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

Filing 97

Declaration of Carlos A. Rodriguez filed by Defendants Motorola Mobility, Inc., Motorola, Inc. re: 96 Claims Construction Initial Brief, 95 Motion Requesting Claims Construction (Attachments: # 1 Exhibit 1 - Patent No. 6,275,983, # 2 Exhibit 2 - Patent No. 5,969,705, # 3 Exhibit 3 - Patent No. 5,566,337, # 4 Exhibit 4 - Patent No. 5,455,599, # 5 Exhibit 5 - Patent No. 6,424,354, # 6 Exhibit 6 - Reissued Patent No. RE 39,486, # 7 Exhibit 7 - Patent No. 5,929,852, # 8 Exhibit 8 - Patent No. 5,946,647, # 9 Exhibit 9 - Patent No. 5,481,721, # 10 Exhibit 10 - Patent No. 6,493,002, # 11 Exhibit 11 - Patent No. 6,175,559, # 12 Exhibit 12 - Patent No. 5,490,230, # 13 Exhibit 13 - Patent No. 5,319,712, # 14 Exhibit 14 - Patent No. 5,572,193, # 15 Exhibit 15 - Excerpts from '983 Patent Prosecution History, # 16 Exhibit 16 - Excerpts from '354 Patent Prosecution History, # 17 Exhibit 17 - Excerpts from '486 Patent Prosecution History, # 18 Exhibit 18 - Excerpts from '230 Patent Prosecution History, # 19 Exhibit 19 - Apple's Infringement Contentions Claim Chart for '983 Patent, # 20 Exhibit 20 - Apple's Infringement Contentions Claim Chart for '705 Patent, # 21 Exhibit 21 - Apple's Infringement Contentions Claim Chart for '337 Patent, # 22 Exhibit 22 - Apple's Infringement Contentions Claim Chart for '599 Patent, # 23 Exhibit 23 - Apple's Infringement Contentions Claim Chart for '354 Patent, # 24 Exhibit 24 - Apple's Infringement Contentions Claim Chart for '486 Patent, # 25 Exhibit 25 - Apple's Infringement Contentions Claim Chart for '852 Patent, # 26 Exhibit 26 - Apple's Infringement Contentions Claim Chart for '647 Patent, # 27 Exhibit 27 - Apple's Infringement Contentions Claim Chart for '721 Patent, # 28 Exhibit 28 - Apple's Infringement Contentions Claim Chart for '002 Patent, # 29 Exhibit 29 - Excerpts from NeXTSTEP Object-Oriented Programming and the Objective C Language, # 30 Exhibit 30 - July 30, 2010 ITC Order Construing Terms of Asserted Claims in Inv. No. 337-TA-704, # 31 Exhibit 31 - April 4, 2011 Joint Motion to Amend Filed in ITC Inv. No. 337-TA-710, # 32 Exhibit 32 - Excerpts from '002 Patent Prosecution History, # 33 Exhibit 33 - Patent No. 5,588,105, # 34 Exhibit 34 - Patent No. 5,659,693, # 35 Exhibit 35 - Henderson & Card Article, # 36 Exhibit 36 - Patent No. 5,202,961, # 37 Exhibit 37 - Patent App. No. 08/316,237) (Hansen, Scott)

EXHIBIT 28

Exhibit B – U.S. Patent No. 6,493,002
Motorola directly and/or indirectly infringes at least claims 1, 21, and 46 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, Flipout, Flipside, i1, and Xoom (collectively, “the ’002 Accused Products”).1
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.
In addition to Motorola’s direct infringement of the claims of the ’002 patent through its development, testing,
manufacture and use of its devices, Motorola also indirectly infringes claim 21 of the ’002 patent. Manufacturers, retailers,
distributors, end-users and others in the distribution channel of the ’002 Accused Products directly infringe these claims by using,
selling, offering for sale, and/or importing these devices into the United States. Motorola contributes to and induces the infringement
of asserted claim 21 through its promotion and provision of intentional marketing, sale and/or technical support of the ’002 Accused
Products and associated specialized components in the United States, and through the intentional design, marketing, manufacture, sale,
and/or technical support of the ’002 Accused Products abroad to induce direct infringement in the United States. Motorola
supplies ’002 Accused Products and actively encourages the use, sale, offer for sale, and importation of the same in the United States
through the promotion and provision of marketing literature and user guides, which induces and results in direct infringement. See,
e.g., Motorola Droid X User Guide (WI-Apple0034078-34145). Upon information and belief, Motorola has known or should have
known that these actions would cause direct infringement of the ’002 patent and did so with specific intent to encourage direct
infringement. Additionally, the ’002 Accused Products have no substantial non-infringing uses.
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.

1

Motorola has announced additional smartphones including XRT and Titanium which may also infringe the ’002 Patent.
Apple reserves the right to supplement this analysis and this list of accused products as discovery into these newly announced products
progresses.

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.

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.

2

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

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.
9

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

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
11

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.

•

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)].

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

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

•

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.

12

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

Infringement Contentions
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.

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.

13

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.

14

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.

15

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.
16

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.

17

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;

18

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.

19

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
20

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.
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

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.
21

U.S. Patent No. 6,493,002
for generating control information
comprising:

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

Infringement Contentions
•

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].

The accused computer readable medium containing executable computer program
instructions, when executed, creates 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 7.
22

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

Infringement Contentions
•

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
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.
•

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
23

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

Infringement Contentions
a textual indication of the new voicemail as well as an icon.
•

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

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.
•

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
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.
24

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

Infringement Contentions

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;

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.

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.

25

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.

26

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
27

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.

28