px 1027 - microsoft€¦ · civil action no. 10-389-lps softview llc's responses to kyocera...

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

SOFTVIEW LLC,

Plaintiff,

v.

APPLE INC.; AT&T MOBILITY LLC; DELL INC.; HTC CORP.; HTC AMERICA, INC.; HUAWEI TECHNOLOGIES CO., LTD.; FUTUREWEI TECHNOLOGIES, INC.; KYOCERA CORP.; KYOCERA WIRELESS CORP.; LG ELECTRONICS, INC.; LG ELECTRONICS USA, INC.; LG ELECTRONICS MOBILECOMM U.S.A., INC.; MOTOROLA MOBILITY INC.; SAMSUNG ELECTRONICS CO., LTD.; SAMSUNG ELECTRONICS AMERICA, INC.; SAMSUNG TELECOMMUNICATIONS AMERICA, LLC; and SONY ERICSSON MOBILE COMMUNICATIONS (USA) INC.,

Defendants.

)))))))))))))))))))))))))))

Civil Action No. 10-389-LPS

SOFTVIEW LLC'S RESPONSES TO KYOCERA CORP. AND KYOCERA WIRELESS CORP.'S FIRST SET OF INTERROGATORIES (NO. 1)

Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, and the Local

Rules of the District of Delaware, Plaintiff SoftView LLC ("SoftView") hereby makes the

following objections and responses to Defendants Kyocera Corp. and Kyocera Wireless

Corp.'s ("Defendants") First Set of Interrogatories (No. 1) as follows:

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INTRODUCTION

This response is made solely for the purpose of this action. The response is subject

to all objections as to competence, relevance, materiality, propriety, and admissibility, and to

any and all other objections on the grounds that would require the exclusion of any

statements contained herein if such Interrogatory were asked of, or statements contained

herein were made by, a witness present and testifying in court, all of which objections and

grounds are expressly reserved and may be interposed at the time of trial.

Discovery in this matter is ongoing. Accordingly, the following response is given

without prejudice to SoftView's right to produce evidence of any subsequently discovered

fact or facts that it may later recall or discover. SoftView further reserves the right to

change, amend, or supplement any or all of the matters contained in this response as

additional facts are ascertained, analyses are made, research is completed, and contentions

are made.

Objections to each Interrogatory are made on an individual basis below. From time

to time, for special emphasis, SoftView will repeat in the specific objections certain

objections also set forth in the General Objections. The specific objections are submitted

without prejudice to, and without in any way waiving, the General Objections listed below

but not expressly set forth in the response. The assertion of any objection to any

Interrogatory below is neither intended as, nor shall in any way be deemed a waiver of

SoftView's right to assert that or any other objection at a later date.

No incidental or implied admissions are intended by the response below. The fact

that SoftView has answered or objected to any of the Interrogatories should not be taken as

an admission that SoftView accepts or admits the existence of any "facts" set forth or

assumed by that Interrogatory. The fact that SoftView has answered part or all of any

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Interrogatory is not intended to be, and shall not be construed to be, a waiver by SoftView

of any part of any objection to that Interrogatory.

GENERAL OBJECTIONS

1. SoftView objects to the Interrogatories to the extent that they purport to

impose on SoftView obligations that differ from or exceed those required by the Federal

Rules of Civil Procedure, the Local Rules of the United States District Court for the District

of Delaware, or any order or ruling by the Court in this action. SoftView will not comply

with any purported obligation not imposed by law.

2. SoftView objects to the Interrogatories on the ground and to the extent that

they purport to seek information protected by the work product doctrine, attorney-client

privilege, the settlement privilege, or any other privilege or restriction on discovery.

SoftView will not produce information protected by such privileges or restrictions. Any

inadvertent or unintentional disclosure of such information shall not be deemed a waiver of

any applicable privilege or restriction.

3. SoftView objects to the Interrogatories to the extent that they seek

information that is neither relevant to the subject matter of this action nor reasonably

calculated to lead to the discovery of admissible evidence.

4. SoftView objects to the Interrogatories as premature to the extent they require

SoftView to make a legal conclusion or seek SoftView's legal contentions and other

information that SoftView is not required to disclose at this stage of the litigation.

SoftView's response is subject to revision.

5. SoftView objects to the Interrogatories to the extent they are compound and

are actually multiple interrogatories on the ground that each is an impermissible effort to

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circumvent the 10 individual interrogatory limit set by the Scheduling Order in this action

(D.I. 250).

6. SoftView objects to the Interrogatories to the extent they are vague,

ambiguous, or without sufficient specificity to identify what information is requested.

7. SoftView objects to the Interrogatories to the extent that they are overbroad,

unduly burdensome, oppressive, or seeking information that is beyond the proper scope of

discovery under the Federal Rules of Civil Procedure, including but not limited to Federal

Rule of Civil Procedure 26(b).

8. SoftView objects to the Interrogatories to the extent that they seek disclosure

of trade secret, proprietary, or other confidential or competitively sensitive information of

SoftView or personal information that is protected by statutory, constitutional, common law

or privacy rights. SoftView reserves the right not to provide any of this information until it

receives appropriate approvals.

9. SoftView objects to the Interrogatories to the extent they call for trade secret,

proprietary, or other confidential or competitively sensitive information of third parties.

SoftView will not disclose any of this information without approval or, where applicable, a

court order.

10. SoftView objects to the Interrogatories to the extent they call for information

SoftView does not have the legal authority to release. SoftView will not disclose any of this

information without approval.

11. SoftView objects to the Interrogatories to the extent they seek premature

expert discovery.

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12. SoftView objects to the Interrogatories to the extent they seek information

that is publicly available, in the possession, custody, or control of either Defendant or any

person or entity other than SoftView, and is equally accessible to Defendants.

13. SoftView objects to the Interrogatories to the extent they seek documents or

things that do not exist or are not within SoftView's possession or control.

14. SoftView objects to the Interrogatories to the extent they request information

concerning patent claims and claim terms that have not yet been construed by the Court.

SoftView reserves its right to modify or supplement its responses as a result of any rulings

by the Court bearing on claim construction and/or discovery bearing on claim construction.

15. SoftView objects to the definition of "SoftView" set forth in paragraph 1 of

the Definitions to the extent that that definition purports to impose discovery obligations on

persons or entities other than the parties to this action, and to the extent it seeks discovery

from individuals or entities over which SoftView has no control.

16. SoftView objects to the defined term "Asserted Patents" in paragraph 3 of the

definitions as vague and ambiguous, overbroad and unduly burdensome to the extent it

encompasses any patents other than U.S. Patent Nos. 7,461,353 (the "'353 patent") and

7,831,926 (the "'926 patent").

17. To the extent that SoftView responds to any Interrogatory, its responses

reflect only the current state of knowledge, understanding, and belief of SoftView with

regard to matters about which inquiry has been made. As discovery in this matter is not yet

complete, SoftView may not yet have uncovered all information or facts pertinent to any

such Interrogatory and may not yet have identified or located all persons with knowledge of

pertinent information or facts. SoftView expects and consequently reserves the right to

modify or supplement its response at a later time with whatever pertinent information it may

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subsequently discover. Furthermore, this response is provided without prejudice to using or

relying on at trial any subsequently discovered information or facts, or information omitted

from these responses as a result of mistake, oversight, or inadvertence. SoftView further

reserves the right to produce additional facts and evidence at trial and to object on

appropriate grounds to the introduction into evidence of any portion of these responses.

Each and all of the foregoing General Objections are hereby expressly incorporated

into each and all of the following specific responses. For particular emphasis, one or more

of these General Objections may be reiterated in a specific response. The absence of any

reiteration in a given specific response is neither intended as, nor shall be construed as, a

limitation or waiver of any General Objection made herein. Moreover, the inclusion of a

specific objection to a specific response is neither intended as, nor shall be construed as, a

limitation or waiver of any General Objection or any other specific objection made herein.

SPECIFIC OBJECTIONS AND RESPONSES

INTERROGATORY NO. 1:

Explain in detail SoftView’s infringement contentions against Kyocera, including

but not limited to, for each Asserted Claim: (a) a chart identifying each Accused

Instrumentality and an identification of where each limitation of each Asserted Claim is

found within each such Accused Instrumentality, including an identification that is as

specific as possible of the structure(s), material(s), code, and/or act(s) in the Accused

Instrumentality that constitutes or performs the claimed limitation, together with an

indication of whether the limitation is present literally or under the doctrine of equivalents in

the Accused Instrumentality and, to the extent SoftView or Kyocera contends a limitation is

governed by 35 U.S.C. § 112 ¶ 6, an identification of the structure(s), material(s) or act(s) in

the Accused Instrumentality that corresponds to the claimed function; (b) an identification of

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each statutory subsection of 35 U.S.C. § 271 that is asserted against each Accused

Instrumentality, including, for each Asserted Claim alleged to be directly infringed in whole

or in part by a person other than Kyocera, a specific identification of the direct infringer or

infringers, a description of the acts that allegedly directly infringe, and a specific description

of the acts of Kyocera that are alleged to establish liability for the alleged direct

infringement; (c) for each Asserted Claim Soft View contends is willfully infringed by

Kyocera, a specific identification of the factual basis for such contention; and (d) an

identification of all documents and things supporting SoftView's infringement contentions

against Kyocera.

RESPONSE TO INTERROGATORY NO. 1:

SoftView incorporates its Introduction and General Statement and Objections recited

above as if set forth fully herein. In addition, SoftView specifically objects to this

Interrogatory as follows: SoftView objects that this Interrogatory is compound and is

actually multiple interrogatories, which is an impermissible effort to circumvent the ten

individual Interrogatory limit set by the Scheduling Order in this action (D.I. 250). SoftView

objects that this Interrogatory seeks information protected by the attorney-client privilege,

the attorney work product doctrine, settlement privilege, or any other applicable privilege or

protection. SoftView objects to this Interrogatory as premature and calling for expert

testimony. SoftView only received initial Interrogatory responses from Defendants several

days ago and has only just begun to receive and review documents from Defendants.

SoftView objects that the Interrogatory calls for an identification of "all" documents and

things supporting SoftView's Infringement contentions at this stage of the litigation.

Discovery in this matter is ongoing, and SoftView's investigation regarding the information

requested by this Interrogatory is not complete. For these and other reasons, any answer to

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this Interrogatory cannot be complete and is subject to supplementation, addition, and/or

correction at a later date when SoftView has had the opportunity to take full discovery and

analyze that discovery.

Subject to, and without waiving, the general and specific objections stated above,

SoftView responds as follows: SoftView asserted that Defendants infringe the asserted

claims in the '353 patent and the '926 patent under 35. U.S.C. § 271(a), (b), and (c).

SoftView incorporates by reference the charts attached as Exhibits A and B setting

forth SoftView's preliminary contentions, based on information currently available to

SoftView, with respect to how Defendants' Accused Devices meet the limitations of the

asserted claims in the '353 patent and the '926 patent.

In addition, Defendants contributorily infringe the asserted method claims in the '353

patent and the '926 patent by offering to sell or selling to third parties within the United

States or importing into the United States the Accused Devices, each of which is an

apparatus constituting a material part of the invention for use by third parties in practicing

the asserted method claims, knowing that the Accused Devices were especially made or

especially adapted for use in infringement of the asserted method claims. The accused

functionalities of the Accused Devices are not suitable for substantial noninfringing use.

In addition, Defendants actively induce infringement of the asserted claims in the

'353 patent and the '926 patent by intentionally causing third parties to infringe by inducing

infringing uses of the Accused Devices. Evidence of the promotion of infringing use

includes Defendants' instructions, marketing, manuals, and guides that are available to users

of the Accused Devices, including documents cited in Exhibits A and B.

All asserted claims are willfully infringed by Defendants. Defendants' infringement

was willful because it had actual knowledge of the '353 patent at least as early as May 2010

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and the '926 patent as early as October 2011. The details of Defendants' actual knowledge

are described in paragraphs 44 and 62 of SoftView's Fourth Amended Complaint in this

action.

Documents and things supporting SoftView's infringement contentions against

Defendants include, but are not limited to, the documents cited in Exhibits A and B.

SoftView expressly reserves the right to supplement this response.

/s/ Erin McCracken By: ______________________________

IRELL & MANELLA LLP Morgan Chu Samuel K. Lu Erin McCracken Dorian Berger Craig Johnson 1800 Avenue of the Stars, Suite 900 Los Angeles, CA 90067-4276 (310) 277-1010 [email protected]; [email protected]; [email protected]; [email protected]; [email protected]

BLANK ROME LLP Steven L. Caponi (# 3484) 1201 Market Street, Suite 800 Wilmington, DE 19801 (302) 425-6400 [email protected]

Attorneys for SoftView LLC July 23, 2012

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U.S. PATENT NO. 7,461,353

EXHIBIT A

2676884

Claim Language Accused Instrumentalities

1. A wireless device, comprising: The accused Kyocera devices1 are wireless devices.

The Echo is a wireless device operating on wireless networks including "EV-DO rev. A dual band digital (800 & 1900 MHz)" and with Wi-Fi connectivity. Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).

The Milano is a wireless device operating on wireless networks including "EV-DO rev. 0 dual band digital (800 & 1900 MHz)" and with Wi-Fi connectivity. Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The Milano also has "Wi-Fi (802.11 b/g/n)" connectivity. Id.

The Zio models are wireless devices. For example, the Zio operates on wireless networks including "CDMA 1x EVDO Rev. A, dual-band digital (800, 1900 MHz)" and has Wi-Fi connectivity. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). Kyocera encourages users to "[u]se Zio's leading-edge, high-speed cellular technology for broadband on the go, or turn it up a notch and settle down in a Wi-Fi hot spot to take advantage of even faster connectivity." Kyocera ZIO, ZIO BY KYOCERA, http://www.ziobykyocera.com/ (last visited January 23, 2012).

processing means; The accused Kyocera devices contain a processing means.

The Echo contains a processing means – a "1GHz Snapdragon processor." Dual Screen

1 The following Kyocera models infringe U.S. Patent No. 7,461,353: Echo, Milano, SANYO Zio, and Zio. SoftView reserves the

right to supplement this infringement analysis with additional Kyocera models as they become known.

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EXHIBIT A


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Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).

The Milano contains a processing means – a "MSM7627T 800MHz" processor. See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Zio models contain a processing means. For example, the Zio contains a "MSM7627 (600MHz)" processor. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012).

wireless communications means, to facilitate wireless communication with a network that supports access to the Internet;

The accused Kyocera devices contain a wireless communication means that facilitates wireless communications with a network that supports access to the Internet.

The Echo contains a wireless communication means. The Echo connects to one or more networks, including the "EV-DO rev. A dual band digital (800 & 1900 MHz)" networks. Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). It also has "Wi-Fi (802.11 b/g)" connectivity and includes "hotspot capability." Id.

The Milano contains a wireless communication means that connects to one or more wireless networks, including the "EV-DO rev. 0 dual band digital (800 & 1900 MHz)" networks. Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). It also has Wi-Fi (802.11 b/g/n) connectivity. Id.

The Zio models contain a wireless communication means that connections to one or more wireless networks. For example, the Zio connects to one or more wireless networks including the "CDMA 1x EVDO Rev. A, dual-band digital (800, 1900 MHz)" networks. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). It also

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has Wi-Fi (IEEE802.11 b/g) connectivity. Id. Kyocera encourages users to "[u]se Zio's leading-edge, high-speed cellular technology for broadband on the go, or turn it up a notch and settle down in a Wi-Fi hot spot to take advantage of even faster connectivity." Kyocera ZIO, ZIO BY KYOCERA, http://www.ziobykyocera.com/ (last visited January 23, 2012).

a display; The accused Kyocera devices contain a display.

The Echo contains "Dual 3.5” WVGA touchscreen displays," which "combine to form a 4.7” display." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).

The Milano contains a "3.0[inch] capacitive touchscreen" display. See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Zio models contain a display. For example, the Zio contains a "3.5[inch] 262K-color TFT LCD WVGA (480x800 pixels)" display with "capacitive touch screen navigation." Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012).

memory; and The accused Kyocera devices contain memory.

The Echo contains "expandable memory." It is sold with a "8GM microSD card included." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).

The Milano contains "512MB/512MB internal memory" and a "2GB microSDTM memory card." See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

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EXHIBIT A


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The Zio models contain memory. For example, the Zio contains "512MB/RAM256MB" of memory. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012).

storage means, in which a plurality of instructions are stored that when executed by the processing means enable the wireless device to perform operations including,

The accused Kyocera devices contain a storage means, in which a plurality of instructions are stored that when executed by the processing means enable the wireless device to perform operations.

The Echo contains memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Echo contains "expandable memory" and is sold with an "8GB microSD card included." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). The instructions, when executed by the processor, enable this model to perform the following operations.

The Milano contains memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Milano contains "512MB/512MB internal memory" and a "2GB microSDTM memory card." See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The instructions, when executed by the processor, enable this model to perform the following operations.

The Zio models contain memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. For example, the Zio contains "512MB/RAM256MB" of memory. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The instructions, when executed by the processor, enable these models to perform the following operations.

rendering a browser interface via which a user is enabled to request access to an

The Echo, Milano, and Zio render a browser interfacevia which a user is enabled to request access to an original Web page, the Web page comprising HTML-based Web

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EXHIBIT A


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original Web page, the Web page comprising HTML-based Web content having an original format defining an original width and height of the Web page and an original page layout, functionality, and design of content on the Web page;

content having an original format defining an original width and height of the Web page and an original page layout, functionality, and design of content on the Web page.

The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, Zio by Kyocera, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, Kyocera Echo, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, Kyocera Wireless, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Android operating system includes a fully functional Web browser capable of requesting and retrieving Web pages. See, e.g., What is Android?, http://developer.android.com/guide/basics/what-is-android.html (last visited February 2, 2012) (describing the Android utilizing an "[i]ntegrated browser based on the open source WebKit engine", and using the associated LibWebCore "modern web browser engine which powers both the Android browser and an embedded web view." The Android graphic engine is "powered by a custom 2D graphics library; 3D graphics based on the Open GL ES 1.0 specification.").

in response to a user request to access the Web page, retrieving the Web page via the wireless communication means, and translating at least a portion of the HTML-based Web content from its original format into scalable content that supports a scalable resolution-independent representation of the Web page that preserves the original page layout, functionality and design of the content defined by its original format

The accused Kyocera devices are configured to translate at least a portion of the HTML-based Web content from its original format into scalable content that supports a scalable resolution-independent representation of the Web page that preserves the original page layout, functionality and design of the content defined by its original format when scaled and rendered. See, e.g., What is Android?, http://developer.android.com/guide/basics/what-is-android.html (last visited February 2, 2012) (describing Android utilizing an "[i]ntegrated browser based on the open source WebKit engine", and using the associated LibWebCore "modern web browser engine which powers both the Android browser and an embedded web view." The Android graphic engine is "powered by a custom 2D graphics library; 3D graphics based on the Open GL ES 1.0 specification."). See, e.g., WebCore Rendering IV – Absolute/Fixed

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EXHIBIT A


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when scaled and rendered; and and Relative Positioning, http://www.webkit.org/blog/117/webcore-rendering-iv-absolutefixed-and-relative-positioning/ (last visited February 2, 2012) (describing the WebCore library in WebKit. WebCore supports four positioning values: "'static', 'absolute', 'fixed,' and 'relative.' Static positioning is the default and means that the object is just positioned using the normal rules of block and line layout." "Relative positioning is exactly like static positioning except that the CSS left, top, right, and bottom properties can be used to apply a translation to the object." "The translation offset that will be applied can be obtained using the following methods…").

scaling the scalable content to render the Web page on the display such that a width of the Web page is rendered to fit across the display.

The accused Kyocera devices all run the Android operating system which includes the Android web browser. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Android web browser takes web page content and scales the the scalable content to render the Web page on the display such that a width of the Web page is rendered to fit across the display. "When the Android Browser loads a web page, the default behavior is to load the page in "overview mode," which provides a zoomed-out perspective of the web page." http://developer.android.com/guide/webapps/targeting.html (last visited June 21, 2012). The "overview mode" displays the web page such that the width of the Web page is rendered to fit across the display. http://developer.android.com/reference/android/webkit/WebSettings.html#getLoadWithOverviewMode() (last visited June 24, 2012).

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EXHIBIT A


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Claim Element Accused Instrumentalities

33. The wireless device of claim 1, wherein a portion of the scalable content comprises vector-based content.

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which supports scalable content that comprises vector-based content.

The Android browser supports scalable vector graphics. See e.g., http://code.google.com/p/svg-android/ (last visited July 12, 2012). The Accused Products also translate HTML based content into scalable content which vector-based content including vector based layout information. WebKit's DOM contains vector-based information associated with the scalable content within a Web page. The generation of a vector-based display list associated with scalable content is illustrated in the RenderBoxModelObject.cpp file which is part of WebKit as shown below.

// If the element is the HTML body element or does not have an associated box // return 0 and stop this algorithm. if (isBody()) return 0; RenderBoxModelObject* offsetPar = offsetParent(); int yPos = (isBox() ? toRenderBox(this)->y() : 0); // If the offsetParent of the element is null, or is the HTML body element, // return the distance between the canvas origin and the top border edge // of the element and stop this algorithm.

Source: http://www.webkit.org/building/checkout.html


36. A mobile hand-held device, comprising:

The accused Kyocera devices are mobile hand-held devices.

The Echo is a mobile hand-held device. The Echo is a mobile device, with battery power

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EXHIBIT A


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and wireless connectivity. See Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). The Echo has dimensions of 4.5 x 2.2 x 0.7 inches, making it easy to hold in one's hand. Id.

The Milano is a mobile hand-held device. The Milano is a mobile device, with battery power and wireless connectivity. Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The Milano has dimensions of 4.1 x 2.4 and 0.7 inches, making it easy to hold in one's hand. Id.

The Zio models are mobile hand-held devices. For example, the Zio is a mobile device, with battery power and wireless connectivity. Kyocera ZIO – Features, ZIO BY

KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Zio has dimensions of 116 x 58.6 x 12.2 mm, making it easy to hold in one's hand. Id.

a processor, The accused Kyocera devices contain a processor.

The Echo contains a "1GHz Snapdragon processor." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).

The Milano contains a "MSM7627T 800MHz" processor. See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Zio models contain a processor. For example, the Zio contains a "MSM7627 (600MHz)" processor. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012).

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EXHIBIT A


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a wireless communications device, to facilitate wireless communication with a network that supports access to the Internet;

The accused Kyocera devices contain a wireless communications devices to facilitate wireless communications with a network that supports access to the Internet.

The Echo contains a wireless communication device that connects to one or more wireless networks, including the "EV-DO rev. A dual band digital (800 & 1900 MHz)" networks. Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). It also has "Wi-Fi (802.11 b/g)" connectivity and includes "hotspot capability." Id.

Milano contains a wireless communication device that connects to one or more wireless networks, including the "EV-DO rev. 0 dual band digital (800 & 1900 MHz)" networks. Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). It also has and "Wi-Fi (802.11 b/g/n) connectivity. Id.

The Zio models contain a wireless communication means devices that connects to one or more wireless networks. For example, the Zio connects to one or more wireless networks, including the "CDMA 1x EVDO Rev. A, dual-band digital (800, 1900 MHz)" networks. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). It also has "Wi-Fi (IEEE802.11 b/g)" connectivity. Id. Kyocera encourages users to "[u]se Zio's leading-edge, high-speed cellular technology for broadband on the go, or turn it up a notch and settle down in a Wi-Fi hot spot to take advantage of even faster connectivity." Kyocera ZIO, ZIO BY KYOCERA, http://www.ziobykyocera.com/ (last visited January 23, 2012).

a display; and The accused Kyocera devices contain a display.

The Echo contains "Dual 3.5” WVGA touchscreen displays," which "combine to form a 4.7” display." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO,

Kyocera PX 1027_18

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http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).



flash memory, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile hand-held device to perform operations including,

The accused Kyocera devices contain flash memory, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile hand-held device to perform operations.

The Echo contains flash memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Echo contains is sold with an "8GB microSD card included." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). The instructions, when executed, enable the this model to perform the following operations.

The Milano contains flash memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Milano contains "512MB/512MB internal memory" and a "2GB microSDTM memory card." See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The instructions, when executed, enable the this model to perform the following operations.

The Zio models contain flash memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. For example, the Zio contains

Kyocera PX 1027_19

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"512MB/RAM256MB" of memory and a "2GB microSD memory card." Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The instructions, when executed, enable these models to perform the following operations.

rendering a browser interface via which a user is enabled to request access to a Web page comprising HTML-based Web content defining an original page layout, functionality, and design of content on the Web page;

The Echo, Milano, and Zio render a browser interfacevia which a user is enabled to request access to an original Web page, the Web page comprising HTML-based Web content having an original format defining an original width and height of the Web page and an original page layout, functionality, and design of content on the Web page.

The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA

ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).


retrieving the Web page via the wireless communications device, and processing HTML-based Web content to produce

The accused Kyocera devices all run the Android web browser which retrieves web pages through the wireless communications interface. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The

Kyocera PX 1027_20

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scalable content; and Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The accused devices all have a wireless communications device:

The Echo contains a wireless communication interface that connects to one or more wireless networks, including the "EV-DO rev. A dual band digital (800 & 1900 MHz)" networks. Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). It also has "Wi-Fi (802.11 b/g)" connectivity and includes "hotspot capability." Id.

The Milano contains a wireless communication interface that connects to one or more wireless networks, including the "EV-DO rev. 0 dual band digital (800 & 1900 MHz)" networks. Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). It also has and "Wi-Fi (802.11 b/g/n) connectivity. Id.

The Zio models contain a wireless communication interface devices that connects to one or more wireless networks. For example, the Zio connects to one or more wireless networks, including the "CDMA 1x EVDO Rev. A, dual-band digital (800, 1900 MHz)" networks. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). It also has "Wi-Fi (IEEE802.11 b/g)" connectivity. Id. Kyocera encourages users to "[u]se Zio's leading-edge, high-speed cellular technology for broadband on the go, or turn it up a notch and settle down in a Wi-Fi hot spot to take advantage of even faster connectivity." Kyocera ZIO, ZIO BY KYOCERA, http://www.ziobykyocera.com/ (last visited January 23, 2012).

Kyocera PX 1027_21

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employing at least one of the scalable content or data derived therefrom to, render the Web page on the display; and

The accused Kyocera devices run the Android operating system which includes the Android Browser. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Android Browser employs at least one of the scalable content or data derived there from to, render the Web page on the accused devices. When the Android Browser loads a web page, the default behavior is to load the page in "overview mode," which provides a zoomed-out perspective of the web page." http://developer.android.com/guide/webapps/targeting.html. The accused devices display the web page content through employing scale factors which convert the content into scalable content. "[T[he Android Browser and WebView scale web pages (effectively zoom the pages) so they display at a size that matches the perceived appearance on a medium density screen. More specifically, the Android Browser and WebView apply approximately 1.5x scaling to web pages on a high density screen (because its screen pixels are smaller) and approximately 0.75x scaling to pages on a low density screen (because its screen pixels are bigger)." Id.

re-render the display in response to associated user inputs to enable the Web page to be browsed at various zoom levels and panned views while preserving the original page layout, functionality, and design of the Web page content at each zoom level and panned view.

The accused Kyocera devices all run the Android operating system, which includes the Android web browser. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/

Kyocera PX 1027_22

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(last visited January 20, 2012).

The Android operating system and its associated browser re-render the display in response to associated user inputs. "[B]rowser . . . Support for double-tap zoom." http://developer.android.com/about/versions/android-2.0-highlights.html (last visited June 23, 2012). "WebView enables smooth transition while panning or zooming." http://developer.android.com/reference/android/webkit/WebSettings.html (last visited June 23, 2012).

The Android browser preserves the original page layout, function and design of the web page when the content is zoomed and/or panned. "Surf the web in style with multi-window browsing, pinch to zoom with auto text reflow." http://www.android.com/devices/detail/htc-wildfire-s (last visited June 23, 2012).

As an example of this functionality, the SANYO Zio re-renders the display in response to associated user inputs to enable a user to browse a web page at various zoom levels and panned views. The SANYO Zio preserves a web page’s original layout and functionality at these various zoom levels and panned views. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to zoom out on the web page.").


43. The mobile hand-held device of claim 36, wherein at least a portion of the scalable content comprises scalable vector-based content.

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which supports scalable content that comprises scalable vector-based content.

The Android browser supports scalable content including Scalable Vector Graphics ("SVG") content. See http://code.google.com/p/svg-android/ (last visited July 16,

Kyocera PX 1027_23

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2012).

The Accused Products translate HTML based content into scalable content wherein at least a portion of the scalable content is scalable vector-based content including vector based layout information. WebKit's DOM contains vector-based information associated with the scalable content within a Web page. The generation of a vector-based display list associated with scalable content is illustrated in the RenderBoxModelObject.cpp file which is part of WebKit as shown below.




48. The mobile hand-held device of claim 36, wherein execution of the instructions performs further operations comprising enabling a user to zoom on a column of the Web content via a

The accused Kyocera devices all incorporate the run the Android operating system, including the Android web browser, which can zoom in on a column so that the column is rendered to fit across the browser display area. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The

Kyocera PX 1027_24

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corresponding user input, wherein in response thereto, the display is re-rendered such that content corresponding to the selected column is rendered to fit across the display.

Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

As an example of this functionality, the SANYO Zio enables a user to zoom on a column such that the column is rendered to fit across the display. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to zoom out on the web page.").


51. The mobile hand-held device of claim 36 wherein the Web content includes at least one image, and wherein execution of the instructions performs further operations comprising enabling a user to zoom on an image via a corresponding user input, wherein in response thereto, the display is re-rendered such that the image is rendered to fit across the display.

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which can zoom in on an image so that the image is rendered to fit across the browser display area. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

As an example of this functionality, the SANYO Zio enables a user to zoom on an image such that the column is rendered to fit across the display. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or

Kyocera PX 1027_25

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the – button to zoom out on the web page.").


52. The mobile hand-held device of claim 51, wherein the corresponding user input comprises tapping on the image via the display.

The accused devices all incorporate the run the Android operating system, including the Android web browser, which can zoom in on an image of the Web page by tapping on the image via the display. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

As an example of this functionality, the Echo enables a user to zoom on an image of the Web page with user input that comprises tapping . See Kyocera Echo Basics Guide (KYC0003514-672) at 101 ("To zoom in . . . on a Web page, tap [graphic] to zoom in.").


58. The mobile hand-held device of claim 36, wherein execution of the instructions performs further operations comprising: parsing HTML-based code corresponding to the retrieved Web page to determine the original page layout of

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which parses markup language code to determine the original page layout of display content within the Web page, wherein the original page layout defines a layout location for a plurality of objects, including at least one of text objects, graphics layout objects, or graphic image objects included in the Web page. For each object, the Android web browser defines an object datum corresponding to the layout location for the object. The Zio models run on the Android 2.2 operating system

Kyocera PX 1027_26

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the content on the Web page; logically grouping selected content into objects; defining a primary datum corresponding to the original page layout; and, for each object, defining an object datum corresponding to a layout location datum for the object's associated display content;

("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Android web browser incorporates the WebKit rendering engine. http://developer.android.com/about/versions/android-1.5-highlights.html (last visited July 12, 2012). The WebKit rendering engine parses markup language code to determine the original page layout of a display content within the Web page. (e.g., the retrieved Web page). See WebCore Rendering I – The Basics, http://webkit.org/blog/114/webcore-rendering-i-the-basics/ (last visited December 20, 2010).

The original page layout which is parsed by WebKit will include a layout location for a plurality of objects, including a list of text objects and graphic layout objects. These objects will be logically grouped. "At the heart of rendering is the render tree. The render tree is very similar to the DOM in that it is a tree of objects, where each object can correspond to the document, elements or text nodes. The render tree can also contain additional objects that have no corresponding DOM node." WebCore Rendering I – The Basics, http://webkit.org/blog/114/webcore-rendering-i-the-basics/ (last visited December 30, 2010).

WebKit defines, for each object, an object datum with the corresponding layout location for the object. "Fixed positioned objects are positioned relative to the viewport, i.e., the visible page area of your browser window. Absolute positioned objects are positioned relative to the containing block." WebCore Rendering IV – Absolute/Fixed and Relative Positioning, http://webkit.org/blog/117/webcore-rendering-iv-absolutefixed-and-relative-positioning/ (last visited December 20, 2010).

Kyocera PX 1027_27

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generating a vector from the primary datum to the object datum for the object; and creating a reference that links the object to the vector that is generated.

The accused Kyocera devices all run the Android operating system, including the Android web browser and the Webkit rendering engine, which generates a vector from the primary datum to the object datum for the object and creates a reference that links the object to the vector that is generated. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

WebKit generates a vector from the primary datum to the object datum. See WebCore Rendering IV Absolute/Fixed and Relative Positioning, http://webkit.org/blog/117/webcore-rendering-iv-absolutefixed-and-relative-positioning/ (last visited December 30, 2010).

Objects in a Web page (e.g., text boxes, images) are laid out using a recursive process. “When renderers are first created and added to the tree, they have no position or size yet. The process by which all of the boxes have their positions and sizes determined is called layout. All renderers have a layout method.” (http://www.webkit.org/blog/116/webcore-rendering-iii-layout-basics/)

Layout begins at the root renderer, which corresponds to the element of the HTML document. The position of the root renderer is 0,0 and its dimensions is the viewport - the visible part of the browser window. The root renderer is the primary datum. The setting of the primary datum can be seen in the Element.cpp file (available from Webkit.org). The layout of an object is performed by generating a vector between the root renderer (primary dotum() and the object datum:

static int adjustForLocalZoom(int value, RenderObject* renderer)

Kyocera PX 1027_28

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Claim Element Accused Instrumentalities { float zoomFactor = localZoomForRenderer(renderer); if (zoomFactor == 1) return value; // Needed because computeLengthInt truncates (rather than rounds) when scaling up. if (zoomFactor > 1) value++; return static_cast<int>(value / zoomFactor);


Webkit creates a reference between the object datum and primary datum. The source code in the RenderBoxModeObject.cpp file shows how the vector between the object datum and primary datum is stored as a reference.

// If the offsetParent of the element is null, or is the HTML body element, // return the distance between the canvas origin and the left border edge // of the element and stop this algorithm. if (offsetPar) { if (offsetPar->isBox() && !offsetPar->isBody()) xPos -= toRenderBox(offsetPar)->borderLeft(); if (!isPositioned()) { if (isRelPositioned()) xPos += relativePositionOffsetX(); RenderObject* curr = parent(); while (curr && curr != offsetPar) { // FIXME: What are we supposed to do inside SVG content? if (curr->isBox() && !curr->isTableRow()) xPos += toRenderBox(curr)->x(); curr = curr->parent(); }

Kyocera PX 1027_29

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Claim Element Accused Instrumentalities if (offsetPar->isBox() && offsetPar->isBody() && !offsetPar->isRelPositioned() && !offsetPar->isPositioned()) xPos += toRenderBox(offsetPar)->x(); } } return xPos; } int RenderBoxModelObject::offsetTop() const {



59. The mobile hand-held device of claim 58, wherein execution of the instructions performs further operations comprising: generating a bounding box for each object, the bounding box representing a portion of a rendered display page occupied by the object's associated group of content.

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which uses the Webkit rendering engine. WebKit, working in conjunction with other technologies on the Accused Devices, generates a bounding box for each object, the bounding box represents a portion of a rendered display page occupied by the object's associated group of content. The bounding boxes are generating by the WebKit engine. "Every block has a positioned objects list that contains all of the absolute/fixed positioned renderers for which it is the containing block. It is the block's responsibility to place these positioned children." WebCore Overview, http://webkit.org/blog/117/webcore-rendering-iv-absolutefixed-and-relative-positioning/ (last visited December 20, 2010).


66. The mobile hand-held device of claim 36, wherein a portion of the

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser. The Zio models run on the Android 2.2 operating

Kyocera PX 1027_30

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HTML-based Web content comprises cascaded style sheet data defining aspects of the Web page design that are preserved at each zoom level and panned view.

system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

Accused Products support Cascading Styles Sheets ("CSS"). WebKit, the rendering engine in the Android Browser, supports the use of Cascading Styles Sheets ("CSS"). See e.g., Public Class WebView Summary, available at: http://developer.android.com/reference/android/webkit/WebView.html (last visited July 12, 2012) ("WebView supports DOM, CSS."). WebKit preserves aspects of the Web page design at each zoom level and panned view. See http://webkit.org/blog/116/webcore-rendering-iii-layout-basics/ (last visited July 11, 2012).


118. A method, comprising:

rendering a browser interface on a display of a device via which a user is enabled to request access to a Web page, the Web page comprising HTML-based Web content having an original format defining an original width and height of the Web page and an original page layout, functionality, and design of

The accused Kyocera devices perform the following steps:


The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system

Kyocera PX 1027_31

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content on the Web page; ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA



in response to a user request to access the Web page, retrieving the Web page via the device, and translating at least a portion of the HTML-based Web content from its original format into scalable content that supports a scalable resolution-independent representation of the Web page that preserves the original page layout, functionality and design of the content defined by its original format when scaled and rendered; and

The accused Kyocera devices are configured to translate at least a portion of the HTML-based Web content from its original format into scalable content that supports a scalable resolution-independent representation of the Web page that preserves the original page layout, functionality and design of the content defined by its original format when scaled and rendered. See, e.g., What is Android?, http://developer.android.com/guide/basics/what-is-android.html (last visited February 2, 2012) (describing Android utilizing an "[i]ntegrated browser based on the open source WebKit engine", and using the associated LibWebCore "modern web browser engine which powers both the Android browser and an embedded web view." The Android graphic engine is "powered by a custom 2D graphics library; 3D graphics based on the Open GL ES 1.0 specification."). See, e.g., WebCore Rendering IV – Absolute/Fixed and Relative Positioning, http://www.webkit.org/blog/117/webcore-rendering-iv-absolutefixed-and-relative-positioning/ (last visited February 2, 2012) (describing the WebCore library in WebKit. WebCore supports four positioning values: "'static', 'absolute', 'fixed,' and 'relative.' Static positioning is the default and means that the object is just positioned using the normal rules of block and line layout." "Relative positioning is exactly like static positioning except that the CSS left, top, right, and bottom properties

Kyocera PX 1027_32

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can be used to apply a translation to the object." "The translation offset that will be applied can be obtained using the following methods…").

scaling the scalable content to render the Web page on the display such that a width of the Web page is rendered to fit across the display.

The accused Kyocera devices all run the Android operating system which includes the Android web browser. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Android web browser takes web page content and scales the the scalable content to render the Web page on the display such that a width of the Web page is rendered to fit across the display. "When the Android Browser loads a web page, the default behavior is to load the page in "overview mode," which provides a zoomed-out perspective of the web page." http://developer.android.com/guide/webapps/targeting.html (last visited June 21, 2012). The "overview mode" displays the web page such that the width of the Web page is rendered to fit across the display. http://developer.android.com/reference/android/webkit/WebSettings.html#getLoadWithOverviewMode() (last visited June 24, 2012).


138. The method of claim 118, further comprising: parsing markup language code corresponding to the retrieved Web page to determine the original page layout of

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which parses markup language code to determine the original page layout of display content within the Web page, wherein the original page layout defines a layout location for a plurality of objects, including at least one of text objects, graphics layout objects, or graphic image objects included in the Web page.

Kyocera PX 1027_33

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the content on the Web page; logically grouping selected content into objects; defining a primary datum corresponding to the original page layout; and, for each object, defining an object datum corresponding to a layout location datum for the object's associated display content;

For each object, the Android web browser defines an object datum corresponding to the layout location for the object. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Android web browser incorporates the WebKit rendering engine. http://developer.android.com/about/versions/android-1.5-highlights.html (last visited July 12, 2012). The WebKit rendering engine parses markup language code to determine the original page layout of a display content within the Web page. (e.g., the retrieved Web page). See WebCore Rendering I – The Basics, http://webkit.org/blog/114/webcore-rendering-i-the-basics/ (last visited December 20, 2010).


WebKit defines, for each object, an object datum with the corresponding layout location for the object. "Fixed positioned objects are positioned relative to the viewport, i.e., the visible page area of your browser window. Absolute positioned objects are positioned relative to the containing block." WebCore Rendering IV – Absolute/Fixed and Relative Positioning, http://webkit.org/blog/117/webcore-rendering-iv-absolutefixed-and-relative-

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positioning/ (last visited December 20, 2010).

generating a vector from the primary datum to the object datum for the object; and creating a reference that links the object to the vector that is generated.

The accused Kyocera devices all run the Android operating system, including the Android web browser and the Webkit rendering engine, which generates a vector from the primary datum to the object datum for the object and creates a reference that links the object to the vector that is generated. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).



Layout begins at the root renderer, which corresponds to the element of the HTML document. The position of the root renderer is 0,0 and its dimensions is the viewport - the visible part of the browser window. The root renderer is the primary datum. The setting of the primary datum can be seen in the Element.cpp file (available from Webkit.org). The layout of an object is performed by generating a vector between the

Kyocera PX 1027_35

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root renderer (primary dotum() and the object datum:

static int adjustForLocalZoom(int value, RenderObject* renderer) { float zoomFactor = localZoomForRenderer(renderer); if (zoomFactor == 1) return value; // Needed because computeLengthInt truncates (rather than rounds) when scaling up. if (zoomFactor > 1) value++; return static_cast<int>(value / zoomFactor);



// If the offsetParent of the element is null, or is the HTML body element, // return the distance between the canvas origin and the left border edge // of the element and stop this algorithm. if (offsetPar) { if (offsetPar->isBox() && !offsetPar->isBody()) xPos -= toRenderBox(offsetPar)->borderLeft(); if (!isPositioned()) { if (isRelPositioned()) xPos += relativePositionOffsetX(); RenderObject* curr = parent(); while (curr && curr != offsetPar) { // FIXME: What are we supposed to do inside SVG content? if (curr->isBox() && !curr->isTableRow())

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Claim Element Accused Instrumentalities xPos += toRenderBox(curr)->x(); curr = curr->parent(); } if (offsetPar->isBox() && offsetPar->isBody() && !offsetPar->isRelPositioned() && !offsetPar->isPositioned()) xPos += toRenderBox(offsetPar)->x(); } } return xPos; } int RenderBoxModelObject::offsetTop() const {



139. The method of claim 138, further comprising: generating a bounding box for each object, the bounding box representing a portion of a rendered display page occupied by the object's associated group of content.

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which uses the Webkit rendering engine. WebKit, working in conjunction with other technologies on the Accused Devices, generates a bounding box for each object, the bounding box represents a portion of a rendered display page occupied by the object's associated group of content. The bounding boxes are generating by the WebKit engine. "Every block has a positioned objects list that contains all of the absolute/fixed positioned renderers for which it is the containing block. It is the block's responsibility to place these positioned children." WebCore Overview, http://webkit.org/blog/117/webcore-rendering-iv-absolutefixed-and-relative-positioning/ (last visited December 20, 2010).


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149. A method, comprising: rendering a browser interface on a hand held device via which a user is enabled to request access to a Web page comprising HTML-based Web content defining an original page layout, functionality, and design of content on the Web page;

The accused Kyocera devices perform the following steps:





retrieving the Web page via the hand-held device, and processing HTML based Web content to produce scalable content; and

The accused Kyocera devices all run the Android web browser which retrieves web pages through the wireless communications interface. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera

Kyocera PX 1027_38

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Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).





employing at least one of the scalable content or data derived therefrom to, render the Web page on a display of the

The accused Kyocera devices run the Android operating system which includes the Android Browser. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-

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hand-held device; and specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Android Browser employs at least one of the scalable content or data derived there from to, render the Web page on the accused devices. When the Android Browser loads a web page, the default behavior is to load the page in "overview mode," which provides a zoomed-out perspective of the web page." http://developer.android.com/guide/webapps/targeting.html. The accused devices display the web page content through employing scale factors which convert the content into scalable content. "[T[he Android Browser and WebView scale web pages (effectively zoom the pages) so they display at a size that matches the perceived appearance on a medium density screen. More specifically, the Android Browser and WebView apply approximately 1.5x scaling to web pages on a high density screen (because its screen pixels are smaller) and approximately 0.75x scaling to pages on a low density screen (because its screen pixels are bigger)." Id.

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re-render the display in response to associated user inputs to enable the Web page to be browsed at various zoom levels and panned views while preserving the original page layout, functionality, and design of the Web page content at each zoom level and panned view.

The accused Kyocera devices all run the Android operating system, which includes the Android web browser. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).



As an example of this functionality, the SANYO Zio re-renders the display in response to associated user inputs to enable a user to browse a web page at various zoom levels and panned views. The SANYO Zio preserves a web page’s original layout and functionality at these various zoom levels and panned views. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to zoom out on the web page.").

Kyocera PX 1027_41

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183. The method of claim 149, wherein a portion of the scalable content comprises vector-based content.

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which supports scalable content that comprises vector-based content.





252. A machine-readable medium having a plurality of instructions

The accused Kyocera devices all contain a machine-readable medium on which a plurality of instructions are tangibly stored. Instructions are stored in the devices' storage

Kyocera PX 1027_42

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comprising a Web browser tangibly stored thereon, which when executed enable a device to perform operations comprising:

and executed by the devices' processors.

As an example, the Zio contains 512MB onboard storage, 256MB RAM, and a "MSM7627 (600MHz)" processor. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012).

rendering a browser interface on a display associated with the device via which a user is enabled to request access to a Web page comprising HTML-based Web content defining an original page layout, functionality, and design of content on the Web page;





retrieving the Web page and processing HTML-based Web content to produce scalable content; and

The accused Kyocera devices all run the Android web browser which retrieves web pages through the wireless communications interface. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA,

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employing at least one of the scalable content or data derived therefrom to, render the Web page on the display; and

http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).




The Zio models contain a wireless communication interface devices that connects to one or more wireless networks. For example, the Zio connects to one or more wireless networks, including the "CDMA 1x EVDO Rev. A, dual-band digital (800, 1900 MHz)" networks. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). It also has "Wi-Fi (IEEE802.11 b/g)" connectivity. Id. Kyocera encourages users to "[u]se Zio's leading-edge, high-speed cellular technology for broadband on the go, or turn it up a notch and settle down in a Wi-Fi hot spot to take advantage of even faster connectivity." Kyocera ZIO, ZIO BY KYOCERA, http://www.ziobykyocera.com/ (last

Kyocera PX 1027_44

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visited January 23, 2012).

re-render the display in response to associated user inputs to enable the Web page to be browsed at various zoom levels and panned views while preserving the original page layout, functionality, and design of the Web page content at each zoom level and panned view of the Web page,




As an example of this functionality, the SANYO Zio re-renders the display in response to associated user inputs to enable a user to browse a web page at various zoom levels and panned views. The SANYO Zio preserves a web page’s original layout and functionality at these various zoom levels and panned views. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to

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zoom out on the web page.").

wherein the Web browser enables a user of the device to browse, zoom, and pan billions of Web pages in a manner that preserves the original layout, functionality, and design of the HTML-based Web page content of each Web page at each zoom level and panned view.

The accused devices all run the Android operating system including the Android web browser which retrieves and displays web pages. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The Android Web browser enables a user to browse, zoom and pan billions of Web pages in a manner that preserves the original layout, functionality, and design of the HTML-based Web page content of each Web page.

As an example of this functionality, the SANYO Zio enables the user to browse, zoom, and pan billions of Web pages in a manner that preserves the original layout, functionality, and design of the HTML-based Web page content of each Web page. The SANYO Zio preserves a web page’s original layout and functionality at these various zoom levels and panned views. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Navigate on Web Pages[:] Use the Trackball or slide your finger on the screen to navigate the areas of a web page. Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to zoom out on the web page.").


283. The machine-readable medium of claim 252, wherein a portion of the scalable content comprises vector-based

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which supports scalable content that comprises

Kyocera PX 1027_46

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content. vector-based content.





317. A hand-held wireless device, comprising:

The Accused Kyocera devices are hand-held wireless devices.

The Echo is a hand-held wireless device. The Echo has dimensions of 4.5 x 2.2 x 0.7 inches, making it easy to hold in one's hand. See Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last

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visited January 19, 2012). The Echo is a wireless device operating on wireless networks including "EV-DO rev. A dual band digital (800 & 1900 MHz)" and with Wi-Fi connectivity. Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).

The Milano is a hand-held wireless device. The Milano has dimensions of 4.1 x 2.4 and 0.7 inches, making it easy to hold in one's hand. Kyocera Milano Phone, KYOCERA

WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The Milano is a wireless device operating on wireless networks including "EV-DO rev. 0 dual band digital (800 & 1900 MHz)" and with Wi-Fi connectivity. Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The Milano contains a wireless communication device. For example, the Milano C5120 connects with "EV-DO rev. 0 dual band digital (800 & 1900 MHz)" and "Wi-Fi (802.11 b/g/n)." Id.

The Zio models are hand-hold wireless devices. For example, the Zio has dimensions of 116 x 58.6 x 12.2 mm, making it easy to hold in one's hand. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The The Zio is a wireless device operating on wireless networks including "CDMA 1x EVDO Rev. A, dual-band digital (800, 1900 MHz)" and with Wi-Fi connectivity. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). Kyocera encourages users to "[u]se Zio's leading-edge, high-speed cellular technology for broadband on the go, or turn it up a notch and settle down in a Wi-Fi hot spot to take advantage of even faster connectivity." Kyocera ZIO, ZIO BY KYOCERA, http://www.ziobykyocera.com/ (last visited January 23, 2012).


The Echo contains a "1GHz Snapdragon processor." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/

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a wireless communications interface, to facilitate wireless communication with a network that supports access to the Internet;

The accused Kyocera devices contain a wireless communications devices to facilitate wireless communications with a network that supports access to the Internet.

The Echo contains a wireless communication device that connects to one or more wireless networks, including the "EV-DO rev. A dual band digital (800 & 1900 MHz)" networks. Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). It also has "Wi-Fi (802.11 b/g)" connectivity and includes "hotspot capability." Id.

The Milano contains a wireless communication device that connects to one or more wireless networks, including the "EV-DO rev. 0 dual band digital (800 & 1900 MHz)" networks. Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). It also has and "Wi-Fi (802.11 b/g/n) connectivity. Id.

The Zio models contain a wireless communication means devices that connects to one or more wireless networks. For example, the Zio connects to one or more wireless networks, including the "CDMA 1x EVDO Rev. A, dual-band digital (800, 1900 MHz)" networks. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). It also has "Wi-Fi (IEEE802.11 b/g)" connectivity. Id. Kyocera encourages users to "[u]se

Kyocera PX 1027_49

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Zio's leading-edge, high-speed cellular technology for broadband on the go, or turn it up a notch and settle down in a Wi-Fi hot spot to take advantage of even faster connectivity." Kyocera ZIO, ZIO BY KYOCERA, http://www.ziobykyocera.com/ (last visited January 23, 2012).

a display; and The accused Kyocera devices contain a display.




non-volatile memory, operatively coupled to the processor, in which software comprising a browser is stored, the browser comprising a plurality of instructions that when executed by the processor enable the device to perform operations including,

The accused Kyocera devices contain non-volatile memory, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile hand-held device to perform operations.

The Echo contains non-volatile memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Echo contains is sold with an "8GB microSD card included." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). The instructions, when executed, enable this model to perform the following operations.

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The Milano contains non-volatile memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Milano contains "512MB/512MB internal memory" and a "2GB microSDTM memory card." See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The instructions, when executed, enable this model to perform the following operations.

The Zio models contain non-volatile memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. For example, the Zio contains "512MB/RAM256MB" of memory and a "2GB microSD memory card." Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The instructions, when executed, enable the these models to perform the following operations.

rendering a browser interface on the display via which a user is enabled to request access to a Web page including at least one image, at least one column, at least one hyperlink to an external reference and having a width and height;

All of the accused Kyocera devices run on the Android operating system. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA


The Android operating system includes a fully functional Web browser capable of requesting and retrieving Web pages. See, e.g., What is Android?, http://developer.android.com/guide/basics/what-is-android.html (last visited February 2, 2012) (describing the Android utilizing an "[i]ntegrated browser based on the open source WebKit engine", and using the associated LibWebCore "modern web browser engine which powers both the Android browser and an embedded web view." The Android graphic engine is "powered by a custom 2D graphics library; 3D graphics based on the Open GL ES 1.0 specification."). The Web page retrieved by the Android

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Browser can include at least one image, at least one column, at least one hyperlink to an external reference and having a width and height.

retrieving the Web page via the wireless communications interface;

The accused Kyocera devices all run the Android web browser which retrieves web pages through the wireless communications interface. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The accused devices all have a wireless communications interface:



The Zio models contain a wireless communication interface devices that connects to one or more wireless networks. For example, the Zio connects to one or more wireless networks, including the "CDMA 1x EVDO Rev. A, dual-band digital (800, 1900 MHz)" networks. Kyocera ZIO – Features, ZIO BY KYOCERA,

Kyocera PX 1027_52

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http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). It also has "Wi-Fi (IEEE802.11 b/g)" connectivity. Id. Kyocera encourages users to "[u]se Zio's leading-edge, high-speed cellular technology for broadband on the go, or turn it up a notch and settle down in a Wi-Fi hot spot to take advantage of even faster connectivity." Kyocera ZIO, ZIO BY KYOCERA, http://www.ziobykyocera.com/ (last visited January 23, 2012).

rendering the Web page on the display such that at least one of the width and height of the Web page is fully displayed; and

The accused devices all incorporate the run the Android operating system, including the Android web browser, which can scale to fit at least one of the width and height of a Web page across the browser display area. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

As an example of this functionality, the SANYO Zio can scale Web pages to fit at least one of the width and height of a Web page across the browser display area. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to zoom out on the web page.").

enabling the user to, zoom and pan a view of the Web page;

The accused Kyocera devices all run the Android operating system which includes an Android Web Browser which enables a user to zoom and pan a view of the Web page. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA

ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012);

Kyocera PX 1027_53

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Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

For example, the Echo offers a "[p]inch-to-zoom" feature in its web browser. Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).

activate a currently displayed hyperlink to an external reference while at a given zoom level and panned view, wherein in response to an activation of a hyperlink to an external reference, Web content associated with the external reference is retrieved and rendered on the display;

The accused devices all run the Android operating system, including the Android web browser, which retrieves and displays web pages that contain hyperlinks. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA


The Android web browser can activate a currently displayed hyperlink to an external reference while at a given zoom level and panned view, wherein in response to an activation of a hyperlink to an external reference, Web content associated with the external reference is retrieved and rendered on the display. When a user selects a hyperlink to an external reference, such as another Web page, further instructions are performed so that the Web content associated with the external reference is retrieved and rendered on the display. See, e.g., SANYO Zio Basics Guide (KYC0000586-739) at 17 ("To open the available options for an item (for example, a link in a Web page), simply touch and hold the item."); id. at 94 ("Links, which are displayed as underlined text, allow you to jump to Web pages . . . .").

zoom in on an image of the Web page by tapping on the image via the display;

The accused devices all incorporate the run the Android operating system, including the Android web browser, which can zoom in on an image of the Web page by tapping on the image via the display. The Zio models run on the Android 2.2 operating system

Kyocera PX 1027_54

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("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).


zoom in on a column of the Web page by tapping on the column via the display; and

The accused Kyocera devices all run the Android operating system including the Android web browser which retrieves and displays web pages. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The Android Web browser allows user to tap on the screen to zoom in.

As an example of this functionality, the Echo enables a user to zoom on a column with user input that comprises tapping . See Kyocera Echo Basics Guide (KYC0003514-672) at 101 ("To zoom in . . . on a Web page, tap [graphic] to zoom in.").

zoom out to a previous view of the Web page.

The accused Kyocera devices all run the Android operating system including the Android web browser which retrieves and displays Web pages. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The

Kyocera PX 1027_55

EXHIBIT A


2676884 - 47 -


Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The Android Web browser performs further operations comprising returning the display of the Web page to a previous view in response to a corresponding user input.

As an example of this functionality, the SANYO Zio can return the display of the Web page to a previous view in response to corresponding user input. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to zoom out on the web page.").

Kyocera PX 1027_56


EXHIBIT B

2676885


30. A mobile phone, comprising: The accused Kyocera devices1 are mobile phones.

The Echo is a mobile phone operating on wireless networks including "EV-DO rev. A dual band digital (800 & 1900 MHz)" and with Wi-Fi connectivity. Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).

The Milano is a mobile phone operating on wireless networks including "EV-DO rev. 0 dual band digital (800 & 1900 MHz)" and with Wi-Fi connectivity. Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Zio models are mobile phone. For example, the Zio is a mobile phone that operates on wireless networks including "CDMA 1x EVDO Rev. A, dual-band digital (800, 1900 MHz). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012).




1 The following Kyocera models infringe U.S. Patent No. 7,831,926: Echo, Milano, SANYO Zio, and Zio. SoftView reserves the right to supplement this

infringement analysis with additional Kyocera models as they become known.

Kyocera PX 1027_57

EXHIBIT B


2676885 - 2 -



wireless communications means operatively coupled to the processor, to facilitate communication with a mobile service provider network via which Web content may be accessed;

The accused Kyocera devices contain a wireless communication means operatively coupled to the processor, to facilitates wireless communication with a mobile servie provider network via which Web content may be accessed..


The Milano contains a wireless communication means that connects to one or more wireless networks, including the "EV-DO rev. 0 dual band digital (800 & 1900 MHz)" networks. Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). It also has Wi-Fi (802.11 b/g/n) connectivity. Id.

The Zio models contain a wireless communication means that connections to one or more wireless networks. For example, the Zio connects to one or more wireless networks including the "CDMA 1x EVDO Rev. A, dual-band digital (800, 1900 MHz)" networks. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). It also has Wi-Fi (IEEE802.11 b/g) connectivity. Id. Kyocera encourages users to "[u]se Zio's leading-edge, high-speed cellular technology for broadband on the go, or turn it up a notch and settle down in a Wi-Fi hot spot to take advantage of even faster connectivity." Kyocera ZIO, ZIO BY KYOCERA, http://www.ziobykyocera.com/ (last visited January 23, 2012).

Kyocera PX 1027_58

EXHIBIT B


2676885 - 3 -


a touch-sensitive display; The accused Kyocera devices contain a touch-sensitive display.



The Zio models contain a touch-sensitive display. For example, the Zio contains a "3.5[inch] 262K-color TFT LCD WVGA (480x800 pixels)" display with "capacitive touch screen navigation." Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012).

a memory, operatively coupled to the processor; and

The accused Kyocera devices contain memory, operatively coupled to the processor.

The Echo contains memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Echo contains "expandable memory" and is sold with an "8GB microSD card included." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).

The Milano contains memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Milano contains "512MB/512MB internal memory" and a "2GB microSDTM memory card." See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Zio devices contains memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. For example, the Zio contains

Kyocera PX 1027_59

EXHIBIT B


2676885 - 4 -


"512MB/RAM256MB" of memory. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012).

storage means, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile phone to perform operations including,

The accused Kyocera devices contain storage means, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile phone to perform the following operations.

The Echo contains memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Echo contains "expandable memory" and is sold with an "8GB microSD card included." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). The instructions, when executed, enable this model to perform the following operations.

The Milano contains memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Milano contains "512MB/512MB internal memory" and a "2GB microSDTM memory card." See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The instructions, when executed, enable this model to perform the following operations.

The Zio models contain memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. For example, the Zio contains "512MB/RAM256MB" of memory. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The instructions, when executed, enable the these models to perform the following operations.

rendering a browser interface via which a user is enabled to request to access to a Web page having an original format

The Echo, Milano, and Zio render a browser interfacevia which a user is enabled to request access to an original Web page, the Web page comprising HTML-based Web content having an original format defining an original width and height of the Web page

Kyocera PX 1027_60

EXHIBIT B


2676885 - 5 -


comprising HTML-based content defining an original page layout, functionality, and design of content on the Web page;

and an original page layout, functionality, and design of content on the Web page.




retrieving HTML-based content associated with the Web page;

The accused Kyocera devices all use the Android web browser to retrieve HTML-based content associated with a web page. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The class named WebView retrieves the HTML based content. http://developer.android.com/guide/webapps/webview.html (last visited June 23, 2012);

Kyocera PX 1027_61

EXHIBIT B


2676885 - 6 -


"Enum for controlling the layout of html. NORMAL means no rendering changes. SINGLE_COLUMN moves all content into one column that is the width of the view. NARROW_COLUMNS makes all columns no wider than the screen if possible." http://developer.android.com/reference/android/webkit/WebSettings.LayoutAlgorithm.html (last visited June 21, 2012).

translating at least a portion of the HTML-based content from its original format to produce translated content including scalable vector-based content that supports a scalable resolution-independent representation of the HTML-based content that preserves an original page layout, functionality and design of the at least a portion of the HTML-based content when scaled and rendered; and-employing the scalable vector-based content to render a view of at least a portion of the Web page on the display using a first scale factor,

The accused devices all run the Android operating system which includes the Android web browser. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, Zio by Kyocera, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, Kyocera Echo, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, Kyocera Wireless, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

"The Android browser puts the web at your fingertips. View multiple open pages at once, use incognito mode to browse privately and sync your Google Chrome bookmarks so all your favorite sites are with you on-the-go." http://www.android.com/about/ (last visited June 22, 2012). The Android web browser is built using the Web Kit rendering engine. http://developer.android.com/reference/android/webkit/package-summary.html (last visited June 22, 2012).

The Android web browser translates at least a portion of HTML based content from its original format. "This class processes HTML strings into displayable styled text. Not all HTML tags are supported." http://developer.android.com/reference/android/webkit/package-summary.html (last visited June 21, 2012). "The Android Open Source implementation uses the WebKit rendering engine to implement the WebView." Android 2.1 Compatibility Definition at 9 available at: http://source.android.com/compatibility/2.1/android-2.1-cdd.pdf (last visited June 21, 2012). "The system image included in the downloadable platform provides these built-in applications. . . browser."

Kyocera PX 1027_62

EXHIBIT B


2676885 - 7 -


http://developer.android.com/about/versions/android-2.1.html#apps (last visited June 21, 2012). Devices running the Android operating system come with a browser which uses WebKit as its rendering engine. Even in cases where a handset maker customizes the web browser in Android or ships a browser which is not the default Android browser – the browser must use the WebKit rendering engine. "However, even if an alternate Browser application is shipped, the WebView component provided to third-party applications MUST be based on WebKit, as above." Android 2.1 Compatibility Definition at 10 available at: http://source.android.com/compatibility/2.1/android-2.1-cdd.pdf (last visited June 21, 2012).

The Android Browser, having been built using the WebKit rendering engine, takes original HTML based content and translates it. The rendering engine in WebKit has the following basic flow: (1) DOM Tree Construction – parse (interpret) the web page (i.e. HTML) and construct a Document Object Model (DOM) tree – this tree is one of the internal data structures that will be used in the rendering process. In particular, it holds the content (i.e. data) of the page that is to be displayed and laid out. (2) Render Tree Construction – this tree is closely tied to the DOM Tree and contains data relevant to how the page will actually look (i.e. visual instructions in the HTML, style information). (3) Layout – The process of formatting and placing data from the DOM tree according to the constraints of the Render Tree. “When renderers are first created and added to the tree, they have no position or size yet. The process by which all of the boxes have their positions and sizes determined is called layout. All renderers have a layout method.”(http://www.webkit.org/blog/116/webcore-rendering-iii-layout-basics/ (last visited June 22, 2012).

The Android Browser parsing of HTML based content preserves the original page layout. " When the Android Browser loads a web page, the default behavior is to load the page in "overview mode," which provides a zoomed-out perspective of the web page." http://developer.android.com/guide/webapps/targeting.html (last visited June 24, 2012).

The Android Browser when loading a web page applies scaling to the original page

Kyocera PX 1027_63

EXHIBIT B


2676885 - 8 -


layout. "Because the default target density is medium, when users have a device with a low or high density screen, the Android Browser and WebView scale web pages (effectively zoom the pages) so they display at a size that matches the perceived appearance on a medium density screen. More specifically, the Android Browser and WebView apply approximately 1.5x scaling to web pages on a high density screen (because its screen pixels are smaller) and approximately 0.75x scaling to pages on a low density screen (because its screen pixels are bigger)." Id.

The scaling of HTML content onto the accused devices converts the content to scalable vector based content. "You should always provide bitmap resources that are properly scaled to each of the generalized density buckets: low, medium, high and extra-high density. This helps you achieve good graphical quality and performance on all screen densities. To generate these images, you should start with your raw resource in vector format and generate the images for each density using the following size scale:" http://developer.android.com/training/basics/supporting-devices/screens.html (last visited June 21, 2012). This scaling of content to fit the screen size of the accused devices relies on generating scalable vector-based content. "The screen density (the number of pixels per inch) on an Android-powered device affects the resolution and size at which a web page is displayed. (There are three screen density categories: low, medium, and high.) The Android Browser and WebView compensate for variations in the screen density by scaling a web page so that all devices display the web page at the same perceivable size as a medium-density screen." http://developer.android.com/guide/webapps/targeting.html (last visited June 21, 2012).

The initial generation of HTML based content which is translated for display on the screens of the accused devices uses an initial scale factor (first scale factor). "The default initial scale is calculated to fit the web page in the viewport size. Because the default viewport width is 800 pixels, if the device screen resolution is less than 800 pixels wide, the initial scale is something less than 1.0, by default, in order to fit the 800-pixel-wide page on the screen." Id.

Kyocera PX 1027_64

EXHIBIT B


2676885 - 9 -


wherein preservation of the functionality defined by the HTML-based content includes preservation of hyperlink functionality.

The accused devices all run the Android operating system, including the Android web browser, which retrieves and displays web pages that contain hyperlinks. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA


The Android web browser can activate a currently displayed hyperlink to an external reference while at a given zoom level and panned view, wherein in response to an activation of a hyperlink to an external reference, Web content associated with the external reference is retrieved and rendered on the display. When a user selects a hyperlink to an external reference, such as another Web page, further instructions are performed so that the Web content associated with the external reference is retrieved and rendered on the display. See, e.g., SANYO Zio Basics Guide (KYC0000586-739) at 17 ("To open the available options for an item (for example, a link in a Web page), simply touch and hold the item."); id. at 94 ("Links, which are displayed as underlined text, allow you to jump to Web pages . . . .").


31. The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising enabling the user to zoom in on a user-selectable portion of a display of the Web page in response to a user interface

The accused Kyocera devices all run the Android operating system, including the Android web browser, which executes instructions to perform further operations comprising enabling the user to zoom in on a user-selectable portion of a display of the Web page in response to a corresponding user interface input. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The

Kyocera PX 1027_65

EXHIBIT B


2676885 - 10 -


input made via the touch-sensitive display.

Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

As an example of this functionality, the SANYO Zio enables the user to zoom in on a user-selectable portion of a display of the Web page in response to a corresponding user interface input. The SANYO Zio preserves a web page’s original layout and functionality at these various zoom levels and panned views. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Navigate on Web Pages[:] Use the Trackball or slide your finger on the screen to navigate the areas of a web page. Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to zoom out on the web page.").

The accused Kyocera devices contain a touch-sensitive display.




Kyocera PX 1027_66

EXHIBIT B


2676885 - 11 -


40. The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising enabling a user to view a column of the Web content at a higher resolution than a current resolution by tapping on the column via the touch-sensitive display,

The accused Kyocera devices all run the Android operating system, including the Android web browser, which retrieves and displays web pages. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY

KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The Android Web browser performs further operations comprising enabling a user to zoom on a column of the Web page via a corresponding user input, wherein in response thereto, the display is re-rendered such that content corresponding to the selected column is enlarged.

As an example of this functionality, the SANYO Zio enables a user to zoom on a column of the Web page via a corresponding user input, wherein in response thereto, the display is re-rendered such that content corresponding to the selected column is enlarged. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to zoom out on the web page.").

The accused Kyocera devices all run the Android operating system including the Android web browser which retrieves and displays web pages. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The Android Web browser allows user to tap on the

Kyocera PX 1027_67

EXHIBIT B


2676885 - 12 -


screen to zoom in.

As an example of this functionality, the Echo enables a user to zoom on a column with user input that comprises tapping . See Kyocera Echo Basics Guide (KYC0003514-672) at 101 ("To zoom in . . . on a Web page, tap [graphic] to zoom in.").

wherein in response thereto, the display is re-rendered such that content corresponding to the selected column is displayed to fit across the touch-sensitive display.

The accused Kyocera devices all incorporate the run the Android operating system, including the Android web browser, which can zoom in on a column so that the column is rendered to fit across the browser display area. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

As an example of this functionality, the SANYO Zio enables a user to zoom on a column such that the column is rendered to fit across the display. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to zoom out on the web page.").



The Milano contains a "3.0[inch] capacitive touchscreen" display. See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/

Kyocera PX 1027_68

EXHIBIT B


2676885 - 13 -




Kyocera PX 1027_69

EXHIBIT B


2676885 - 14 -


41. The mobile phone of claim 30, wherein the Web content includes at least one image, and wherein execution of the instructions performs further operations comprising enabling a user to view an image at a higher resolution than a current resolution by tapping on the image via the touch-sensitive display,

The accused devices all incorporate the run the Android operating system, including the Android web browser, which can zoom in on an image of the Web page by tapping on the image via the display. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).


The accused Kyocera devices contain a touch-sensitive display. The Echo contains "Dual 3.5” WVGA touchscreen displays," which "combine to form a 4.7” display." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). The Milano contains a "3.0[inch] capacitive touchscreen" display. See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The Zio models contain a touch-sensitive display. For example, the Zio contains a "3.5[inch] 262K-color TFT LCD WVGA (480x800 pixels)" display with "capacitive touch screen navigation." Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012).

Kyocera PX 1027_70

EXHIBIT B


2676885 - 15 -


wherein in response thereto, the display is re-rendered such that the image is displayed to fit across at least one of a width and height of a display area of the touch-sensitive display.

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which can zoom in on an image so that the image is rendered to fit across the browser display area. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

As an example of this functionality, the SANYO Zio enables a user to zoom on an image such that the column is rendered to fit across the display. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to zoom out on the web page.").




The Zio models contain a touch-sensitive display. For example, the Zio contains a "3.5[inch] 262K-color TFT LCD WVGA (480x800 pixels)" display with "capacitive touch screen navigation." Kyocera ZIO – Features, ZIO BY KYOCERA,

Kyocera PX 1027_71

EXHIBIT B


2676885 - 16 -


http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012).


43. The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising: generating a display list associated with the scalable vector-based content; and

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which retrieves and displays web pages that contain hyperlinks. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Android web browser incorporates the WebKit rendering engine. http://developer.android.com/about/versions/android-1.5-highlights.html (last visited July 12, 2012). The WebKit rendering engine generates a vector-based display list associated with scalable content.


The DOM contains vector-based information associated with the scalable content within

Kyocera PX 1027_72

EXHIBIT B


2676885 - 17 -


a Web page. The generation of a vector-based display list associated with scalable content is illustrated in the RenderBoxModelObject.cpp file which is part of WebKit as shown below.



employing the display list to re-render the display at different scale factors to enable rapid zooming of the Web page.

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which uses the Webkit rendering engine. WebKit, working in conjunction with other technologies on the Accused Devices, employs the display list to re-render the display at different scale factors to zoom the Web page. See WebCore V- Rendering v. Floats, http://webkit.org/blog/118/webcore-rendering-v-floats/ (last visited December 20, 2010).

The use of scale factors and display list is illustrated in the RenderView.cpp file which contains methods the ability to zoom using the display list to re-render the display.

if (resize != RESIZE_HORIZONTAL && difference.height()) { if (element->isFormControlElement()) { // Make implicit margins from the theme explicit (see <http://bugs.webkit.org/show_bug.cgi?id=9547>). style->setProperty(CSSPropertyMarginTop,

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Claim Element Accused Instrumentalities String::number(renderer->marginTop() / zoomFactor) + "px", false, ec); style->setProperty(CSSPropertyMarginBottom, String::number(renderer->marginBottom() / zoomFactor) + "px", false, ec); } int baseHeight = renderer->height() - (isBoxSizingBorder ? 0 : renderer->borderAndPaddingHeight()); baseHeight = baseHeight / zoomFactor; style->setProperty(CSSPropertyHeight, String::number(baseHeight + difference.height()) + "px", false, ec); } document->updateLayout();



52. A mobile device, comprising: The accused Kyocera devices are mobile devices.

The Echo is a mobile device, with battery power, wireless connectivity, and dimensions that make it easy to hold in one's hand. See Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).

The Milano is a mobile device, with battery power, wireless connectivity, and dimensions that make it easy to hold in one's hand. Kyocera Milano Phone, KYOCERA

WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Zio models are mobile devices, with battery power, wireless connectivity, and

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dimensions that make the easy to hold in one's hand. See, e.g., Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012).





wireless communications means, to facilitate wireless communication with a network via which Web content may be accessed;

The accused Kyocera devices contain a wireless communication means that facilitates wireless communications with a network that supports access to the Internet.


The Milano contains a wireless communication means that connects to one or more wireless networks, including the "EV-DO rev. 0 dual band digital (800 & 1900 MHz)" networks. Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). It also has Wi-Fi (802.11

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b/g/n) connectivity. Id.

The Zio models contain a wireless communication means that connections to one or more wireless networks. For example, the Zio connects to one or more wireless networks including the "CDMA 1x EVDO Rev. A, dual-band digital (800, 1900 MHz)" networks. Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). It also has Wi-Fi (IEEE802.11 b/g) connectivity. Id. Kyocera encourages users to "[u]se Zio's leading-edge, high-speed cellular technology for broadband on the go, or turn it up a notch and settle down in a Wi-Fi hot spot to take advantage of even faster connectivity." Kyocera ZIO, ZIO BY KYOCERA, http://www.ziobykyocera.com/ (last visited January 23, 2012).

a touch-sensitive display; The accused Kyocera devices contain a touch-sensitive display.




flash memory, operatively coupled to the processor, in which a plurality of instructions are stored that when

The accused Kyocera devices contain flash memory, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the

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executed by the processor enable the mobile device to perform operations including,

processor enable the mobile hand-held device to perform operations.

The Echo contains flash memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Echo contains is sold with an "8GB microSD card included." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). The instructions, when executed, enable the this model to perform the following operations.

The Milano contains flash memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. The Milano contains "512MB/512MB internal memory" and a "2GB microSDTM memory card." See, e.g., Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012). The instructions, when executed, enable the this model to perform the following operations.

The Zio models contain flash memory on which a plurality of instructions are stored. The memory is operatively coupled to the processor. For example, the Zio contains "512MB/RAM256MB" of memory and a "2GB microSD memory card." Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The instructions, when executed, enable these models to perform the following operations.

rendering a browser interface via which a user is enabled to request access to a Web page comprising HTML-based Web content defining an original page layout, functionality, and design of content on the Web page; and


The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system

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("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA



retrieving and processing the HTML-based Web content to produce scalable content;

The accused Kyocera devices all run the Android web browser which retrieves web pages through the wireless communications interface. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).


The Echo contains a wireless communication interface that connects to one or more wireless networks, including the "EV-DO rev. A dual band digital (800 & 1900 MHz)" networks. Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012). It also has

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"Wi-Fi (802.11 b/g)" connectivity and includes "hotspot capability." Id.



employing the scalable content and/or data derived therefrom to, render a view of the Web page on the touch-sensitive display; and

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which employs scalable content and/or data derived therefrom to render a view of a Web page on the touch-sensitive display. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA


The accused devices translate at least a portion of the HTML-based Web content from its

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original format into scalable content that supports a scalable resolution-independent representation of the Web page that preserves the original page layout, functionality and design of the content defined by its original format when scaled and rendered. See, e.g., What is Android?, http://developer.android.com/guide/basics/what-is-android.html (last visited February 2, 2012) (describing Android utilizing an "[i]ntegrated browser based on the open source WebKit engine", and using the associated LibWebCore "modern web browser engine which powers both the Android browser and an embedded web view." The Android graphic engine is "powered by a custom 2D graphics library; 3D graphics based on the Open GL ES 1.0 specification."). See, e.g., WebCore Rendering IV – Absolute/Fixed and Relative Positioning, http://www.webkit.org/blog/117/webcore-rendering-iv-absolutefixed-and-relative-positioning/ (last visited February 2, 2012) (describing the WebCore library in WebKit. WebCore supports four positioning values: "'static', 'absolute', 'fixed,' and 'relative.' Static positioning is the default and means that the object is just positioned using the normal rules of block and line layout." "Relative positioning is exactly like static positioning except that the CSS left, top, right, and bottom properties can be used to apply a translation to the object." "The translation offset that will be applied can be obtained using the following methods…").





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re-render the Web page in response to associated user inputs to enable the user to iteratively zoom in and out views of the Web page while preserving an original page layout, functionality, and design defined by the HTML-based Web content as interpreted by a rendering engine, wherein preservation of the functionality defined by the HTML-based Web content includes preservation of hyperlink functionality.




As an example of this functionality, the SANYO Zio re-renders the display in response to associated user inputs to enable a user to browse a web page at various zoom levels and panned views. The SANYO Zio preserves a web page’s original layout and functionality at these various zoom levels and panned views. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to

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zoom out on the web page.").


55. The mobile device of claim 52, wherein execution of the instructions performs further operations comprising enabling the user to zoom in on a user-selectable portion of a display of the Web page in response to a user interface input made via the touch-sensitive display.

The accused Kyocera devices all run the Android operating system, including the Android web browser, which executes instructions to perform further operations comprising enabling the user to zoom in on a user-selectable portion of a display of the Web page in response to a corresponding user interface input. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

As an example of this functionality, the SANYO Zio enables the user to zoom in on a user-selectable portion of a display of the Web page in response to a corresponding user interface input. The SANYO Zio preserves a web page’s original layout and functionality at these various zoom levels and panned views. See SANYO Zio by Kyocera user guide (KYC0000346-447) at 55 ("Navigate on Web Pages[:] Use the Trackball or slide your finger on the screen to navigate the areas of a web page. Zoom In or Out on Web Pages[:] 1. Slide your finder on the screen to display the zoom buttons. 2. Touch the + button to zoom in or the – button to zoom out on the web page.").


The Echo contains "Dual 3.5” WVGA touchscreen displays," which "combine to form a 4.7” display." Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO,

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http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012).




59. The mobile device of claim 52, wherein at least a portion of the scalable content comprises scalable vector-based content.

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which supports scalable content that comprises scalable vector-based content.

The Android browser supports scalable content including Scalable Vector Graphics ("SVG") content. See http://code.google.com/p/svg-android/ (last visited July 16, 2012).

The Accused Products translate HTML based content into scalable content wherein at least a portion of the scalable content is scalable vector-based content including vector based layout information. WebKit's DOM contains vector-based information associated with the scalable content within a Web page. The generation of a vector-based display list associated with scalable content is illustrated in the RenderBoxModelObject.cpp file which is part of WebKit as shown below.

// If the element is the HTML body element or does not have an associated box

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Claim Element Accused Instrumentalities // return 0 and stop this algorithm. if (isBody()) return 0; RenderBoxModelObject* offsetPar = offsetParent(); int yPos = (isBox() ? toRenderBox(this)->y() : 0); // If the offsetParent of the element is null, or is the HTML body element, // return the distance between the canvas origin and the top border edge // of the element and stop this algorithm.



72. The mobile device of claim 52, wherein execution of the instructions performs further operations comprising: parsing HTML-based code corresponding to the received Web content to identify content on the Web page; logically grouping selected content into objects; defining a primary datum corresponding to the original page layout; and, for each object, defining an object datum corresponding to a layout location datum for the object's associated display content;

The accused Kyocera devices all incorporate the run the Android operating system including the Android web browser, which parses markup language code to determine the original page layout of display content within the Web page, wherein the original page layout defines a layout location for a plurality of objects, including at least one of text objects, graphics layout objects, or graphic image objects included in the Web page. For each object, the Android web browser defines an object datum corresponding to the layout location for the object. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).

The Android web browser incorporates the WebKit rendering engine.

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http://developer.android.com/about/versions/android-1.5-highlights.html (last visited July 12, 2012). The WebKit rendering engine parses markup language code to determine the original page layout of a display content within the Web page. (e.g., the retrieved Web page). See WebCore Rendering I – The Basics, http://webkit.org/blog/114/webcore-rendering-i-the-basics/ (last visited December 20, 2010).


WebKit defines, for each object, an object datum with the corresponding layout location for the object. "Fixed positioned objects are positioned relative to the viewport, i.e., the visible page area of your browser window. Absolute positioned objects are positioned relative to the containing block." WebCore Rendering IV – Absolute/Fixed and Relative Positioning, http://webkit.org/blog/117/webcore-rendering-iv-absolutefixed-and-relative-positioning/ (last visited December 20, 2010).

generating a vector from the primary datum to the object datum for the object; and creating a reference that links the object to its corresponding vector.

The accused Kyocera devices all run the Android operating system, including the Android web browser and the Webkit rendering engine, which generates a vector from the primary datum to the object datum for the object and creates a reference that links the object to the vector that is generated. The Zio models run on the Android 2.2 operating system ("FroYo"). Kyocera ZIO – Features, ZIO BY KYOCERA, http://www.ziobykyocera.com/tech-specs/sprint/ (last visited January 20, 2012). The Echo and Milano run on the Android 2.3 operating system ("Gingerbread"). Dual Screen Touch Phone – Kyocera Echo Tech Spec, KYOCERA ECHO, http://www.echobykyocera.com/tech-specs/ (last visited January 19, 2012); Kyocera

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Milano Phone, KYOCERA WIRELESS, http://www.kyocera-wireless.com/c5120-phone/ (last visited January 20, 2012).



Layout begins at the root renderer, which corresponds to the element of the HTML document. The position of the root renderer is 0,0 and its dimensions is the viewport - the visible part of the browser window. The root renderer is the primary datum. The setting of the primary datum can be seen in the Element.cpp file (available from Webkit.org). The layout of an object is performed by generating a vector between the root renderer (primary dotum() and the object datum:

static int adjustForLocalZoom(int value, RenderObject* renderer) { float zoomFactor = localZoomForRenderer(renderer); if (zoomFactor == 1) return value; // Needed because computeLengthInt truncates (rather than rounds) when scaling up. if (zoomFactor > 1) value++; return static_cast<int>(value / zoomFactor);

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// If the offsetParent of the element is null, or is the HTML body element, // return the distance between the canvas origin and the left border edge // of the element and stop this algorithm. if (offsetPar) { if (offsetPar->isBox() && !offsetPar->isBody()) xPos -= toRenderBox(offsetPar)->borderLeft(); if (!isPositioned()) { if (isRelPositioned()) xPos += relativePositionOffsetX(); RenderObject* curr = parent(); while (curr && curr != offsetPar) { // FIXME: What are we supposed to do inside SVG content? if (curr->isBox() && !curr->isTableRow()) xPos += toRenderBox(curr)->x(); curr = curr->parent(); } if (offsetPar->isBox() && offsetPar->isBody() && !offsetPar->isRelPositioned() && !offsetPar->isPositioned()) xPos += toRenderBox(offsetPar)->x(); } } return xPos; } int RenderBoxModelObject::offsetTop() const {

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75. The mobile device of claim 52, wherein the original format of the Web page defines a width for the Web page, and wherein execution of the instructions performs further operations comprising: determining an applicable scale factor to fit the width of the Web page across a display area of the touch-sensitive display; and

The accused devices run the Android operating system which includes the Android Browser. The Android Browser determines an applicable scale factor to fit the width of the Web page across a display area. "When the Android Browser loads a web page, the default behavior is to load the page in "overview mode," which provides a zoomed-out perspective of the web page." http://developer.android.com/guide/webapps/targeting.html. The accused devices display the web page content through employing scale factors which convert the content into scalable content. "[T[he Android Browser and WebView scale web pages (effectively zoom the pages) so they display at a size that matches the perceived appearance on a medium density screen. More specifically, the Android Browser and WebView apply approximately 1.5x scaling to web pages on a high density screen (because its screen pixels are smaller) and approximately 0.75x scaling to pages on a low density screen (because its screen pixels are bigger)." Id.





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employing the scale factor to render the display area.

The accused devices run the Android operating system which includes the Android Browser. The Android Browser employs a scale factor to render the display area. "When the Android Browser loads a web page, the default behavior is to load the page in "overview mode," which provides a zoomed-out perspective of the web page." http://developer.android.com/guide/webapps/targeting.html. The accused devices display the web page content through employing scale factors which convert the content into scalable content. "[T[he Android Browser and WebView scale web pages (effectively zoom the pages) so they display at a size that matches the perceived appearance on a medium density screen. More specifically, the Android Browser and WebView apply approximately 1.5x scaling to web pages on a high density screen (because its screen pixels are smaller) and approximately 0.75x scaling to pages on a low density screen (because its screen pixels are bigger)." Id.

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