 3D
LG Thrive Phoenix
LG Vortex
2
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
The LG Android‐Powered Smartphones infringe claims of U.S. Patent
number 7,716,629 because they include "A system for generating a
computer application on a host system in an arbitrary object
framework that separates a content of said computer application,
a form of said computer application, and a functionality of said
computer application." LG imports these Smartphones into the
United States.
A user of the LG Android‐Powered Smartphones can generate a
computer application within the Android framework on the LG
Android‐Powered Smartphones themselves by using text editors or
other text manipulation techniques provided on the Smartphone.
After compiling the application, the executable can be put back on
the Smartphone and run.
3
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
INFRINGEMENT BY THE ANDROID FRAMEWORK
The book “Professional Android 2 Application Development”, ISBN
978‐0‐470‐5656552‐0 written by Reto Meier will be used to explain
the infringement. "Reto Meier is a software developer who has
been involved in Android since its initial release in 2007. He is an
Android Developer Advocate at Google”. This book will be referred
to henceforth as the “Meier Book”.
4
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
GENERATION OF AN ANDROID APPLICATION ON THE
SMARTPHONE
The Android Framework includes the Linux Operating System. As per
the Meier Book, Page 14, in the lowermost block, it shows that the
Linux is the lowest part of the Android Framework:
The Linux Portion of the Android Framework includes built‐in
command line commands such as CAT, VI, CP, MV and RM. (Cat Can
create text files, VI can modify them, CP, MV and RM can Copy ,
Move, Rename and Delete files).
5
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
In The Meier Book, Page 19, 4th paragraph, it shows that to create
Android Applications , all that its needed is a Text Editor, or anything
that can create text files:
Using the Linux Portion of the Android Framework which includes
built‐in command line commands such as CAT, VI, CP, MV and RM,
One can Create Arbitrary Objects, Manage Arbitrary Objects and
Deploy these Arbitrary Objects.
6
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page xvii (more specifically 4th paragraph) and Page 4 (more
specifically 7th bullet) essentially describes what is known in the industry as
a framework.
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
7
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page xvii (more specifically 4th paragraph) and Page 4 (more
specifically 7th bullet) essentially describes what is known in the industry as
a framework.
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
8
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page 28 explains how the UI (Form) "decouples" the
application logic (function) from your UI design (form) on its first paragraph.
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
9
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page 209 defines how the "Content Providers" "decouples"
data storage (content) from your application logic (function) on its third
paragraph.
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
10
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
Android’s objects can be arbitrary objects. We created a sample application
using the Android Software Developers’ Kit (Android SDK). In the following
example:
The Arbitrary Object “textview” is being called by its name
(android:id="@+id/textview"), and additionally has three parameters.
When compiling and running the application, the compilation completes,
and the application runs fine (it prints “Alo mundo,Hello Android!”) on the
Android device as seen in here:
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
11
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
However, when we modify the call to “textview” to include just the name of
the Arbitrary Object, the call looks this way:
When making the above modification, the program compiles and the
application runs normally, as can be seen on this screen print (We will refer
to this later as “Sample Application”)
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
12
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
The creation of those Arbitrary objects can be using command line
tools, such as a text editor, or using the recommended tool , Eclipse.
Using a text editor is more work because all of the files needed to
create the object must be edited correctly and placed on the correct
location (folders), in order for the compiler to work. Using Eclipse
facilitates the process
The steps for generating a Computer application on the Android
Framework when not using Eclipse are:
‐Creation of the application either by manually creating each source
file with a text editor
‐Compiling of the application using a Java Compiler
‐Creating a “package” (A file which’s extension is .APK”, using the
Android SDK named apkbuilder.bat , which is distributed with the
Android SDK.
‐Moving that package file to the Android device, either by using
Google’s “Android Market” application (in the case of a
SmartPhone), or using the builtin android application named “File
Manager”, clicking on the file, and Android will then install it on the
device.
When using eclipse, all is necessary is to click on the “Run” menu –
that is what was done on the application described earlier.
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
13
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
The content can be generated by the “Content Provider” feature of
Android. Meier Book, Pages 209‐211 is a description of how it works.
The title of the chapter, and throughout the whole text, it clarifies
that the Android Framework can be used for generating the content:
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
14
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
Form in the Android Framework normally is defined on the Resource
folder, referred to as “R” or “Layouts”, having the default
“layout.xml” as the Form, but this name can be changed. On Meier
Book, Page 63 and 64 describes how they work. More specifically ,
the last three paragraphs of Page 63 define Layouts as your
“Presentation Layer” and “User Interface”, which is Form.
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
15
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
Also on Meier Book, Page 50, it describes “Activities” as
Presentation Layer (which can be Form) of Android Applications.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
16
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
Meier Book, Page 50, second bullet, describes “Services” as “The
invisible workers of the application”, (Which is Functionality):
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
17
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
The object library, when using eclipse is described as the
“Workspace” of the Android Applications. If not using Eclipse, the
management of these objects can be done manually by using normal
command‐line commands , such as “Copy”, “Rename” , “Delete” or
“Move”, inside of a folder structure which is mandated by the
Android SDK so the Computer Application can be built properly.
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
18
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 1.
A system for generating a computer application on a host
system in an arbitrary object framework that separates a
content of said computer application, a form of said
computer application, and a functionality of said computer
application, said system including a computer comprising a
processor and a memory operably coupled to said processor,
said memory being configured for storing a computer
program executable by said processor, said computer
program comprising:
These Arbitrary objects are deployed by building the complete
application as described earlier then moving that package file to the
Android device, either by using Google’s “Android Market”
application (in the case of a SmartPhone), or using the builtin
android application named “File Manager”, clicking on the file, and
Android will then install it on the device.
The Meier Book, page XVII, on its 5th Paragraph, describes that the
Android Market can be used for distribution, or Deployment:
a first set of executable instructions for creating arbitrary
objects with corresponding arbitrary names of content
objects used in generating said content of said computer
application, form objects used in defining said form of said
computer application, and function objects used in executing
said functionality of said computer application each arbitrary
object being separate from each other arbitrary object;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a
design framework to create said computer application.
19
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 4.
The system of claim 1, wherein the third set of
executable instructions are for deploying arbitrary
objects locally.
The Computer Application demonstrated on Claim 1, Element 1,
makes use of arbitrary objects locally.
Bellow Picture, shows in the arbitrary object named textview being
accessed locally within the mobile device.
20
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 8.
The system of claim 1, wherein the third set of
executable instructions include instructions to
access and deploy arbitrary objects into said
design framework using said corresponding
arbitrary names.
The Android Framework enables access and deployment of said
arbitrary names into said design framework. Bellow picture shows
the deployment of said arbitrary objects (the arbitrary object named
“textview”) accessed and deployed into said design framework with
the said arbitrary names (textview):
21
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 10.
The system of claim 1, further comprising
executable instructions for caching objects.
The Android Framework caches objects. In this picture showing the
Android terminal emulation application, the response to the
command “ls” shows a subdirectory named “cache”:
22
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 12.
The system of claim 1, further comprising
executable instructions for generating arbitrary
objects in a programming language that is
compatible and supported by said host system.
The Android Framework allows such arbitrary objects to be
developed in Java, which is a programming language supported by
the host system. This can be shown in “Meyer Book”, page 28
(below), the program named “LISTING 2‐3”, written in Java:
23
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page xvii (more specifically 4th paragraph) and Page 4 (more
specifically 7th bullet) essentially describes what is known in the industry as
a framework.
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
24
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page xvii (more specifically 4th paragraph) and Page 4 (more
specifically 7th bullet) essentially describes what is known in the industry as
a framework.
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
25
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page 28 explains how the UI (Form) "decouples" the
application logic (function) from your UI design (form) on its first paragraph.
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
26
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page 209 defines how the "Content Providers" "decouples"
data storage (content) from your application logic (function) on its third
paragraph.
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
27
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
Android’s objects can be arbitrary objects. We created a sample application
using the Android Software Developers’ Kit (Android SDK). In the following
example:
The Arbitrary Object “textview” is being called by its name
(android:id="@+id/textview"), and additionally has three parameters.
When compiling and running the application, the compilation completes,
and the application runs fine (it prints “Alo mundo,Hello Android!”) on the
Android device as seen in here:
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
28
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
However, when we modify the call to “textview” to include just the name of
the Arbitrary Object, the call looks this way:
When making the above modification, the program compiles and the
application runs normally, as can be seen on this screen print (We will refer
to this later as “Sample Application”)
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
29
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
The creation of those Arbitrary objects can be using command line tools,
such as a text editor, or using the recommended tool , Eclipse. Using a text
editor is a more work because all of the files needed to create the object
need to be edited correctly and placed on the correct location (folders), in
order for the compiler to work. Using Eclipse facilitates the process
The steps for generating a Computer application on the Android Framework
when not using Eclipse are:
‐Creation of the application either by manually creating each source file
with a text editor
‐Compiling of the application using a Java Compiler
‐Creating a “package” (A file which’s extension is .APK”, using the Android
SDK named apkbuilder.bat , which is distributed with the Android SDK.
‐Moving that package file to the Android device, either by using Google’s
“Android Market” application (in the case of a SmartPhone), or using the
buil tin android application named “File Manager”, clicking on the file, and
Android will then install it on the device.
When using eclipse, all is necessary is to click on the “Run” menu – that is
what was done on the application described earlier.
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
30
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
The content can be generated by the “Content Provider” feature of Android.
Meier Book, Pages 209‐211 is a description of how it works. The title of the
chapter, and throughout the whole text, it clarifies that the Android
Framework can be used for generating the content:
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
31
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
Form in the Android Framework normally is defined on the Resource
folder, referred to as “R” or “Layouts”, having the default
“layout.xml” as the Form, but this name can be changed. On Meier
Book, Page 63 and 64 describes how they work. More specifically ,
the last three paragraphs of Page 63 define Layouts as your
“Presentation Layer” and “User Interface”, which is Form.
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
32
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
Also on Meier Book, Page 50, it describes “Activities” as
Presentation Layer (which can be Form) of Android Applications.
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
33
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
Meier Book, Page 50, second bullet, describes “Services” as “The
invisible workers of the application”, (Which is Functionality):
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
34
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
The Sample Application demonstrated in Claim 21, Element 1, calls
the arbitrary object by name only.
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
35
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
In the Meier Book, there are many references of “decoupling” form from
content, and from form, as a way of showing how these objects can be
independently modified without changes to the other arbitrary objects. The
Meier book, on page 209, defines how the “Content Providers” decouples
data storage from your application logic on its third paragraph:
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
36
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
The Meier Book, Page 63, under the headline named “Layouts”,
defines how layouts decouple your user interface from your code:
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
37
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 21.
A system for generating a computer application on a host system
in an arbitrary object framework that separates a content of said
computer application, a form of said computer application, and a
functionality of said computer application, said system including
a computer comprising a processor and a memory operably
coupled to said processor, said memory being configured for
storing a computer program executable by said processor, said
computer program comprising:
Again in the Meier Book, Page 63 in the last paragraph it explains
how these arbitrary objects are interchangeable, for the benefit of
having the application support Android devices of varying screen
sizes, keyboards and such:
a first set of executable instructions for creating arbitrary objects
with corresponding arbitrary names of content objects used in
generating said content of said computer application, form
objects used in defining said form of said computer application,
and function objects used in executing said functionality of said
computer application, each arbitrary object being callable by
name only, each arbitrary object being independently modifiable
without corresponding modifications being made to any other
arbitrary object, and each arbitrary object further being
interchangable with other arbitrary objects;
a second set of executable instructions for managing said
arbitrary objects in an arbitrary object library;
and a third set of executable instructions for deploying said
arbitrary objects from said arbitrary object library into a design
framework to create said computer application.
38
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 24.
The system of claim 21, wherein the third set of
executable instructions are for deploying arbitrary
objects locally.
The Computer Application demonstrated on Claim 1, Element 1,
makes use of arbitrary objects locally.
Below Picture, shows in the arbitrary object named textview being
accessed locally within the mobile device.
39
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 28.
The system of claim 21, wherein the third set of
exectable instructions include instructions to
access and deploy arbitrary objects into said
design framework using said corresponding
arbitrary names.
The Android Framework enables access and deployment of said
arbitrary names into said design framework. Bellow picture shows
the deployment of said arbitrary objects (the arbitrary object named
“textview”) accessed and deployed into said design framework with
the said arbitrary names (textview):
40
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 30.
The system of claim 21, further comprising
executable instructions for caching objects.
The Android Framework caches objects. In this picture showing the
Android terminal emulation application, the response to the
command “ls” shows a subdirectory named “cache”:
41
Infringement of United States Patent number 7,726,629 by LG’s
Android‐Powered Smartphones
Claim 32.
The system of claim 21, further comprising
executable instructions for generating arbitrary
objects in a programming language that is
compatible and supported by said host system.
The Android Framework allows such arbitrary objects to be
developed in Java, which is a programming language supported by
the host system. This can be shown in “Meyer Book”, page 28
(bellow), the program named “LISTING 2‐3”, written in Java:
42
Infringement of United States Patent number 6,826,744 by
LG’s Android‐Powered Smartphones
FIGURE 1 (LG.COM Website)
1
Infringement of United States Patent number 6,826,744 by LG’s
Android‐Powered Smartphones
LG’s Infringing Android‐Powered Smartphones
LG Ally/Apex/Axis
LG DoublePlay
LG Enlighten/Optimus Slider
LG Esteem
LG G2x/Optimus 2x
LG Genesis
LG Marquee
LG my Touch Q
LG my Touch
LG Optimus M/Optimus C
LG Optimus S/Optimus U/
Optimus V
LG Optimus T
LG Revolution
LG Thrill 4 G/Optimus 3D
LG Thrive Phoenix
LG Vortex
2
Infringement of United States Patent number 6,826,744 by LG’s
Android‐Powered Smartphones
LG STANDARD APPLICATIONS INFRINGE
The LG Android‐Powered Smartphones infringe claims of U.S. Patent
number 6,826,744 because Android Framework standard
applications are installed into these phones by LG during the
manufacturing process (many of which are non‐removable). The
Smartphones are then imported into the United States containing
these non‐removable applications. These applications are
developed using: "A method for generating a computer application
on a host system in an arbitrary object framework that separates a
content of said computer application, a form of said computer
application and a functionality of said computer application."
The LG Android‐Powered Smartphones include the following
standard Android apps:
‐Dialer
‐SMS
‐Email
‐Gmail
‐Google Maps
‐Navigation
‐Internet Browser
‐You Tube Video Player
‐Contacts
‐Calendar
‐Phones
‐Camera
‐Market
‐Alarm Clock
‐Calculator
‐Music Player
These standard applications, many of which are non‐removable,
form the heart of the Smartphones. Without them, the phones
would not operate and could not be sold in the U.S.
3
Infringement of United States Patent number 6,826,744 by LG’s
Android‐Powered Smartphones
INFRINGEMENT BY THE ANDROID FRAMEWORK
The book “Professional Android 2 Application Development”, ISBN
978‐0‐470‐5656552‐0 written by Reto Meier will be used to explain
the infringement. "Reto Meier is a software developer who has
been involved in Android since its initial release in 2007. He is an
Android Developer Advocate at Google”. This book will be referred
to henceforth as the “Meier Book”.
4
Infringement of United States Patent number 6,826,744 by LG’s
Android‐Powered Smartphones
Claim 1.
A method for generating a computer application
on a host system in an arbitrary object framework
that separates a content of said computer
application, a form of said computer application
and a functionality of said computer application,
said method comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page xvii (more specifically 4th paragraph) and (more
specifically 7th bullet) essentially describes what is known in Page 4 the
industry as a framework.
creating arbitrary objects with corresponding
arbitrary names of various object types for
generating said content of said computer
application, said form of said computer
application, and said functionality of said
computer application;
managing said arbitrary objects in an object
library;
and deploying said arbitrary objects from said
object library into a design framework to create
said computer application.
5
Infringement of United States Patent number 6,826,744 by LG’s
Android‐Powered Smartphones
Claim 1.
A method for generating a computer application
on a host system in an arbitrary object framework
that separates a content of said computer
application, a form of said computer application
and a functionality of said computer application,
said method comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page xvii (more specifically 4th paragraph) and Page 4 (more
specifically 7th bullet) essentially describes what is known in the industry as
a framework.
creating arbitrary objects with corresponding
arbitrary names of various object types for
generating said content of said computer
application, said form of said computer
application, and said functionality of said
computer application;
managing said arbitrary objects in an object
library;
and deploying said arbitrary objects from said
object library into a design framework to create
said computer application.
6
Infringement of United States Patent number 6,826,744 by LG’s
Android‐Powered Smartphones
Claim 1.
A method for generating a computer application
on a host system in an arbitrary object framework
that separates a content of said computer
application, a form of said computer application
and a functionality of said computer application,
said method comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page 28 explains how the UI (Form) "decouples" the
application logic (function) from your UI design (form) on its first paragraph.
creating arbitrary objects with corresponding
arbitrary names of various object types for
generating said content of said computer
application, said form of said computer
application, and said functionality of said
computer application;
managing said arbitrary objects in an object
library;
and deploying said arbitrary objects from said
object library into a design framework to create
said computer application.
7
Infringement of United States Patent number 6,826,744 by LG’s
Android‐Powered Smartphones
Claim 1.
A method for generating a computer application
on a host system in an arbitrary object framework
that separates a content of said computer
application, a form of said computer application
and a functionality of said computer application,
said method comprising:
Android is a framework of arbitrary objects which separates form, function
and content of a computer application, which runs on a host, either a smart
phone, a tablet PC or even a virtual machine on a PC.
Meier Book, Page 209 defines how the "Content Providers" "decouples"
data storage (content) from your application logic (function) on its third
paragraph.
creating arbitrary objects with corresponding
arbitrary names of various object types for
generating said content of said computer
application, said form of said computer
application, and said functionality of said
computer application;
managing said arbitrary objects in an object
library;
and deploying said arbitrary objects from said
object library into a design framework to create
said computer application.
8
Infringement of United States Patent number 6,826,744 by LG’s
Android‐Powered Smartphones
Claim 1.
A method for generating a computer application
on a host system in an arbitrary object framework
that separates a content of said computer
application, a form of said computer application
and a functionality of said computer application,
said method comprising:
creating arbitrary objects with corresponding
arbitrary names of various object types for
generating said content of said computer
application, said form of said computer
application, and said functionality of said
computer application;
Android’s objects are arbitrary objects. We created a sample application
using the Android Software Developers’ Kit (Android SDK). In the following
example:
The Arbitrary Object “textview” is being called by its name
(android:id="@+id/textview"), and additionally has three parameters.
When compiling and running the application, the compilation completes,
and the application runs fine (it prints “Alo mundo,Hello Android!”) on the
Android device as seen in here:
managing said arbitrary objects in an object
library;
and deploying said arbitrary objects from said
object library into a design framework to create
said computer application.
9
Infringement of United States Patent number 6,826,744 by LG’s
Android‐Powered Smartphones
Claim 1.
However, when we modify the call to “textview” to include just the name of
the Arbitrary Object, the call looks this way:
A method for generating a computer application
on a host system in an arbitrary object framework
that separates a content of said computer
application, a form of said computer application
and a functionality of said computer application,
said method comprising:
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