Apple, Inc. v. Motorola, Inc. et al

Filing 107

Declaration of Winslow B. Taub filed by Plaintiffs Apple, Inc., Next Softward, Inc. re: 90 Motion Requesting Claims Construction by Plaintiffs. (Attachments: # 1 Ex. A, '486 Inf. Chart, # 2 Ex. B, '354 file history excerpt, # 3 Ex. C, '354 file history excerpt, # 4 Ex. D, Spielman report excerpts, # 5 Ex. E, '983 file history excerpts, # 6 Ex. F, '983 file history excerpts, # 7 Ex. G, '337 Inf. Chart, # 8 Ex. H, '002 Inf. Chart, # 9 Ex. I, '002 file history excerpt, # 10 Ex. J, '002 file history excerpt, # 11 Ex. K, '002 file history excerpt, # 12 Ex. L, dictionary definitions, # 13 Ex. N, JPS63-167588 cert. trans., # 14 Ex. O, appl. 08/050952 file history excerpt, # 15 Ex. P, invalidity conten. excerpt, # 16 Ex. Q, 6,371,977, # 17 Ex. R, 5,474,831) (Haslam, Robert) Modified on 7/18/2011 (llj).

EXHIBIT H

Exhibit B – U.S. Patent No. 6,493,002
Motorola directly and/or indirectly infringes at least claims 1, 3-7, 11, 21, 22, 26, 28-32, 36-37, and 46-47 of the ’002
patent, either literally or through the doctrine of equivalents. Motorola’s infringing products include mobile devices such as
smartphones and tablet computers, including but not limited to the: Atrix, Bravo, Cliq, Cliq XT, Cliq 2, Charm, Defy, Devour,
BackFlip, Droid, Droid 2, Droid 2 Global, Droid X, Droid Pro, Droid Bionic, Flipout, Flipside, i1, Xoom, (collectively, “the ’002
Accused Products”).
For the purposes of this analysis, Apple will examine a representative mobile device, Motorola’s Droid X, which
operates with the Android 2.1 Platform. All other Accused Products meet the limitations of the asserted claims on the same bases as
indicated for the Droid X unless otherwise stated.
These infringement contentions are preliminary and based only on publicly available information as to the ’002
Accused Products. Motorola has not yet provided discovery as to its Accused Products and in addition Apple’s investigation of
Motorola’s infringement is ongoing. Based on discovery and Apples continued investigations Apple reserves the right to amend
these contentions to identify additional bases for infringement and additional ’002 Accused Products., including products that
Motorola may introduce in the future. Accordingly, Apple reserves its right to amend these contentions as discovery and its
investigation proceeds.

U.S. Patent No. 6,493,002
1. An interactive computer-controlled
display system comprising: a processor;

Infringement Contentions
The ’002 Accused Products comprise interactive computer-controlled display systems,
each of which include a processor.
•

As one example, the Droid X includes an interactive computer-controlled display
system including a processor.

U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 2.
a data display screen coupled to the
processor;

The ’002 Accused Products include a data display screen coupled to the processor.
•

As one example, the Droid X includes a touchscreen display coupled to the
processor for displaying data.

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Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 2.
a cursor control device coupled to said
processor for positioning a cursor on said
data display screen;

The ’002 Accused Products include a cursor control device coupled to said processor for
positioning a cursor on said data display screen.
•

As one example, the Droid X includes a touchscreen circuitry that detects the
location where a user is touching the display screen in order to indicate to the
processor where to place a cursor on the display screen.

3

U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 2.
a window generation and control logic
coupled to the processor and data display
screen to create an operating environment
for a plurality of individual programming
modules associated with different
application programs that provide status
and/or control functions,

The ’002 Accused Products include window generation and control logic coupled to the
processor and data display screen to create an operating environment for a plurality of
individual programming modules associated with different application programs that
provide status and/or control functions.
•

As one example, the Android operating system software as implemented on the
Droid X allows for the operation of a plurality of individual programming
modules associated with different application programs that provide status and/or
control functions. These different application programs can include a phone
application, a map application, and a messaging application. Exh. B-1 [Droid
X User’s Guide] at 10; 31; 39.

4

U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 7.
•

One example of an application program that provides control information is the
phone application, which instructs the Droid X to perform phone functions
including making and answering calls. Exh. B-1 [Droid X User’s Guide] at 1011.

5

U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 10.
•

wherein the window generation and
control logic generates and displays a first
window region having a plurality of
display areas on said data display screen,

One example of an application that provides status functions is the voicemail
application, which indicates, for example, that a new voicemail has been
received.

For the ’002 Accused Products, the window generation and control logic generates and
displays a first window region having a plurality of display areas on said data display
screen.
•

As one example, the Android operating system software as implemented on the
Droid X generates a phone status and notifications window (“Notification
Window”) having a plurality of display areas.

6

U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

wherein the first window region is
independently displayed and
independently active of any application
program, and

In the above reproduced image of the Notification Window for the Droid X, the
display areas on the Notifications Window of the Droid X each include a display
area indicating the reception of a “new email” and a display area indication the
reception of a “new voicemail.”

For the ’002 Accused Products, the first window region is independently displayed and
independently active of any application program.

7

U.S. Patent No. 6,493,002

Infringement Contentions
Exh. B-1 [Droid X User’s Guide] at 9.
•

•

wherein each of the plurality of display
areas is associated with one of the
plurality of individual programming
modules,

In the above reproduced image of the Notification Window for the Droid X, the
Notification Window is displayed and active independent of whatever application
program was displayed when the Notification Window was dragged open by the
user. Id.
The Notification Window is independent of the application programs. It receives
messages passed from applications requesting the display of a notification in the
form of “Intent” messages. Exh. B-2 [Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)].

For the ’002 Accused Products, each of the plurality of display areas is associated with
one of the plurality of individual programming modules.
•

As one example, the display areas within the Notification Window generated by
the Android operating system software as implemented on the Droid X are each
associated with an individual programming module.

.
Exh. B-1 [Droid X User’s Guide] at 9.
•

In the above reproduced image of the Notification Window for the Droid X, the
display areas are each associated with one of the programming module. Id. For
8

U.S. Patent No. 6,493,002

Infringement Contentions
example, the display area for the “new email” notification is associated with an
email programming module and the “new voicemail” notification is associated
with a voicemail module. Id.

the first window region and the plurality
of independent display areas implemented
in a window layer that appears on top of
application programming windows that
may be generated; and

For the ’002 Accused Products, the first window region and the plurality of independent
display areas implemented in a window layer that appears on top of application
programming windows that may be generated.

Exh. B-1 [Droid X User’s Guide] at 9.
•

an indicia generation logic coupled to the
data display screen to execute at least one
of the plurality of individual programming
modules to generate information for
display in one of the plurality of display

In the above reproduced image of the Notification Window for the Droid X, the
Notification Window shown being pulled down by a user over whichever
application was previously active. Id. The Notification Window, including its
display areas, is implemented on a window layer on top of whichever application
program was displayed when the Notification Window is opened by the user. Id.

The ’002 Accused Products include indicia generation logic coupled to the data display
screen to execute at least one of the plurality of individual programming modules to
generate information for display in one of the plurality of display areas in the first
window region.
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Infringement Contentions

areas in the first window region,

Exh. B-1 [Droid X User’s Guide] at 9.
•

wherein at least one of the plurality of
display areas and its associated
programming module is sensitive to user
input, and

In the above reproduced image of the Notification Window for the Droid X, the
Android operating system software generates indicia, which are displayed in each
of the display areas by executing a programming module corresponding to the
indicia. For example, the “new email” display area includes indicia resulting
from executing an email module. The indicia for the “new email” display area
include a textual indication of the new email as well as an icon. A second
example is shown in the “new voicemail” display area, which includes indicia
resulting from executing a voicemail module. Id. The indicia for the “new
voicemail” display area include a textual indication of the new voicemail as well
as an icon.

For the ’002 Accused Products at least one of the plurality of display areas and its
associated programming module is sensitive to user input.

10

U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

In the above reproduced image of the Notification Window for the Droid X, one
of the indicia can be selected based on a touch-based indication from a user.

•

Exh. B-2 [Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)]. The
selection results in a message called an “intent” that is sent to the programming
module responsible for generating a display of that indicia. For example, if a
user touches the “new email” indicia, an intent will be sent to an email
programming module and if a user touches the “new voicemail” indicia, an intent
will be sent to a voicemail programming module. Exh. B-1 [Droid X User’s
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U.S. Patent No. 6,493,002

Infringement Contentions
Guide] at 9; Exh. B-2 [Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)].

further wherein the window generation
and control logic and the indicia
generation logic use message-based
communication to exchange information
to coordinate activities of the indicia
generation logic to enable interactive
display activity.

For the ’002 Accused Products the window generation and control logic and the indicia
generation logic use message-based communication to exchange information to
coordinate activities of the indicia generation logic to enable interactive display activity.

•

3. The display system defined in claim 1
wherein said at least one display area is
variably sized.

Exh. B-2 [Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)]. The
window generation and control logic and indicia generation logic of the Android
operating system software use messages called “intents” to exchange information
to provide interactive display activity. For example, if a user touches the “new
email” indicia, an intent will be sent to an email programming module and if a
user touches the “new voicemail” indicia, an intent will be sent to a voicemail
programming module. Exh. B-1 [Droid X User’s Guide] at 9; Exh. B-2
[Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)].

For the ’002 Accused Products, at least one of the plurality of display areas is variably
sized.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

4. The display system defined in claim 1
wherein size of the first window region is
variable.

In the above reproduced image of the Notification Window for the Droid X, the
display areas for the notifications are variably sized. Id. For example, the four
notifications depicted above are of at least three different sizes.

For the accused devices, the size of the first window region is variable.

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U.S. Patent No. 6,493,002

Infringement Contentions
Exh. B-1 [Droid X User’s Guide] at 9.
•

5. The display system defined in claim 4
wherein the first window region is sized
such that none of the plurality of display
areas is visible.

In the above reproduced image of the Notification Window for the Droid X, the
Notification Window is shown being pulled down by a user as indicated by the
blue arrow. Id. The Notification Window is variably sized as the user pulls
down the Notification Window.

For the ’002 Accused Products, the first window region can be sized such that none of
the plurality of display areas is visible.

Exh. B-1 [Droid X User’s Guide] at 7.
•

6. The display system defined in claim 4
wherein the first window region is sized
such that all of the plurality of display

In the above reproduced image of the home screen for the Droid X, the
Notification Window is shown before being pulled down by a user, where none
of the display areas is visible.

For the ’002 Accused Products, the first window region can be sized such that all of the
plurality of display areas are visible.
14

U.S. Patent No. 6,493,002

Infringement Contentions

areas are visible.

Exh. B-1 [Droid X User’s Guide] at 9.
•

7. The display system defined in claim 4
wherein the first window region is sized
such that a portion of the plurality of
display areas is visible.

As shown in the above reproduced image of the Notification Window for the
Droid X, for small numbers of notifications all of the display areas associated
with the notifications can be visible.

For the ’002 Accused Products, the first window regions is sized such that a portion of
the plurality of display areas is visible.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

11. The display system defined in claim 1
wherein each of the plurality of display
areas is individually and variably sized.

As shown in the above reproduced image of the Notification Window for the
Droid X, for a large number of notifications, only a portion of the display areas
can be visible all of the display areas associated with the notifications can be
visible.

For the ’002 Accused Products, each of the plurality of display areas is individually and
variably sized.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

As shown in the above reproduced image of the Notification Window for the
Droid X, the display areas are individually sized to display the information to be
displayed. In particular, the first display area is larger than the new two display
areas.

21. A method for generating control
information comprising:

The ’002 Accused Products perform methods for generating control information.

creating an operating environment for a
plurality of individual programming
modules associated with different
application programs that provide status
and/or control functions;

The ’002 Accused Products create an operating environment for a plurality of individual
programming modules associated with different application programs that provide status
and/or control functions.

•

•

As one example, the Droid X includes the Android 2.1 operating system software.
The Android operating system software included on the Droid X generates
control information for controlling the operation of the Droid X.

As one example, the Android operating system software as implemented on the
Droid X allows for the operation of a plurality of individual programming
modules associated with different application programs that provide status and/or
control functions. These different application programs can include a phone
application, a map application, and a messaging application. Exh. B-1 [Droid
17

U.S. Patent No. 6,493,002

Infringement Contentions
X User’s Guide] at 10; 31; 39.

Exh. B-1 [Droid X User’s Guide] at 7.
•

One example of an application program that provides control information is the
phone application, which instructs the Droid X to perform phone functions
including making and answering calls. Exh. B-1 [Droid X User’s Guide] at 1011.

18

U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 10.
•

One example of an application that provides status functions is the voicemail
application, which indicates, for example, that a new voicemail has been
received.

19

U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

generating a first window sized to
accommodate a plurality of display areas
for indicia resulting from executing at
least one of the plurality of individual
programming modules,

A second example of an application that provides status functions is the email
application, which indicates, for example, that a new email has been received.
Exh. B-1 [Droid X User’s Guide] at 9.

The Accused ’002 Products generate a first window sized to accommodate a plurality of
display areas for indicia resulting from executing at least one of the plurality of
individual programming modules,
•

As one example, the Android operating system software as implemented on the
Droid X generates a phone status and notifications window (“Notification
Window”) that is sized to accommodate a plurality of display areas.

20

U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

•

wherein each of the plurality of display
areas is associated with one of the
plurality of individual programming
modules, and

In the above reproduced image of the Notification Window for the Droid X, the
display areas on the Notifications Window of the Droid X each include an indicia
that results from executing a programming module. Id. For example, the “new
email” display area includes indicia resulting from executing an email module.
The indicia for the “new email” display area include a textual indication of the
new email as well as an icon. A second example is shown in the “new
voicemail” display area, which includes indicia resulting from executing a
voicemail module. Id. The indicia for the “new voicemail” display area include
a textual indication of the new voicemail as well as an icon.
The sizing of the “Notification Window” changes as the window is dragged down
by the user. The arrow in the above reproduced image represents the window
being dragged down by the user, where multiple notifications can be provided.

For the ’002 Accused Products, each of the plurality of display areas is associated with
one of the plurality of individual programming modules.
•

As one example, the display areas within the Notification Window generated by
the Android operating system software as implemented on the Droid X are each
associated with an individual programming module.
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U.S. Patent No. 6,493,002

Infringement Contentions

.
Exh. B-1 [Droid X User’s Guide] at 9.
•

wherein the first window is independently
displayed and independently active of any
application program, the first window
region and the plurality of independent
display areas implemented in a window
layer that appears on top of application
programming windows that may be
generated;

In the above reproduced image of the Notification Window for the Droid X, the
display areas are each associated with one of the programming module. Id. For
example, the display area for the “new email” notification is associated with an
email programming module and the “new voicemail” notification is associated
with a voicemail module. Id.

For the ’002 Accused Products, the first window is independently displayed and
independently active of any application program, the first window region and the
plurality of independent display areas implemented in a window layer that appears on top
of application programming windows that may be generated.

22

U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

In the above reproduced image of the Notification Window for the Droid X, the
Notification Window is displayed and active independent of whatever application
program was displayed when the Notification Window was dragged open by the
user. Id. The Notification Window, including its display areas, is implemented
on a window layer on top of whichever application program was displayed when
the Notification Window is opened by the user. Id.

•

The Notification Window is independent of the application programs. It receives
messages passed from applications requesting the display of a notification in the
form of “Intent” messages. Exh. B-2 [Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)].

displaying the indicia in each of said
The ’002 Accused Products display the indicia in each of said plurality of display areas
plurality of display areas by executing one by executing one of a plurality of individual programming modules corresponding to
of a plurality of individual programming
each indicia.
modules corresponding to each indicia;

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

selecting one of the indicia, wherein the
selecting comprises a first programming
module determining which of said
plurality of display areas is selected and
sending a message to a programming
module of said plurality of individual
programming modules responsible for
generating a display of a selected indicia;

In the above reproduced image of the Notification Window for the Droid X,
indicia are displayed in each of the display areas by executing a programming
module corresponding to the indicia. For example, the “new email” display area
includes indicia resulting from executing an email module. The indicia for the
“new email” display area include a textual indication of the new email as well as
an icon. A second example is shown in the “new voicemail” display area, which
includes indicia resulting from executing a voicemail module. Id. The indicia
for the “new voicemail” display area include a textual indication of the new
voicemail as well as an icon.

The ’002 Accused Products select one of the indicia, wherein the selecting comprises a
first programming module determining which of said plurality of display areas is selected
and sending a message to a programming module of said plurality of individual
programming modules responsible for generating a display of a selected indicia.

24

U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

In the above reproduced image of the Notification Window for the Droid X, one
of the indicia can be selected based on a touch-based indication from a user. The
touch-based indication is performed by a programming module that determines
which display area was touched by the user.

Exh. B-2 [Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)]. The
selection results in a message called an “intent” that is sent to the programming
module responsible for generating a display of that indicia. For example, if a
user touches the “new email” indicia, an intent will be sent to an email
25

U.S. Patent No. 6,493,002

Infringement Contentions
programming module and if a user touches the “new voicemail” indicia, an intent
will be sent to a voicemail programming module. Exh. B-1 [Droid X User’s
Guide] at 9; Exh. B-2 [Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)].

said programming module performing a
function in response to a selection.

The programming module of the ’002 Accused Products performs a function in response
to a selection.
•

As a result of receiving an Intent as discussed in the preceding step, the receiving
programming module can perform a function called an “Activity.”

Exh. B-2 [Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)]. For
example, the “new email” display area includes indicia resulting from executing
an email module. The indicia for the “new email” display area include a textual
indication of the new email as well as an icon. A second example is shown in
the “new voicemail” display area, which includes indicia resulting from
executing a voicemail module. Exh. B-1 [Droid X User’s Guide] at 9. The
indicia for the “new voicemail” display area include a textual indication of the
new voicemail as well as an icon.
22. The method defined in claim 21
wherein one of said plurality of indicia
comprises status information.

For the ’002 Accused Products one of the plurality of indicia can include status
information.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•
26. An interactive computer-controlled
display system comprising:

In the above reproduced image of the Notification Window for the Droid X, the
“new email” notification is status information. Id.

The ’002 Accused Products comprise interactive computer-controlled display systems.
•

As one example, the Droid X includes an interactive computer-controlled display
system.

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Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 2.
a means for positioning a cursor on a data
display screen;

The ’002 Accused Products include a means for positioning a cursor on a data display
screen.
•

As one example, the Droid X includes a touch screen for positioning a cursor on
the display screen.

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Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 2.
•

a means for creating an operating
environment for a plurality of individual
programming modules associated with
different application programs that
provide status and/or control functions,

The ’002 patent discloses structure corresponding to the recited “means for
positioning” as including a “trackball, stylus, mouse, or trackpad, etc.” ’002
patent 5:2-3. The touch screen included in the Droid X falls within the scope of
equivalents under 35 U.S.C. § 112, ¶ 6, to the disclosed corresponding structures.

The ’002 Accused Products include a means for creating an operating environment for a
plurality of individual programming modules associated with different application
programs that provide status and/or control functions.
•

As one example, the Droid X includes the Android 2.1 operating system software,
which creates an operating environment for programming modules associated
with different application programs that provide status and/or control functions.

•

The ’002 patent discloses structure corresponding to the recited “means for
creating” as including “an operating system and system functions.” ’002 patent
8:55-64. The Android 2.1 operating system falls within the scope of equivalents
under 35 U.S.C. § 112, ¶ 6, to the disclosed corresponding structures.
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U.S. Patent No. 6,493,002
wherein a first window region is
displayed having a plurality of display
areas on said data display screen,

Infringement Contentions
The ’002 Accused Products display a first window region having a plurality of display
areas on the data display screen.
•

As one example, the Android operating system software as implemented on the
Droid X generates a Notification Window having a plurality of display areas on
the data display screen.

Exh. B-1 [Droid X User’s Guide] at 9.
wherein the first window region is
independently displayed and
independently active of any application
program, and

For the ’002 Accused Products, the first window region is independently displayed and
independently active of any application program.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

wherein each of the plurality of display
areas is associated with one of the
plurality of individual programming
modules,

In the above reproduced image of the Notification Window for the Droid X, the
Notification Window is displayed and active independent of whatever application
program was displayed when the Notification Window was dragged open by the
user. Id.

For the ’002 Accused Products, each of the plurality of display areas is associated with
one of the plurality of individual programming modules.
•

As one example, the display areas within the Notification Window generated by
the Android operating system software as implemented on the Droid X are each
associated with an individual programming module.

31

U.S. Patent No. 6,493,002

Infringement Contentions

.
Exh. B-1 [Droid X User’s Guide] at 9.
•

the first window region and the plurality
of independent display areas implemented
in a window layer that appears on top of
application programming windows that
may be generated; and

In the above reproduced image of the Notification Window for the Droid X, the
display areas are each associated with one of the programming module. Id. For
example, the display area for the “new email” notification is associated with an
email programming module and the “new voicemail” notification is associated
with a voicemail module. Id.

For the ’002 Accused Products, the first window region and the plurality of independent
display areas implemented in a window layer that appears on top of application
programming windows that may be generated.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

a means for executing at least one of the
plurality of individual programming
modules to generate information for
display in one of the plurality of display
areas in the first window region, wherein
at least one of the plurality of display
areas and its associated programming
module is-sensitive to user input, wherein
an interactive display activity is enabled.

The Notification Window, including its display areas, is implemented on a
window layer on top of whichever application program was displayed when the
Notification Winder is opened by the user. Id.

The ’002 Accused Products include a means for executing at least one of the plurality of
individual programming modules to generate information for display in one of the
plurality of display areas in the first window region, wherein at least one of the plurality
of display areas and its associated programming module is-sensitive to user input,
wherein an interactive display activity is enabled.
•

As one example, the Droid X includes a processor that generates individual
programming modules to generate information for display in one of the display
areas in the Notification Window, wherein at least one of the display areas and its
associated programming module is sensitive to user input, wherein an interactive
display is enabled.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 2.
•

28. The display system defined in claim
26 wherein said at least one of the
plurality of display areas is variably sized.

The ’002 patent discloses structure corresponding to the recited “means for
executing” as a “processor.” ’002 patent 4:28-38. The processor included in the
Droid X is the same as or equivalent under 35 U.S.C. § 112, ¶ 6, to the disclosed
corresponding structure.

For the ’002 Accused Products, at least one of the plurality of display areas is variably
sized.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

In the above reproduced image of the Notification Window for the Droid X, the
display areas for the notifications are variably sized. Id. For example, the four
notifications depicted above are of at least three different sizes.

29. The display system defined in claim
For the accused devices, the size of the first window region is variable.
26 wherein size of the first window region
is variable.

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U.S. Patent No. 6,493,002

Infringement Contentions
Exh. B-1 [Droid X User’s Guide] at 9.
•

30. The display system defined in claim
29 wherein the first window region is
sized such that none of the plurality of
display areas is visible.

In the above reproduced image of the Notification Window for the Droid X, the
Notification Window is shown being pulled down by a user as indicated by the
blue arrow. Id. The Notification Window is variably sized as the user pulls
down the Notification Window.

For the ’002 Accused Products, the first window region can be sized such that none of
the plurality of display areas is visible.

Exh. B-1 [Droid X User’s Guide] at 7.
•

31. The display system defined in claim
29 wherein the first window regions is
sized such that all of the plurality of

In the above reproduced image of the home screen for the Droid X, the
Notification Window is shown before being pulled down by a user, where none
of the display areas is visible.

For the ’002 Accused Products, the first window region can be sized such that all of the
plurality of display areas are visible.
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U.S. Patent No. 6,493,002

Infringement Contentions

display areas are visible.

Exh. B-1 [Droid X User’s Guide] at 9.
•

As shown in the above reproduced image of the Notification Window for the
Droid X, for small numbers of notifications all of the display areas associated
with the notifications can be visible.

32. The display system defined in claim
For the ’002 Accused Products, the first window regions is sized such that a portion of
29 wherein the first window regions is
the plurality of display areas is visible.
sized such that a portion of the plurality of
display areas is visible.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

As shown in the above reproduced image of the Notification Window for the
Droid X, for a large number of notifications, only a portion of the display areas
can be visible all of the display areas associated with the notifications can be
visible.

36. The display system defined in claim
For the ’002 Accused Products, each of the plurality of display areas is individually and
26 wherein each of the plurality of display variably sized.
areas is individually and variably sized.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

37. The display system defined in claim
26 wherein the first window region
always appears in front of application
windows.

As shown in the above reproduced image of the Notification Window for the
Droid X, the display areas are individually sized to display the information to be
displayed. In particular, the first display area is larger than the new two display
areas.

For the ’002 Accused Products, the first window region always appears in front of
application windows.

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U.S. Patent No. 6,493,002

Infringement Contentions

•

As shown in the above reproduced images of the Notification Window for the
Droid X, for a large number of notifications, only a portion of the display areas
can be visible all of the display areas associated with the notifications can be
visible.

46. A computer readable medium
containing executable computer program
instructions, which when executed by a
data processing system, cause the data
processing system to perform a method
for generating control information
comprising:

The ’002 Accused Products include a computer readable medium containing executable
computer program instructions, which when executed by a data processing system, cause
the data processing system to perform a method for generating control information
comprising.

creating an operating environment for a
plurality of individual programming

The accused computer readable medium containing executable computer program
instructions, when executed, creates an operating environment for a plurality of

•

As one example, the Droid X includes a memory that stores the Android 2.1
operating system software. The Android operating system software included on
the Droid X when executed by the processor of the Droid X, causes the processor
to generate control information. See generally Exh. B-1 [Droid X User’s
Guide].

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U.S. Patent No. 6,493,002
modules associated with different
application programs that provide status
and/or control functions;

Infringement Contentions
individual programming modules associated with different application programs that
provide status and/or control functions.
•

As one example, the Android operating system software as implemented on the
Droid X allows for the operation of a plurality of individual programming
modules associated with different application programs that provide status and/or
control functions. These different application programs can include a phone
application, a map application, and a messaging application.

Exh. B-1 [Droid X User’s Guide] at 7.
•
generating a first window sized to
accommodate a plurality of display areas
for indicia resulting from executing at
least one of the plurality of individual
programming modules,

An example application program that provides control information is the phone
application, which instructs the Droid X to perform phone functions.

The accused computer readable medium containing executable computer program
instructions, when executed, generates a first window sized to accommodate a plurality
of display areas for indicia resulting from executing at least one of the plurality of
individual programming modules.
•

As one example, the Android operating system software as implemented on the
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U.S. Patent No. 6,493,002

Infringement Contentions
Droid X generates a Notification Window that is sized to accommodate a
plurality of display areas.

Exh. B-1 [Droid X User’s Guide] at 9.
•

•

wherein each of the plurality of display
areas is associated with one of the
plurality of individual programming

In the above reproduced image of the Notification Window for the Droid X, the
display areas on the Notifications Window of the Droid X each include an indicia
that results from executing a programming module. Id. For example, the “new
email” display area includes indicia resulting from executing an email module.
The indicia for the “new email” display area include a textual indication of the
new email as well as an icon. A second example is shown in the “new
voicemail” display area, which includes indicia resulting from executing a
voicemail module. Id. The indicia for the “new voicemail” display area include
a textual indication of the new voicemail as well as an icon.
The sizing of the “Notification Window” changes as the window is dragged down
by the user. The arrow in the above reproduced image represents the window
being dragged down by the user, where multiple notifications can be provided.

For the accused computer readable medium containing executable computer program
instructions, when executed, each of the plurality of display areas is associated with one
of the plurality of individual programming modules.
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U.S. Patent No. 6,493,002
modules, and

Infringement Contentions
•

As one example, the display areas within the Notification Window generated by
the Android operating system software as implemented on the Droid X are each
associated with an individual programming module.

.
Exh. B-1 [Droid X User’s Guide] at 9.
•

wherein the first window is independently
displayed and independently active of any
application program, the first window
region and the plurality of independent
display areas implemented in a window
layer that appears on top of application
programming windows that may be
generated;

In the above reproduced image of the Notification Window for the Droid X, the
display areas are each associated with one of the programming module. Id. For
example, the display area for the “new email” notification is associated with an
email programming module and the “new voicemail” notification is associated
with a voicemail module. Id.

For the accused computer readable medium containing executable computer program
instructions, when executed, the first window is independently displayed and
independently active of any application program, the first window region and the
plurality of independent display areas implemented in a window layer that appears on top
of application programming windows that may be generated.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

displaying the indicia in each of the
plurality of display areas by executing one
of a plurality of individual programming
modules corresponding to each indicia;
and

In the above reproduced image of the Notification Window for the Droid X, the
Notification Window is displayed and active independent of whatever application
program was displayed when the Notification Window was dragged open by the
user. Id. The Notification Window, including its display areas, is implemented
on a window layer on top of whichever application program was displayed when
the Notification Winder is opened by the user. Id.

The accused computer readable medium containing executable computer program
instructions, when executed, displays the indicia in each of the plurality of display areas
by executing one of a plurality of individual programming modules corresponding to
each indicia.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

selecting one of the indicia, wherein the
selecting comprises a first programming
module determining which of the plurality
of display areas is selected and sending a
message to a programming module of the
plurality of individual programming
modules responsible for generating a
display of a selected indicia, and

In the above reproduced image of the Notification Window for the Droid X,
indicia are displayed in each of the display areas by executing a programming
module corresponding to the indicia. For example, the “new email” display area
includes indicia resulting from executing an email module. The indicia for the
“new email” display area include a textual indication of the new email as well as
an icon. A second example is shown in the “new voicemail” display area, which
includes indicia resulting from executing a voicemail module. Id. The indicia
for the “new voicemail” display area include a textual indication of the new
voicemail as well as an icon.

The accused computer readable medium containing executable computer program
instructions, when executed, selects one of the indicia, wherein the selecting comprises a
first programming module determining which of the plurality of display areas is selected
and sending a message to a programming module of the plurality of individual
programming modules responsible for generating a display of a selected indicia.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

In the above reproduced image of the Notification Window for the Droid X, one
of the indicia can be selected based on a touch-based indication from a user. The
touch-based indication is performed by a programming module that determines
which display area was touched by the user.

Exh. B-2 [Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)]. The
selection results in a message called an “intent” that is sent to the programming
module responsible for generating a display of that indicia. For example, if a
user touches the “new email” indicia, an intent will be sent to an email
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U.S. Patent No. 6,493,002

Infringement Contentions
programming module and if a user touches the “new voicemail” indicia, an intent
will be sent to a voicemail programming module. Exh. B-1 [Droid X User’s
Guide] at 9; Exh. B-2 [Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)].

the programming module performing a
function in response to a selection.

The accused computer readable medium containing executable computer program
instructions, when executed, includes a programming module that performs a function in
response to a selection.
•

As a result of receiving an Intent as discussed in the preceding step, the receiving
programming module can perform a function called an “Activity.”

Exh. B-2 [Creating Status Bar Notifications
(http://developer.android.com/guide/topics/ui/notifiers/notifications.html)]. For
example, if a user touches the “new email” indicia in the above reproduced
Notification Window, an Intent will result in an Activity including the opening of
an email programming module and if a user touches the “new voicemail” indicia
in the above reproduced Notification Window, an Intent will result in an Activity
including opening a voicemail programming module.
47. The computer readable medium as set
forth in claim 46 wherein ones of the
indicia comprises status information.

For the accused computer readable medium, ones of the indicia comprise status
information.

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U.S. Patent No. 6,493,002

Infringement Contentions

Exh. B-1 [Droid X User’s Guide] at 9.
•

In the above reproduced image of the Notification Window for the Droid X, the
“new email” notification is status information. Id.

48