APPENDIX A4
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`
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`
`Infringement Claim Chart re: U.S. Patent No. 8,594,651
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`
`The preamble is presumed not to be limiting. In the case that this preamble were
`determined to be limiting, AT&T’s Multimedia Message Service Center (“MMSC”) and
`related server computers for Multimedia Message Service (“MMS”) messaging perform
`the claimed method of format converting a video file received from a first wireless
`communications device for communication to a second wireless communications device,
`because they perform receipt, content adaptation, and delivery of MMS messages between
`two devices.
`
`Claim Language
`What is claimed is:
`
`[pre] 1. A method of format converting a
`video file received from a first
`wireless communications device for
`communication to a second
`wireless communications device,
`the method comprising:
`
`1
`
`AT&T - Exhibit 1022
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`

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`
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`Claim Language
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`
`APPENDIX A4
`
`
`
`“5.7.1 MMS Environment
`
`The MMS Environment (MMSE) refers to the set of MMS elements, under the control of a
`single administration (MMS provider, e.g., mobile network operator), in charge of
`providing the service to MMS subscribers. Recipient and originator MMS clients are
`attached, respectively, to the recipient and originator MMSEs.
`
`5. 7.2 MMS Client
`
`2
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`

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`Claim Language
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`
`The MMS client (also known as MMS user agent in the 3GPP terminology) is the software
`application shipped with the mobile handset, which allows the composition, viewing,
`sending, retrieval of multimedia messages, and the management of reports. For the
`exchange of a multimedia message, the MMS client that generates and sends the
`multimedia message is known as the originator MMS client, whereas the MMS client that
`receives the multimedia message is known as the recipient MMS client.
`
`The MMS client offers the following features:
`• Management of messages, notifications, and reports: devices are commonly
`shipped with a "unified" message box for the management of MMS elements
`(messages, notifications, and reports) and other elements such as SMS/EMS
`messages, WAP push messages, and so on.
`
`• Message composition: the message composer is used for creating new multimedia
`messages.
`
`
`
`
`
`• Message viewing: the message viewer is used to render received messages or to
`preview newly created messages before sending.
`
`…
`
`5.7.3 MMS Center
`
`The MMS Center (MMSC) is a key element in the MMS architecture. Logically, the
`MMSC is composed of an MMS relay and an MMS server. The relay is responsible for
`routing messages not only within the MMSE but also outside the MMSE, but also outside
`the MMSE, whereas the server is in charge of storing messages. The MMSC server is in
`charge of temporarily storing messages that are awaiting retrieval from recipient MMS
`clients. The MMSC may have built-in transcoding capabilities, functions for supporting
`legacy users, databases for storing user profiles. However, these functions can also be
`realized with specialized components implemented outside the MMSC.”
`
`3
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`

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`APPENDIX A4
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`
`
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`Claim Language
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`
`Source: Gwenael Le Bodic, Mobile Messaging Technologies and Services: SMS, EMS,
`and MMS, 2nd Ed., 2005, at 218-220 (SCRN00004700-772 at 757-759).
`
`
`
`AT&T provides access to one such MMSC at the following address:
`
` http://mmsc.cingular.com
`See http://apn-settings.com/us/att-apn-settings/ (SCRN00004773-775)
`
`AT&T provides MMS message services to its subscribers:
`
`“Picture/Video Messaging
`Picture & Video Messaging-capable devices use Multimedia Messaging Service (MMS) to send
`messages that include multimedia content to and from mobile devices. With a Picture & Video
`Messaging-capable device, you can:
`• Send pictures, animations, videos, and voice messages to any 10-digit wireless number or
`email address.
`• Personalize the message with text or a voice recording.
`• Receive picture and video messages on your device sent to your 10-digit wireless number
`or emailed to your 10-digit wireless number@mms.att.net.
`
`…
`Send Picture & Video Messages
`To learn to send Picture & Video Messages from your device, please visit the Device How-To
`Center:
`1. If needed, select your device, brand, and model and then click Save.
`2. Under Device instructions, select Messaging & email:
`• To send a picture or video message, select Text & picture messaging, and then,
`from the Interactive tutorials, select Send a multimedia message.
`
`4
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`Claim Language
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`• To send a picture or video as an email, select Email, and then, from the Interactive
`tutorials, select Send email.
`
`…
`Don't have a Picture & Video Messaging-capable device?
`If you don't have a Picture & Video Messaging-capable device and receive a picture or video
`message, you'll receive a text message explaining how to view your picture or video message. The
`text message will include a link to an internet address where the message can be viewed online (a
`login and password will be provided). You'll need to download and install Quicktime Player to watch
`a video message.
`
`If you send a message to a device incapable of viewing a Picture & Video Message, your recipient
`receives a text message with a link to view your message online. Some wireless providers may
`choose not to deliver these message notifications to their customers.
`…
`
`Picture & Video Message size limits and file types
`The AT&T mobile broadband network will deliver MMS (picture, video or audio) messages of up to
`600 kilobytes (KB). Media file attachments will be compressed on the device prior to being sent in
`order to keep the message size below 600 KB. The maximum size for sending and receiving MMS
`messages is also dependent upon the recipient's device and the limitations of other carriers'
`networks (e.g., other carriers may have a lower MMS size limit than AT&T).
`
`Image, video, and audio files come in several formats. Compatible file types vary from device to
`device. Please visit the Device How-To Center to determine the specifications of your device.
`
`Supported image formats:
`• JPEG (Baseline JPEG)
`• GIF 87a (still images)
`
`5
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`Claim Language
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`• GIF89a (animated images)
`• WBMP (Wireless bitmap still images)
`• BMP (still images)
`• PNG (still images)
`• WBMP (animated images)
`
`Supported audio formats:
`• MIDI
`iMelody
`•
`• AMR
`• SP
`
`Supported video formats:
`• H.263
`• MPEG4”
`
`
`See http://www.att.com/esupport/article.jsp?sid=53119&cv=820#fbid=uM7xjcxMRKA
`(SCRN00004776-777)
`
`
`
`The operation of MMSCs and related servers is informed by several standards, including
`3GPP TS 22.140, 3GPP TS 23.140, and 3GPP TS 26.140, and Open Mobile Alliance
`(“OMA”) Multimedia Messaging Service Releases v1.1, 1.2, and 1.3. In accordance with
`these standards, the typical handling of MMS message transmission between two devices
`by MMSCs and associated servers is as follows:
`
`
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`6
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`Claim Language
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`
`APPENDIX A4
`
`
`
`• “MMS Client: A device through which the user receives or sends
`multimedia messages. This might be a phone or a PC-based MMS
`client. The Client sends messages to and receives messages from the
`MMSC using WAP/HTTP as transport.
`
`7
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`Claim Language
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`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`• MMS Gateway: Switches messages between different MMS clients
`and between MMS and Email. The Gateway may also interface with
`other gateways to exchange messages destined for foreign
`networks. This is also more properly known as the MMSC.
`• MMS Server: This component provides persistent storage of
`messages on the network. Typically users can access stored
`messages via a web interface.
`• Other MMS Systems:Other systems, such as Third Party MMS
`systems (e.g. MMS VAS providers) can interface to the MMSC to
`receive and send MMS content. The Interface used is termed MM7.
`• SMSC: The MMSC utilises WAP Push to send notifications to MMS
`Clients. These are typically sent using SMS as the bearer service,
`hence the need for a link to a Short Message Service Centre.
`Typically, the message cycle begins with a user sending a multimedia
`message (MM) from the MMS client. The client must be configured for
`MMS, which includes bearer settings (i.e. GPRS or GSM/CSD settings), WAP
`gateway address and MMS Gateway address (a URL). On receipt of the
`message, the MMSC decides how to deliver the message (e.g. to another
`MMS client or to a VASP), and proceeds to dispatch the message. A VASP
`may also originate a message to the MMSC, for onward delivery.
`An MM is typically a multi-part message with pictures, sound, text and
`other media. Each part of the message is identified by media (MIME) type,
`name and/or Content ID. Usually the message is of a multipart/related
`MIME type, with the start element being a SMIL part that controls how the
`message should be displayed.
`
`8
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`
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`Claim Language
`
`[a]
`
`receiving from a first wireless
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`
`When submitting a message, the MMS client indicates the intended
`recipient list, but usually not the sender address, which the MMSC retrieves
`from the WAP gateway. Like Email, a single MMS can specify multiple
`recipients (MSISDNs and Email addresses), and it is up to the MMSC to
`ensure correct delivery to each of the recipients.
`When the MMSC receives a message destined for an email address, it
`typically re-codes the message as standard MIME and passes it on to an
`SMTP server for delivery. Email messages received are similarly re-coded as
`MMS and forwarded to the relevant MMS Client.
`When the MMSC receives a message destined to MMS Clients in the area
`served by the MMSC, the message is stored and an MMS notification sent
`to the recipient via WAP Push. On receipt of the notification, the client
`typically fetches the message via a URL provided in the notification.
`When a recipient requests an incoming MM from the server, it indicates to
`the server its capabilities for a User Agent Profile URL. The profile data
`includes such things as supported media types, screen size, supported
`character sets, etc. Typically, the MMSC will re-code the MM to suit the
`client's capabilities before returning the message. Messages destined to
`email may also be re-coded to make them more suitable for email readers.”
`[http://mbuni.org/userguide.shtml#Section_.1.1.1] (SCRN00001347-399). See also
`http://www.nowsms.com/faq/how-mms-works (SCRN00001340-344)
`
`Pursuant to P.R. 3-1(g), Plaintiff asserts this limitation is implemented in software.
`
`9
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`
`Claim Language
`communications device at least one
`video file selected by a user of the
`first wireless communications
`device for transmission to a second
`wireless communications device
`having video playing capability;
`
`[b]
`
`determining a format of the selected
`video file;
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`
`AT&T’s MMSC and associated servers perform the step of receiving from a first wireless
`communications device at least one video file selected by a user of the first wireless
`communications device for transmission to a second wireless communications device
`having video playing capability, because AT&T provides MMS message services to its
`subscribers, which requires an MMSC to receive from a mobile device a video file, such as
`an image, or movie, for transmission to another device. The originating device could be a
`device in AT&T’s network, or one outside of it.
`
`See evidence and discussion for Ex. A2, ‘759 Patent, Claim 53[a].
`
`Pursuant to P.R. 3-1(g), Plaintiff asserts this limitation is implemented in software.
`
`AT&T’s MMSC and related servers perform the step of determining a format of the
`selected video file. For example, as part of the MMS message transmission process, the
`originating device identifies the format of the video file via specifying a MIME type. See,
`e.g.,
`
`“An MM is typically a multi-part message with pictures, sound, text and
`other media. Each part of the message is identified by media (MIME) type,
`name and/or Content ID. Usually the message is of a multipart/related
`MIME type, with the start element being a SMIL part that controls how the
`message should be displayed.”
`
`[http://mbuni.org/userguide.shtml#Section_.1.1.1] (SCRN00001347-399). See also
`http://www.nowsms.com/faq/how-mms-works (SCRN00001340-344)
`
`See, e.g.:
`
`
`10
`
`

`
`APPENDIX A4
`
`
`
`
`Claim Language
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`“6.1. Sending of Multimedia Message
`
`The Send transaction of the MM consists of two messages: M-Send.req and M-Send.conf.
`The transaction identifier is created and used by the originating MMS Client and it is
`OMA-MMS-ENC-V1_2-20050301-A
`Page 18 (113)
`unique within the send transaction only.
`
`6.1.1. Send Request
`Optional.
`Reply-charging-size-
`X-Mms-Reply-
`Charging-Size
`value
`This header field SHALL NOT be present if the X-Mms-
`This chapter describes the header fields of the M-Send.req sent by the MMS Client to the
`Reply-Charging header field is not present. It specifies
`MMS Proxy-Relay, and how these header fields may be modified by the sender's MMS
`the maximum size (number of octets) for the Reply-MM.
`Proxy-Relay.. These header fields are used to generate the MMS notification to the
`X-Mms-Reply-
`Reply-charging-ID-
`Optional.
`recipient, and are delivered with the message body parts to the recipient MMS Client at
`Charging-ID
`value
`This header field SHALL only be present if this PDU
`retrieval.
`contains the Reply-MM that was offered by the value
`“accepted” or “accepted text only” in the X-Mms-Reply-
`Table 1 contains the field names, the field values and descriptions of the header fields of
`Charging header field in M-Retrieve.conf received
`M-Send.req PDU.
`earlier and if the Reply-Charging limitations are met.
`The value of this header field SHALL be the same as the
`Message-ID of the Original-MM that is replied to.
`Mandatory.
`The content type of the MM.
`Table 1. Header fields of M-Send.req PDU
`
`…
`Content-Type
`
`Content-type-value
`
`
`
`
`The message body follows the MMS header.
`The message body follows the MMS header.”
`6.1.2.
`Send confirmation
`Source: OMA-MMS-ENC-V1_2-20050301-A, p. 15, 18 (SCRN00000799-911 at 813,
`When the MMS Proxy-Relay has received the M-Send.req PDU, it sends an M-Send.conf PDU back to the MMS Client
`816)
`indicating the status of the operation. The response PDU contains MMS header only.
`Table 2 contains the field names, the field values and descriptions of the header fields of the M-Send.conf PDU.
`
`
`
`[c]
`
`determining from information
`associated with the second wireless
`
`Pursuant to P.R. 3-1(g), Plaintiff asserts this limitation is implemented in software.
`
`
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`11
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`[d]
`
`Claim Language
`communications device video file
`format requirements of the second
`wireless communications device;
`
`comparing, with one or more
`computer processors, the video file
`format requirements of the second
`wireless communications device
`with the format of the selected
`video file;
`
`[e]
`
`in response to said comparison,
`converting with one or more
`computer processors, the format of
`the selected video file to a format
`that is compatible with the video
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`AT&T’s MMSC and related servers perform the step of determining, from information
`associated with the second wireless communications device, the video file format
`requirements of that device. For example, as part of the content adaptation process,
`standards-based MMS messaging utilizes the user agent profile (UAProf) associated with
`the receiving device to determine the capabilities of the receiving device. The UAProf
`describes, among other things, file formats compatible with the playback device.
`
`See evidence and discussion for Ex. A2, ‘759 Patent, Claim 53[b] and 54.
`
`Pursuant to P.R. 3-1(g), Plaintiff asserts this limitation is implemented in software.
`
`AT&T’s MMSC and related servers perform the step of comparing, with one or more
`computer processors, the video file format requirements of the second wireless
`communications device with the format of the selected video file, because AT&T’s MMS
`message services support content adaptation, which provides for the conversion of video
`files transmitted by an originating device into formats suitable for display on a terminating
`(receiving) device. For example, as part of the content adaptation process, standards-based
`MMS messaging utilizes the user agent profile (UAProf) associated with the receiving
`device to determine the capabilities of the receiving device. The UAProf describes, among
`other things, file formats compatible with the playback device. The capability of AT&T’s
`MMSC to adapt content for display on the receiving device necessarily entails comparison
`of the file format of the selected video file with the capability information, such as the
`UAProf file, associated with the receiving device.
`
`See evidence and discussion for Ex. A2, ‘759 Patent, Claim 53[b] and 54.
`
`Pursuant to P.R. 3-1(g), Plaintiff asserts this limitation is implemented in software.
`
`AT&T’s MMSC and related servers perform the step of converting with one or more
`computer processors, the format of the selected video file to a format that is compatible
`with the video file format requirements of the second wireless communications device,
`
`12
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`Claim Language
`file format requirements of the
`second wireless communications
`device; and
`
`[f]
`
`sending the converted video file to
`the second wireless
`communications device.
`
`
`
`2. The method of claim 1, wherein
`the selected video file comprises
`one or more video clips.
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`because AT&T’s MMS message services support content adaptation, which provides for
`the conversion of video files transmitted by an originating device into formats suitable for
`display on a terminating (receiving) device. For example, as part of the content adaptation
`process, standards-based MMS messaging utilizes the user agent profile (UAProf)
`associated with the receiving device to determine the capabilities of the receiving device.
`AT&T’s MMSC and related servers utilize this information in performing format
`conversion, if necessary, so that the video file may be displayed on the receiving device.
`
`See evidence and discussion for Ex. A2, ‘759 Patent, Claim 53[b] and 54.
`
`Pursuant to P.R. 3-1(g), Plaintiff asserts this limitation is implemented in software.
`
`AT&T’s MMSC and associated servers sending the converted video file to the second
`wireless communications device. As part of the MMS process, the MMSC sends a push
`notification to the receiving device, typically via an SMS message. The notification
`includes a URL by which the MMS message can be downloaded to the receiving device
`for playback when the end user desires.
`
`See evidence and discussion for Ex. A2, ‘759 Patent, Claim 53[c].
`Pursuant to P.R. 3-1(g), Plaintiff asserts this limitation is implemented in software.
`
`AT&T’s MMSC and associated servers perform the method of claim 1, wherein the
`selected video file comprises one or more video clips, because AT&T provides MMS
`message services to its subscribers, and MMS messaging supports transmission of video
`clips.
`
`At least the following video clip file types are supported for receipt by MMSCs that
`comply with 3GPP standards: H.264, MPEG-4, H.263, .mp4, .mp4v-es, 3gpp, 3gp, and
`3g2. See, e.g., 3GPP TS 26.140 version 11.1.0, Release 11 (SCRN00000607-621).
`
`According to CTIA MMS Interoperability Guidelines, Revision: 3.0, U.S. wireless carriers
`should support receiving at least the following native video types:
`
`13
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`

`
`4. File Types
`
`Each participating service provider should handle inbound MMS messaging traffic with
`their own network capabilities and feature sets. Message types and feature sets are
`APPENDIX A4
`defined later in this document.
`
`U.S. Patent No. 8,594,651
`The following media types should be supported (at a minimum) by the participating
`service providers. Support does not imply device or service capability, but rather
`infrastructure support (i.e., transcoding can be performed at the terminating network).
`Infringement by AT&T Mobility, LLC (“AT&T”)
`
`
`
`
`JPEG (same as JPG
`PNG
`
`IMAGES
`BMP
`87a GIF (same as GIF)
`
`TEXT
`AMR
`
`AUDIO
`
`mp3
`mpeg
`qcelp
`sp-mid (same as sp-midi)
`vnd.qcelp (same as QCELP)
`
`wav
`x-wav
`mid
`ogg
`
`
`VIDEO
`
`
`
`SMIL
`
`
`
`3gpp
`3gpp2
`amr
`evrc
`midi
`
`
`
`
`
`Claim Language
`
`h264
`3g2
`3gpp
`mp4
`h263-2000
`3gp
`egpp2
`h263
`mp4v-es
`
`At least h.263, h.264, .mp4, .mp4v-es, 3gpp, 3gp, and 3g2 are video clip file formats.
`
`It is recommended that all service providers support H.264 media type.
`Source: CTIA MMS Interoperability Guidelines, Revision: 3.0, at 19 (SCRN00000622-
`654 at 640).
`Pursuant to P.R. 3-1(g), Plaintiff asserts this limitation is implemented in software.
`
`AT&T’s MMSC and associated servers perform the method of claim 1, wherein the
`selected video file is an MPEG file, because AT&T provides MMS message services to its
`subscribers, and MMS messaging supports transmission of MPEG video files.
`MMS Interoperability Guidelines Rev.3.0
`Page 19
`
`
`
`
`
`
`
`3. The method of claim 1, wherein
`the selected video file is an MPEG
`file.
`
`14
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`

`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`4. File Types
`Infringement by AT&T Mobility, LLC (“AT&T”)
`
`Each participating service provider should handle inbound MMS messaging traffic with
`At least the following video file types are supported for receipt by MMSCs that comply
`their own network capabilities and feature sets. Message types and feature sets are
`with 3GPP standards, and are MPEG files: H.264, MPEG-4, H.263. See, e.g., 3GPP TS
`defined later in this document.
`26.140 version 11.1.0, Release 11 (SCRN00000607-621).
`
`
`The following media types should be supported (at a minimum) by the participating
`According to CTIA MMS Interoperability Guidelines, Revision: 3.0, U.S. wireless carriers
`service providers. Support does not imply device or service capability, but rather
`infrastructure support (i.e., transcoding can be performed at the terminating network).
`should support receiving at least the following native video types:
`
`
`
`
`JPEG (same as JPG
`PNG
`
`IMAGES
`BMP
`87a GIF (same as GIF)
`
`
`
`
`
`
`Claim Language
`
`TEXT
`AMR
`
`AUDIO
`
`mp3
`mpeg
`qcelp
`sp-mid (same as sp-midi)
`vnd.qcelp (same as QCELP)
`
`wav
`x-wav
`mid
`ogg
`
`
`VIDEO
`
`
`
`SMIL
`
`
`
`3gpp
`3gpp2
`amr
`evrc
`midi
`
`
`h264
`3g2
`3gpp
`mp4
`h263-2000
`3gp
`egpp2
`h263
`mp4v-es
`
`At least h.263, h.264, .mp4, .mp4v-es, 3gpp, 3gp, and 3g2 are MPEG file formats.
`
`It is recommended that all service providers support H.264 media type.
`Source: CTIA MMS Interoperability Guidelines, Revision: 3.0, at 19 (SCRN00000622-
`
`
`
`15
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`MMS Interoperability Guidelines Rev.3.0
`
`Page 19
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`Claim Language
`
`4. The method of claim 1, wherein
`the selected video file comprises
`one or more digital images.
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`654 at 640).
`Pursuant to P.R. 3-1(g), Plaintiff asserts this limitation is implemented in software.
`
`AT&T’s MMSC and associated servers perform the method of claim 1, wherein the
`selected video file is an MPEG file, because AT&T provides MMS message services to its
`subscribers, and MMS messaging supports transmission of digital images.
`
`At least the following video file types are supported for receipt by MMSCs that comply
`with 3GPP standards, and are digital images: JPEG, PNG, BMP, GIF. See, e.g., 3GPP TS
`26.140 version 11.1.0, Release 11 (SCRN00000607-621).
`
`According to CTIA MMS Interoperability Guidelines, Revision: 3.0, U.S. wireless carriers
`should support receiving at least the following native video types:
`
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`
`Each participating service provider should handle inbound MMS messaging traffic with
`their own network capabilities and feature sets. Message types and feature sets are
`defined later in this document.
`APPENDIX A4
`
`The following media types should be supported (at a minimum) by the participating
`service providers. Support does not imply device or service capability, but rather
`U.S. Patent No. 8,594,651
`infrastructure support (i.e., transcoding can be performed at the terminating network).
`Infringement by AT&T Mobility, LLC (“AT&T”)
`
`
`
`JPEG (same as JPG
`PNG
`
`IMAGES
`BMP
`87a GIF (same as GIF)
`
`TEXT
`AMR
`
`AUDIO
`
`mp3
`mpeg
`qcelp
`sp-mid (same as sp-midi)
`vnd.qcelp (same as QCELP)
`
`wav
`x-wav
`mid
`ogg
`
`
`VIDEO
`
`
`
`SMIL
`
`
`
`3gpp
`3gpp2
`amr
`evrc
`midi
`
`
`
`
`
`Claim Language
`
`
`
`5. The method of claim 1, wherein
`the selected video file is a JPEG
`file.
`
`h264
`3g2
`3gpp
`mp4
`h263-2000
`3gp
`egpp2
`h263
`mp4v-es
`At least JPEG, PNG, BMP, GIF are digital image formats.
`
`It is recommended that all service providers support H.264 media type.
`Source: CTIA MMS Interoperability Guidelines, Revision: 3.0, at 19 (SCRN00000622-
`654 at 640).
`Pursuant to P.R. 3-1(g), Plaintiff asserts this limitation is implemented in software.
`
`AT&T’s MMSC and associated servers perform the method of claim 1, wherein the
`selected video file is a JPEG file, because AT&T provides MMS message services to its
`subscribers, and MMS messaging supports transmission of JPEG files.
`MMS Interoperability Guidelines Rev.3.0
`Page 19
`
`
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`17
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`

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`
`
`
`
`Claim Language
`
`6. The method of claim 1, wherein
`at least one of the first wireless
`communications device or the
`second wireless communications
`device comprises a wireless
`telephone.
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`See evidence and discussion for Claim 4.
`AT&T’s MMSC and associated servers perform the method of claim 1, wherein at least
`one of the first wireless communications device or the second wireless communications
`device comprises a wireless telephone, because AT&T provides MMS message services to
`its subscribers, and MMS messaging supports transmission MMS messages from and to
`wireless telephones.
`
`AT&T provides MMS message services to its subscribers, including wireless telephones:
`
`“Picture/Video Messaging
`Picture & Video Messaging-capable devices use Multimedia Messaging Service (MMS) to send
`messages that include multimedia content to and from mobile devices. With a Picture & Video
`Messaging-capable device, you can:
`• Send pictures, animations, videos, and voice messages to any 10-digit wireless number or
`email address.
`• Personalize the message with text or a voice recording.
`• Receive picture and video messages on your device sent to your 10-digit wireless number
`or emailed to your 10-digit wireless number@mms.att.net.
`
`…
`Send Picture & Video Messages
`To learn to send Picture & Video Messages from your device, please visit the Device How-To
`Center:
`If needed, select your device, brand, and model and then click Save.
`1.
`2. Under Device instructions, select Messaging & email:
`• To send a picture or video message, select Text & picture messaging, and then,
`from the Interactive tutorials, select Send a multimedia message.
`• To send a picture or video as an email, select Email, and then, from the Interactive
`tutorials, select Send email.
`
`18
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`

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`
`
`
`Claim Language
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`…
`Don't have a Picture & Video Messaging-capable device?
`If you don't have a Picture & Video Messaging-capable device and receive a picture or video
`message, you'll receive a text message explaining how to view your picture or video message. The
`text message will include a link to an internet address where the message can be viewed online (a
`login and password will be provided). You'll need to download and install Quicktime Player to watch
`a video message.
`
`If you send a message to a device incapable of viewing a Picture & Video Message, your recipient
`receives a text message with a link to view your message online. Some wireless providers may
`choose not to deliver these message notifications to their customers.
`…
`
`Picture & Video Message size limits and file types
`The AT&T mobile broadband network will deliver MMS (picture, video or audio) messages of up to
`600 kilobytes (KB). Media file attachments will be compressed on the device prior to being sent in
`order to keep the message size below 600 KB. The maximum size for sending and receiving MMS
`messages is also dependent upon the recipient's device and the limitations of other carriers'
`networks (e.g., other carriers may have a lower MMS size limit than AT&T).
`
`Image, video, and audio files come in several formats. Compatible file types vary from device to
`device. Please visit the Device How-To Center to determine the specifications of your device.
`
`Supported image formats:
`• JPEG (Baseline JPEG)
`• GIF 87a (still images)
`• GIF89a (animated images)
`
`19
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`

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`
`
`
`Claim Language
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`• WBMP (Wireless bitmap still images)
`• BMP (still images)
`• PNG (still images)
`• WBMP (animated images)
`
`Supported audio formats:
`• MIDI
`iMelody
`•
`• AMR
`• SP
`
`
`
`
`
`8. The method of claim 1, wherein
`the selected video file includes a
`single digital image.
`
`10. The method of claim 1, wherein
`the selected video file is acquired
`using a digital camera of the first
`
`Supported video formats:
`• H.263
`• MPEG4”
`
`
`See http://www.att.com/esupport/article.jsp?sid=53119&cv=820#fbid=uM7xjcxMRKA
`(SCRN00004776-777)
`
`Pursuant to P.R. 3-1(g), Plaintiff asserts this limitation is implemented in software.
`
`AT&T’s MMSC and associated servers perform the method of claim 1, wherein the
`selected video file includes a single digital image, because AT&T provides MMS message
`services to its subscribers, and MMS messaging supports transmission of digital images.
`
`See evidence and discussion for Claim 4.
`
`AT&T’s MMSC and associated servers perform the method of claim 1, wherein the
`selected video file is acquired using a digital camera of the first wireless communications
`
`20
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`
`
`
`Claim Language
`wireless communications device.
`
`APPENDIX A4
`
`U.S. Patent No. 8,594,651
`Infringement by AT&T Mobility, LLC (“AT&T”)
`device, because AT&T provides MMS message services to its subscribers, and MMS
`messaging supports transmission of pictures taken using the sending device’s digital
`camera.
`
`AT&T provides MMS message services to its subscribers, including wireless telephones:
`“Picture/Video Messaging
`Picture & Video Messaging-capable devices use Multimedia Messaging Service (MMS) to send
`messages that include multimedia content to and from mobile devices. With a Picture & Video
`Messaging-capable device, you can:
`• Send pictures, animations, videos, and voice messages to any 10-digit wireless number or
`email address.
`• Personalize the message with text or a voice recording.
`• Receive picture and video messages on your device sent to your 10-digit wireless number
`or emailed to your 10-digit wireless number@mms.att.net.
`
`…
`Send Picture & Video Messages
`To learn to send Picture & Video Messages from your device, please visit the Device How-To
`Center:
`If needed, select your device, brand, and model and then click Save.
`1.
`2. Under Device instructions, select Messaging & email:
`• To send a picture or video message, select Text & picture messaging, and then,
`from the Interactive tutorials, select Send a multimedia message.
`• To send a picture or video as an email, select Email, and then, from the Interactive
`tutorials, select Send email.
`
`…
`Don't have a Picture & Video Messaging-capable device?
`If you don't have a Picture & Video Messaging-capable device and receive a picture or video
`message, you'll receive a text message explaining how to view your pictur