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

Filing 92

Declaration of Christine Saunders Haskett filed by Plaintiffs Apple, Inc., NEXT SOFTWARE, INC. re: 90 Motion Requesting Claims Construction (Attachments: # 1 Ex. 1 Moto Infring. Cont. Ex. A, # 2 Ex. 2 '157 patent, # 3 Ex. 3 '179 patent, # 4 Ex. 4 '329 patent, # 5 Ex. 5 '230 file history, # 6 Ex. 6 Oxford dictionary definition, # 7 Ex. 7 '559 file history, # 8 Ex. 8 The OSI Model, # 9 Ex. 9 ISO Standard, # 10 Ex. 10 Japanese file history, # 11 Ex. 11 Japanese prosecution appeal, # 12 Ex. 13 Moto Infring. Cont. Ex. E, # 13 Ex. 14 IEEE Standard, # 14 Ex. 15 '333 patent, # 15 Ex. 16 '721 file history, # 16 Ex. 17 '193 file history, # 17 Ex. 18 Moto Infring. Cont. Ex. F, # 18 Ex. 19 Merriam Webster Dictionary, # 19 Ex. 20 Webster's Dictionary) (Haslam, Robert)

EXHIBIT 18

EXHIBIT F
UNITED STATES PATENT NO. 5,572,193
PRELIMINARY INFRINGEMENT ANALYSIS OF CLAIMS 16–19, 29–361
Accused Apple Products:2 iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPad, iPad 3G, iPod
Touch (each generation), MacBook, MacBook Pro, MacBook Air,
iMac, Mac mini, Mac Pro, Apple TV, AirPort Extreme Card,
AirPort Extreme Base Station, AirPort Express Base Station, Time
Capsule
'193 Patent Claim

Accused Apple Products

16. A method of authentication
between a subscriber unit and a
communication unit of a
communication system,
comprising:

Upon information and belief, an iPhone 43 performs each and
every step of this claim in the course of normal use.
Additionally, a user of an iPhone 4 performs each and every
step of this claim in the course of such use. Furthermore,
Apple has performed each and every step of this claim, has
actively induced users to perform such steps, and has
contributed to such use at least by selling the iPhone 4 and
providing directions for its use.
The iPhone 4 is stated to be compliant with at least IEEE Std.
802.11b-1999 in the United States. See, e.g., iPhone 4
Technical Specifications, available at http://www.apple.com/
iphone/specs.html; Wi-Fi Certified Interoperability Certificate
for iPhone 4, available at http://certifications.wi-fi.org/
pdf_certificate.php?cid=WFA8724 (certifying Wi-Fi
compliance). The iPhone 4 is stated to be compliant with WiFi Protected Access 2 ("WPA2"). See Wi-Fi Certified
Interoperability Certificate for iPhone 4, available at
http://certifications.wi-fi.org/pdf_certificate.php?cid=
WFA8724 (certifying WPA2 compliance). Upon information
and belief, WPA2 certification requires compliance with IEEE
Std. 802.11i-2004. See Wi-Fi Alliance, WPA2 Q&A

1

Motorola Mobility's investigation is ongoing and discovery and claim construction are not yet complete. Mobility
reserves the right to supplement or amend these contentions with contentions arising under the doctrine of
equivalents in response to any proposed or ordered claim construction, subsequent discovery response or production,
or subsequent disclosure made pursuant to FRCP 26.

2

This list of Accused Apple Products was created based on publicly available information. Motorola reserves the
right to supplement and/or update this list of Accused Apple Products as appropriate.
3

This chart provides Motorola's preliminary infringement analysis based upon the iPhone 4's stated compliance
with representative standards referenced herein. Upon information and belief, the analysis set forth in this chart for
claims 16–19 applies equally to each of the following identified Accused Apple Products that comply with those
standards: iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPad, iPad 3G, iPod Touch (each generation), MacBook,
MacBook Pro, MacBook Air, iMac, Mac mini, Mac Pro, Apple TV, AirPort Extreme Card, AirPort Base Station,
AirPort Extreme Base Station, AirPort Express Base Station, Time Capsule.

EXHIBIT F

See id. § 7.2.2 ("The DA field is the destination of the
MSDU . . . ."). Thus, an iPhone 4 generates an authentication
message as a function of the provided plurality of bits
identifying the destination because the CCMP MPDU is
computed in part as a function of the received destination
MAC address.

(c) transmitting the
authentication message and the
at least part of the plurality of
information bits from the
subscriber unit to the
communication system.

Upon information and belief, the CCMP MPDU is an
authentication message because the CCMP MPDU cannot be
successfully decapsulated, i.e., received, unless the frame
body and AAD can be authenticated. See id. § 8.3.3.4.1.
Upon information and belief, an iPhone 4 transmits the
authentication message and at least part of the plurality of
information bits to the communication system because, in
accordance with IEEE Std. 802.11-2007, and in compliance
with WPA2 certification, an iPhone 4 transmits a CCMP
MPDU using the services of the physical layer. See IEEE Std.
802.11-2007 §§ 6.1.1, 12.1.
Upon information and belief, both the authentication message
and the at least part of the plurality of the information bits
from the subscriber system are transmitted because the CCMP
MPDU comprises both the authentication message and the
destination MAC address.

See IEEE Std. 802.11-2007 § 8.3.3.2. The CCMP MPDU
comprises the authentication message because the MIC is part