Bradium Techs. LLC v. Microsoft Corp. , No. 15-cv-31-RGA (D. Del.)
`INITIAL CLAIM CHART, PURSUANT TO SCHEDULING ORDER (D.I. 43. L6)
`
`Microsoft Bing Mags, Bing Search, and Bing Maps Preview
`
`1
`
`U'§"9P;'t§:}t612qo'
`
`Microsoft Bing Maps, Bing Search, and Bing Maps Preview‘
`
`1
`
`A method of retrieving
`large—scale images over
`network
`commlmications
`
`As explained below, Bing Maps, operating on an Android device, such as a smart phone,
`requests, receives, and displays Bing Maps map tiles based on a user’s image viewpoint.
`Further, as explained below, Microsoft servers process Bing Maps map tiles in an infringing
`manner.
`
`
`
`channels for display on
`a limited
`commtmication
`bandwidth computer
`device, said method
`
`comprising:
`
`To the extent the preamble is limiting,4 Bing Maps as accessed via an Android device
`provides a method of retrieving large—scale images over network communications channels
`for display on a hunted communication bandwidth computer device.
`
`Bing Maps provides and displays. for example, a world map that users can directly
`manipulate and zoom. E.g., Joe Schwartz, Bing Maps Tile Svstem, MICROSOFT,
`https://msdn.microsoft.com/en-us/library/bb259689.aspx (last visited Apr. 29, 2016) (“Bing
`Ma s Tile Svsrem” .
`
`1 These charts are initial claim charts. Bradium is engaged in ongoing discovery and reserves the right to supplement or amend these charts as the case develops.
`Microsoft has yet to provide any version information on the accused products. despite Bradiunrs requests served on February 9. 2016. Microsoft has further
`provided inadequate core technical documents to describe the fimctionality of all of the Accused Products. Bradium has not yet had an opportunity to review
`source code. Therefore. Bradium provides a representative chart.
`2 This chart also applies to related U.S. Patent Publication No. 2011/0175914. The claims of Publication No. US 2011/0175914 are substantially identical to the
`claims of the ‘S06 atent.
`
`3 This chart uses an Android device for exemplary purposes. but the chart also applies to all other implementations of the Accused Products during the damages
`period. including without limitation all versions of Bing Maps as accessed. for example. on an Android. iOS. Windows. or other mobile device. all versions of
`Bing Search, including, for example as an application or website on an Android. iOS. Windows. or other mobile device. and all versions of the Bing Maps
`Preview app. operating. for example. as a Microsoft Windows application. This chart includes the Accused Products operating as a first party website or
`application and as operating through the website or application of a Microsoft customer who has contracted to use Bing Maps. for example by using a Bing Maps
`API or re - isterin as a b2b Bin Ma s client.
`
`
`
`

`

`Bradium Techs. LLC v. Microsoft Corp, No. 15-cv-31-RGA (D. Del.)
`INITIAL CLAIM CHART. PURSUANT TO SCHEDULING ORDER (D.I. 43. l.e)
`
`U.S. Patent No.
`8,924,506,
`
`Microsoft Bing Maps, Bing Search, and Bing Maps Preview’
`Bing Maps Custom Tile Layer Hierarchical Directory Structure
`
`/l TN2008_NC_BingMaps_Tiles
`(master tile directory)
`
`Zoorr Level Subdirectories Named by Zoom Level Number (2)
`
`,‘,I-.',!J,lJ,'/'24/lbgmk
`
`5
`
`6
`
`7
`
`e
`
`9
`
`1011
`
`‘l21314151617pNG
`
`Tile Row Subdirectoiies
`Named by
`Tue Row Nun-we, (V)
`
`I
`’
`199
`
`J
`’
`200
`
`‘
`”‘
`201
`
`202
`
`Tie Files Named by Tie Column Number (X)
`
`i IIII
`
`128.png
`
`129png
`
`130.png
`
`131.jpg
`
`132.jpg
`
`133.jpg
`
`134.jpg
`
`135 png
`
`136.prig
`
`137 png
`
`138.png
`
`139.prig
`
`Directory structure for a Bing Maps Custom Tile Layer created in TNTmips using the
`Automatic option for Tile Format, which creates JPEG files for interior tiles and PNG
`files for edge tiles to provide transparency for non-image areas. This tile layer in-
`ckides zoom levels 5 through 17 Tiles are stored in nested sLbdirectories first by
`Mom level number and than by tile row number
`Individual tile files are named by tile
`column number
`
`See also, e.g., MSFT-BRAD-0001031 at 2 (0001032) (describing a “custom tile layer,"
`which can be stored b level of detail, tile row, and tile coluum .
`
`A display system for
`displaying a large-scale
`image retrieviedover a
`limitedbandwidfll
`communications
`
`To the extent the preamble is limiting. a display system (for example on an Android device)
`in combination with Bing Maps provides a system for displaying large-scale images
`retrieved over limited bandwidth comnnmications channels. Microsoft induces
`infringement of this system because Microsoft has intended, a11d continues to intend, to
`cause end users to use at least Bin Ma - s in a manner covered b one or more claims of the
`
`

`

`Bradium Techs. LLC v. [Microsoft Corp. No. 15-cv-31-RGA (D. Del.)
`H‘TlTIAL CLA]]\/I CHART. PURSUANT TO SCHEDULING ORDER (D.I. 43. l.e)
`
`Ref. Claim
`No.
`
`U.S. Patent No.
`8,924,506’
`channel, said display
`system comprising:
`
`’343 patent.
`
`Microsoft Bing Maps, Bing Search, and Bing Maps Preview’
`
`Bing Maps provides a11d displays, for example, a world map that users can directly
`manipulate and zoom. E.g., Joe Schwartz, Bing Maps Tile System, MICROSOFT.
`https://msdn.microsoft.com/en-us/library/bb259689.aspx (last visited Apr. 29, 2016) (“Bing
`Maps Tile Svstenf’).
`
`Folders. Tiles. and File Size by Zoom Level
`for a Sample Bing Maps Custom Tile Layer
`(1-m Orthoimage Mosaic of a US State)
`(see Technical Gu dc entitled
`Tile-sets Understanding Sizes)
`Source image size: 352 G8 (uncompressed)
`
`Image area:
`Tile Size:
`
`109,185 square kilometers
`256 x 256 DIXEIS [required]
`
`Tile Formals:
`
`JPEG 0 PNG lcr edge tiles
`
`See also, e.g., MSFT-BRAD—000103l at 3 (0001033) (appearing to show image data size
`for a sample source image of the United States).
`
`Microsoft provides and displays Bing Maps through, for example, a web browser for use on
`a user computing device such as an Android device connected to a network communication
`channel such as, for exam a le, the Internet.
`
`