Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 634

MOTION FOR LEAVE TO SUPPLEMENT INFRINGEMENT CONTENTIONS FOR ANDROID 3.0 by Eolas Technologies Incorporated. (Attachments: # 1 Exhibit A.1, # 2 Exhibit A.2, # 3 Exhibit A.3, # 4 Exhibit A.4, # 5 Exhibit A.5, # 6 Exhibit A.6, # 7 Exhibit A.7, # 8 Exhibit A.8, # 9 Exhibit A.9, # 10 Exhibit A.10, # 11 Text of Proposed Order)(McKool, Mike)

EXHIBIT A.10

Claim Chart for Google Showing Infringement Of The '906 Patent by the
Google Browser and YouTube Player for the Android 3.0 operating
system for tablets
Claim
1pre

Claim Language
A

method

Evidence

for

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets

an

(and/or users of the Google Browser and/or the YouTube Player for the Android 3.0 operating system

application program

for tablets), alone and/or in combination with plug-ins such as Adobe Flash, comprises a method for

in

running an application program in a computer network environment, comprising the claim elements

running
a

computer

network

set forth below.

environment,
comprising:

The Google Browser for the Android 3.0 operating system for tablets alone and/or in combination with
plug-ins such as Adobe Flash, runs in a computer network environment, including the internet. For
example:

Page 1 of 58

Claim

Claim Language

Evidence

Source: http://developer.android.com/guide/basics/what-is-android.html
“Android will ship with a set of core applications including an email client, SMS program, calendar,

Page 2 of 58

Claim

Claim Language

Evidence
maps, browser, contacts, and others. All applications are written using the Java programming
language. “
Source: http://developer.android.com/guide/basics/what-is-android.html

Page 3 of 58

Claim

Claim Language

Evidence
Source:

http://www.motorola.com/staticfiles/Support/US-EN/TABLETS/XOOM/US-

EN/Documents/StaticFiles/68014293001a.HC.030111.pdf

The Google Browser for the Android 3.0 operating system for tablets also uses various plug-ins,
including:

Page 4 of 58

Claim

Claim Language

Evidence

Source:

http://blogs.adobe.com/flashplayer/2011/03/update-on-flash-player-10-2-for-mobile-

devices.html
“Update on Flash Player 10.2 for Mobile Devices

Page 5 of 58

Claim

Claim Language

Evidence
Today we are happy to announce that Flash Player 10.2 will be available for download via Android
Market on March 18th. Flash Player 10.2 is a production GA (General Availability) release for Android
2.2 (Froyo) and 2.3 (Gingerbread) devices which meet the Flash Player hardware system
requirements.

It is initially a beta release for Android 3.0 (Honeycomb) tablets which requires

Google’s 3.0.1 system update.
We have been working very closely with Google to ensure tight integration between Flash Player 10.2
and new OS and browser capabilities in Android 3.0. The March 18th beta release of Flash Player 10.2
in conjunction with Google’s first system update to Android 3.0 (version 3.0.1) currently underway for
the MOTOROLA XOOM™ will deliver the first phase of our work together.

This will be followed by

subsequent updates, which will complete the optimizations and result in a production GA release of
Flash Player 10.2 for Android 3.0.
Some of the new capabilities of Flash Player 10.2 for Android include:
Hardware accelerated video presentation for H.264 (Android 3.0.1+ only)
Flash Player 10.2 leverages the Stage Video rendering pipeline to enable users of Android 3.0 tablets,
like the MOTOROLA XOOM™, to enjoy smooth playback of high-definition Flash video content on the
web.

Users will experience reduced CPU usage and higher frame rates for existing H.264 video

content.
Deeper integration with the Android browser rendering engine (Android 3.0.1+ only)

Page 6 of 58

Claim

Claim Language

Evidence
Deeper integration of Flash Player and the enhanced Android 3.0 browser delivers faster and better
rendering of rich, interactive web content resulting in a browsing experience similar to the desktop.
Flash Player can now render content as part of the web page along with other components such as
HTML, images and gif animation. As a result, users will experience:
Improved scrolling of web pages;
Uncompromised viewing of rich, immersive content in the way intended by the page designer,
including support for instances where HTML and other web content is composited over Flash Player
rendered content. Flash Player rendered content will continue to be placed in a separate window on
top of HTML in the Android 2.2 and 2.3 browsers, as these browsers do not support the new Android
3.0 browser rendering model.
Enhanced performance for the latest smartphones and tablets
Experience performance improvements designed to take advantage of the current generation of multicore, GPU-enabled processors to deliver Flash videos, games and other interactive Web content on the
latest smartphones and tablets.”
Source:

http://blogs.adobe.com/flashplayer/2011/03/update-on-flash-player-10-2-for-mobile-

devices.html
The YouTube Player for the Android 3.0 operating system for tablets also runs in a computer network
environment, including the internet. For example:

Page 7 of 58

Claim

Claim Language

Evidence

Source: YouTube Player for the Android 3.0 operating system for tablets

Page 8 of 58

Claim

Claim Language

Evidence

Source:

http://www.motorola.com/staticfiles/Support/US-EN/TABLETS/XOOM/US-

EN/Documents/StaticFiles/68014293001a.HC.030111.pdf
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation

Page 9 of 58

Claim

Claim Language

Evidence
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

1a

providing

at

least

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets

client

(and/or users of the Google Browser and/or the YouTube Player for the Android 3.0 operating system

and

for tablets), alone and/or in combination with plug-ins such as Adobe Flash, operates in a computer

one network server

network environment, wherein said network environment is a distributed hypermedia environment,

coupled

such as the internet.

one
workstation
to

said

network
environment,
wherein

The Google Browser for the Android 3.0 operating system for tablets in a distributed hypermedia
said

network
environment

environment that includes at least one client workstation which executes the browser and one network
server coupled to said network environment which hosts the webpage viewed by the Google Browser.

is

a

distributed
hypermedia
environment;

Page 10 of 58

Claim

Claim Language

Evidence

Source: http://www.android.com/media/
The YouTube Player for the Android 3.0 operating system for tablets in a distributed hypermedia
environment that includes at least one client workstation which executes the browser and one network
server coupled to said network environment which hosts the page viewed by the YouTube Player.

Page 11 of 58

Claim

Claim Language

Evidence

Source: YouTube Player for the Android 3.0 operating system for tablets
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.
1b

executing, at said

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets

Page 12 of 58

Claim

Claim Language
client

Evidence

workstation,

(and/or users of the Google Browser and/or the YouTube Player for the Android 3.0 operating system

browser

for tablets), alone and/or in combination with plug-ins such as Adobe Flash, is a browser application,

application,

that

executed at the client workstation, that parses a first distributed hypermedia document to identify text

parses

first

formats included in said distributed hypermedia document and for responding to predetermined text

a
a

distributed

formats to initiate processing specified by said text formats.

hypermedia
document

For example, the Google Browser for the Android 3.0 operating system for tablets responds to the

text

identify

to

HTML and other text formats (e.g. JavaScript, etc.) on the webpage http://www.android.com/media/

formats included in
said

to initiate the processing specified by those formats in order to render the view shown below.

distributed

hypermedia
document and for
responding

to

predetermined text
formats to initiate
processing specified
by

said

text

formats;

Page 13 of 58

Claim

Claim Language

Evidence

Source: http://www.android.com/media/
Examples of the text formats on this page, which the Google Browser for the Android 3.0 operating
system for tablets responds to, include, but are not limited to:

<!DOCTYPE html>
<html lang="media">
<head>
<meta charset="utf-8">

Page 14 of 58

Claim

Claim Language

Evidence
<title>
Android.com - Press/Media
</title>
<meta content="Learn about Android Partners, Developers, Android Market, and more." name=
"description">
****
<body>
<div class="page">
<div class="header">
<h1>
<a href="/index.html"><img alt="Android" src="/images/android2-logo.gif"></a>
****
<img alt="" height="" src="" width="">
</div></noscript>
</body>
</html>

Source: http://www.android.com/media/
In another example, the YouTube Player for the Android 3.0 operating system for tablets responds to
the

XML

text

formats

in

the

file

http://gdata.youtube.com/feeds/api/standardfeeds/US/most_discussed?time=this_week&format=2%2
C3%2C8%2C9&start-index=1&max-results=15&safeSearch=moderate

to

initiate

the

processing

specified by those formats in order to render the view shown below.

Page 15 of 58

Claim

Claim Language

Evidence

Source: YouTube Player for the Android 3.0 operating system for tablets
Examples of the text formats on this page, which the YouTube Player for the Android 3.0 operating
system for tablets responds to, include, but are not limited to:
<?xml version="1.0" standalone="yes"?>
<feed gd:etag='W/"DkQFRH47eCp7ImA9Wx9bGEg."' xmlns="http://www.w3.org/2005/Atom"
xmlns:media="http://search.yahoo.com/mrss/" xmlns:gd="http://schemas.google.com/g/2005"
xmlns:openSearch="http://a9.com/-/spec/opensearch/1.1/" xmlns:yt="http://gdata.youtube.com/schemas/2007">
<id>tag:youtube.com,2008:standardfeed:us:most_popular</id>
****

Page 16 of 58

Claim

Claim Language

Evidence
<title>Playable Angry Birds birthday cake</title>
****
<media:description type="plain">Find out how to make your own at
http://www.electricpig.co.uk/2011/02/21/bake-your-own-playable-angry-birds-cake/
It's become a family tradition that I make increasingly ridiculous birthday cakes for my kids each year. So
with my little boy Ben turning 6-years-old over the weekend, and appreciating his love of Angry Birds, I
thought I'd have a shot a making him a playable Angry Birds birthday cake with working catapult and iced
birds as ammunition.</media:description>
****
</entry>
</feed>

Source:
http://gdata.youtube.com/feeds/api/standardfeeds/US/most_discussed?time=this_week&format=2%2
C3%2C8%2C9&start-index=1&max-results=15&safeSearch=moderate
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.
1c

utilizing

said

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets

browser to display,

(and/or users of the Google Browser and/or the YouTube Player for the Android 3.0 operating system

on

client

for tablets), alone and/or in combination with plug-ins such as Adobe Flash, is a browser application,

at

which is utilized to display, on said client workstation, at least a portion of a first hypermedia

least a portion of a

document received over said network from said server, wherein the portion of said first hypermedia

first

document is displayed within a first browser-controlled window on said client workstation.

said

workstation,

hypermedia

Page 17 of 58

Claim

Claim Language

Evidence

document received
over said network
from

said

For example:

server,

wherein the portion
of

said

first

hypermedia
document

is

displayed within a
first

browser-

controlled
on

said

window
client

workstation,

Source: http://developer.android.com/guide/basics/what-is-android.html
“Android will ship with a set of core applications including an email client, SMS program, calendar,
maps, browser, contacts, and others. All applications are written using the Java programming
language. “

Page 18 of 58

Claim

Claim Language

Evidence
Source: http://developer.android.com/guide/basics/what-is-android.html

Source:

http://www.motorola.com/staticfiles/Support/US-EN/TABLETS/XOOM/US-

Page 19 of 58

Claim

Claim Language

Evidence
EN/Documents/StaticFiles/68014293001a.HC.030111.pdf
As an additional example:

Source: http://www.android.com/media/
As an additional example:

Page 20 of 58

Claim

Claim Language

Evidence

Source:

http://www.motorola.com/staticfiles/Support/US-EN/TABLETS/XOOM/US-

EN/Documents/StaticFiles/68014293001a.HC.030111.pdf

Page 21 of 58

Claim

Claim Language

Evidence

Source: YouTube Player for the Android 3.0 operating system for tablets
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.
1d

wherein

said

first

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets

Page 22 of 58

Claim

Claim Language

Evidence

distributed

(and/or users of the Google Browser and/or the YouTube Player for the Android 3.0 operating system

hypermedia

for tablets), alone and/or in combination with plug-ins such as Adobe Flash, is a browser application,

document
an

includes

embed

text

format, located at a

which identifies an embed text format in said first distributed hypermedia document which is located at
a first location in said first distributed hypermedia document, that specifies the location of at least a
portion of an object external to the first distributed hypermedia document.

first location in said
first

distributed

hypermedia

For example, the Google Browser responds to various embed text formats. For example, the Google
Browser responds to the following text formats which include an HTML <embed> and/or <object> tag

document,

that

located at a first location in said first distributed hypermedia document, which the Google Browser

specifies

the

identifies as specifying the location of at least a portion of an object external to the first distributed

location of at least
a

portion

of

an

object external to
the first distributed
hypermedia
document,

hypermedia document (in this case the video shown below):

<!DOCTYPE html>
<html lang="media">
<head>
<meta charset="utf-8">
<title>
Android.com - Press/Media
</title>
<meta content="Learn about Android Partners, Developers, Android Market, and more." name=
"description">
****
<embed allowfullscreen="true" allowscriptaccess="always" height="275" src=
"http://www.youtube.com/v/hPUGNCIozp0?fs=1&amp;hl=en&amp;fs=1&amp;rel=0&amp;showinfo=0"
type="application/x-shockwave-flash" width="450" wmode="transparent">
****
<img alt="" height="" src="" width="">
</div></noscript>
</body>
</html>

Source: http://www.android.com/media/

Page 23 of 58

Claim

Claim Language

Evidence

Source: http://www.android.com/media/
In another example, the YouTube Player responds to various embed text formats. For example, the
YouTube Player responds to the following text formats which include an XML <media:content> tag
located at a first location in said first distributed hypermedia document, which the YouTube Player
identifies as specifying the location of at least a portion of an object external to the first distributed
hypermedia document (in this case the video shown below):

Page 24 of 58

Claim

Claim Language

Evidence

<?xml version="1.0" standalone="yes"?>
<feed gd:etag='W/"DkQFRH47eCp7ImA9Wx9bGEg."' xmlns="http://www.w3.org/2005/Atom"
xmlns:media="http://search.yahoo.com/mrss/" xmlns:gd="http://schemas.google.com/g/2005"
xmlns:openSearch="http://a9.com/-/spec/opensearch/1.1/" xmlns:yt="http://gdata.youtube.com/schemas/2007">
<id>tag:youtube.com,2008:standardfeed:us:most_popular</id>
<updated>2011-02-27T16:51:55.000-08:00</updated>
****
<media:content medium="video"
url="http://v24.lscache6.googlevideo.com/videoplayback?id=fa1c154736903640&amp;itag=22&amp;uaopt=nosave&amp;ip=0.0.0.0&amp;ipbits=0&amp;expire=1301611177&amp;sparams=id,itag,uaopt,ip,ipbits,expire&amp;signat
ure=4BD3B4BF77DA43E1AF9FB46FF93AB958685FD38D.B942932349EA445518C97E3C5EAB3CCCB9E343B8&amp;key=yta1&amp;el=st
andard&amp;devKey=ATpxuMO4AN5NR1nGmfaQDBQO88HsQjpE1a8d1GxQnGDm&amp;app=youtube_gdata" type="video/mp4"
duration="208" expression="full" yt:format="8"/>
****
</entry>
</feed>

Source:

http://gdata.youtube.com/

feeds/api/standardfeeds/US/most_discussed?time=this_week&format=2%2C3%2C8%2C9&startindex=1&max-results=15&safeSearch=moderate

Page 25 of 58

Claim

Claim Language

Evidence

Source: YouTube Player for the Android 3.0 operating system for tablets
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.
1e

wherein said object

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets

Page 26 of 58

Claim

Claim Language
has

type

information
associated
utilized

Evidence
(and/or users of the Google Browser and/or the YouTube Player for the Android 3.0 operating system
for tablets), alone and/or in combination with plug-ins such as Adobe Flash, is a browser application,

with

by

it

said

which uses type information associated with the object to identify and locate an executable application
external to the first distributed hypermedia document.

browser to identify
and

locate

an

For example, the Google Browser uses type information associated with the object, to identify and

executable

locate an executable application external to the first distributed hypermedia document.

application external

example, the Google Browser uses the type information associated with the movie identified in the

to

code below (e.g. “type=’application/x-shockwave-flash’”) to identify the shockwave/flash executable

the

distributed

first

In one

application, which is external to the first distributed hypermedia document.

hypermedia
document,

<!DOCTYPE html>
<html lang="media">
<head>
<meta charset="utf-8">
<title>
Android.com - Press/Media
</title>
<meta content="Learn about Android Partners, Developers, Android Market, and more." name=
"description">
****
<embed allowfullscreen="true" allowscriptaccess="always" height="275" src=
"http://www.youtube.com/v/hPUGNCIozp0?fs=1&amp;hl=en&amp;fs=1&amp;rel=0&amp;showinfo=0"
type="application/x-shockwave-flash" width="450" wmode="transparent">
****
<img alt="" height="" src="" width="">
</div></noscript>
</body>
</html>

Source: http://www.android.com/media/

Page 27 of 58

Claim

Claim Language

Evidence

Source: http://www.android.com/media/
In another example, the Google Browser uses the type information associated with the movie identified
in the Content-Type header of a HTTP GET response below (e.g. “type=’application/x-shockwaveflash’”) to identify the shockwave/flash executable application, which is external to the first distributed
hypermedia document.

Page 28 of 58

Claim

Claim Language

Evidence
GET /v/hPUGNCIozp0?fs=1&hl=en&fs=1&rel=0&showinfo=0 HTTP/1.1
Host: www.youtube.com
Connection: keep-alive
Referer: http://www.android.com/media/
User-Agent: Mozilla/5.0 (Linux; U; Android 3.0.1; en-us; Xoom Build/HRI66) AppleWebKit/534.13 (KHTML, like
Gecko) Version/4.0 Safari/534.13
Accept-Encoding: gzip,deflate
Accept-Language: en-US
Accept-Charset: utf-8, iso-8859-1, utf-16, *;q=0.7
Cookie: …
HTTP/1.1 200 OK
Date: Sat, 19 Mar 2011 18:37:29 GMT
Server: Apache
X-Content-Type-Options: nosniff
Expires: Tue, 27 Apr 1971 19:44:06 EST
Cache-Control: no-cache
Content-Length: 1090
Content-Type: application/x-shockwave-flash

Source: www.youtube.com
In another example, the YouTube Player uses the type information associated with the movie identified
in the code below (e.g. “type= video/mp4’”) to identify the video player executable application, which
is external to the first distributed hypermedia document.

<?xml version="1.0" standalone="yes"?>
<feed gd:etag='W/"DkQFRH47eCp7ImA9Wx9bGEg."' xmlns="http://www.w3.org/2005/Atom"
xmlns:media="http://search.yahoo.com/mrss/" xmlns:gd="http://schemas.google.com/g/2005"
xmlns:openSearch="http://a9.com/-/spec/opensearch/1.1/" xmlns:yt="http://gdata.youtube.com/schemas/2007">
<id>tag:youtube.com,2008:standardfeed:us:most_popular</id>
<updated>2011-02-27T16:51:55.000-08:00</updated>
****
<media:content medium="video"
url="http://v24.lscache6.googlevideo.com/videoplayback?id=fa1c154736903640&amp;itag=22&amp;uaopt=nosave&amp;ip=0.0.0.0&amp;ipbits=0&amp;expire=1301611177&amp;sparams=id,itag,uaopt,ip,ipbits,expire&amp;signat
ure=4BD3B4BF77DA43E1AF9FB46FF93AB958685FD38D.B942932349EA445518C97E3C5EAB3CCCB9E343B8&amp;key=yta1&amp;el=st
andard&amp;devKey=ATpxuMO4AN5NR1nGmfaQDBQO88HsQjpE1a8d1GxQnGDm&amp;app=youtube_gdata" type="video/mp4"
duration="208" expression="full" yt:format="8"/>

Page 29 of 58

Claim

Claim Language

Evidence
****
</entry>
</feed>

Source:

http://gdata.youtube.com/

feeds/api/standardfeeds/US/most_discussed?time=this_week&format=2%2C3%2C8%2C9&startindex=1&max-results=15&safeSearch=moderate
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.
1f

and

wherein

said

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets

embed text format

(and/or users of the Google Browser and/or the YouTube Player for the Android 3.0 operating system

is parsed by said

for tablets), alone and/or in combination with plug-ins such as Adobe Flash, is a browser application,

browser

which parses the embed text format to automatically invoke said executable application to execute on

to

automatically
invoke

said client workstation in order to display said object.
said

executable
application
execute
client

on

For example, when the Google Browser parses the embed text format, it automatically invokes said
to

executable application on the client workstation in order to display said object.

For example, in

said

response to identifying the embed text format identified in the prior elements, the Google Browser

workstation

displays the video, by automatically invoking the shockwave/flash executable application on the client

in order to display

workstation:

said object

Page 30 of 58

Claim

Claim Language

Evidence

Source: http://www.android.com/media/
In another example, when the YouTube Player parses the embed text format, it automatically invokes
said executable application on the client workstation in order to display said object. For example, in
response to identifying the embed text format identified in the prior elements, the YouTube Player
displays the video, by automatically invoking the video player executable application on the client
workstation:

Page 31 of 58

Claim

Claim Language

Evidence

Source: YouTube Player for the Android 3.0 operating system for tablets
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

Page 32 of 58

Claim
1g

Claim Language

Evidence

and enable an end-

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets

user

(and/or users of the Google Browser and/or the YouTube Player for the Android 3.0 operating system

to

directly

interact

with

object

within

for tablets), alone and/or in combination with plug-ins such as Adobe Flash, is a browser application,

a

which enables an end-user to directly interact with said object within a display area created at said

area

display

said

first location within the portion of said first distributed hypermedia document being displayed in said

created at said first

first browser-controlled window.

location within the
portion of said first

A user can directly interact using a touch screen with the video object being displayed by the Flash

distributed

Player within a display area created at the first location within the portion of the Web page displayed

hypermedia

within the Google Browser window. One example on interaction is the user can touch the play icon in

document

being

displayed

in

first

the middle of the Flash Player display in order to play the video:

said

browser-

controlled window.

Page 33 of 58

Claim

Claim Language

Evidence

Source: http://www.android.com/media/
Once the video file begins playing, the user can further interact with the video using the touchscreen
to change the sound volume of the video, pause the video, rewind or fast forward the video, and so
on.
“ActionScript is the programming language for the Adobe® Flash® Player and Adobe® AIR™ run-time
environments. It enables interactivity, data handling, and much more in Flash, Flex, and AIR content

Page 34 of 58

Claim

Claim Language

Evidence
and applications.”
Source:
http://help.adobe.com/en_US/ActionScript/3.0_ProgrammingAS3/WS5b3ccc516d4fbf351e63e3d118a9
b90204-7ff4.html
A user can also directly interact using a touch screen with the movie object being displayed by the
video player within a display area created at the first location within the portion of the hypermedia
document being displayed within the YouTube Player browser window. One example is the user can
touch the “pause” button in the lower left-hand corner of the player to stop the video from being
played.

Page 35 of 58

Claim

Claim Language

Evidence

Source: YouTube Player for the Android 3.0 operating system for tablets
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.
2pre

The

method

of

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets

Page 36 of 58

Claim

Claim Language
claim

1,

Evidence
(and/or users of the Google Browser and/or the YouTube Player for the Android 3.0 operating system

executable

said

wherein

for tablets), alone and/or in combination with plug-ins such as Adobe Flash, is a browser application,

application

is

a

controllable

application and further comprising the step set forth below.

application
further

which comprises the method of claim 1, wherein said executable application is a controllable

and

comprising

See the evidence cited for element 1pre and 1g, supra.

the step of:
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.
2a

interactively
controlling

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets
said

(and/or users of the Google Browser and/or the YouTube Player for the Android 3.0 operating system

controllable

for tablets), alone and/or in combination with plug-ins such as Adobe Flash, interactively controls said

application on said

controllable application on said client workstation via inter-process communications between said

client

browser and said controllable application.

via

workstation
inter-process

communications

Google Browser supports the use of different types of applications (e.g. flash, shockwave, etc.), to

between

said

enable an end-user to directly interact with said object within a display area created at said first

said

location within the portion of said first distributed hypermedia document being displayed in said first

browser

and

controllable

browser-controlled window, for example:

application.
“For the purposes of this article, "fscommand()" refers mainly to Flash -> JavaScript communication

Page 37 of 58

Claim

Claim Language

Evidence
(ie. Flash executing javascript statements in a web browser). However, fscommand's scope is actually
broader than that. Without going into too much detail, here's a slightly longer description of
fscommand():
"fscommand()" is the name of a function in Flash that provides communication with a flash
movie's host application ("application" means anything that can play Flash media, whether natively,
eg. the stand-alone Flash player, or with the use of a plug-in, eg. a web browser). For example, a
web-based fscommand() might execute a JavaScript function from a Flash button click. (We'll see later
that JavaScript can also control the Flash movie playback.) fscommand() can also communicate with
Lingo and can send a limited set of built-in commands to the stand-alone Flash player (eg. "Quit",
"FullScreen", "AllowScale", "ShowMenu").”
See

also:

Macromedia

Flash

-

Action

Script

Dictionary:

fscommand,

http://www.adobe.com/support/flash/action_scripts/actionscript_dictionary/actionscript_dictionary372.
html. “fscommand . . . allows the Flash movie to communicate with either the Flash Player, or the
program hosting the Flash Player, such as a Web browser.”
See also the evidence cited for element 1f and 1g, supra.
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.
3

The

method

of

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets

Page 38 of 58

Claim

Claim Language
claim

2,

Evidence

wherein

(and/or users of the Google Browser and/or the YouTube Player for the Android 3.0 operating system

the communications

for tablets), alone and/or in combination with plug-ins such as Adobe Flash, comprises the method of

to

interactively

claim 2, wherein the communications to interactively control said controllable application continue to

said

be exchanged between the controllable application and the browser even after the controllable

control
controllable

application program has been launched.

application continue
to

be

exchanged

between

See the evidence cited in element 2a, supra.

the

controllable

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

application and the

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

browser even after

Android 3.0 operating system for tablets and documentation to users (including the documentation

the

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the

controllable

application program

Android 3.0 operating system for tablets in their default, intended, and infringing manner.

has been launched.
6pre

A

computer

The Google Browser and the YouTube Player for the Android 3.0 operating system for tablets are

product

computer program products for use in a system having at least one client workstation and one network

for use in a system

server coupled to said network environment, wherein said network environment is a distributed

having at least one

hypermedia environment, the computer program product further comprising the elements set forth

client

below.

program

and

workstation
one

server
said

network

coupled

to

network

See the evidence and information cited for the claim elements 1pre and 1a supra which is expressly
incorporated herein.

environment,
wherein

said

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

Page 39 of 58

Claim

Claim Language

Evidence

network

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

environment

is

a

Android 3.0 operating system for tablets and documentation to users (including the documentation

distributed

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the

hypermedia

Android 3.0 operating system for tablets in their default, intended, and infringing manner.

environment,
computer

the

program

product comprising:
6a

a computer usable

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

medium

having

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

readable

for download, and the computers of users of the Google Browser and/or the YouTube Player each

code

comprise a computer usable medium having computer readable program code physically embodied

computer
program
physically

therein, said computer program product further comprising the elements set forth below.

embodied
said

therein,
computer

program

See also the evidence identified for elements 1pre and 1a supra which is expressly incorporated herein.

product

further comprising:

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

6b

computer
program

readable
code

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

for

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

causing said client

for download, and the computers of users of the Google Browser and/or the YouTube Player each

workstation

comprise computer readable program code for causing said client workstation to execute a browser

to

Page 40 of 58

Claim

Claim Language

Evidence

execute a browser

application to parse a first distributed hypermedia document to identify text formats included in said

application to parse

distributed hypermedia document and to respond to predetermined text formats to initiate processes

a

specified by said text formats.

first

distributed

hypermedia
document

to

identify

See the evidence identified for element 1b supra which is expressly incorporated herein.

text

formats included in

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

said

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

distributed

Android 3.0 operating system for tablets and documentation to users (including the documentation

hypermedia
and

respond

to

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the

to

document

Android 3.0 operating system for tablets in their default, intended, and infringing manner.

predetermined text
formats to initiate
processes specified
by

said

text

formats;
6c

computer
program

readable
code

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

for

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

causing said client

for download, and the computers of users of the Google Browser and/or the YouTube Player each

workstation

to

comprise computer readable program code for causing said client workstation to utilize said browser to

utilize said browser

display, on said client workstation, at least a portion of a first hypermedia document received over said

to display, on said

network from said server, wherein the portion of said first hypermedia document is displayed within a

client

first browser-controlled window on said client workstation.

workstation,

Page 41 of 58

Claim

Claim Language

Evidence

at least a portion of
a first hypermedia

See the evidence identified for element 1c supra which is expressly incorporated herein.

document received
over said network

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

from

server,

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

wherein the portion

Android 3.0 operating system for tablets and documentation to users (including the documentation

of

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the

said
said

first

Android 3.0 operating system for tablets in their default, intended, and infringing manner.

hypermedia
document

is

displayed within a
first

browser-

controlled
on

window

said

client

workstation,
6d

wherein

said

first

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

distributed

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

hypermedia

for download, is a browser application, which identifies an embed text format in said first distributed

document
an

includes

embed

text

format, located at a

hypermedia document which is located at a first location in said first distributed hypermedia document,
that specifies the location of at least a portion of an object external to the first distributed hypermedia
document.

first location in said
first

distributed

See the evidence identified for element 1d supra which is expressly incorporated herein.

hypermedia

Page 42 of 58

Claim

Claim Language

Evidence

document,

that

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

specifies

the

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

location of at least

Android 3.0 operating system for tablets and documentation to users (including the documentation

a

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the

portion

of

an

object external to

Android 3.0 operating system for tablets in their default, intended, and infringing manner.

the first distributed
hypermedia
document,
6e

wherein said object

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

has

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

type

information
associated
utilized

for download, is a browser application, identifies the type information associated with said object and
with

by

it

said

utilizes it to identify and locate an executable application external to the first distributed hypermedia
document.

browser to identify
and

locate

an

See the evidence identified for element 1e supra which is expressly incorporated herein.

executable
application external

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

to

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

the

first

distributed
hypermedia

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the

document,
6f

Android 3.0 operating system for tablets and documentation to users (including the documentation
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

and

wherein

said

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

Page 43 of 58

Claim

Claim Language

Evidence

embed text format

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

is parsed by said

for download, is a browser that parses the embed text format to automatically invoke said executable

browser

application to execute on said client workstation in order to display said object.

to

automatically
invoke

said

See the evidence identified for element 1f supra which is expressly incorporated herein.

executable
to

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

said

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

workstation

Android 3.0 operating system for tablets and documentation to users (including the documentation

in order to display

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the

said object

Android 3.0 operating system for tablets in their default, intended, and infringing manner.

and enable an end-

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

user

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

application
execute
client

6g

on

to

directly

interact

with

object

within

for download, and the computers of users of the Google Browser and/or the YouTube Player, is a

a

browser that enables an end-user to directly interact with said object within a display area created at

area

display

said

said first location within the portion of said first distributed hypermedia document being displayed in

created at said first

said first browser-controlled window.

location within the
portion of said first

See the evidence identified for element 1g supra which is expressly incorporated herein.

distributed
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

hypermedia
being

document
displayed

in

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

said

Android 3.0 operating system for tablets and documentation to users (including the documentation

Page 44 of 58

Claim

Claim Language
first

Evidence

browser-

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the

controlled window.
The

computer

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

program product of

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

claim

7pre

Android 3.0 operating system for tablets in their default, intended, and infringing manner.

wherein

for download, and the computers of users of the Google Browser and/or the YouTube Player, comprises

executable

the computer program product of claim 6, wherein said executable application is a controllable

6,

said

application

is

a

application and further comprising the elements set forth below.

controllable
application

and

See the evidence identified for element 1pre supra which is expressly incorporated herein.

further comprising:
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.
7a

computer
program

readable
code

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

for

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

causing said client

for download, and the computers of users of the Google Browser and/or the YouTube Player, comprise

workstation

to

computer readable program code for causing said client workstation to interactively control said

interactively control

controllable application on said client workstation via inter-process communications between said

said

browser and said controllable application

controllable

application on said
client
via

workstation

See the evidence identified for element 2a supra which is expressly incorporated herein.

inter-process

Page 45 of 58

Claim

Claim Language

Evidence

communications

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

between

said

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

said

Android 3.0 operating system for tablets and documentation to users (including the documentation

browser

and

controllable
application.

Android 3.0 operating system for tablets in their default, intended, and infringing manner.

The

computer

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

program product of

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

claim

wherein

for download, and the computers of users of the Google Browser and/or the YouTube Player, comprise

the communications

the computer program product of claim 7, wherein the communications to interactively control said

to

8

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the

controllable application continue to be exchanged between the controllable application and the browser

7,

interactively

control

said

even after the controllable application program has been launched.

controllable
application continue
to

be

See the evidence identified for claim 3 supra which is expressly incorporated herein.

exchanged

between

the

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

controllable

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

application and the

Android 3.0 operating system for tablets and documentation to users (including the documentation

browser even after

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the

the

Android 3.0 operating system for tablets in their default, intended, and infringing manner.

controllable

application program
has been launched.
11pre

The

method

claim

3,

the

of

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

wherein

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

additional

for download, comprises the method of claim 3, wherein the additional instructions for controlling said

Page 46 of 58

Claim

Claim Language
instructions

for

controlling

said

Evidence
controllable application reside on said network server, wherein said step of interactively controlling
said controllable application includes the following sub-steps.

controllable
application
on

said

reside
network

server,
said

See the evidence identified for claim 3 supra which is expressly incorporated herein.

wherein
step

of

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation

interactively
controlling

said

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

controllable
application includes
the following substeps:
11a

issuing,

from

the

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

client

workstation,

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

one

or

for download, is a browser application which issues, from the client workstation, one or more

commands

more
to

the

commands to the network server.

network server;
For example, with the Google Browser and the Flash plug-in, the client workstation will issue
commands to the network server when the video scroll control is changed by a user to play a video at
a different time location within the video:

Page 47 of 58

Claim

Claim Language

Evidence

Source: http://www.android.com/media/
In another example, with the YouTube player, the client workstation will issue commands to the
network server when the video scroll control is changed by a user to play a video at a different time
location within the video:

Page 48 of 58

Claim

Claim Language

Evidence

Source: YouTube Player for the Android 3.0 operating system for tablets
As a further example:
ActionScript is the programming language for the Adobe® Flash® Player and Adobe® AIR™ run-time
environments. It enables interactivity, data handling, and much more in Flash, Flex, and AIR content
and applications.”

Page 49 of 58

Claim

Claim Language

Evidence
Source:
http://help.adobe.com/en_US/ActionScript/3.0_ProgrammingAS3/WS5b3ccc516d4fbf351e63e3d118a9
b90204-7ff4.html
“This chapter explains how to enable your SWF file to communicate with external files and other
Adobe Flash Player and Adobe AIR instances. It also explains how to load data from external sources,
send messages between a Java server and Flash Player, and perform file uploads and downloads using
the FileReference and FileReferenceList classes.”
Source: http://help.adobe.com/en_US/ActionScript/3.0_ProgrammingAS3/flash_as3_programming.pdf
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

11b

executing,

on

the

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

network server, one

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

or

for download, is a browser application which operates in an environment where the network server

more

instructions
response

in
to

commands;

executes one or more instructions in response to said commands.

said
For example, with the Google Browser and the Flash plug-in, the YouTube network server will execute
one or more instructions to send new video information to the client workstation for playback to the
user:

Page 50 of 58

Claim

Claim Language

Evidence

Source: http://www.android.com/media/
In another example, with the YouTube Player, the YouTube network server will execute one or more
instructions to send new video information to the client workstation for playback to the user:

Page 51 of 58

Claim

Claim Language

Evidence

Source: YouTube Player for the Android 3.0 operating system for tablets
As a further example:
ActionScript is the programming language for the Adobe® Flash® Player and Adobe® AIR™ run-time
environments. It enables interactivity, data handling, and much more in Flash, Flex, and AIR content
and applications.”

Page 52 of 58

Claim

Claim Language

Evidence
Source:
http://help.adobe.com/en_US/ActionScript/3.0_ProgrammingAS3/WS5b3ccc516d4fbf351e63e3d118a9
b90204-7ff4.html
“This chapter explains how to enable your SWF file to communicate with external files and other
Adobe Flash Player and Adobe AIR instances. It also explains how to load data from external sources,
send messages between a Java server and Flash Player, and perform file uploads and downloads using
the FileReference and FileReferenceList classes.”
Source: http://help.adobe.com/en_US/ActionScript/3.0_ProgrammingAS3/flash_as3_programming.pdf
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

11c

sending information

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

from said network

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

server to said client

for download, is a browser application which operates in an environment where the network server

workstation

sends information from said network server to said client workstation in response to said executed

response

to

in
said

instructions.

executed
instructions;

See the evidence identified for element 11b supra which is expressly incorporated herein.
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

Page 53 of 58

Claim

Claim Language

Evidence
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

11d

and processing said

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

information at the

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

client

workstation

for download, is a browser application processes said information at the client workstation to

to

interactively

interactively control said controllable application.

control

said

See the evidence identified for element 11b supra which is expressly incorporated herein.

controllable
application.

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.
12

The

method

of

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

claim 11, wherein

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

said

for download, comprises the method of claim 11, wherein said additional instructions for controlling

additional

instructions

for

controlling

said

said controllable application reside on said client workstation.

See the evidence identified for element 11b supra which is expressly incorporated herein.

controllable
application

reside

on

client

said

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

Page 54 of 58

Claim

Claim Language
workstation.

Evidence
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

13pre

The

computer

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

program product of

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

claim

for download, comprises the computer program product of claim 8, wherein additional instructions for

8,

wherein

additional

controlling said controllable application reside on said network server, wherein said computer readable

instructions

for

controlling

said

program code for causing said client workstation to interactively control said controllable application on
said workstation includes.

controllable
application
on

said

See the evidence identified for element 11a supra which is expressly incorporated herein.

network
wherein

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

computer

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

program

Android 3.0 operating system for tablets and documentation to users (including the documentation

causing

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the

server,
said
readable
code

reside

for

said

client

workstation

Android 3.0 operating system for tablets in their default, intended, and infringing manner.

to

interactively control
said

controllable

application on said
workstation
includes:

Page 55 of 58

Claim
13a

Claim Language
computer
program

readable

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

for

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

causing said client

for download, comprises computer readable program code for causing said client workstation to issue,

workstation

from the client workstation, one or more commands to the network server.

issue,

code

Evidence

to

from

the

client

workstation,

one

or

See the evidence identified for element 11a supra which is expressly incorporated herein.

more

commands

to

the

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

network server;

Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.
13b

computer
program

readable
code

for

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

said

causing

for download, comprises computer readable program code for causing said network server to execute

network server to
execute

one
to

commands;

one or more instructions in response to said commands.

or

more instructions in
response

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

See the evidence identified for element 11b supra which is expressly incorporated herein.

said
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
contributory infringement. Google provides the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

Page 56 of 58

Claim
13c

Claim Language
computer
program

readable
code

Evidence
The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone
and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

said

causing

for

for download, comprises computer readable program code for causing said network server to send

network server to

information to said client workstation in response to said executed instructions.

send information to
said

client

workstation
response

to

See the evidence identified for element 11c supra which is expressly incorporated herein.

in
said

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

executed

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

instructions; and

Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

13d

computer
program

readable
code

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

for

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

causing said client

for download, comprises computer readable program code for causing said client workstation to

workstation

process said information at the client workstation to interactively control said controllable application.

process

to
said

information at the

See the evidence identified for element 11d supra which is expressly incorporated herein.

client

workstation

to

interactively

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

said

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

control
controllable

Android 3.0 operating system for tablets and documentation to users (including the documentation

application.

cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

Page 57 of 58

Claim
14

Claim Language
The

Evidence

computer

The Google Browser and/or the YouTube Player for the Android 3.0 operating system for tablets (alone

program product of

and/or in combination with plug-ins like Flash), as well as the Google servers which make it available

claim 13, wherein

for download, comprises the computer program product of claim 13, wherein said additional

said

instructions for controlling said controllable application reside on said client workstation.

additional

instructions

for

controlling

said

See the evidence identified for element 11b supra which is expressly incorporated herein.

controllable
application

reside

In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or

on

client

contributory infringement. Google provides the Google Browser and/or the YouTube Player for the

said

workstation.

Android 3.0 operating system for tablets and documentation to users (including the documentation
cited above). Google causes the users to use the Google Browser and/or the YouTube Player for the
Android 3.0 operating system for tablets in their default, intended, and infringing manner.

Page 58 of 58