Case 5:11-cv-00155-cr Document 11 Filed 01/17/12 Page 1 of 10
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`UNITED STATES DISTRICT COURT
`FOR THE
`DISTRICT OF VERMONT
`
`Case No. 5:11-cv-155
`
`))) ))) )
`
`ARNOUSE DIGITAL DEVICES CORP.,
`Plaintiff,
`
`v.
`
`MOTOROLA MOBILITY, INC.,
`Defendant.
`
`PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION
`TO DISMISS PLAINTIFF'S COMPLAINT
`
`Plaintiff Amouse Digital Devices Corporation ("Amouse Digital") hereby opposes
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`Defendant Motorola Mobility, Inc.'s ("Motorola") Rule 12(b)(6) Motion to Dismiss (Doc. 8, the
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`"Motorola Motion") Plaintiffs Amended Complaint (Doc. 4). The Motorola Motion puts forth
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`certain "facts" that Motorola asserts are "common knowledge" and then draws an erroneous
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`conclusion based on these facts.
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`In doing so, Motorola is attempting to preemptively impose a
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`definition of certain claim terms involved in the litigation and to circumvent the claim
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`construction process for this patent infringement case. Doing so is clearly improper at this
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`pleading stage and thus, the Court should decline Motorola's invitation to take "judicial notice"
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`of facts and engage in claim construction at this point in the litigation.
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`In the event the Court were to decide to take judicial notice of the "facts" proffered by
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`Motorola, Amouse Digital submits two Declarations with associated exhibits which present
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`factual matters outside the pleadings that contradict those proffered by Motorola and, if
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`considered by the Court, require that Motorola's Motion then be treated as one for summary
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`judgment under Rule 56. Fed. R. Civ. P. 12(d). In that event, the parties must be given notice of
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`the Court's decision to convert the motion to a summary judgment proceeding and an
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`opportunity to take fact discovery so they may submit all material that is pertinent to the motion
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 1
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`

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`Case 5:11-cv-00155-cr Document 11 Filed 01/17/12 Page 2 of 10
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`as provided for in the rule. Chambers v. Time Warner, 282 F.3d 147, 154 (2d Cir. 2002) (Rule
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`12(d)'s "conversion requirement is strictly enforced whenever a district court considers extra(cid:173)
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`pleading material in ruling on a motion to dismiss"). Moreover, whatever facts are considered
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`by the Court cannot be properly assessed without first engaging in the Markman process of claim
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`construction over disputed claim terms.
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`In short, the Court should DENY the Motorola Motion without the need to consider facts
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`outside the pleadings or engage in claim construction because judicial notice of the facts claimed
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`is inappropriate here and Plaintiff s Complaint alleges facts sufficient to state a plausible claim
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`for relief. Nothing more is needed or required at this stage of the case. As further support for its
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`opposition, Amouse Digital relies upon the following Memorandum of Law.
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`MEMORANDUM OF LAW
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`1.
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`Relevant Factual Background
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`Amouse Digital is the exclusive licensee of U.S. Patent No. 7,516,484 ("the '484
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`Patent"), for an invention titled "Reader Adapted for a Portable Computer." Doc. 1-1. The '484
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`Patent protects Amouse Digital's exclusive rights to manufacture, use, offer for sale, sell, and
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`import, inter alia, a "reader configured to interact with a portable computer without input and
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`output means for interacting directly therewith," a "reader configured to interact with a least one
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`hand-held portable computer" that "exclude[es] means for a user to interact with the computer", .
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`and a system made up of a reader and a portable computer in which the portable computer
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`"excludes means for a user to interact directly with [it]." '484 Patent at col. 13-14. Notably, for
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`most claims ofthe '484 Patent, (i.e., claims 1-14), the invention claimed is a reader, not a
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`portable computer, or is a system including both a reader and a portable computer (i.e., claims
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`2
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 2
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`Case 5:11-cv-00155-cr Document 11 Filed 01/17/12 Page 3 of 10
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`15-20). Amended Complaint at ~13. Thus, the reference to the portable computer of claims 1-14
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`is only pertinent to define attributes of the reader.
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`Motorola manufactures and sells the Atrix, Atrix II, and DROID 40 and other
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`smartphones (the "smartphones"), all of which allow users to interact with them through means
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`such as keyboards, speakers, buttons, microphones and screens. Amended Complaint at ~ 6;
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`Motorola Motion at 4-5. All the smartphones at issue are also capable of interacting with a
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`"reader" consisting of one or more versions of Motorola's Atrix Lapdock (the "Lapdock"), a
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`laptop shell that includes a housing that has a display screen, a keyboard, speakers, a
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`microphone, a battery, and a docking area for a smartphone, but which is a non-functioning shell
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`when not connected to a portable computer. Declaration of Daniel Gallic, attached as Exhibit A
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`("Gallic Declaration") at ~ 7.
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`When an Atrix smartphone is docked with the Lapdock, the Lapdock becomes a fully
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`functional general computer. Id. at ~ 9. Once the Atrix smartphone is docked to the Lapdock,
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`the smartphone itself can no longer receive user input or provide output from its keys, buttons,
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`microphone, speakers or screen. Id. Thus, the Lapdock is "configured to interact with a portable
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`computer without input and output means," as required by certain claims of '484 Patent. Id. at
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`~~9, 16, 17.
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`Moreover, when the Atrix's touch screen is disabled via a simple physical modification,
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`the smartphone completely lacks input/output means. Id. at ~ 10. However, once docked with
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`the Lapdock, the Atrix smartphone works in conjunction with the Lapdock to form a fully
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`functional computer by using the Atrix's hardware and software and the Lapdock's input/output
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`means. Id. at ~ 11. Thus, the Lapdock is "configured to interact with a portable computer
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 3
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`Case 5:11-cv-00155-cr Document 11 Filed 01/17/12 Page 4 of 10
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`without input and output means," as required by certain claims of<484 Patent. [d. at ~~ 11, 16,
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`17.
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`A Lapdock becomes a fully functioning computer when combined with the Atrix II, the
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`DROID 4G, and other smartphones offered by Motorola. Id. at ~~ 12-13. At least eleven
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`Motorola smartphones include two operating systems. Id. at ~ 12. One of the operating systems,
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`the "Android O/S", operates when the smartphone is undocked from a Lapdock. [d. The second
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`operating system, the "Webtop App", operates when the same smartphone is docked to a
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`Lapdock. Id. When undocked, each smartphone when standing alone is a fully interactive device
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`running the Android O/S while the Webtop App lies dormant and inaccessible to the user. When
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`docked with a Lapdock, however, each smartphone ceases to run the Android O/S and instead
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`operates through the Webtop App. Id.
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`In short, while docked, the smartphones' applications are
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`accessible only through the Lapdocks, and the displays on the smartphones go dark-in other
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`words, they lack input and output means.
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`!d. at ~~ 12, 13, 16-17; Motorola Motion at 4_5. 1
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`2.
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`The Amended Complaint States A Claim For Patent Infringement Against Motorola
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`A.
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`The Motion to Dismiss Standard
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`Federal Rule of Civil Procedure 8 states simply that a complaint must set forth a "short
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`and plain statement of the claim showing that the pleader is entitled to relief." This standard
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`requires a plaintiff to plead <'factual content that allows the court to draw the reasonable
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`inference that the defendant is liable for the conduct alleged." Ashcroft v. Iqbal, 129 S. Ct. 1937,
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`1949 (2009). In patent suits, Rule 8 may be satisfied when a patentee "plead[s] facts sufficient to
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`1 Arnouse Digital does not agree with or accept Motorola's suggested claim construction that the
`Patent's reference to a lack of input/output means is made with respect to the smartphones.
`Rather, it is Amouse Digital's position that the Patent's reference to a lack of input/output means
`is directed to functionality of the reader --- or in the case of Motorola's devices, the accused
`Lapdocks. To resolve this issue, the Patent and these claim terms must undergo the complete
`claim construction exercise required by Markman and its progeny.
`
`4
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 4
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`

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`Case 5:11-cv-00155-cr Document 11 Filed 01/17/12 Page 5 of 10
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`place the alleged infringer on notice as to what he must defend." McZeal v. Sprint Nextel Corp.,
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`501 F.3d 1354,1357 (Fed. Cir. 2007) (complaint satisfied Bell Atlantic Corp. v. Twombly where
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`plaintiff asserted ownership of patent, named defendant, cited patent in suit as allegedly
`
`infringed, and described means by which defendant's acts infringed). A "complaint attacked on a
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`motion to dismiss pursuant to Rule 12(b)(6) will survive so long as the factual allegations-
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`viewed in the light most favorable to the plaintiff and drawing all reasonable inferences in [its]
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`favor-are sufficient to 'raise a right to relief above the speculative level. '" Matson v. Board of
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`Ed., City Sch. Dist. ofNY, 631 F.3d 57, 72 (2d Cir. 2011) (quoting Twombly, 550 U.S. 544, 555
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`(2007)). Resolution of disputed factual issues is improper on a motion to dismiss. See, e.g.,
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`Pena v. DePrisco, 432 F.3d 98, 112 (2d Cir. 2005).
`
`B.
`
`otiee Of The Properti OfSmanphone
`Motorola's Request For Judicial
`Improperly Seeks To Have The Court Usurp The Jury's Fact-Finding Function
`And Is Inappropriate To The Complex Technology At Issue
`
`Motorola does not claim that the Amended Complaint fails to give notice as to what it
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`must defend. Instead, Motorola seeks to shortcut a trial altogether and asks the Court to dismiss
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`the case at the pleadings stage by using the evidentiary procedure ofjudicial notice to determine
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`the scope of the claims of the' 484 Patent, and to then to make a factual finding it cannot infringe
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`Amouse Digital's patent. Specifically, Motorola asks the Court to take judicial notice that the
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`claims of the' 484 patent, in fact, require a portable computer, that the claim term "portable
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`computer" is coextensive with the meaning of the term smartphone, and that the phrase "a
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`portable computer without input and output means" requires that the portable computer lack
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`input and output means at all times, not only when connected to a reader. As is clearly evident,
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`in order to accept Motorola's request, the Court would have to forgo the claim construction
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`process mandated by Markman v. Westview Instruments, Inc., 517 U.S. 370 (1996) over disputed
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`5
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 5
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`Case 5:11-cv-00155-cr Document 11 Filed 01/17/12 Page 6 of 10
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`claim tenns and the scope ofthe claims ofthe '484 Patent and then substitute its own judgment
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`for the jury's on a disputed question of fact. The Court should reject this invitation.
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`The Motorola Motion posits that "[i]t is common knowledge...that the smartphones at
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`issue here have input and output means" and asserts that this quality of the smartphones is
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`appropriate for judicial notice because it is "capable of accurate and ready detennination by
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`resort to sources whose accuracy cannot reasonably be questioned." Motorola Motion at 5.
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`Amouse Digital does not dispute that Motorola's smartphones include input and output means
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`when not connected to a Lapdock. However, the fact that Motorola's smartphones, in one
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`operating mode (un-docked), include input and output means does not lead inexorably to the
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`conclusion that it has not infringed the '484 Patent. For example, claims 1-14 of the '484 Patent
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`do not require a portable computer in order for infringement to exist. Furthennore, the meaning
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`of the tenn "portable computer" is likely in dispute. When operating under the Webtop App
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`operating system, the Atrix and certain other Motorola smartphones do not include input and
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`output means unless connected to a Lapdock. As a result, Amouse Digital contends that
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`Motorola smartphones in such operating configuration are portable computers. Additionally,
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`Amouse Digital contends that the Motorola smartphones do not have input and output means at
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`all times, and specifically, when Motorola smartphones are coupled to a Lapdock the smartphone
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`no longer has input or output means. Thus, under a variety of scenarios, Motorola's smartphones
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`and readers continue to infringe one or more claims of the' 484 patent even if the court takes
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`judicial notice that a smartphone includes input and output means.
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`Amouse Digital also contends that taking judicial notice of the fact that Motorola
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`smartphones include input and output means, in this instance, would be improper. In support of
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`its argument that what it claims are the common characteristics of a consumer electronic product
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`6
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 6
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`Case 5:11-cv-00155-cr Document 11 Filed 01/17/12 Page 7 of 10
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`are subject to judicial notice, Motorola relies on Eden Toys, Inc. v. Marshall Field & Co., 675
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`F.2d 498 (2d. Cir. 1982), a copyright dispute between two companies manufacturing stuffed toy
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`snowmen. Motorola Motion at 5. There, in finding that the basic design of a snowman was
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`subject to judicial notice, the court observed that "[f]or countless generations, children and the
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`young at heart have built snowmen by rolling moist snow into balls and placing them one atop
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`the other." Id. at 500.
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`Eden Toys is readily distinguishable. First, this is not a copyright case. It is a patent case
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`that will require claim construction and interpretation by this Court over disputed terms. Here,
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`given Motorola's argument, it is plain that there is a significant dispute over the term "portable
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`computer" which should be resolved via the Markman process. But Markman is not needed to
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`properly deny Motorola's motion. Setting aside disputes over the meaning of the claim terms
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`and the facile nature of Motorola's attempt to analogize the functionality of a mobile computer to
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`the basic design of a snowman, the takeaway from Eden Toys is that the basic attributes of a
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`snowman were subject to judicial notice because they have remained unchanged for "countless
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`generations." By contrast, if anything, the Court can and should take judicial notice that the
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`smartphones made and marketed by Motorola and others present a dizzying and quickly
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`changing range of functionality, features and options.
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`In short, the inventions protected by the
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`'484 Patent are part of a competitive, rapidly developing market in which the functionality and
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`characteristics of products is constantly changing. Moreover, and as demonstrated in the Gallic
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`Declaration and by Motorola's own statements, these product characteristics are not unchanging
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`even within a single unit but instead can depend on whether the product is used on its own or in
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`conjunction with accessories such as the Lapdock. Gallic Declaration at ~~ 9-13. Pinning and
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`7
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 7
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`Case 5:11-cv-00155-cr Document 11 Filed 01/17/12 Page 8 of 10
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`fixing what a "smartphone" does or does not do through judicial notice is wholly inappropriate.
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`A computer is simply more complicated than the shape of a toy snowman.
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`At the appropriate time in this litigation, this Court will construe the claim terms of the
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`'484 Patent, possibly including "portable computer" and "input and output means," in order to
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`determine their meaning and scope. Every Penny Counts v. American Express, 563 F.3d 1378,
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`1381 (Fed. Cir. 2009). Based on the meaning of the claim terms, a jury will then decide the fact
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`question of whether Motorola's accused devices infringe the '484 Patent. Lucent Techs., Inc. v.
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`Gateway, Inc., 580 F,3d 1301,1309 (Fed. Cir. 2009). Without the benefit of claim construction,
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`however, the Court cannot determine the meaning of the language ofthe '484 Patent. And
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`without evidence to show whether the accused devices meet the construed claim language, no
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`factual determination of infringement or non-infringement could be proper.
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`Given Motorola's motion, the Court here is charged with only determining whether the
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`facts alleged by Amouse Digital, viewed in the most favorable light to Amouse Digital, state a
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`claim for patent infringement. Seen in that light, the Amended Complaint satisfies Twombly and
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`McZeal by placing Motorola on notice of what it must defend. And, in this context, it would be
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`improper for this Court to take judicial notice of how smartphones operate and leap over the
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`claim construction process. And, even accepting Motorola's claim construction, as shown both
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`by the Gallic Declaration and by Motorola's own representations, the Motorola smartphones in
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`fact lack input and output means when joined with the Lapdock. The Court should therefore
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`deny Motorola's Motion.
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`3.
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`Conclusion
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`Plaintiff Amouse Digital Device Corp.'s Amended Complaint satisfies Fed. R. Civ. P. 8
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`by placing Defendant Motorola Mobility, Inc. on notice as to what it must defend. Whether the
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 8
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`Case 5:11-cv-00155-cr Document 11 Filed 01/17/12 Page 9 of 10
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`Motorola smartphones at issue lack input and output means when joined with the Lapdock is a
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`mixed question of fact and law that cannot be resolved on a motion to dismiss but rather must be
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`resolved by a jury in light of binding claim construction by the Court. The Court should
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`therefore DENY Defendant's Motion to Dismiss, order Defendant to answer Plaintiffs Amended
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`Complaint, and grant all other relief that is just and proper.
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`Respectfully Submitted,
`
`DOWNS RACHLIN MARTIN PLLC
`
`/s/ R. Bradford Fawley
`R. Bradford Fawley
`28 Vernon S1. Suite 501
`Brattleboro VT 05302
`(802) 258 3070
`bfawley@drm.com
`
`ATTORNEYS FOR PLAINTIFF
`ARNOUSE DIGITAL DEVICES CORP.
`
`9
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 9
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`Case 5:11-cv-00155-cr Document 11 Filed 01/17/12 Page 10 of 10
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`UNITED STATES DISTRICT COURT
`
`DISTRICT OF VERMONT
`
`I hereby certify that on January 17, 2012, I electronically filed PLAINTIFF'S OPPOSITION
`TO DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT with the Clerk
`of Court using the CM/ECF system which will send notification of such filing(s) to the
`following: Samuel Hoar, Jr., Esq.
`
`lsi R. Bradford Fawley
`R. Bradford Fawley
`Downs Rachlin Martin PLLC
`28 Vernon Street, Suite 501
`Brattleboro, VT 05301
`(802) 258-3070
`bfawley@drm.com
`
`4855178.4
`
`10
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 10
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`Case 5:11-cv-00155-cr Document 11-1 Filed 01/17/12 Page 1 of 2
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`UNITED STATES DISTRICT COURT
`FOR THE
`DISTRICT OF VERMONT
`
`Case No. 5:II-cv-155
`
`) ))) ) ))
`
`ARNOUSE DIGITAL DEVICES CORP.,
`Plaintiff,
`
`v.
`
`MOTOROLA MOBILITY, INC.,
`Defendant.
`
`DECLARATION OF JUSTIN McCABE IN SUPPORT OF
`PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION
`TO DISMISS PLAINTIFF'S COMPLAINT
`
`I.
`
`My name is Justin McCabe. I am an attorney with Downs Rachlin Martin PLLC,
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`counsel of record for Plaintiff Arnouse Digital Devices Corporation (hereinafter "Arnouse
`
`Digital"). I am over 18 years of age and understand the obligations of an oath. I make this
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`declaration based upon my personal knowledge.
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`2.
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`As part of my research with respect to Defendant Motorola Mobility, Inc.'s
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`("Motorola") Motion to Dismiss, I went on the Internet and visited Motorola's website,
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`motorola.com.
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`3.
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`Once at motorola.com, I clicked on the tab labeled "SOFTWARE/APPS" in the
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`website's top bar. By clicking on "SOFTWARE/APPS" I triggered a drop-down menu from
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`which I selected the first option, "app picks."
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`4.
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`Once at the "app picks" page, I scrolled to the bottom ofthe page, where I clicked
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`on a link labeled "MOTODEV." The "MOTODEV" link took me to separate website titled
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`"MOTODEV: The Motorola developer network."
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`5.
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`Once at "MOTODEV: The Motorola developer network" I clicked on the link
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`labeled "Android Technical Library." Once at the "Android Technical Library" page, I clicked
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 11
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`Case 5:11-cv-00155-cr Document 11-1 Filed 01/17/12 Page 2 of 2
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`on the link labeled "Webtop Application Overview" which can be found at
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`A copy of the
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`"Webtop Application Overview" page I saw is attached to this Declaration as Exhibit A.
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`6.
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`On that "Webtop Application Overview" page, Motorola states that (I) when
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`connected to a Lapdock with its display screen opened, the smartphones automatically cease to
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`use the Android Operating System and instead begin working as computers through an integrated
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`Linux-based "Webtop" software application, (2) when the Webtop application is launched in a
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`Lapdock, the smartphones go into sleep mode and do not display the mobile phone's device's
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`applications, and (3) that once docked, "[y]our phone will automatically go to Webtop mode and
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`your phone will appear to go into sleep mode." On that same page, I also saw a photograph ofan
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`Atrix Smartphone screen that was blank when docked to the operating Lapdock.
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`7.
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`For the Webtop Application Overview page I clicked the linked labeled "Show all
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`devices with the webtop application", which can be found at
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`hup://dev loper.mot rola.com/products/?filter. =1509#fiIter/. A copy of the ''Android™_
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`Powered Devices" page I saw is attached to this Declaration as Exhibit B.
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`Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and
`correct.
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`Dated: January 17,2012
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`4802934.2
`
`By:
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`--r-T-.~--:----------
`Ju
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`2
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 12
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`Case 5:11-cv-00155-cr Document 11-2 Filed 01/17/12 Page 1 of 8
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`Exhibit A
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 13
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`

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`MOTODEV> Docwnentation & Tools> Android Technical Library> Webtop Application Overview
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`http://developer.motorola.com'docstools/library/webtop-application-overview/
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`Case 5:11-cv-00155-cr Document 11-2 Filed 01/17/12 Page 2 of 8
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`alleU
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`~ Print Document
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`ro SHARE ~ ;.
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`Table of Contents
`)- What is the v-ebtop application?
`
`) Supported devices
`) Peripherals
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`) Activating the v-ebtop application
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`) Undocking and re-docking
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`)- The v-ebtop application desktop
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`) Mobile View
`) Firefox browser
`) File manager
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`) Webtop application types
`)- Android app support
`) HTML5 app support
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`) App tray icons
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`Webtop Application Overview
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`Although there is little that an Android™ or HTML5 developer must do to tailor their apps to run v-ell I'.1th the v-ebtop application developers
`should be familiar I'.1th the v-ebtop application and how an end user interacts I'.1th it Accordingly, this article presents an introduction to the
`v.ebtop application and points out those aspects that 1'.111 be of particular interest to developers_
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`What is the webtop application?
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`Webtop refers to a v-eb-based desktop environment that is presented by the v-ebtop
`application found on certain Android devices such as Motorola ATRIXTM 4G. The
`>;vebtop application is launched when you connect the device to a full-sized display
`and (optionally) a keyboard and mouse through one of the available docks,
`morphing the device into one better suited for a given situation:
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`)- The Lapdock™, I'.1th its built-in 11.5" (1366 x 768 pixel) screen. keyboard. and
`trackpad. allows you to use the v-ebtop application while on the go
`)- The HD Multimedia Dock allows you to use the device as an entertainment center (complete I'.1th remote control) and is suitable for office
`use: it can connect the device to an external monitor, keyboard, and mouse.
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`The v-ebtop application presents a full Firefox desktop browser (version 4.0.1 on Gingerbread. version 3.6 13 on Froyo)-complete I'.1th
`Adobe Flash 10.1. multiple I'.1ndows. tabs, themes, and add-ons-along I'.1th the "Mobile View': a I'.1ndow V>ithin which the user can run
`Android apps and otherV>ise interact I'.1th their mobile device. The v-ebtop application extends the multitasking and computing experience of
`the mobile device V>ithout compromising on the device's mobile features.
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`This ability of the device to readily adapt itself to differing situations means that users V>ill be able to leave their computers behind while still
`enjoying an uncompromised experience whether at \M)rk, at play. or on the go.
`
`Supported devices
`Show all devices V>ith the v-ebtop application
`
`Petlpherals
`As befitting a desktop or laptop computer, Votlen the device is running the v-ebtop application, you have the option to connect a number of
`peripherals. The v-ebtop application includes support for standard HID keyboards and mice. either V>ired (through a dock's USB ports) or
`I'.1reless (such as Bluetooth keyboards and nlice). As v-ell. you can connect a V>ired or V>ireless headset (as you can Votlen the device is not
`running the v-ebtop application). Printers are supported (you can print from Firefox from v-eb apps, or from the PDF viev-er). but only if they
`are IP-accessible on the same V>ireless netv.ork
`
`Using one of the dock's USB ports you can connect a USB mass-storage device such as a flash drive. When you plug in a recognized
`mass-storage device it mounts automatically. Mounted USB storage is visible in both the v-ebtop application's File Manager and in the Mobile
`Views Files app, as is tile deVIce's internal storage and removable SD card (if one is present in the device). Android apps can access these
`various volumes using their paths:
`
`)- The device's internal storage (essentially, a "non-remcvable SD card") is mounted as ,,,.JcMdl
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`1 of7
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`1/2/2012 12:57 PM
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`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 14
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`

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`MOTODEV> Docwnentation & Tools> Android Technical Library> Webtop Application Overview
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`http://developer.lOOtorola.comldocstools/library/webtop-application-overviewl
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`Case 5:11-cv-00155-cr Document 11-2 Filed 01/17/12 Page 3 of 8
`
`> The devices removable SO card IS mounted as ~'t·~o_<.J-2>:t/
`> USB mass storage devices are mounted using sorrething along the lines of ,-,Sbciis,c _. ~
`USB deVIce and the number of devices currently mounted)
`
`(the exact narre may vary depending upon the
`
`As is standard practice. be sure to unmount any connected mass-storage devices before disconnecting them
`
`At this tirne only keyboards, mice, and USB mass storage deVIces can be plugged into the dock's USB port at this time. You wll be notified if
`you attempt to plug in an unrecognized USB deVIce.
`
`Remote Control
`
`The HD Multimedia Dock Includes a remote control that proVIdes a rreasure of control from a distance
`Although it is intended to allow a user to remotely control mullimedia playback on a docked deVIce connected
`to their television and/or stereo app developers can take advantage of the remote in their applications if they
`so choose. Note that the remote Wlrks wth the dock. not the deVIce. so that an app wll only be able to
`respond if the device is docked
`
`The Menu. Home, and Back buttons on the remote act just like the corresponding buttons on the deVIce. The
`other buttons on the remote cause the followng key events to be generated:
`
`Key(s)
`
`Event(s)
`
`5-way navigation control
`
`Sends and ro id. v Ie., . Ke';Event . KEYCOD£ DPi'.D events
`
`Rewnd, Play/Pause, Fast Forward Sends android. vie',]. EeyEvent. KEYCODE _l~EDIA key events
`
`Volume dOIMl. mute. volume up
`
`Sends andrOId. VltW. KeyEvent. KEYCfJDE VOLU~IE key events
`
`Apps IIlat register for the listed events wll receive them when the user presses the appropriate buttons on the
`HO Multimedia Dock remote control
`
`Activating the webtop application
`The v.ebtop application is always present on the deVIce but is only available when you Insert the device into a
`dock wth a dedicated display (sllch as the Lapdock) or when you drop it into a dock to which an external
`monitor IS connected. You \/VIII then be given the option to launch the v.ebtop app, run the Entertainment
`Center app. or do neither Note that wth the Lapdock, the v.ebtop application wiliaunch automatically if the
`display IS open.
`
`Allhough an external display is required. input devices are optional: the device itself stands In for either or
`both. If neither a keyboard nor a mouse is connected, the device's touchscreen presents both when the v.ebtop application IS running. If only
`a keyboard IS connected, the device display acts as a large trackpad. If only a mouse is connected, the device presents a QWER1Y
`keyboard that can be used for data Input. Finally, if both a keyboard and a mouse are connected, the device display show.; the current time
`and date, and Information about any incomng calls. It IS important to be aware that when the v.ebtop application is running. the Android
`deVIce display is presented on the connected monitor, in the Mobile View.
`
`Undoddng and re-docJdng
`The v.ebtop application is designed so that you can simply grab your device out of the dock. IMthout having to take any action (besides
`unmounting any connected USB mass-storage devices). When the device is undocked, allv.ebtop application activity is suspended and the
`v.ebtop application itself moves to the background. For a period of time. hov.ever, the Firefox brow.;er remains running, to allow any auto-save
`functionality to trigger for v.eb sites such as Gmall or Microsoft Office Live. After this period of time. Firefox IS suspended and ItS priority is
`
`2of7
`
`112/20]2 12:57 PM
`
`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 15
`
`

`
`MOTODEV> Documentation & Tools> Android Technical Library> Webtop Application Overview
`
`http://developer.motorola.comldocstools/library/webtop-application-overview/
`
`Case 5:11-cv-00155-cr Document 11-2 Filed 01/17/12 Page 4 of 8
`
`lo_red, allolMng It to be killed if Android deems it necessary
`
`As you would expect. when the device is undocked v.nalever was running in the foreground inlhe Mobile View (that is the top tab) becomes
`lrle foreground app on tile device,
`
`Once undocked, you can use the Webtop Connector app on the device to get a list of all browser pages that 'Aere open In Firefox, as _II as
`a list of all of the Firefox bookmarks (bookmarks only: other information such as your browsing history is not included). Selecting one of these
`_b pages or bookmarks in the Webtop Connector app broadcasts an Android Intent allowng ti,e URL to be opened either in the WebKit
`browser or in any other app that can handle that URL For IIlstance, a Google M8PS URL could be opened in the WebKit bro\loSer in the
`Google Maps app, or in a third-pal ty maps application.
`
`For easy access the Webiop Connector app appears in tl",e deVice's status bar
`
`When you "re-dock' your device after undocking, the device restores the state of the v.ebtop applici.ltion as it vvas prior to undocking and
`moves the vl€btop application to the foreground The Mobile View sho\l'.';3 v.natever IS I unnlng on the device at the time it is re-docked (rather
`than v.nat was shovo.ing v.nen the device was undocked). It Wlile the device was undocked, a low memory situation caused Android to kill
`Firefox, upon re-docklllg Firefox is relaunched and lIs stale (all \,,;ndom and tabS) is restored
`
`The webtop application desktop
`The desktop presented by the v.ebtop application on the connected monitor looks like a typical computer desktop vo.ith a status bar across the
`top, an "applications tray" across the bottom, and user-sized \\indoviS V't1erever the user chooses to position theill. One \\indow (tile Mobile
`View) presents the device's display, Wlile one or mare Firefox windows are managed by the desktop bromer.
`
`30f7
`
`1/2/201212:57 PM
`
`Petitioner Motorola Mobility LLC - Exhibit 1009 - Page 16
`
`

`
`MOTODEV> Docwnentation & Tools> Android Technical Library> Webtop Application Overview
`
`http://developer.motorola.comidocstools/library/webtop-application-overview/
`
`Case 5:11-cv-00155-cr Document 11-2 Filed 01/17/12 Page 5 of 8
`
`The left side of the status bar show.; the notification icons from the left side of the device's OWl status bar; you can double-click these to see
`details of the notifications wth the resuijs showng in the Mobile View. The right side of the v.ebtop application's status bar show.; a clock along
`wth icons for various menus and status indicators, including Wi-Fi. Bluetooth, GPS, HSDPA, and cellular netv.ork status and settings; battery
`lel.€l. and audio volume IeI.€I. Finally, the right side of the status bar has an icon for a status menu that allow.; you to specify desktop-specific
`settings (including printer and proxy settings).
`
`As on the Android device, notifications are initially presented in a transientwndow. Phone calls that come in while the device is sholAing the
`v.ebtop desktop are presented in one of these transientwndow.;, along wth buttons that allow the user to specify whether the call should be
`ansv.ered or ignored.
`
`The applications tray is an array of icons across the bottom of the screen A divi