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

Filing 239

Exhibit to 236 Declaration,,,, filed by Motorola, Inc., Motorola Mobility, Inc. (Attachments: # 1 Exhibit 1 - Patent No. RE39,486, # 2 Exhibit 2 - Patent No. 5,929,852, # 3 Exhibit 4 - Apple's Infringement Contentions Chart for RE '486 Patent, # 4 Exhibit 5 - Apple's Infringement Contentions Chart for '852 Patent, # 5 Exhibit 6 - Excerpts from '575 File History, # 6 Exhibit 9 - Patent No. 5,455,599, # 7 Exhibit 10 - July 30, 2010 ITC Order No. 18, Inv. No. 337-TA-704, # 8 Exhibit 12.1 - July 15, 2011 ITC Initial Determination, Inv. No. 337-TA-710, # 9 Exhibit 12.2 - July 15, 2011 ITC Initial Determination, Inv. No. 337-TA-710, # 10 Exhibit 13 - Patent No. 5,481,721, # 11 Exhibit 14 - Excerpts from '721 File History) (Burrows, James)

Exhibit 5

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WISCONSIN

APPLE INC. and NeXT SOFTWARE INC.
(f/k/a NeXT COMPUTER, INC.),
Plaintiffs,

Case No. 10-CV-662 (BBC)
JURY TRIAL DEMANDED

v.
MOTOROLA, INC. and MOTOROLA
MOBILITY, INC.
Defendants.

PLAINTIFFS’ SUPPLEMENTAL OBJECTIONS AND RESPONSES TO
DEFENDANTS’ FIRST SET OF INTERROGATORIES (NO. 6)
Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Plaintiffs
Apple Inc. (“Apple”) and NeXT Software, Inc. (“NeXT”) (collectively, “Plaintiffs”)
hereby provide their first supplemental objections and responses to the first set of
interrogatories served by Defendants Motorola, Inc. and Motorola Mobility, Inc.
(collectively, “Defendants”).
GENERAL OBJECTIONS
Plaintiffs reiterate and incorporate by reference their objections to Defendants’
First Set of Interrogatories, as if specifically stated herein.
FURTHER OBJECTIONS AND RESPONSES
INTERROGATORY NO. 6
For each claim of the Apple Asserted Patents that you allege Defendants have
infringed or are infringing, describe the complete basis for your contention that

Defendants are infringing or have infringed that claim by describing in a claim chart on
an element-by-element basis where each element of each Asserted Claim can be found in
each Accused Instrumentality of Defendants that you contend infringes that claim,
whether such alleged infringement is literal or by equivalents, how 35 U.S.C. § 112(6) is
satisfied, if applicable, and whether such alleged infringement is direct (i.e., under 35
U.S.C. § 271(a)) or indirect (i.e., under 35 U.S.C. §§ 271(b) or (c)).
RESPONSE TO INTERROGATORY NO. 6
In addition to their General Objections, Plaintiffs object to this interrogatory as
vague and ambiguous, overly broad, and unduly burdensome. Plaintiffs further object to
this interrogatory to the extent that it seeks information that is (a) protected by the
attorney-client privilege or work product doctrine; (b) confidential, proprietary, or trade
secret; (c) subject to Plaintiffs’ legal or contractual obligation of nondisclosure or
confidentiality to a third party; and/or (d) public or readily available to Defendants.
Plaintiffs further object to the extent this interrogatory calls for a legal conclusion.
Plaintiffs also object to this contention interrogatory as premature because, among other
things, Defendants have not yet produced documents or information about its products
used to infringe the Apple Asserted Patents. Plaintiffs expressly reserve the right to
amend, supplement, and/or correct its response to this interrogatory as additional
information becomes available to Plaintiffs during the course of their discovery and
investigation, in response to any claim construction by the Court, or in response to
Defendants’ responses to Plaintiffs’ interrogatories (or any supplement thereto).
Subject to their General and Specific Objections, Plaintiffs respond as follows:
Plaintiffs will provide their infringement contentions by March 4, 2011 pursuant to the

2

Court’s Preliminary Pretrial Order and will supplement those contentions as appropriate.
Plaintiffs will provide their expert reports regarding infringement of the Apple Asserted
Patents by September 2, 2011 pursuant to the Court’s Preliminary Pretrial Order and will
supplement those reports as appropriate and necessary and as permitted by the Court.
SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 6
Subject to their General and Specific Objections above, Plaintiffs hereby
incorporate by reference Plaintiffs’ Identification of Asserted Claims and Accused
Products regarding U.S. Patent Nos. 7,479,949 (“the ’949 patent”), 6,493,002 (“the ’002
patent”), 5,838,315 (“the ’315 patent”), RE 39,486 (the “RE ’486 patent”), 6,424,354
(“the ’354 patent”), 6,343,263 (“the ’263 patent”), 6,275,983 (“the ’983 patent”),
5,969,705 (“the ’705 patent”), 5,946,647 (“the ’647 patent”), 5,929,852 (“the ’852
patent”), 5,915,131 (“the ’131 patent”), 5,566,337 (“the ’337 patent”), 5,519,867 (“the
’867 patent”), 5,481,721 (“the ’721 patent”) and 5,455,599 (“the ’599 patent”), served on
March 4, 2011. In addition, based upon presently known information, Plaintiffs append
claim charts for each of the Apple Patents-in-Suit as follows:
•
•
•
•
•
•
•
•
•
•
•
•
•

Ex. A: ’949 Patent, claims 1, 2, 4-6, and 9-20.
Ex. B: ’002 Patent, claims 1, 3-7, 11, 21, 22, 26, 28-32, 36, 37, 46,
and 47.
Ex. C: ’315 Patent, claims 1, 7, 8, and 12-14.
Ex. D: RE ’486 Patent, claims 1-3, 6-12, 14-17, and 20.
Ex. E: ’354 Patent, claims 1, 3, 5-8, 41, and 42.
Ex. F: ’263 Patent, claims 1-6, 24, 25, 29, and 30.
Ex. G: ’983 Patent, claims 1-11, 16, 17, and 22.
Ex. H: ’705 Patent, claim 1.
Ex. I: ’647 Patent, claims 1, 3, 4, 8, 9, 13-15, 19, 20, and 22.
Ex. J: ’852 Patent, claims 1-3, 7-13, and 15-19.
Ex. K: ’131 Patent, claims 1, 3, 4, 7-12, and 15-17.
Ex. L: ’337 Patent, claims 1, 3, 6-10, 12, 14, 16-19, 21, 23, and 24.
Ex. M: ’867 Patent, claims 1-3, 7-10, 12, 13, and 32.

3

•
•

Ex. N: ’721 Patent, claims 1, 3-7, 11-14, 19-22, and 24.
Ex. O: ’599 Patent, claims 1-3, 15, 16, 18, 19, 22, and 24-26.

Defendants infringe or have infringed these claims (collectively, “the Asserted
Claims”) by making, using, selling, offering for sale or importing at least the following
devices: Droid, Droid 2, Droid 2 Global, Droid X, Droid Pro, Cliq, Cliq XT, Cliq 2,
Charm, BackFlip, Devour, i1, Citrus, Defy, Bravo, Flipout, Flipside, Atrix 4G, and Xoom
(collectively “the Accused Products”). As described in further detail in the appended
claim charts, see Exs. A-O, each element of each of the Asserted Claims is met by the
Accused Products. Where the basis for infringement is not significantly distinct,
Plaintiffs have selected representative Accused Products as appropriate.
Defendants directly and indirectly infringe all of the Asserted Claims. Defendants
directly infringe these claims by making, using, offering for sale, or selling the Accused
Products within the United States, or by importing the Accused Products into the United
States. In addition, Defendants’ customers directly infringe the Asserted Claims by using
the Accused Products, and Defendants induce this direct infringement of the Asserted
Claims by selling the Accused Products and by providing manuals and other user guides
encouraging their customers to use the Accused Products in an infringing manner.
Defendants further contribute to this direct infringement of the Asserted Claims by
selling the Accused Products, which are specifically designed to practice the inventions
of the Asserted Claims and have no substantial non-infringing uses. Based on presently
known information, Plaintiffs contend that the Accused Products made, used, sold,
offered for sale or imported by Defendants infringe each of the Asserted Claims literally
or, in the alternative, under the doctrine of equivalents.

4

These contentions are preliminary and based only on publicly available
information. Defendants have not yet provided discovery as to twelve of the fifteen
Apple Patents-in-Suit and Plaintiffs’ investigation of Defendants’ infringement is
ongoing. Based on discovery and Plaintiffs’ continued investigations, Plaintiffs may
identify additional claims that are infringed and additional accused products, including
products that Defendants may introduce in the future. Plaintiffs expressly reserve the
right to amend their response to this Interrogatory to include such products. Also, these
contentions are made based on information ascertained to date, and Plaintiffs expressly
reserve the right to modify or amend the contentions contained herein based on the
Court’s claim constructions or to reflect additional information that becomes available to
Plaintiffs as discovery and their investigation proceeds.

Dated: March 18, 2011

WEIL, GOTSHAL & MANGES LLP
By:

/s/ Jill J. Ho
Jill J. Ho
Attorneys for Apple Inc. and
NeXT Software, Inc.

5

CERTIFICATE OF SERVICE
I declare that I am employed with the law firm of Weil, Gotshal & Manges
LLP, whose address is 201 Redwood Shores Parkway, Redwood Shores, California
94065-1175. I am not a party to the within cause, and I am over the age of eighteen
years. I further declare that on March 18, 2011, I served a corrected copy of:
PLAINTIFFS’ SUPPLEMENTAL OBJECTIONS AND RESPONSES TO
DEFENDANTS’ FIRST SET OF INTERROGATORIES (NO. 6)
BY U.S. MAIL by placing a true copy thereof enclosed in a sealed
envelope with postage thereon fully prepaid, addressed as follows, for collection and
mailing in accordance with the firm’s ordinary business practices. I am readily familiar
with the practice for collection and processing of mail, and know that in the ordinary
course of business practice that the document(s) described above will be deposited with
the U.S. Postal Service on the same date as sworn to below.
BY ELECTRONIC SERVICE by electronically mailing a true
and correct copy through the electronic mail system to the email address(es) set forth in
the service list below.
BY OVERNIGHT DELIVERY by placing a true copy thereof
enclosed in a sealed envelope with overnight delivery fees provided for, addressed as
follows, for collection by Federal Express in accordance with ordinary business practices.
I am readily familiar with the practice for collection and processing of correspondence
for overnight delivery and know that in the ordinary course of business practice the
document(s) described above will be deposited by an employee or agent in a box or other
facility regularly maintained by Federal Express for collection on the same day that the
document(s) are deposited.
Lynn Stathas (# 1003695)
[e-mail]
REINHART BOERNER VAN DEUREN, S.C.
22 East Mifflin Street
Madison, WI 53701-2018
Phone: [phone]
Fax: [phone]

Edward J. DeFranco
[e-mail]
51 Madison Avenue, 22nd Floor
New York, NY 10010
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendants Motorola, Inc. and
Motorola Mobility, Inc.

I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct. Executed on March 18, 2011, at Redwood
Shores, California.
/s/ Jill J. Ho
Jill J. Ho

Exhibit J – U.S. Patent No. 5,929,852
Motorola directly and/or indirectly infringes at least claims 1-3, 7-13, and 15-19 of the ’852 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: Atrix, Bravo, Cliq, Cliq XT, Cliq 2, Charm, Defy, BackFlip, Devour, Droid, Droid 2, Droid 2 Global,
Droid X, Droid Pro, Droid Bionic, Flipout, Flipside, i1, and Xoom (collectively, the “’852 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 ’852 Accused Products meet the limitations of the asserted claims on the same bases as indicated
for the Droid X, unless otherwise stated.
This infringement is preliminary and based only on publicly available information as to the 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 Apple’s continued investigations Apple reserves the right to amend these contentions to identify
additional bases for infringement and additional accused products, including products that Motorola may introduce in the future that
will be infringement. Accordingly, Apple reserves its right to amend these contentions as discovery and its investigation proceeds.
Also, these disclosures are made based on information ascertained to date, and Apple expressly reserves the right to modify or amend
the disclosures contained herein based on the Court’s claim constructions or to reflect additional information that becomes available to
Apple.
U.S. Patent 5,929,852

Infringement Contentions

1. A method of efficiently accessing
information from a network resource
located on a computer network for display
on a computer coupled to the network, the
network resource having one or more
associated data types, each data type being
accessible by a corresponding objectoriented software component, the method
comprising the steps of:

The ’852 Accused Products perform a method of efficiently accessing information from a
network resource located on a computer network for display on a computer coupled to the
network, the network resource having one or more associated data types, each data type
being accessible by a corresponding object-oriented software component.
The ’852 Accused Products are computers coupled to a computer network.
• For example, the Motorola Droid X includes a Texas Instruments OMAP36301000 1GHz processor See Exh. J-1 [Droid X by Motorola MotoDev Specs] and
is capable of executing numerous computer programs such as email programs,
web browsers, and instant messaging applications. See Exh. J-2 [Droid X by
Motorola Tech Specs]. Accordingly, the Droid X is a computer.
Moreover, the ’852 Accused Products are coupled to computer networks, such as the

U.S. Patent 5,929,852

Infringement Contentions
Internet via cellular and wireless networks. (Id.).
The ’852 Accused Products perform a method of efficiently accessing information from a
network resource.
• For example. the ’852 Accused Products use widgets to allow a user to access
information from a network resource and to display network information to a
user. See Exh. J-3 [Android Developer Site - “App Widgets”]; see also Exh.
J-4 [Droid X By Motorola User Guide] at p.8. A widget includes data located
on the Internet of various types, such as text and images. Each such data type is
accessible by a corresponding object-oriented software component. See Exh. J3 [Android Developer Site - “App Widgets”].

defining at least one network component
that integrates the object-oriented
software components needed to access the
one or more data types associated with the
network resource;

The ’852 Accused Products perform the step of defining at least one network component
that integrates the object-oriented software components needed to access the one or more
data types associated with the network resource.
• For example, the Android framework is object-oriented; its applications are
written using the Java programming language. See Exh. J-5 [Android
Developer Site - “Application Fundamentals”].
Moreover, the Android software framework defines components, including network
components. In general, Android applications are composed of essential components
that the system can instantiate and run as needed. Id.
• For example, Android includes Java classes designed to access services directed
to the computer network, such as the URLStreamHandler and URLConnection
classes, along with the HttpURLConnection and JarURLConnection classes,
which are subclasses of the URLConnection class. See, e.g., Exh. J-6 [Android
Developer Site - “java.net.HttpURLConnection”]; Exh. J-7 [Android Developer
Site - “java.net.URLStreamHandler”]; Exh. J-8 [Android Developer Site “java.net.URLConnection”]; Exh. J-9 [Android Developer Site “java.net.JarURLConnection”]. The combination of these classes defines the
network component layer.
The network component layer in Android is designed to be used in developing network
2

U.S. Patent 5,929,852

Infringement Contentions
navigation components, such as web browsers, email viewers, and similar applications,
which provide services directed to the network. See Exh. J-10 [Android Developer Site“What is Android?”]
• For example, the Droid X includes a weather widget, news application, and
news and weather application, which integrate the object-oriented software
components needed to access data types associated with the network resources.
See Exh. J-3 [Android Developer Site - “App Widgets”]; see also Exh. J-4
[Droid X By Motorola User Guide] at p.8.

Closed Weather Widget on Droid X, Source: Droid X
creating an encapsulated entity component
containing a reference to a location of the
network resource on the computer
network, the encapsulated entity
component also identifying the at least
one network component that was defined

The ’852 Accused Products perform the step of creating an encapsulated entity
component containing a reference to a location of the network resource on the computer
network, the encapsulated entity component also identifying the at least one network
component that was defined for the network resource.
• For example, on information and belief, Droid X’s weather widget, for example,
3

U.S. Patent 5,929,852
for the network resource;

Infringement Contentions
has at least one object corresponding to an encapsulated entity that contains a
reference to a location of the network resource on the computer network.
• For example, the weather widget contains the contents of a referenced network
resource, such as a URL for a webpage, and can display the content on the Droid
X display screen.
Moreover, the weather widget on the Droid X, for example, also identifies the at least one
network component that was defined for each of the network resources.
• For instance, the weather widget in the Motorola Droid X defines that, when a
user taps on the widget, the Droid X should open the Weather widget. See Exh.
J-3 [Android Developer Site - “App Widgets”]. The user may further change
the temperature units or add location when the weather widget is open. Id.

4

U.S. Patent 5,929,852

Infringement Contentions
Open Weather Widget on Droid X, Source: Droid X

storing the encapsulated entity component
as a visual object on the computer;

The ’852 Accused Products perform the step of storing an encapsulated entity component
as a visual object on the computer.
• For example, the Droid X stores the weather widget as a visual object on its
screen. See Exh. J-4 [Droid X By Motorola User Guide] at p.8.

Closed Weather Widget on Droid X, Source: Droid X
in response to manipulation of the visual
object with a pointing device, displaying
the contents of the network resource on a
screen of the computer by invoking the
object-oriented software components
integrated by the at least one identified

The ’852 Accused Products perform the step of, in response to manipulation of a visual
object with a pointing device, displaying the contents of the network resource on the
screen of the computer by invoking the object-oriented software components integrated
by the at least one identified network component.
• For example, when a user touches the weather widget on the Droid X, the Droid
X responds by invoking a visual representation of the network resource, i.e.,
5

U.S. Patent 5,929,852
network component.

Infringement Contentions
weather information displaying the information on the Droid X display. See
Exh. J-4 [Droid X By Motorola User Guide] at p.8.

Open Weather Widget on Droid X, Source: Droid X
2. The method of claim 1 wherein the step
of displaying comprises the step of
invoking a first network component for
displaying the contents of the referenced
network resource on the screen, the first
network component comprising a
browsing component.

The ’852 Accused Products perform the method of claim 1 wherein the step of displaying
comprises the step of invoking a first network component for displaying the contents of
the referenced network resource on the screen, the first network component comprising a
browsing component.
• For example, the weather widget in the Droid X is invoked for displaying the
contents of a referenced network resource, such as a URL for a webpage, on the
Droid X display screen. See Exh. J-4 [Droid X By Motorola User Guide] at
p.8.
• On information and belief, the weather widget comprises a browsing
component.
6

U.S. Patent 5,929,852

Infringement Contentions

3. The method of claim 2 wherein the step
of displaying further comprises the step of
invoking a second network component for
transfering [sic] the contents of the
referenced network resource to the first
network component, the second network
component comprising a data stream
component.

The ’852 Accused Products perform the method of claim 2 wherein the step of displaying
further comprises the step of invoking a second network component for transferring the
contents of the referenced network resource to the first network component, the second
network component comprising a data stream component.
• For example, Android includes Java classes designed to access services directed
to the computer network, such as the HttpURLConnection class. See Exh. J-6
[Android Developer Site - “java.net.HttpURLConnection”]. The
HttpURLConnection class includes network components, and can be considered
a second network component. (Id.). In the Droid X, the HttpURLConnection
transfers contents of the reference network resource to the widget, and the
HttpURLConnection comprises a data stream. See Exh. J-6 [Android
Developer Site - “java.net.HttpURLConnection”]; see also Exh. J-3 [Android
Developer Site - “App Widgets”]
• On information and belief, the weather widget, for example, implements
HttpURLConnection class.

7. Apparatus for efficiently accessing
information from a network resource
located on a computer network for display
on a computer coupled to the network, the
network resource having one or more
associated data types, each data type being
accessible by a corresponding objectoriented software component, the
apparatus comprising:

The ’852 Accused Products include an apparatus for efficiently accessing information
from a network resource located on a computer network for display on a computer
coupled to the network, the network resource having one or more associated data types,
each data type being accessible by a corresponding object-oriented software component.
The ’852 Accused Products are computers coupled to a computer network.
• For example, the Motorola Droid X includes a Texas Instruments OMAP36301000 1GHz processor See Exh. J-1 [Droid X by Motorola MotoDev Specs] and
is capable of executing numerous computer programs such as email programs,
web browsers, and instant messaging applications. See Exh. J-2 [Droid X by
Motorola Tech Specs]. Accordingly, the Droid X is a computer.
Moreover, the ’852 Accused Products are coupled to computer networks, such as the
Internet via cellular and wireless networks. Id.
The ’852 Accused Products efficiently access information from a network resource.
• For example. the ’852 Accused Products use widgets to allow a user to access
7

U.S. Patent 5,929,852

Infringement Contentions
information from a network resource and to display network information to a
user. See Exh. J-3 [Android Developer Site - “App Widgets”]; see also Exh.
J-4 [Droid X By Motorola User Guide] at p.8. A widget includes data located
on the Internet of various types, such as text and images. Each such data type is
accessible by a corresponding object-oriented software component. See Exh. J3 [Android Developer Site - “App Widgets”].

an object-oriented software component
architecture layer configured to define at
least one network component that
integrates the object-oriented software
components needed to access the one or
more data types associated with the
network resource; and

The ’852 Accused Products include an object-oriented software component architecture
layer that is configured to define at least one network component that integrates the
object-oriented software components needed to access the one or more data types
associated with the network resource.
• For example, the Android framework is object-oriented; its applications are
written using the Java programming language. See Exh. J-5 [Android
Developer Site - “Application Fundamentals”].
Moreover, the Android software framework defines components, including network
components. In general, Android applications are composed of essential components
that the system can instantiate and run as needed. Id.
• For example, Android includes Java classes designed to access services directed
to the computer network, such as the URLStreamHandler and URLConnection
classes, along with the HttpURLConnection and JarURLConnection classes,
which are subclasses of the URLConnection class. See, e.g., Exh. J-6 [Android
Developer Site - “java.net.HttpURLConnection”]; Exh. J-7 [Android Developer
Site - “java.net.URLStreamHandler”]; Exh. J-8 [Android Developer Site “java.net.URLConnection”]; Exh. J-9 [Android Developer Site “java.net.JarURLConnection”]. The combination of these classes defines the
network component layer.
The network component layer in Android is designed to be used in developing network
navigation components, such as web browsers, email viewers, and similar applications,
which provide services directed to the network. See Exh. J-10 [Android Developer Site“What is Android?”].
• For example, the Droid X includes a weather widget, news application, and
8

U.S. Patent 5,929,852

Infringement Contentions
news and weather application, which integrate the object-oriented software
components needed to access data types associated with the network resources.
See Exh. J-3 [Android Developer Site - “App Widgets”]; see also Exh. J-4
[Droid X By Motorola User Guide] at p.8.

Closed Weather Widget on Droid X, Source: Droid X
an encapsulated network entity
component cooperating with the
component architecture layer and
containing a reference to the network
resource and an identifier for the at least
one network component that was defined
for the network resource

The ’852 Accused Products include an encapsulated network entity component
cooperating with the component architecture layer and containing a reference to the
network resource and an identifier for the at least one network component that was
defined for the network resource.
• For example, on information and belief, Droid X’s weather widget, for example,
has at least one object corresponding to an encapsulated entity that contains a
reference to a location of the network resource on the computer network.
• For example, the weather widget contains the contents of a referenced network
resource, such as a URL for a webpage, and can display the content on the Droid
9

U.S. Patent 5,929,852

Infringement Contentions
X display screen.
Moreover, the weather widget on the Droid X, for example, also identifies the at least one
network component that was defined for each of the network resources.
• For instance, the weather widget in the Motorola Droid X defines that, when a
user taps on the widget, the Droid X should open the Weather widget. See Exh.
J-3 [Android Developer Site - “App Widgets”]. The user may further change
the temperature units or add location when the weather widget is open. Id.

Weather Widget Settings on Droid X, Source: Droid X
wherein, the encapsulated network entity
component is manifested as visual object

The ’852 Accused Products include an encapsulated network entity component that is
10

U.S. Patent 5,929,852
on a display screen of the computer and

Infringement Contentions
manifested as a visual object on a display screen of the computer.
• For example, in the Droid X, the weather widget is manifested as a visual object
on the Droid X computer display screen. See Exh. J-4 [Droid X By Motorola
User Guide] at p.8.

Closed Weather Widget on Droid X, Source: Droid X
further wherein, the encapsulated network
entity component is adapted for
manipulation by a pointing device of the
computer to display contents of the
network resource on the screen by
invoking the object-oriented software
components integrated by the at least one
identified network component.

The ’852 Accused Products include an encapsulated network entity component that is
adapted for manipulation by a pointing device of the computer to display contents of the
network resource on the screen by invoking the object-oriented software components
integrated by the at least one identified network component.
• For example, when a user touches the weather widget on the Droid X, the Droid
X responds by invoking the object-oriented software comprising the weather
widget, and displaying the contents of the widget on the Droid X’s display. See
Exh. J-4 [Droid X By Motorola User Guide] at p.8.
11

U.S. Patent 5,929,852

Infringement Contentions

Open Weather Widget on Droid X, Source: Droid X
8. The apparatus of claim 7 further
comprising:
an operating system interfacing with the
component architecture layer to control
the operations of the computer; and
a network component layer coupled to the
component architecture layer to form a
cooperating component computing
arrangement.

The ’852 Accused Products include the apparatus of claim 7 further comprising an
operating system interfacing with the component architecture layer to control the
operations of the computer and a network component layer coupled to the component
architecture layer to form a cooperating component computing arrangement.
• For example, Android is composed of multiple layers, such as layers that include
applications, application frameworks, core libraries, and the underlying Linux
kernel, which interface with each other. See Exh. J-10 [Android Developer
Site - “What is Android?”].
Moreover, Android includes low level code that implements the basic Java class
structure. This layer, which is implemented by the Dalvik Virtual Machine, interfaces
with the operating system to control the operations of the computer. Id.
Moreover, the Android software framework defines components, including network
12

U.S. Patent 5,929,852

Infringement Contentions
components. In general, Android applications are composed of essential components
that the system can instantiate and run as needed. Id.
• For example, Android includes Java classes designed to access services directed
to the computer network, such as the URLStreamHandler and URLConnection
classes, along with the HttpURLConnection and JarURLConnection classes,
which are subclasses of the URLConnection class. See, e.g., Exh. J-6 [Android
Developer Site - “java.net.HttpURLConnection”]; Exh. J-7 [Android Developer
Site - “java.net.URLStreamHandler”]; Exh. J-8 [Android Developer Site “java.net.URLConnection”]; Exh. J-9 [Android Developer Site “java.net.JarURLConnection”]. The combination of these classes defines the
network component layer.
The network component layer in Android is designed to be used in developing network
navigation components, such as web browsers, email viewers, and similar applications,
which provide services directed to the network. See Exh. J-10 [Android Developer Site“What is Android?”]
Moreover, the network component layer and the component architecture layer in the ’852
Accused Products are coupled in integrating relation to form a cooperating component
computing arrangement.
• For example, components within the software component architecture layer take
advantage of the network-directed services provided by network components,
thus coupling the component architecture layer and the network component
layer in integrating relation. See Exh. J-5 [Android Developer Site “Application Fundamentals”].

9. The apparatus of claim 8 wherein the
cooperating component computing
arrangement generates the encapsulated
network entity.

The ’852 Accused Products include the apparatus of claim 8 wherein the cooperating
component computing arrangement generates the encapsulated network entity.
• For example, in the Droid X, the Android framework generates the weather
widget, which encapsulates the weather data from the network. See Exh. J-3
[Android Developer Site - “App Widgets”]; see also Exh. J-4 [Droid X By
Motorola User Guide] at p.8.
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10. The apparatus of claim 9 wherein the
reference to the network resource is a
pointer that identifies the address of the
network resource on a computer network.

The ’852 Accused Products include the apparatus of claim 9 wherein the reference to the
network resource is a pointer that identifies the address of the network resource on a
computer network.

11. The apparatus of claim 10 wherein the
pointer is a uniform resource locator.

The ’852 Accused Products include the apparatus of claim 10 wherein the pointer is a
uniform resource locator.

• For instance, in the Droid X, the widget includes a pointer, for example, a
uniform resource locator, that can be resolved to the network address of the
network resource. See Exh. J-3 [Android Developer Site - “App Widgets”];
see also Exh. J-4 [Droid X By Motorola User Guide] at p.8.

• For example, the weather widget in the Droid includes a pointer, which is a
uniform resource locator. See Exh. J-3 [Android Developer Site - “App
Widgets”]; see also Exh. J-4 [Droid X By Motorola User Guide] at p.8.
12. The apparatus of claim 11 wherein the
uniform resource locator has a first
portion that identifies the network
resource and a second portion that
specifies a means for accessing that
resource.

The ’852 Accused Products include the apparatus of claim 11 wherein the uniform
resource locator has a first portion that identifies the network resource and a second
portion that specifies a means for accessing that resource.

13. The apparatus of claim 11 wherein the
uniform resource locator is a character
string that describes a protocol used to
address the network resource, a server on
which the resource resides, a path to the
resource and a resource filename.

The ’852 Accused Products include the apparatus of claim 11 wherein the uniform
resource locator is a character string that describes a protocol used to address the network
resource, a server on which the resource resides, a path to the resource and a resource
filename.

• For example, in the Droid X, the uniform resource locator has a first portion that
identifies the network resource and a second portion that specifies a means for
accessing that resource. For example, if the uniform resource locator were
http://www.accuweather.com, the first portion is accuweather.com and the
second portion is http:// that specifies a means for accessing accuweather.com.
See Exh. J-3 [Android Developer Site - “App Widgets”]; see also Exh. J-4
[Droid X By Motorola User Guide] at p.8.

• For example, in the Droid X, if the uniform resource locator were http://
www.accuweather.com/USNY0996, the protocol is http that is used to address
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the network resource, the server would be accuweather.com on which the
resource resides, and this includes a path to the resource and resource filename,
www.accuweather.com/USNY0996. See Exh. J-3 [Android Developer Site “App Widgets”]; see also Exh. J-4 [Droid X By Motorola User Guide] at p.8.

15. Apparatus for efficiently accessing
information from a network resource
located on a computer network for display
on a computer coupled to the network, the
network resource having one or more
associated data types, each data type being
accessible by a corresponding objectoriented software component, the
apparatus comprising:

The ’852 Accused Products include an apparatus for efficiently accessing information
from a network resource located on a computer network for display on a computer
coupled to the network, the network resource having one or more associated data types,
each data type being accessible by a corresponding object-oriented software component.
The ’852 Accused Products are computers coupled to a computer network.
• For example, the Motorola Droid X includes a Texas Instruments OMAP36301000 1GHz processor. See Exh. J-1 [Droid X by Motorola MotoDev Specs]
and is capable of executing numerous computer programs such as email
programs, web browsers, and instant messaging applications. See Exh. J-2
[Droid X by Motorola Tech Specs]. Accordingly, the Droid X is a computer.
Moreover, the ’852 Accused Products are coupled to computer networks, such as the
Internet via cellular and wireless networks. Id.
The ’852 Accused Products efficiently access information from a network resource.
For example. the ’852 Accused Products use widgets to allow a user to access
information from a network resource and to display network information to a user. See
Exh. J-3 [Android Developer Site - “App Widgets”]; see also Exh. J-4 [Droid X By
Motorola User Guide] at p.8. A widget includes data located on the Internet of various
types, such as text and images. Each such data type is accessible by a corresponding
object-oriented software component. See Exh. J-3 [Android Developer Site - “App
Widgets”].

means for defining at least one network
component that integrates the objectoriented software components needed to
access the one or more data types
associated with the network resource;

The ’852 Accused Products include means for defining at least one network component
that integrates the object-oriented software components needed to access the one or more
data types associated with the network resource.
• For example, the means for defining at least one network component that
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integrates the object-oriented software components needed to access the one or
more data types associated with the network resource is the Android software
framework, which is the low level code that implements the basic Java class
structure. This layer is implemented by the Dalvik Virtual Machine. See Exh.
J-10 [Android Developer Site - “What is Android?”].
Moreover, Android framework is object-oriented; its applications are written using the
Java programming language. See Exh. J-5 [Android Developer Site - “Application
Fundamentals”].
Moreover, the Android software framework defines components, including network
components. In general, Android applications are composed of essential components
that the system can instantiate and run as needed. Id.
• For example, Android includes Java classes designed to access services directed
to the computer network, such as the URLStreamHandler and URLConnection
classes, along with the HttpURLConnection and JarURLConnection classes,
which are subclasses of the URLConnection class. See, e.g., Exh. J-6 [Android
Developer Site - “java.net.HttpURLConnection”]; Exh. J-7 [Android Developer
Site - “java.net.URLStreamHandler”]; Exh. J-8 [Android Developer Site “java.net.URLConnection”]; Exh. J-9 [Android Developer Site “java.net.JarURLConnection”]. The combination of these classes defines the
network component layer.
The network component layer in Android is designed to be used in developing network
navigation components, such as web browsers, email viewers, and similar applications,
which provide services directed to the network. See Exh. J-10 [Android Developer Site“What is Android?”]
• For example, the Droid X includes a weather widget, news application, and
news and weather application, which integrate the object-oriented software
components needed to access data types associated with the network resources.
See Exh. J-3 [Android Developer Site - “App Widgets”]; see also Exh. J-4
[Droid X By Motorola User Guide] at p.8.

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Closed Weather Widget on Droid X, Source: Droid X
means for creating an encapsulated entity
component containing a reference to a
location of the network resource on the
computer network, the encapsulated entity
component also identifying the at least
one network component that was defined
for the network resource;

The ’852 Accused Products include means for creating an encapsulated entity component
containing a reference to a location of the network resource on the computer network, the
encapsulated entity component also identifying the at least one network component that
was defined for the network resource.
• For example, the means for creating an encapsulated entity component
containing a reference to a location of the network resource on the computer
network is the Android software architecture.
• On information and belief, Droid X’s weather widget, for example, has at least
one object corresponding to an encapsulated entity that contains a reference to a
location of the network resource on the computer network.
• For example, the weather widget contains the contents of a referenced network
resource, such as a URL for a webpage, and can display the content on the Droid
X display screen.
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Moreover, the weather widget on the Droid X, for example, also identifies the at least one
network component that was defined for each of the network resources.
• For instance, the weather widget in the Motorola Droid X defines that, when a
user taps on the widget, the Droid X should open the Weather widget. See Exh.
J-3 [Android Developer Site - “App Widgets”]. The user may further change
the temperature units or add location when the weather widget is open. Id.

Open Weather Widget on Droid X, Source: Droid X
means for storing the encapsulated entity
component as a visual object on the
computer; and

The ’852 Accused Products include means for storing an encapsulated entity component
as a visual object on the computer.
• For example, the means for storing an encapsulated entity component as a visual
object on the computer in the Droid X is the RAM. See Exh. J-1 [Droid X by
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Motorola MotoDev Specs].
The Droid X stores the weather widget as a visual object on its screen. See Exh. J-4
[Droid X By Motorola User Guide] at p.8.

Closed Weather Widget on Droid X, Source: Droid X
means, responsive to manipulation of the
visual object with a pointing device, for
displaying contents of the network
resource on a screen of the computer by
invoking the object-oriented software
components integrated by the at least one
identified network component.

The ’852 Accused Products include means, responsive to manipulation of a visual object
with a pointing device, for displaying the contents of the network resource on the screen
of the computer by invoking the object-oriented software components integrated by the at
least one identified network component.
• For example, the means, responsive to manipulation of a visual object with a
pointing device, for displaying the contents of the network resource on the
screen of the computer by invoking the object-oriented software components
integrated by the at least one identified network component in Android is
Window Manager. See Exh. J-10 [Android Developer Site -“What is
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Android?”].
In addition, when a user touches the weather widget on the Droid X, the Droid X
responds by invoking a visual representation of the network resource, i.e., weather
information displaying the information on the Droid X display. See Exh. J-4 [Droid X
By Motorola User Guide] at p.8.

Open Weather Widget on Droid X, Source: Droid X
16. The apparatus of claim 15 wherein the
means for displaying comprises means for
invoking a first network component for
displaying the contents of the referenced
network resource on the screen, the first
network component comprising a
browsing component.

The ’852 Accused Products include the apparatus of claim 15 wherein the means for
displaying comprises means for invoking a first network component for displaying the
contents of the referenced network resource on the screen, the first network component
comprising a browsing component.
• For example, the means for invoking a first network component for displaying
the contents of the referenced network resource on the screen is the Android
software architecture.
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In addition, the weather widget in the Droid X is invoked for displaying the contents of a
referenced network resource, such as a URL for a webpage, on the Droid X display
screen and the widget comprises a browsing component. See Exh. J-4 [Droid X By
Motorola User Guide] at p.8.

17. The apparatus of claim 16 wherein the
means for displaying further comprises
means for invoking a second network
component for transfering [sic] the
contents of the referenced network
resource to the first network component,
the second network component
comprising a data stream component.

The ’852 Accused Products include the apparatus of claim 16 wherein the means for
displaying further comprises means for invoking a second network component for
transferring the contents of the referenced network resource to the first network
component, the second network component comprising a data stream component.
• For example, the means for invoking a second network component for
transferring the contents of the referenced network resource to the first network
component is the Android software framework.
In addition, Android’s architecture includes Java classes designed to access services
directed to the computer network, such as the HttpURLConnection class. See Exh. J-6
[Android Developer Site - “java.net.HttpURLConnection”]. The HttpURLConnection
class includes network components, and can be considered a second network component.
Id.. In the Droid X, the HttpURLConnection transfers contents of the reference network
resource to the widget, and the HttpURLConnection comprises a data stream. See id.;
see also Exh. J-3 [Android Developer Site - “App Widgets”].

18. The apparatus of claim 17 further
comprising means for creating objects for
communication among the encapsulated
entity and network components through
application programming interfaces.

The ’852 Accused Products include the apparatus of claim 17 further comprising means
for creating objects for communication among the encapsulated entity and network
components through application programming interfaces.

19. The apparatus of claim 18 wherein the
means for creating comprises means for
constructing the encapsulated entity
component from an Item objected defined
by an Item object class.

The ’852 Accused Products include the apparatus of claim 18 wherein the means for
creating comprises means for constructing the encapsulated entity component from an
Item objected defined by an Item object class.

• For example, the means for creating objects for communication among the
encapsulated entity and network components through application programming
interfaces is the Android software framework.

• For example, the means for constructing the encapsulated entity component
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from an Item objected defined by an Item object class is the Android software
framework.

22