U.S. PATENT NO. 7,461,353
`
`
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`Android Product
`Cell phones and tablets are wireless devices. The Android products1 are all cell phones or
`tablets. For example, the Motorola Atrix is a cell phone. Motorola Atrix 4G Page,
`http://www.motorola.com/us/consumers/Motorola-ATRIX-
`4G/72112,en_US,pd.html?cgid=mobile-phones ("smartphone") (Exhibit 2036-1).
`
`A processor constitutes a processing means. The Android products each contain at least
`one processor. For example, the Atrix models contain a processing means; the Atrix 2
`contains a "1GHz Dual Core" processor. Motorola ATRIX 2 – Dual Core 4G Android
`Smartphone, Motorola, available at http://www.motorola.com/Consumers/US-
`EN/Consumer-Product-and-Services/Mobile-Phones/ci.MOTOROLA-ATRIX-2-US-
`EN.alt#anchor (Exhibit 2037-1).
`
`An antenna constitutes a wireless communications means that facilitates wireless
`communication with a network that supports access to the Internet. The Android
`products each contain at least one antenna. For example, the Motorola Atrix has an
`antenna. Motorola Atrix 4G Page, available at
`http://www.motorola.com/us/consumers/Motorola-ATRIX-
`4G/72112,en_US,pd.html?selectedTab=tab-2&cgid=mobile-phones#tab (Exhibit 2038-1
`and 2) (touting the Motorola Atrix's support for Wi-Fi, Bluetooth, and 3G wireless
`technologies).
`
`The Android products each contain a display. For example, the Motorola Atrix has a
`touch-screen display. Motorola Atrix 4G Display Page, available at
`http://www.motorola.com/us/consumers/Motorola-ATRIX-
`4G/72112,en_US,pd.html?selectedTab=tab-4&cgid=mobile-phones#tab (Exhibit 2042)
`(showing display):
`
`
`
`Claim Language
`1. A wireless device, comprising:
`
`processing means;
`
`wireless communications means, to
`facilitate wireless communication with a
`network that supports access to the
`Internet;
`
`a display;
`
`
`1 The term "Android products" as used herein refers to all smartphones and tablets running Android OS version 2.0 or higher.
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`SoftView Exhibit 2034-1
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
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`Claim Language
`
`Android Product
`
`
`U.S. PATENT NO. 7,461,353
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`memory; and
`
`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 Android products each contain memory. For example, the Atrix models contain
`memory. The Atrix 2 contains "8GB on board, 1GB Dual Channel RAM." Motorola
`ATRIX 2 – Dual Core 4G Android Smartphone, Motorola, available at
`http://www.motorola.com/us/consumers/MOTOROLA-ATRIX-
`2/73912,en_US,pd.html?selectedTab=tab-2&cgid=mobile-phones#tab (Exhibit 2043-2).
`The Atrix 2 also contains removable memory: "2GB micro SD card preloaded
`(expandable up to 32GB)." Id. at 2043-3.
`
`Non-volatile memory constitutes a storage means. The Android products each contain
`memory on which programs, which include a plurality of instructions that are executed
`by the processor, are stored. For example, the Atrix models contain memory. The Atrix 2
`contains non-volatile memory and "8GB on board, 1GB Dual Channel RAM." Motorola
`ATRIX 2 – Dual Core 4G Android Smartphone, Motorola,
`http://www.motorola.com/us/consumers/MOTOROLA-ATRIX-
`2/73912,en_US,pd.html?selectedTab=tab-2&cgid=mobile-phones#tab (Exhibit 2043-2).
`The Atrix 2 also contains removable memory: "2GB micro SD card preloaded
`(expandable up to 32GB)." Id. at 2043-3. The instructions, when executed, enable these
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`SoftView Exhibit 2034-2
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
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`
`U.S. PATENT NO. 7,461,353
`
`Claim Language
`
`Android Product
`models to perform the following operations.
`
`rendering a browser interface via 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;
`
`These programs include the Android operating system, which includes the Android Web
`browser. These programs enable the wireless device to perform operations. See, e.g.,
`Motorola Atrix 4G Specifications Page, available at
`http://www.motorola.com/us/consumers/Motorola-ATRIX-
`4G/72112,en_US,pd.html?selectedTab=tab-2&cgid=mobile-phones#tab (Exhibit 2038-2)
`(identifying the operating system as "Android 2.3 (Gingerbread)"); About Android,
`http://www.android.com/about/ (Exhibit 2039-2) (describing "on Android, the home
`screen, Web browser, email and everything in between are designed to make your life
`easier.").
`
`The Android products each contain the Android operating system, which includes the
`Android Web browser. For example, the Motorola Atrix runs Android. Motorola Atrix
`4G Specifications Page, available at http://www.motorola.com/us/consumers/Motorola-
`ATRIX-4G/72112,en_US,pd.html?selectedTab=tab-2&cgid=mobile-phones#tab (Exhibit
`2038-2) (identifying the operating system as "Android 2.3 (Gingerbread)").
`
`The Android Web browser is a fully functional Web browser capable of requesting and
`retrieving Web pages. The Web page requested by the user may comprise HTML-based
`Web content, for example, an HTML file. The HTML file may have an original format
`defining a width and height. The HTML-based Web content has an original page layout,
`functionality, and design. See, e.g., Android 4.0 for Users,
`http://developer.android.com/about/versions/android-4.0-highlights.html (Exhibit 2040-
`7) ("The Android Browser offers an experience that's as rich and convenient as a desktop
`browser.").
`
`For example, a user may request access to an original Web page on the Android Web
`browser by clicking on a hyperlink in the Android Web browser or another Android
`application. See, e.g., Android User's Guide (Exhibit 2041-1) ("You can open links on a
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`SoftView Exhibit 2034-3
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
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`

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`U.S. PATENT NO. 7,461,353
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`Claim Language
`
`Android Product
`Webpage."); id. ("Touch a link to open it.").
`
`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
`when scaled and rendered; and
`
`In response to a user request to access a Web page, the Android products can access
`networks, including the Internet, via their antenna or antennae. See, e.g., Android User's
`Guide (Exhibit 2041-1) ("You can open links on a Webpage."); id. ("Touch a link to
`open it.").
`
`In response to a user request to access a Web page, the Android Web browser retrieves
`the Web page from a network, including the Internet, using the antenna. See, e.g.,
`Android User's Guide (Exhibit 2041-1) ("You can open links on a Webpage."); id.
`("Touch a link to open it."); See also claim element "wireless communications means, to
`facilitate wireless communication with a network that supports access to the Internet,"
`supra.
`
`Critical Acclaim for Preservation of Page Layout, Functionality and Design
`
`When this feature was first introduced by the iPhone, it was the subject of widespread
`industry praise because it allows users to see an overview of the full desktop version of a
`Web page on a mobile device. As noted by MacWorld, "Steve Jobs has promoted the
`Web-browsing experience on the iPhone as one that brings you the 'real Internet' – in
`other words, the experience of viewing the Web via a full-fledged computer browser, not
`dumbed-down pages simplified for mobile phones (or, what's worse, complicated Web
`pages that a puny cell phone browser can't properly render)." Snell, Jason, "The iPhone:
`Complete Review," MacWorld (July 3, 2007), available at
`http://www.macworld.com/2007/07/reviews/iphone_rev/index.php (Exhibit 2046-8).
`MacWorld goes on to explain that "[w]hen you're using Safari on the iPhone, you feel as
`if you're using Safari on your Mac. Web pages load in full, scaled-down to fit on the
`iPhone's screen." Id. The New York Times also praised this feature, noting that "[t]he
`Web browser… is the real dazzler. This isn't some stripped-down, claustrophobic My
`First Cellphone Browser; you get full Web layouts, fonts and all, shrunk to fit the
`screen." Pogue, David, "The iPhone Matches Most of Its Hype," The New York Times
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`SoftView Exhibit 2034-4
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
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`Claim Language
`
`Android Product
`
`
`U.S. PATENT NO. 7,461,353
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`(June 27, 2007), available at
`http://www.nytimes.com/2007/06/27/technology/circuits/27pogue.html?pagewanted=all
`(Exhibit 2047-3). This browser explains why "iPhone owners are the first people with a
`mobile phone to view Web pages at the same rate as people using a PC"; according to
`The Wall Street Journal, "it's just a matter of time until an iPhone-like browser is a
`standard feature on mobile devices." Worthen, Ben, "IPhones Take Over the Internet,"
`The Wall Street Journal Online (Dec. 4, 2007) (Exhibit 2022-1).
`
`Following in the iPhone's footsteps, the Android browser also has received critical
`acclaim for its ability to preserve the layout, functionality and design of Web pages
`designed for desktop viewing on a mobile device. For example, Computer Active praised
`the Android Honeycomb release as "[a]nother win for Google as the redesigned Android
`browser resembles the closest thing to a desktop experience." "Android, iPad,
`BlackBerry and Windows tablet group test," Computer Active (August 13, 2011)
`(Exhibit 2048-13). Because of their similarities, the Apple and Android WebKit
`browsers have been compared often. For example, in its review of the Motorola DROID,
`Smartphone Nation explained that "[i]t's crazy how we've gone from WAP sites to the
`mobile Web and now the real Web experience on your phone. The browser on the
`DROID is just as good as Safari if not better since they do run on WebKit." Collazo,
`Luis, "Motorola DROID Review," Smartphone Nation (Dec. 22, 2009), available at
`http://smartphonenation.com/2009/12/droid-review/ (Exhibit 2049-5).
`
`These shared features have led to the widespread use of both Android's standard WebKit
`browser and Apple's Mobile Safari Browser. Wireless Week noted that "[t]he fact that
`Apple and Android are generating the most mobile Web usage is no surprise. AdMob's
`Mobile Metrics Report for March of 2009 found that Android has enjoyed exceptional
`adoption since its launch, growing an average of 47 percent in the four months since
`launch." Berg, Andrew, "Report: Android, Apple Top Mobile Web Page Requests,"
`Wireless Week (May 27, 2009) (Exhibit 2050-1). Four years later, Apple and Android
`have taken over as much as 94% of the market. Gold, Jon, "Apple iOS battles back in
`market share struggle," Network World (July 8, 2013), available at
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`SoftView Exhibit 2034-5
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
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`Claim Language
`
`
`U.S. PATENT NO. 7,461,353
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`Android Product
`http://www.networkworld.com/news/2013/070813-iphone6-ios-marketshare-apple-
`android-271583.html (Exhibit 2051-1) ("[B]oth overall smartphone sales and Android's
`share thereof remain[ed] steady on a year-over-year basis[;] the gains made by iOS
`represent a closing of the gap between the two top mobile operating systems – the latter
`platform accounted for nearly 42% of sales, while Google's Android remained on top
`with 52%. Windows Phone took a distant third place, with 4.6%.").
`
`This success has been linked directly to the mobile browsers' ability to preserve the
`layout, functionality and design of Web pages designed for desktop computers. See, e.g.,
`Lev-Ram, Michal, "RIM: What the hell happened?" CNN Money (May 30, 2012),
`available at http://tech.fortune.cnn.com/2012/05/30/rim-2/ (Exhibit 2052-2) ("Both iOS
`and Android managed to overtake RIM precisely because they appealed to everyday
`users, not enterprise customers . . . And they gave users access to the full Web, not the
`miniaturized version offered on BlackBerries and low-end handsets. RIM's device – once
`the poster-child for mobile innovation – fell badly behind.").
`
`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.
`
`In addition to the critical acclaim for the Android browser's ability to preserve Web page
`layout, functionality and design, the inclusion of this feature with the release of Android
`2.0 was celebrated by the press. For example, when Engadget reviewed the Motorola
`DROID, the first phone released running Android 2.0, it specifically praised this
`improvement to the browser:
`
`You'll notice some major changes within the browser, most
`notably the fact that when you load up pages now, you're presented
`with a fully-zoomed out "overview" (much like the iPhone and
`Pre). If you've been griping about that weird, half-zoom that
`Android had relied on for so long (as we have), this is a breath of
`fresh air. Coupled with the DROID's massive display, it makes
`navigating pages roughly a million times more pleasant.
`
`Topolsky, Joshua, "Motorola DROID review," Engadget (Oct. 30, 2009), available at
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`SoftView Exhibit 2034-6
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
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`U.S. PATENT NO. 7,461,353
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`Claim Language
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`Android Product
`http://www.engadget.com/2009/10/30/motorola-droid-review/ (Exhibit 2053-12).
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`2835865
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`SoftView Exhibit 2034-7
`Kyocera Corp. v. SoftView LLC
`IPR2013-00007
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