PRELIMINARY INFRINGEMENT ANALYSIS FOR DEFENDANT Google
`Exemplary Accused Instrumentality: Google's Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`U.S. PA1ENTNO.
`7,496,854
`
`INFRINGEMENT BY EXEMPLARY ACCUSED INSTRUMENTALITY
`
`Claim No.19
`
`19(a)
`
`inf01mation Defendant Google performs the method recited in this asse1ied claim, at least in Gmail and
`A method for
`handling within a document
`related Google products identified herein, and all products incorporating the same or similar
`infonnation handling functionality detailed and illustrated herein.
`created by a first application
`program comprising the steps
`of:
`
`See Annexure 1 for screens hots of the exemplary product.
`
`See Annexure 2 for Gmail (first application program) which handles email document.
`
`19(b)
`
`entering a first inf01mation in Google enters first infonnation in Gmail, e.g. as shown, by opening an email and for example,
`displaying a telephone number, and/or address inf01mation (the first infonnation).
`the first application program;
`
`See Annexure 2 for screens hots of the first application program opening and/or displaying
`the first information.
`
`Gmail (first application) can also be employed by users 1 to enter text as first inf01mation.
`
`See Annexure 4 for screenshots that show information that can be entered in the first
`application program.
`
`19(c)
`
`marking
`intervention
`
`without
`the
`
`user Google, without user intervention, marks the first inf01mation (see below) that can be used in
`first a second application program. For example2, Google marks at least one of the following first
`
`1 Wherever a claim step or element is alleged, by defendants or otherwise, to require action by a user for its perfonnance, Plaintiffs contend that - at least beginning
`with service of the complaint in this lawsuit - defendants' are inducing and/or contributing to the infringement of such elements by users.
`2 All examples provided herein are illustrative only.
`
`Page 1 of 12
`
`Google Inc. 1014
`
`

`

`PRELIMINARY INFRINGEMENT ANAL YSIS FOR DEFENDANT Google
`
`Exemplary Accused Instrumentality: Google’s Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`
`- U.S.PATENTNo.
`
`INFRINGWTBYEXEMPLARYAccus-INSTRUMENTALITY
`
`
`7,496,854
`
`information to alert the user
`that the first information can
`be
`utilized
`in
`a
`second
`
`application program: and
`
`information, without user intervention, such as by highlighting, underscoring or otherwise
`calling attention to it:
`
`o A telephone number (first information) which can be used to initiate a phone call by
`a second application program, such as Google Voice.
`
`information) which can be used to initiate an email
`0 An email address (first
`communication and/or searched for by a second application program, such as Google
`Contacts.
`
`0 An address (first information) which can be used to initiate a location map display by
`a second application program, such as Maps.
`
`0 A time/date (first information) which can be used to initiate showing calendar events
`by a second application, such as Calendar.
`
`0 A shipment tracking identifier (first information) which can be used to initiate a
`display of webpage containing shipment delivery status information by second
`application program such as FedEx, UPS, USPS tracking pages etc.
`
`See Annexnre 3, for screenshots offirst information that is marked.
`
` 19(d)
`
`responding to a user selection
`by performing an operation
`related
`to
`a
`second
`
`second
`the
`information,
`information associated with
`
`In response to a user selection, Google performs an operation related to a second information
`that is associated with the first information, as described in the examples below:
`
`Page 2 of 12
`
`Google Inc. 1014
`Google Inc. 1014
`
`

`

`PRELIMINARY INFRINGEMENT ANAL YSIS FOR DEFENDANT Google
`
`Exemplary Accused Instrumentality: Google’s Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`
`- U.S.PATENTNo.
`
`7,496,854
`
`INFRNGEMENTBYEXEMPLARYAccus-INSTRUMENTALITY
`
`the first information from the
`second application program.
`
`o
`
`o
`
`0
`
`0
`
`o
`
`In response to a user click/tap3 on a number (first information), Gmail initiates a
`Google Voice application and displays (operation related to second information) the
`country flag (second information) associated with that number from the second
`application program, such as Google Voice.
`
`In response to a user click/tap on an email address (first information), Gmail initiates
`sending an email and displays (operation related to second information) the name of
`the person or entity (second information) associated with that email address from the
`second application program, such as Google Contacts.
`
`In response to a click on an address (first information), Gmail initiates a display
`(operation related to second information) of the location/map of the entity (second
`information) associated with, or nearby locations associated with, that address from
`the second application program, such as Maps.
`
`In response to a click/tap on a “tracking identifier” (first information), Gmail initiates
`a display (operation related to second information) of the delivery status of the
`shipment (second information) associated with that tracking identifier from the second
`application program, such as FedEx, UPS, USPS tracking pages etc.
`
`In response to a click on date/time (first information), Gmail initiates a display
`(operation related to second information) of the Calendar event (second information)
`associated with that date/time from the second application program, such as Calendar.
`
`See Annarnre 5, for screenshots of the operations performed related to second information
`that is associated with thefirst informationfrom the second application program.
`
`3 “Click". “tap“. “tapping". or “tapped." as used herein. includes all form of user commands.
`
`Page 3 of 12
`
`

`

`PRELIMINARY INFRINGEMENT ANAL YSIS FOR DEFENDANT Google
`
`Exemplary Accused Instrumentality: Google’s Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`
`A computer readable medium,
`including
`program
`instluctions
`related
`to
`
`information handling within a
`document created by a fist
`application program and for
`performing the steps of:
`
`sells, offers and/or imports, contains at least one computer readable medium with program
`instructions related to the infringing information handling functionality detailed and
`illustrated herein.
`
`See Annexure 1 for screenshots ofthe exemplary product.
`See Annexure 2for Gmail (first application program) which handles email document.
`
`enteiing a first information in
`the fist application program:
`
`Google enters a first information in Gmail, e.g. as shown by opening an email and for
`example, displaying a telephone number, and/or address information (the first infonnation).
`
`application program; and Gmail and related Google products identified herein, which defendant Google makes, uses,
`
`marking
`intervention
`
`without
`the
`
`user
`first
`
`inf01mation to ale11 the user
`
`that the fn‘st information can
`
`be
`
`utilized
`
`in
`
`a
`
`second
`
`See Annexure 3 for screenshots of the first application program opening and/or displaving
`thefirst information.
`
`Gmail first application) can also be employed by users to enter text as first information.
`
`See Armature 4 for screenshots that show information that was entered into the first
`application program.
`
`Google, without user intervention, marks the first information (see below) that can be used in
`a second application program. For example, Google marks at least one of the following first
`information, without user intervention, such as by highlighting, underscoring or otherwise
`calling attention to it:
`
`o A telephone number (first information) which can be used to initiate a phone call by
`a second application program, such as Google Voice.
`
`Page 4 of 12
`
`

`

`PRELIMINARY INFRINGEMENT ANAL YSIS FOR DEFENDANT Google
`
`Exemplary Accused Instrumentality: Google’s Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`
`- U.S.PATENTNo.
`
`INFRINGWTBYEXEMPLARYAccus-INSTRUMENTALITY
`
`7,496,854
`
`information) which can be used to initiate an email
`An email address (first
`communication and/or searched for by a second application program, such as Google
`Contacts.
`
`An address (first information) which can be used to initiate a location map display by
`a second application program, such as Maps.
`
`A time/date (first information) which can be used to initiate showing calendar events
`appointments by a second application, such as Calendar.
`
`A shipment tracking identifier (first information) which can be used to initiate a
`display of webpage containing shipment delivery status information by second
`application program such as FedEx, UPS, USPS tracking pages etc.
`
`See Annexm'e 3, for screenshots offirst information that is marked.
`
`by performing an operation
`related
`to
`a
`second
`
`second
`the
`inf01mation,
`infonnation associated with
`
`the fn‘st information from the
`
`25(d) responding to a user selection
`
`second application program.
`
`In response to a user selection, Google performs an operation related to a second information
`that is associated with the first information, as described in the examples below:
`
` In response to a user click/tap on a number (first information), Gmail initiates a Google
`
`Voice application and displays (operation related to second information) the country
`flag (second information) associated with that nlnnber from the second application
`program, such as Google Voice.
`
`In response to a user click/tap on an email address (first information), Gmail initiates
`sending an email and displays (operation related to second information) the name of
`
`Page 5 of 12
`
`

`

`PRELIMINARY INFRINGEMENT ANAL YSIS FOR DEFENDANT Google
`
`Exemplary Accused Instrumentality: Google’s Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`
`- U.S.PATENTNo.
`
`7,496,854
`
`INFRINGErmNTBYEXEMPLARYAccus-INSTRUMENTALITY
`
`the person or entity (second information) associated with that email address from the
`second application program, such as Google Contacts.
`
`In response to a user click/tap on an address (first information), Gmail initiates a
`display (operation related to second information) of the location/map of the entity
`(second information) associated with, or nearby locations associated with, that address
`from the second application program, such as Maps.
`
`In response to a click/tap on a “tracking identifier” (first information), Gmail initiates
`a display (operation related to second information) of the delivery status of the
`shipment (second information) associated with that tracking identifier from the second
`application program, such as FedEx, UPS, USPS tracking pages etc.
`
`In response to a click on date/time (first information), Gmail initiates a display
`(operation related to second information) of the Calendar event (second information)
`associated with that date/time from the second application program, such as Calendar.
`
`o
`
`0
`
`o
`
`See Annexure 5, for screenshots of the operations performed related to second information
`that is associated with thefirst informationfrom the second application program.
`
`
`
`See Armature 1 for screenshots ofthe exemplary product.
`
`57. A method for information Defendant Google performs the method for information handling fimctionality detailed and
`handling within a document
`illustrated herein in Gmail and related Google products identified herein.
`operated
`on
`by
`a
`first
`application
`program,
`the
`
`Page 6 of 12
`
`

`

`PRELIMINARY INFRINGEMENT ANAL YSIS FOR DEFENDANT Google
`
`Exemplary Accused Instrumentality: Google’s Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`
`- U.S.PATENTNo.
`
`INFRINGWTBYEXEMPLARYAccus-INSTRUMENTALITY
`
`
`7,496,854
`
`document
`information
`utilized
`in
`
`first
`containing
`be
`that
`can
`a
`second
`
`program the
`application
`method comprising the steps
`of:
`
`See Annerure 2for Gmail (first application program) which handles email document.
`
`57(b)
`
`57(c)
`
`user
`identifying without
`intervention or designation
`the first information; and
`
`Google, without user intervention or designation, identifies the first information (see below)
`that can be used in a second application program. For example, Google identifies at least one
`of the following first information, without user intervention or designation:
`
`A telephone number.
`
`An email address.
`
`An address.
`
`A time/date.
`
`A shipment tracking identifier.
`
`
`
`See Annexare 3, for screenshots offirst information that is identified.
`
`second
`
`responding to a user selection
`by performing an operation
`related
`to
`a
`second
`
`information,
`
`the
`
`In response to a user selection, Google performs an operation related to a second information
`that is associated with the first information, as described in the examples below:
`
`Page 7 of 12
`
`

`

`PRELIMINARY INFRINGEMENT ANAL YSIS FOR DEFENDANT Google
`
`Exemplary Accused Instrumentality: Google’s Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`
`- U.S.PATENTNo.
`
`INFRINGWTBYEXEMPLARYAccus-INSTRUMENTAHTY
`
`7,496,854
`
`
`information associated With
`the first information from the
`second application program.
`
`o
`
`0
`
`0
`
`0
`
`o
`
`In response to a user click/tap on a number (first information), Gmail initiates a Google
`Voice application and displays (operation related to second information) the country
`flag (second information) associated with that number from the second application
`program, such as Google Voice.
`
`In response to a user click/tap on an email address (first information), Gmail initiates
`sending an email and displays (operation related to second information) the name of
`the person or entity (second information) associated with that email address from the
`second application program, such as Google Contacts.
`
`In response to a click on an address (first information), Gmail initiates a display
`(operation related to second information) the location/map of the entity (second
`information) associated with, or nearby locations associated with, that address from
`the second application program, such as Maps.
`
`In response to a click/tap on a “tracking identifier” (first information), Gmail initiates
`a display (operation related to second information) of the delivery status of the
`shipment (second information) associated with that tracking identifier from the second
`application program, such as Feder, UPS, USPS tracking pages etc.
`
`In response to a click on date/time (first information), Gmail initiates a display
`(operation related to second information) of the Calendar event (second information)
`associated with that date/time from the second application program, such as Calendar.
`
`See Armature 5, for screenshots of the operations performed related to second information
`that is associated with thefirst informationfrom the second application program.
`
`Page 8 of 12
`
`

`

`PRELIMINARY INFRINGEMENT ANAL YSIS FOR DEFENDANT Google
`
`Exemplary Accused Instrumentality: Google’s Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`
`- U.S.PATENTNo.
`
`INFRINGWTBYEXEMPLARYAccus-INSTRUMENTALITY
`
`
`7,496,854
`
`Claim No. 64
`
`64(a)
`
`64(b)
`
`64(c)
`
`The method of claim 63, Google performs the method of claim 63, which recites, “The method of claim 57 wherein the
`wherein
`the
`step
`of user selection comprises an activation of a menu.
`performing
`the
`operation
`fluther comprises the steps of:
`
`See Annexure 8for menu activation options.
`
`Google further performs the additional step recited in claim 64 by performing an operation
`comprising the following steps recited and discussed separately below.
`
`
`
`the
`initializing
`application program;
`
`second Google initializes the second application program, such as by initializing, for example, one or
`more of the following second application programs: Google Voice, Google Contacts, Maps,
`Shipment status information tracking webpage, or Calendar.
`
`See Annexure 5 for screenshots ofsecond application programs.
`
`searching, using the second Google uses the second application program (e.g., Google Voice, Google Contacts, Maps,
`application program, for the
`Shipment status information trackingpage, or Calendar) to search for the second information
`second information associated
`(e.g., country flag of phone number,
`location of address, shipment status information,
`with the first information: and
`scheduled event, etc.) associated with the first information (e.g., phone number, email,
`address, tracking id, time/date, etc.).
`
`See Annexure 5for screenshots ofsecond information associated with thefirst information.
`
`Page 9 of 12
`
`

`

`PRELIMINARY INFRINGEMENT ANAL YSIS FOR DEFENDANT Google
`
`Exemplary Accused Instrumentality: Google’s Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`
`- U.S.PATENTNo.
`
`INFRINGEME4TBYEXEMPLARYAccusmINSTRUMENTALITY
`
`7,496,854
`
`
`64(d)
`
`retrieving
`information.
`
`second Google retrieves the second information, such as the country flag or phone number, location
`of address, shipment status information, and scheduled event associated with the first
`information (e.g., phone number, email, address, tracking id, time/date).
`
`See Annernre 5for screens/lots showing the retrieved second information.
`
`The method of claim 57 Google performs the recited method, for example, by retrieving second information (e. g.,
`wherein
`the
`second
`country flag of phone number, location of address, scheduled event) that18 associated with
`inf01mation is associated with
`something less than all of the first information, such as a part of any of the following first
`only part of the identified fn‘st
`information used to search for second information: phone number, address or date/time.
`information.
`
`ClaimNo.72
`
`See Annexnre 3for screenshots showingfirst information.
`
`See Annexnre 5 for screenshots of second information associated with the first information
`being displayed.
`
`Exemplary Claim No. 73
`
`7-
`
`-
`
`73(a)
`
`
`be
`
`Acomputer readable medium, Gmail and the related Google products identified herein contains at least one computer
`including
`program readable medium with program instructions related to the infringing information handling
`instructions
`related
`to
`fimctionality detailed and illustrated herein.
`information handling Within a
`document operated on by a
`first application program, the
`document
`containing
`first
`information
`that
`can
`
`See Annernre 2for Gmail (first application program) which handles email document.
`
`See Annexnre I for screenshots ofthe exemplary product.
`
`Page 10 of 12
`
`

`

`PRELIMINARY INFRINGEMENT ANAL YSIS FOR DEFENDANT Google
`
`Exemplary Accused Instrumentality: Google’s Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`
`
`- U.S.PATENTNo.
`
`7,496,854
`
`INFRINGWTBYEXEMPLARYAccus-INSTRUMENTAIJTY
`
`utilized
`
`in
`
`a
`
`second
`
`application program, and for
`performing the steps of:
`
`user
`identifying without
`intervention or designation
`the first information; and
`
`Google, without user intervention or designation, identifies the first information (see below).
`For example, Google identifies at least one of the following first information, without user
`intervention or designation:
`
`73(b)
`
`73(c)
`
`
`
`A telephone number.
`
`An email.
`
`An address.
`
`A time/date.
`
`A shipment tracking identifier.
`
`See Annexm‘e 3, for screenshots offirst information that is identified.
`
`program, such as Google Voice.
`
`In response to a user selection, Google performs an operation related to a second information
`that is associated with the first information, as described in the examples below:
`
`0
`
`In response to a user click/tap on a number (first information), Gmail initiates a Google
`Voice application and display (operation related to second information) of the country
`flag (second information) associated with that number from the second application
`
`responding to a user selection
`by performing an operation
`related
`to
`a
`second
`
`second
`the
`information,
`information associated With
`the first information from the
`second application program.
`
`Page 11 of 12
`
`

`

`PRELIMINARY INFRINGEMENT ANAL YSIS FOR DEFENDANT Google
`
`Exemplary Accused Instrumentality: Google’s Gmail and related Google products identified herein, and all products
`incorporating the same or similar information handling functionality detailed and illustrated herein
`
`
`- U.S.PATENTNo.
`
`7,496,854
`
`INFRINGWTBYEXEMPLARYAccus-INSTRUMENTALITY
`
`0
`
`o
`
`0
`
`o
`
`In response to a user click/tap on an email address (first information), Gmail initiates
`sending an email and display (operation related to second information) of the name of
`the person or entity (second information) associated with that email address from the
`second application program, such as Google Contacts.
`
`In response to a user click on an address (first information), Gmail initiates a display
`(operation related to second information) of the location/map of the entity (second
`information) associated with, or nearby locations with, that address from the second
`application program, such as Maps.
`
`In response to a click/tap on a “tracking identifier” (first information), Gmail initiates
`a display (operation related to second information) of the delivery status of the
`shipment (second information) associated with that tracking identifier from the second
`application program, such as Feder, UPS, USPS tracking pages etc.
`
`In response to a click on date/time (first information), Gmail initiates a display
`(operation related to second information) of the Calendar event (second information)
`associated with that date/time from the second application program, such as Calendar.
`
`See Armature 5, for screenshots of the operations perforated related to second information
`that is associated with thefirst informationfrom the second application program.
`
`Page 12 of 12
`
`