throbber
EXHIBIT 1
`
`Affinity Labs Exemplary Infringement Contentions for U.S. Patent No. 8,359,007
`Samsung Android Smartphones and Tablets
`
`Affinity Labs contends that Samsung Android smartphones and tablets made, used, offered for sale, sold in, of imported into the
`United States by Samsung infringe U.S. Patent No. 8,359,007 in the manner charted herein.
`
`For Samsung smartphones, this chart identifies specific structures in the Galaxy Note II. Other Samsung cellular phones,
`identified in Appendix A below, infringe claims 1-10 of U.S. Patent No. 8,359,007 in the same manner as charted for the Galaxy Note
`II, or with insignificant technological differences of their employed hardware or software as compared to the Galaxy Note II.
`Accordingly, the manner in which the Galaxy Note II infringes is representative of the manner in which other Samsung devices also
`infringe U.S. Patent No. 8,359,007, and these infringement contentions cover all below-identified Samsung products.
`
`Additionally, Appendix B identifies Samsung tablet computing devices that infringe claims 7-10 of U.S. Patent No. 8,359,007.
`
`Unless otherwise noted, the tablets listed in Appendix B infringe claims 7-10 in the same manner as the Galaxy Note II smartphone.
`Solely for the purposes of illustration, the chart also describes how one representative tablet is a computing device.
`
`Affinity Labs bases these infringement contentions on information presently known, publicly available, and accessible with
`
`reasonable diligence, as well as information and belief. Information regarding the physical structure and software operation of the
`identified devices comprises information purportedly proprietary and/or confidential to Samsung, and which is not available to
`Affinity Labs. For example, Affinity Labs has attempted to obtain from Defendants information pertaining to the applications that
`come preloaded on Defendants’ products so that it may determine whether those applications provide additional grounds for
`infringement. Given Affinity Labs limited knowledge, at this time, of the scope of these preloaded applications, as well as Affinity
`Labs’ access to the source code for the preloaded application, Affinity Labs reserves its rights to update its infringement contentions
`based on ongoing discovery and investigation. By way of non-limiting example, Affinity Labs has not had access to the source code
`for the following preloaded applications and has not been able to determine whether they provide additional means of infringement:
`AllShare Play, Media Hub, Music Hub, Music Player, Play Books, Play Magazines, Play Movies & TV, Play Music, Play Store,
`Samsung Apps, Talk, Video Player, YouTube, Xbox Live, Zune Music & Videos, Slacker Radio, Samsung Zone, Podcasts, and
`Google Play. Further, to the extent Affinity Labs uncovers a claim of induced infringement regarding an application that is not
`preloaded but provides additional grounds for infringement, Affinity Labs reserves its rights to supplement its contentions. By one of
`non-limiting example, such applications might include Netflix, and Hulu.
`
`
`84103029.1
`
`1
`
`Samsung-LG-HTC Ex. 1015 p. 1
`
`

`

`Affinity Labs believes the disclosures provided in these infringement contentions are sufficient to provide notice of Affinity
`Labs’ infringement theories in accordance with the local rules and case law, and without reliance upon source code under Rule 3-1(g).
`This is because while certain claim elements are implemented in software, they are not software algorithm claims. Affinity Labs
`further believes that infringement can be proven directly, circumstantially or inferentially using the products, manuals, specifications
`and other documentation, and without using source code, but that source code provides the most concrete proof of infringement for
`some claim elements. Accordingly Affinity Labs expects that source code will be produced in this case in accordance P.R. 3-4 and
`Affinity Labs expects to introduce source code as evidence at trial for some claim elements. In order to ensure compliance with the
`scheduling order, Affinity Labs has identified these claim elements as “software limitations” in accordance with Rule 3-1(g).
`
` Affinity Labs believes, however, that the parties should meet and confer regarding whether or how Rule 3-1(g) should be applied in
`this case. For instance, the parties have no agreement yet regarding representative products. It will be burdensome to produce all
`versions of all source code for all products, and it may not be possible for Affinity Labs to review all of that code and supplement
`contentions in 30 days. Furthermore, Affinity Labs may need to seek 30(b)(6) depositions for the sole purpose of identifying the
`appropriate code, which will not be cost effective for the parties if all source code for all products is implicated. Affinity Labs will
`seek to meet and confer on this topic immediately upon providing these contentions.
`
`Affinity Labs may expand or reduce these contentions and subdivide or consolidate the categorization of representative products
`based on Samsung’s disclosure of source code and documents describing the physical structure and operation of the devices. Affinity
`Labs may change the groupings of accused products. Affinity Labs reserves the right to amend or supplement these contentions based
`on information ascertained in discovery.
`
`
`
`84103029.1
`
`2
`
`Samsung-LG-HTC Ex. 1015 p. 2
`
`

`

`
`
`1.
`
`1.a
`
`Claim
`
`A system comprising:
`
`Exemplary Infringement Support
`
`Samsung directly infringes this claim by making, using, selling, or offering for sale the Galaxy
`Note II. Alternatively, Samsung induces its customers to infringe this claim. Alternatively,
`Samsung contributorily infringes this claim.
`
`The Galaxy Note II is an infringing system, as described below.
`
`The Galaxy Note II is a cellular telephone.
`
`
`a cellular telephone
`comprising a display, a non-
`volatile memory, and a
`processing device operable
`to execute instructions
`stored in the non-volatile
`memory;
`
`
`Galaxy Note II Sprint User Guide at 41
`
`
`
`84103029.1
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`3
`
`Samsung-LG-HTC Ex. 1015 p. 3
`
`

`

`
`The Galaxy Note II has a display.
`
`
`
`Galaxy Note II Sprint User Guide at 1.
`
`
`
`
`
`Galaxy Note II Online Specification (available at
`
`
`
`84103029.1
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`4
`
`Samsung-LG-HTC Ex. 1015 p. 4
`
`

`

`http://www.samsung.com/global/microsite/galaxynote/note2/spec.html?type=find)
`
`
`
`
`
`Galaxy Note II Online Tech Specs (available at
`http://www.samsung.com/ph/support/model/GT-N7100RWDXTC-techspecs)
`
`
`The Galaxy Note II has a non-volatile memory.
`
`
`
`
`
`Galaxy Note II Online Specification (available at
`http://www.samsung.com/global/microsite/galaxynote/note2/spec.html?type=find)
`
`
`
`
`
`Galaxy Note II Online Tech Specs (available at
`http://www.samsung.com/ph/support/model/GT-N7100RWDXTC-techspecs)
`
`
`The Galaxy Note II also accepts SD cards. Once inserted, an SD card also acts as non-volatile
`memory.
`
`84103029.1
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`5
`
`Samsung-LG-HTC Ex. 1015 p. 5
`
`

`

`
`
`
`
`
`Galaxy Note II Online Specification (available at
`http://www.samsung.com/global/microsite/galaxynote/note2/spec.html?type=find)
`
`
`
`
`Galaxy Note II User Manual at 16.
`
`
`The Galaxy Note II has a processing device operable to execute instructions stored in the Galaxy
`Note II’s non-volatile memory.
`
`
`
`
`
`
`
`Galaxy Note II Online Specification (available at
`http://www.samsung.com/global/microsite/galaxynote/note2/spec.html?type=find)
`
`
`
`Galaxy Note II Online Tech Specs (available at
`
`
`
`84103029.1
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`6
`
`Samsung-LG-HTC Ex. 1015 p. 6
`
`

`

`http://www.samsung.com/ph/support/model/GT-N7100RWDXTC-techspecs)
`
`
`
`Galaxy Note II User Manual at 122.
`
`
`
`1.b
`
`a browser saved locally at
`the cellular telephone and
`configured to facilitate
`accessing of a webpage; and
`
`The Galaxy Note II has a browser saved on the Galaxy Note II and configured to facilitate the
`accessing of a webpage.
`
`
`
`Galaxy Note II Sprint User Guide at 189.
`
`
`
`
`
`
`
`Galaxy Note II Sprint User Guide at 192.
`
`
`To the extent that an accused product does not literally meet this limitation, Affinity Labs asserts
`that the limitation is met under the doctrine of equivalents.
`
`84103029.1
`
`7
`
`Samsung-LG-HTC Ex. 1015 p. 7
`
`

`

`Pursuant to Rule 3-1(g) as set forth in the Court’s Scheduling Order, and under the conditions set
`forth in the cover pleading, Affinity Labs identifies this limitation as a software limitation.
`
`Affinity Labs also notes that, though this limitation is related to the “collection of instructions”
`and therefore may be demonstrated with source code, Affinity Labs reserves its rights to establish
`the limitation by way of other evidence. By way of non-limiting example, Affinity Labs includes
`the following examples in its infringement contentions. The examples below should in no way be
`construed as limiting the scope of source code that Defendants are required to produce pursuant to
`Local Patent Rules 3-1(g) and 3-4(a). For example, the discussion of HTTP Live Streaming
`(“HLS”) below should not be interpreted to limit the scope of Defendants’ production to source
`code related to HLS.
`
`The Galaxy Note II has the Android operating system, version 4.1, stored in its non-volatile
`memory when sold.
`
`
`1.c
`
`a collection of instructions
`stored in the non-volatile
`memory and operable to
`direct the cellular telephone
`to request a list of network
`addresses for a plurality of
`portions of an available
`media, to request delivery
`of a first portion of the
`available media such that
`the first portion is delivered
`at a first communication
`rate, and to request delivery
`of a second portion of the
`available media such that
`the second portion is
`delivered at a second
`communication rate that is
`different from the first
`communication rate.
`
`
`Galaxy Note II Online Specification (available at
`http://www.samsung.com/global/microsite/galaxynote/note2/spec.html?type=find)
`
`
`
`
`
`Galaxy Note II User Manual at 122.
`
`
`
`
`
`84103029.1
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`8
`
`Samsung-LG-HTC Ex. 1015 p. 8
`
`

`

`The Android operating system, version 4.1, has a collection of instructions for playing streaming
`media available via the HLS protocol.
`
`
`
`http://developer.android.com/about/versions/android-3.0-highlights.html
`
`
`
`
`
`http://developer.android.com/guide/appendix/media-formats.html
`
`
`
`
`84103029.1
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`9
`
`Samsung-LG-HTC Ex. 1015 p. 9
`
`

`

`
`http://developer.android.com/about/versions/android-4.0.html#api
`
`
`
`
`
`
`
`
`http://developer.android.com/about/versions/android-4.0-highlights.html
`
`The Galaxy Note II has instructions to request a list of network address for a plurality of portions
`of an available media. When accessing media available via the HTTP live streaming protocol, the
`Galaxy Note II will request an index file containing a list of network addresses corresponding to
`portions of an available media.
`
`84103029.1
`
`10
`
`Samsung-LG-HTC Ex. 1015 p. 10
`
`

`

`
`http://www.heywatchencoding.com/http-live-streaming-hls
`
`
`
`
`
`
`
`84103029.1
`
`11
`
`Samsung-LG-HTC Ex. 1015 p. 11
`
`

`

`
`HTTP/HTTPS Live Streaming Draft Protocol at 3-4 (available at
`http://tools.ietf.org/html/draft-pantos-http-live-streaming-10)
`
`
`
`
`The Galaxy Note II supports playback of variant playlists using the HTTP live streaming protocol.
`
`
`
`http://developer.android.com/about/versions/android-3.0-highlights.html
`
`
`The Galaxy Note II contains instructions operable to request a first segment of a streaming media
`file at a first communication rate, and a second segment of a streaming media file at a second
`communication rate. The Galaxy Note II can therefore issue a request for the next segment of the
`streaming media such that it is delivered at a different communication rate.
`
`
`
`
`84103029.1
`
`12
`
`Samsung-LG-HTC Ex. 1015 p. 12
`
`

`

`
`
`
`http://www.heywatchencoding.com/http-live-streaming-hls
`
`The Galaxy Note II therefore contains instructions operable to request switching between variants
`of encoded media such that the second portion is delivered at a second communication rate.
`
`This limitation would likewise be met by any Samsung product that uses a version of Android that
`supports HLS, which, based on Affinity Labs initial investigations includes all devices with
`Android 3.0 or later.
`
`To the extent that an accused product does not literally meet this limitation, Affinity Labs asserts
`that the limitation is met under the doctrine of equivalents.
`
`Samsung directly infringes this claim by making, using, selling, or offering for sale the Galaxy
`Note II. Alternatively, Samsung induces its customers to infringe this claim. Alternatively,
`Samsung contributorily infringes this claim.
`
`Every claim limitation of claim 1 is present in the Galaxy Note II as described above.
`
`The Galaxy Note II’s browser uses HTTP to facilitate accessing available media using the HTTP
`live streaming protocol.
`
`2.
`
`The system of claim 1,
`wherein
`
`2.a
`
`the browser utilizes hyper
`text transfer protocol (http)
`to facilitate accessing the
`available media.
`
`84103029.1
`
`13
`
`Samsung-LG-HTC Ex. 1015 p. 13
`
`

`

`5.
`
`The system of claim 1,
`further comprising
`
`Samsung directly infringes this claim by making, using, selling, or offering for sale the Galaxy
`Note II. Alternatively, Samsung induces its customers to infringe this claim. Alternatively,
`Samsung contributorily infringes this claim.
`
`Every claim limitation of claim 1 is present in the Galaxy Note II as described above.
`
`5.a
`
`an email client saved locally
`to the cellular telephone,
`
`The Galaxy Note II has a locally-saved e-mail client.
`
`
`
`Galaxy Note II User Manual at 63
`
`
`
`The Galaxy Note II’s e-mail client is operable to receive an email with a media file attachment.
`
`
`5.b wherein the e-mail client is
`operable to receive an email
`with a media file
`attachment.
`
`84103029.1
`
`14
`
`Samsung-LG-HTC Ex. 1015 p. 14
`
`

`

`
`Galaxy Note II User Manual at 64
`
`
`
`Samsung directly infringes this claim by making, using, selling, or offering for sale the Galaxy
`Note II. Alternatively, Samsung induces its customers to infringe this claim. Alternatively,
`Samsung contributorily infringes this claim.
`
`Every claim limitation of claim 1 is present in the Galaxy Note II as described above.
`
`The Galaxy Note II has a Micro-USB port that acts as a single docking point that includes a
`portion configured to transmit power and a different portion configured to transmit data.
`
`
`6.
`
`The system of claim 1,
`further comprising
`
`6.a
`
`a non-circular physical
`interface configured such
`that the non-circular
`physical interface acts as a
`single docking point that
`includes a portion
`configured to transmit
`power and a different
`portion configured to
`
`84103029.1
`
`15
`
`Samsung-LG-HTC Ex. 1015 p. 15
`
`

`

`transmit data.
`
`
`Galaxy Note II Sprint User Guide at 3.
`
`
`
`
`
`
`Galaxy Note II User Manual at 14.
`
`
`
`84103029.1
`
`16
`
`Samsung-LG-HTC Ex. 1015 p. 16
`
`

`

`
`Galaxy Note II User Manual at 50.
`
`
`
`Samsung directly infringes this claim by making, using, selling, or offering for sale the Galaxy
`Note II. Alternatively, Samsung induces its customers to infringe this claim. Alternatively,
`Samsung contributorily infringes this claim.
`
`The Galaxy Note II is an infringing system, as described below.
`
`The Galaxy Note II is a computing device equipped with a processor, memory, an operating
`system and various applications. It also possesses a wireless receiver. (Although the products
`listed in the attached appendices do not necessarily have all of the wireless communication
`systems listed below, all of the products have at least WiFi and Bluetooth systems.)
`
`
`7.
`
`A system comprising:
`
`7.a
`
`a computing device having
`a wireless receiver, a top
`surface, a display that
`makes up a majority of the
`top surface, a non-volatile
`memory, and a processing
`device operable to execute
`instructions stored in the
`non-volatile memory.
`
`84103029.1
`
`17
`
`
`
`Samsung-LG-HTC Ex. 1015 p. 17
`
`

`

`
`Galaxy Note II Online Specification (available at
`http://www.samsung.com/global/microsite/galaxynote/note2/spec.html?type=find)
`
`
`In addition to the Galaxy Note II, and the other phones listed in Appendix A, Samsung
`manufactures tablets that similarly infringe claim 7 and the claims, listed below, that depend
`therefrom. These tablets are computing devices having a wireless receiver. For example, the
`Galaxy Tab 3 is a computing device having a wireless receiver.
`
`
`
`http://downloadcenter.samsung.com/content/UM/201307/20130704043753330/GEN_SM-
`T310O_Galaxy_Tab_3_JB_English_User_Manual_MF2_F2.pdf
`
`
`
`84103029.1
`
`18
`
`Samsung-LG-HTC Ex. 1015 p. 18
`
`

`

`
`The other limitations of claim 7 and the listed claims that depend therefrom are likewise met by
`the Galaxy Tab 3 and the other tablets listed in Appendix B. For the purposes of these
`infringement contentions, the manner in which the Galaxy Note II infringes is representative of
`the tablets listed in Appendix B.
`
`
`The Galaxy Note II has a top surface and a display that makes up a majority of the top surface.
`
`
`
`Galaxy Note II Sprint User Guide at 1.
`
`
`
`
`84103029.1
`
`19
`
`Samsung-LG-HTC Ex. 1015 p. 19
`
`

`

`
`Galaxy Note II Online Specification (available at
`http://www.samsung.com/global/microsite/galaxynote/note2/spec.html?type=find)
`
`
`
`
`
`
`
`Galaxy Note II Online Tech Specs (available at
`http://www.samsung.com/ph/support/model/GT-N7100RWDXTC-techspecs)
`
`
`The Galaxy Note II has a non-volatile memory.
`
`
`84103029.1
`
`20
`
`
`
`Samsung-LG-HTC Ex. 1015 p. 20
`
`

`

`
`Galaxy Note II Online Specification (available at
`http://www.samsung.com/global/microsite/galaxynote/note2/spec.html?type=find)
`
`
`
`
`
`Galaxy Note II Online Tech Specs (available at
`http://www.samsung.com/ph/support/model/GT-N7100RWDXTC-techspecs)
`
`
`The Galaxy Note II also accepts SD cards. Once inserted, an SD card also acts as non-volatile
`memory.
`
`
`
`Galaxy Note II Online Specification (available at
`http://www.samsung.com/global/microsite/galaxynote/note2/spec.html?type=find)
`
`
`
`
`
`
`Galaxy Note II User Manual at 16.
`
`
`The Galaxy Note II has a processing device operable to execute instructions stored in the Galaxy
`Note II’s non-volatile memory.
`
`
`
`
`84103029.1
`
`21
`
`Samsung-LG-HTC Ex. 1015 p. 21
`
`

`

`
`
`
`Galaxy Note II Online Specification (available at
`http://www.samsung.com/global/microsite/galaxynote/note2/spec.html?type=find)
`
`
`
`
`
`Galaxy Note II Online Tech Specs (available at
`http://www.samsung.com/ph/support/model/GT-N7100RWDXTC-techspecs)
`
`
`
`Galaxy Note II User Manual at 122.
`
`
`
`The Galaxy Note II has a browser saved on the Galaxy Note II and configured to facilitate the
`accessing of a webpage.
`
`
`
`Galaxy Note II Sprint User Guide at 189.
`
`
`
`
`7.b
`
`a browser saved locally at
`the computing device and
`configured to facilitate
`accessing of a web page;
`and
`
`84103029.1
`
`22
`
`Samsung-LG-HTC Ex. 1015 p. 22
`
`

`

`
`Galaxy Note II Sprint User Guide at 192.
`
`To the extent that an accused product does not literally meet this limitation, Affinity Labs asserts
`that the limitation is met under the doctrine of equivalents.
`
`
`
`Pursuant to Rule 3-1(g) as set forth in the Court’s Scheduling Order, and under the conditions set
`forth in the cover pleading, Affinity Labs identifies this limitation as a software limitation.
`
`Affinity Labs also notes that, though this limitation is related to the “collection of instructions”
`and therefore may be demonstrated with source code, Affinity Labs reserves its rights to establish
`the limitation by way of other evidence. By way of non-limiting example, Affinity Labs includes
`the following in its infringement contentions. The examples below should in no way be construed
`as limiting the scope of source code that Defendants are required to produce pursuant to Local
`Patent Rules 3-1(g) and 3-4(a). For example, the discussion of HTTP Live Streaming (“HLS”)
`below should not be interpreted to limit the scope of Defendants’ production to source code
`related to HLS.
`
`The Galaxy Note II has the Android operating system, version 4.1, stored in its non-volatile
`memory when sold.
`
`
`7.c
`
`a collection of instructions
`stored in the non-volatile
`memory and operable to
`direct the computing device
`to request a list of network
`addresses for a plurality of
`portions of an available
`media, to request delivery
`of a first portion of the
`available media such that
`the first portion is delivered
`at a first communication
`rate, and to request delivery
`of a second portion of the
`available media such that
`the second portion is
`delivered at a second
`communication rate that is
`
`84103029.1
`
`23
`
`Samsung-LG-HTC Ex. 1015 p. 23
`
`

`

`different from the first
`communication rate.
`
`
`Galaxy Note II Online Specification (available at
`http://www.samsung.com/global/microsite/galaxynote/note2/spec.html?type=find)
`
`
`
`
`
`Galaxy Note II User Manual at 122.
`
`
`The Android operating system, version 4.1, has a collection of instructions for playing streaming
`media available via the HLS protocol.
`
`
`
`
`
`http://developer.android.com/about/versions/android-3.0-highlights.html
`
`
`
`
`84103029.1
`
`24
`
`Samsung-LG-HTC Ex. 1015 p. 24
`
`

`

`
`http://developer.android.com/guide/appendix/media-formats.html
`
`
`
`
`
`http://developer.android.com/about/versions/android-4.0.html#api
`
`
`
`
`
`84103029.1
`
`25
`
`Samsung-LG-HTC Ex. 1015 p. 25
`
`

`

`
`
`
`http://developer.android.com/about/versions/android-4.0-highlights.html
`
`The Galaxy Note II has instructions to request a list of network address for a plurality of portions
`of an available media. When accessing media available via the HTTP live streaming protocol, the
`Galaxy Note II will request an index file containing a list of network addresses corresponding to
`portions of an available media.
`
`The Galaxy Note II supports playback of variant playlists using the HTTP live streaming protocol.
`
`
`
`http://developer.android.com/about/versions/android-3.0-highlights.html
`
`
`The Galaxy Note II contains instructions operable to request a first segment of a streaming media
`file at a first communication rate, and a second segment of a streaming media file at a second
`communication rate. The Galaxy Note II can therefore issue a request for the next segment of the
`streaming media such that it is delivered at a different communication rate.
`
`
`
`
`84103029.1
`
`26
`
`Samsung-LG-HTC Ex. 1015 p. 26
`
`

`

`
`
`
`http://developer.android.com/about/versions/android-3.0-highlights.html
`
`
`The Galaxy Note II therefore contains instructions operable to request switching between variants
`of encoded media such that the second portion is delivered at a second communication rate.
`
`This limitation would likewise be met by any Samsung product that uses a version of Android that
`supports HLS, which, based on Affinity Labs initial investigations includes all devices with
`Android 3.0 or later.
`
`To the extent that an accused product does not literally meet this limitation, Affinity Labs asserts
`that the limitation is met under the doctrine of equivalents.
`
`8.
`
`The system of claim 7,
`wherein
`
`8.a
`
`the computing device is
`configured such that a user
`is able to access the browser
`and choose the available
`media without a physical
`keyboard or an external
`mouse.
`
`Samsung directly infringes this claim by making, using, selling, or offering for sale the Galaxy
`Note II. Alternatively, Samsung induces its customers to infringe this claim. Alternatively,
`Samsung contributorily infringes this claim.
`
`Every claim limitation of claim 7 is present in the Galaxy Note II as described above.
`
`The Galaxy Note II is configured such that a user can access the browser and choose the available
`media without a physical keyboard or an external mouse. A user can operate the Galaxy Note II’s
`browser and choose an available media using the Galaxy Note II’s touch screen interface.
`
`
`84103029.1
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`27
`
`Samsung-LG-HTC Ex. 1015 p. 27
`
`

`

`
`Galaxy Note II User Manual at 8.
`
`
`
`
`
`
`Galaxy Note II Sprint User Guide at 192.
`
`
`
`10. The system of claim 7,
`further comprising:
`
`Samsung directly infringes this claim by making, using, selling, or offering for sale the Galaxy
`Note II. Alternatively, Samsung induces its customers to infringe this claim. Alternatively,
`Samsung contributorily infringes this claim.
`
`84103029.1
`
`28
`
`Samsung-LG-HTC Ex. 1015 p. 28
`
`

`

`
`Every claim limitation of claim 7 is present in the Galaxy Note II as described above.
`
`10.a an email client saved locally
`to the cellular telephone,
`
`The Galaxy Note II has a locally-saved e-mail client.
`
`
`
`Galaxy Note II User Manual at 63
`
`
`
`The Galaxy Note II’s e-mail client is operable to receive an email with a media file attachment.
`
`
`10.b wherein the email client is
`operable to receive an email
`with a media file
`attachment;
`
`84103029.1
`
`29
`
`Samsung-LG-HTC Ex. 1015 p. 29
`
`

`

`
`Galaxy Note II User Manual at 64
`
`
`
`10.c an audio file player; and
`
`The Galaxy Note II has an audio file player.
`
`
`84103029.1
`
`30
`
`Samsung-LG-HTC Ex. 1015 p. 30
`
`

`

`
`Galaxy Note II User Manual at 76.
`
`
`
`The Galaxy Note II has a Micro-USB port that acts as a single docking point that includes a
`portion configured to transmit power and a different portion configured to transmit data.
`
`
`10.d a non-circular physical
`interface configured such
`that the non-circular
`physical interface acts as a
`single docking point that
`
`84103029.1
`
`31
`
`Samsung-LG-HTC Ex. 1015 p. 31
`
`

`

`includes a portion
`configured to transmit
`power and a different
`portion configured to
`transmit data.
`
`
`Galaxy Note II Sprint User Guide at 3.
`
`
`
`
`
`
`Galaxy Note II User Manual at 14.
`
`
`
`84103029.1
`
`32
`
`Samsung-LG-HTC Ex. 1015 p. 32
`
`

`

`
`Galaxy Note II User Manual at 50.
`
`
`
`
`
`
`
`
`84103029.1
`
`33
`
`Samsung-LG-HTC Ex. 1015 p. 33
`
`

`

`
`EXHIBIT 1 APPENDIX A
`
`Included Phone Products
`
`Affinity Labs asserts that the Galaxy Note II is representative of the products listed below. Each product listed below is intended
`
`to include all variations of the model listed (i.e., LTE variations, CDMA variations, Duos variations, color variations, memory
`variations, etc.). As noted in the attached chart, the Samsung smartphones that infringe the asserted claims includes at least those
`smartphones using the Android 3.0 operating system or later. Affinity Labs therefore incorporates by reference all Samsung
`smartphones that use the Android 3.0 operating system or later into the list below. Affinity Labs reserves the right to amend,
`supplement, or otherwise modify this list.
`
`Galaxy Ace 3
`Galaxy Ace II X
`Galaxy Admire 2
`Galaxy Amp
`Galaxy Axiom
`Galaxy Camera
`Galaxy Centura
`Galaxy Chat
`Galaxy Core
`Galaxy Discover
`Galaxy Exhibit
`Galaxy Express
`Galaxy Fame
`Galaxy Grand
`Galaxy Music
`Galaxy Music Duos
`Galaxy Nexus
`Galaxy Nexus LTE
`Galaxy Note
`Galaxy Pocket Neo
`Galaxy Pocket plus
`Galaxy Pop
`
`Galaxy Premier
`Galaxy Prevail 2
`Galaxy Reverb
`Galaxy Ring
`Galaxy Rugby Pro
`Galaxy Rush
`Galaxy S Duos
`Galaxy S II
`Galaxy S II Plus
`Galaxy S II Skyrocket
`Galaxy S III
`Galaxy S III mini
`Galaxy S Relay
`Galaxy S4
`Galaxy S4 Active
`Galaxy S4 mini
`Galaxy S4 Zoom
`Galaxy Star
`Galaxy Stellar
`Galaxy Stratosphere II
`Galaxy Trend II
`Galaxy Victory
`
`84103029.1
`
`34
`
`Samsung-LG-HTC Ex. 1015 p. 34
`
`

`

`Galaxy Win
`Galaxy Xcover 2
`Galaxy Y
`
`
`
`
`
`
`
`Galaxy Y Plus
`Galaxy Young
`
`
`84103029.1
`
`2
`
`Samsung-LG-HTC Ex. 1015 p. 35
`
`

`

`EXHIBIT 1 APPENDIX B
`
`Included Tablet Products
`
`Affinity Labs asserts that the Galaxy Note II and Galaxy Tab 3 are representative of the products listed below. Each product
`
`listed below is intended to include all variations of the model listed (i.e., LTE variations, CDMA variations, Duos variations, color
`variations, memory variations, etc.). As noted in the attached chart, the Samsung tablets that infringe the asserted claims includes at
`least those tablets using the Android 3.0 operating system or later. Affinity Labs therefore incorporates by reference all Samsung
`tablets that use the Android 3.0 operating system or later into the list below. Affinity Labs reserves the right to amend, supplement, or
`otherwise modify this list.
`
`Galaxy Nexus 10
`Galaxy Note 10.1
`Galaxy Note 10.1
`Galaxy Note 10.1 LTE
`Galaxy Note 8.0
`Galaxy Note 8.0
`Galaxy Tab 10.1
`Galaxy Tab 2 10.1
`Galaxy Tab 2 7.0
`
`
`
`
`
`Galaxy Tab 2 7.0 LTE
`Galaxy Tab 3 10.1
`Galaxy Tab 3 7.0
`Galaxy Tab 3 8.0
`Galaxy Tab 7.0 Plus
`Galaxy Tab 7.0 Plus
`Galaxy Tab 7.7
`Galaxy Tab 7.7 LTE
`Galaxy Tab 8.9
`
`
`
`
`
`84103029.1
`
`Samsung-LG-HTC Ex. 1015 p. 36
`
`

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