UNITED STATES DISTRICT COURT FOR
`THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`
`
`
`
`
`
`Civil Action No. 15-cv-10605
`
`Honorable Judge Joan H. Lefkow
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`
`
`ROSETTA-WIRELESS CORP., an Illinois
`Corporation,
`
`
`
`
`
`Plaintiff
`
`
`
`
`
`v.
`
`
`
`
`SAMSUNG ELECTRONICS CO. LTD., and
`SAMSUNG ELECTRONICS AMERICA,
`INC., a New York Corporation,
`
`
`
`
`
`Defendants.
`
`
`
`
`
`PLAINTIFF’S LOCAL PATENT RULE 2.2 INITIAL INFRINGEMENT
`CONTENTIONS
`
`
`
`Pursuant to Local Patent Rule 2.2, Plaintiff Rosetta-Wireless Corporation (“Rosetta” or
`
`“Plaintiff”) hereby submits the following Initial Infringement Contentions.
`
`Discovery is far from complete, and Rosetta is still seeking information from Samsung
`
`Electronics Co. Ltd. and Samsung Electronics America, Inc. (collectively, “Samsung”) that may
`
`affect Rosetta’s infringement contentions. Not all information about the Accused
`
`Instrumentalities is publicly available. Further, Rosetta understands that Samsung intends to
`
`release products in the future that infringe the asserted claims.
`
`Accordingly, Rosetta’s investigation into Samsung’s infringement is ongoing, and
`
`Rosetta makes these disclosures based on its current knowledge. In light of the foregoing,
`
`Rosetta reserves the right to supplement or amend these disclosures as further facts are revealed
`
`during the course of this litigation.
`
`
`
`1
`
`Samsung Exhibit 1028 Page 00001
`
`

`
`
`
`I.
`
`INITIAL INFRINGEMENT CONTENTIONS
`
`A. Local Patent Rules 2.2(a) – Asserted Claims
`
`Samsung is liable under 35 U.S.C. § 271(a) for infringement of claims 1-2, 4-6, 8-9, 58-
`
`59, and 62-63 of United States Patent No. 7,149,511 (the “’511 Patent”) (infringement claim
`
`charts attached as Exhibit B). Rosetta’s investigation is ongoing, and Rosetta reserves the right to
`
`identify additional asserted claims based upon continued discovery and investigation.
`
`B. Local Patent Rules 2.2(b) – Accused Instrumentalities
`
`The Accused Instrumentalities listed in Exhibit A infringe the asserted claims.
`
` Exhibit B discloses which claims of each asserted patent that each Accused Instrumentality
`
`infringes based on Rosetta’s investigation thus far. Rosetta further accuses any other Samsung
`
`products that Samsung is currently developing, making and/or using, including but not limited to
`
`any newer but unreleased versions of the accused products that have been recently announced by
`
`Samsung. Accordingly, Rosetta reserves its right to supplement this disclosure to include any
`
`additional Samsung products it identifies through discovery and its continuing investigation.
`
`Rosetta further reserves the right to supplement its disclosure to include any additional
`
`information it learns about the accused Samsung products through discovery (which is in its
`
`early stages) and its continuing investigation.
`
`C. Local Patent Rules 2.2(c) – Claim Charts for the Accused Instrumentalities
`
`Attached as Exhibit B are claim charts that identify where each element of each asserted
`
`claim of the asserted patents is found within the Accused Instrumentalities, based on the
`
`information available to Rosetta.
`
`Rosetta’s investigation is ongoing, and Rosetta reserves the right to amend or supplement
`
`these claim charts based upon continued discovery and investigation.
`
`
`
`2
`
`Page 00002
`
`

`
`
`
`D. Local Patent Rules 2.2(d) – Nature of Infringement
`
`Based on Rosetta’s current understanding, each element or limitation of each asserted
`
`claim of each asserted patent is literally present in the Accused Instrumentalities. To the extent
`
`that any element or limitation of the asserted claims is not found to have literal correspondence
`
`in the Accused Instrumentalities, Rosetta alleges, on information and belief, that any such
`
`elements or limitations are present under the doctrine of equivalents in the Accused
`
`Instrumentalities.
`
`E. Local Patent Rules 2.2(e) – Direct Infringement
`
`Each of the asserted claims is currently alleged to be infringed directly. Rosetta’s
`
`investigation is ongoing, and Rosetta reserves the right to amend or supplement its infringement
`
`allegations based upon continued discovery and investigation.
`
`F. Local Patent Rules 2.2(f) – Priority Dates
`
`Not applicable.
`
`G. Local Patent Rules 2.2(g) – Basis for Willful Infringement
`
`Upon information and belief, Samsung had knowledge of the ’511 Patent no later than
`
`January 27, 2015, yet Samsung has continued to infringe said patent. The infringement of the
`
`’511 Patent by Samsung is willful, deliberate and unreasonable, and with full knowledge of the
`
`patent, entitling Rosetta to increased damages under 35 U.S.C. § 284 and to attorneys’ fees and
`
`costs incurred in prosecuting this action under 35 U.S.C. § 285.
`
`H. Local Patent Rules 2.2(h) – Patentee’s Patent-Practicing Products
`
`Rosetta produced approximately five prototype wireless personal network servers in or
`
`about 2005. These devices were never offered for sale or sold, were produced prior to issuance
`
`of the patent-in-suit and were not marked with the patent number.
`
`
`
`
`
`3
`
`Page 00003
`
`

`
`
`
` I
`
`Date: January 20, 2016
`
`
`
`
`KOBRE & KIM LLP
`
`
`
`/s/ Daniel Zaheer
`Daniel A. Zaheer (pro hac vice)
`Michael Ng (pro hac vice)
`Michael C. Fasano (pro hac vice)
`Kobre & Kim LLP
`150 California, 19th Floor
`San Francisco, California 94111
`michael.ng@kobrekim.com
`daniel.zaheer@kobrekim.com
`michael.fasano@kobrekim.com
`(415) 582-4803
`
`STADHEIM & GREAR, LTD.
`
`Rolf O. Stadheim
`Kyle L. Harvey
`Robert M. Spalding
`Christopher H. St. Peter
`400 North Michigan Avenue, Suite 2200
`Chicago, Illinois 60611
`stadheim@stadheimgrear.com
`harvey@stadheimgrear.com
`spalding@stadheimgrear.com
`stpeter@stadheimgrear.com
`(312) 755-4400
`
`Attorneys for Plaintiff Rosetta-Wireless Corp.
`
`
`
`
`CERTIFICATE OF SERVICE
`
` hereby certify that on January 20, 2016, I served Rosetta-Wireless Corporation’s Initial
`
`Infringement Contentions upon counsel for Samsung by email.
`
`
`
`
`
`
`
`
`
`
`/s/ Travis Anderson-Hamilton
`Travis Anderson-Hamilton
`
`
`
`
`
`4
`
`Page 00004
`
`

`
`ooooooo 05
`
`
`
`EXHIBIT A
`
`EXHIBIT A
`
`Page 00005
`
`

`
`
`
`Ativ Odyssey
`Ativ S
`Ativ S Neo
`Ativ SE
`Exhilarate
`Focus 2
`Freeform M
`Galaxy A3
`Galaxy A5
`Galaxy A7
`Galaxy A7 Duos
`Galaxy A8
`Galaxy A8 Duos
`Galaxy Ace 2
`Galaxy Ace 3
`Galaxy Ace 4
`Galaxy Ace Duos
`Galaxy Ace II x
`Galaxy Ace NXT
`Galaxy Ace Plus
`Galaxy Ace Style
`Galaxy Admire 4G
`Galaxy Alpha
`Galaxy Amp
`Galaxy Appeal
`Galaxy Attain 4G
`Galaxy Avant
`Galaxy Axiom
`Galaxy Beam
`
`Accused Instrumentalities
`
`Galaxy Beam 2
`Galaxy Centura
`Galaxy Chat
`Galaxy Core
`Galaxy Core 2
`Galaxy Core Advance
`Galaxy Core LTE
`Galaxy Core Plus
`Galaxy Discover
`Galaxy Discover S730G
`Galaxy Exhibit
`Galaxy Express
`Galaxy Express 2
`Galaxy Express i437
`Galaxy E5
`Galaxy E7
`Galaxy Fame
`Galaxy Fame Lite Duos
`Galaxy Folder
`Galaxy Golden
`Galaxy Grand
`Galaxy Grand 2
`Galaxy Grand Neo
`Galaxy Grand Max
`Galaxy Grand Prime
`Galaxy II Plus
`Galaxy J1
`Galaxy J1 4G
`Galaxy J1 Ace
`
`Galaxy J2
`Galaxy J5
`Galaxy J7
`Galaxy K zoom
`Galaxy Light
`Galaxy Mega 2
`Galaxy Mega 5.8
`Galaxy Mega 6.3
`Galaxy mini 2
`Galaxy Music
`Galaxy Nexus Sprint
`Galaxy Note 3
`Galaxy Note 3 Neo
`Galaxy Note 4
`Galaxy Note5
`Galaxy Note5 Duos
`Galaxy Note Edge
`Galaxy Note II
`Galaxy Note II AT&T
`Galaxy Note II Sprint
`Galaxy Note II T-Mobile
`Galaxy Note II US Cellular
`Galaxy Note II Verizon
`Galaxy Note LTE
`Galaxy Note T-Mobile
`Galaxy On5
`Galaxy On7
`Galaxy Player 3.6
`Galaxy Player 4.2
`
`Page 00006
`
`

`
`Galaxy Young
`Galaxy Young 2
`Omnia M
`Rugby Smart
`
`
`
`
`
`Galaxy Pocket
`Galaxy Pocket 2
`Galaxy Pocket Duos
`Galaxy Pocket Neo
`Galaxy Pocket Plus
`Galaxy Premier
`Galaxy Prevail 2
`Galaxy Reverb
`Galaxy Ring
`Galaxy Round
`Galaxy Rugby Pro
`Galaxy Rush
`Galaxy S Advance
`Galaxy S Blaze 4G
`Galaxy S Duos
`Galaxy S II CDMA
`Galaxy S II TV
`Galaxy S III
`Galaxy S III AT&T
`Galaxy S III Cricket
`Galaxy S III MetroPCS
`Galaxy S III mini
`Galaxy S III mini Value
`Edition
`Galaxy S III Sprint
`Galaxy S III T-Mobile
`Galaxy S III Verizon
`Galaxy S Lightray 4G
`Galaxy S Relay 4G
`Galaxy S3 Neo
`Galaxy S3 Slim
`
`Galaxy S4
`Galaxy S4 Active
`Galaxy S4 mini
`Galaxy S4 mini I9195I
`Galaxy S4 Value Edition
`Galaxy S4 Zoom
`Galaxy S5
`Galaxy S5 Active
`Galaxy S5 Mini
`Galaxy S5 Neo
`Galaxy S5 Plus
`Galaxy S5 Sport
`Galaxy S6
`Galaxy S6 active
`Galaxy S6 Duos
`Galaxy S6 edge
`Galaxy S6 edge+
`Galaxy S6 edge+ Duos
`Galaxy Star
`Galaxy Star 2
`Galaxy Stellar
`Galaxy Stratosphere II
`Galaxy Trend Lite
`Galaxy V
`Galaxy V Plus
`Galaxy Victory 4G LTE
`Galaxy Win
`Galaxy Xcover 2
`Galaxy Xcover 3
`Galaxy Y Duos
`Galaxy Y Pro Duos
`
`Page 00007
`
`

`
`ooooooo os
`
`
`
`EXHIBIT B
`
`EXHIBIT B
`
`Page 00008
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`A wireless intelligent
`personal network server,
`comprising:
`
`a radio frequency (RF)
`receiver for receiving
`downstream data
`transmitted over a first
`wireless communications
`channel;
`
`Samsung Galaxy S III Claim Chart
`
`
`
`Infringement by Galaxy S III
`
`The Samsung Galaxy S III (the “Accused Device”) comprises a wireless
`intelligent personal network server. Specifically, and as described below in
`detail with respect to each limitation, the Transceiver Modules (defined
`below), Memory Modules (defined below), External Connectors (defined
`below), the CPU (which implements the interface, as described below, and
`including embedded machine instructions governing the operations of the
`CPU), the interconnection between the External Connectors and the CPU,
`and other connectors and components necessary to enable their functionality
`of the above comprise the structures within the Accused Device that carry out
`the Accused Device’s wireless intelligent personal network server.
`
`Moreover, the Accused Device is configured to operate as a wireless
`intelligent personal network server. The Accused Device wirelessly connects
`to a network, automatically receives and stores data, and acts as a personal
`server for the user. Said wireless transmission and receipt of data is
`implemented via the Transceiver Components described in detail below. The
`Accused Device maintains the individual user’s data and allows access to that
`data via an external display device, as described below. Such access
`includes, but is not limited to, picking and opening files of different types,
`including but not limited to music files, document files, email files, SMS
`files, image files and social media update files. Such files may be updated in
`the background, as described below. The Accused Device is configured to
`access information on a network, which may include a user’s personal
`computer, an enterprise server, cloud storage or other device, accessed via
`the internet, a corporate or personal network, a wireless local area network, a
`wide area network, or other network.
`
`The Accused Device comprises a wireless intelligent personal network server
`containing a radio frequency (RF) receiver for receiving downstream data
`transmitted over a first wireless communications channel.
`
`The Accused Device is capable of both transmission and reception wirelessly
`through components that enable compliance with various wireless data
`transmission standards, namely: Wi-Fi (IEEE 802.11a/b/g/n); a Bluetooth
`4.0; and GSM/GPRS/EDGE, HSPA+, and 4G LTE.
`
`
`
`
`
`
`1
`
`Page 00009
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`
`
`
`
`
`See http://www.samsung.com/global/galaxys3/specifications.html.
`
`Data reception by the Accused Device using said standards comprises the
`reception of data transmitted over a wireless communications channel.
`
`Specifically, the Accused Device includes at least three transceivers1 that are
`capable of receiving downstream data transmitted at radio frequencies on a
`wireless communications channel: a Wi-Fi (IEEE 802.11a/b/g/n) transceiver
`(the “Wi-Fi Transceiver”); a Bluetooth 4.0 transceiver (the “Bluetooth
`Transceiver”); and GSM/GPRS/EDGE, HSPA+, and 4G LTE (the “Cellular
`Transceiver”). Said transceivers or elements thereof may be combined, for
`example, with certain signal processing or transmission functions for
`Bluetooth or Wi-Fi carried out by the same structures on a single chip.
`
`The Accused Device includes an Infineon PMB5712 RF transceiver that
`comprises the Cellular Transceiver, and a Murata M2322007 module that
`comprises the Wi-Fi and Bluetooth Transceivers.
`
`
`
`
` Murata M2322007 Wi-Fi Module
`
`1 Transceivers are capable of both transmission and reception, and therefore comprise a
`“receiver.”
`
`
`
`
`
`2
`
`Page 00010
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`
`
`
`
`
`
` Infineon PMB5712 RF Transceiver
`
`
`See
`https://www.ifixit.com/Teardown/Samsung+Galaxy+S+III+Teardown/9391.
`
`The specific Wi-Fi, Bluetooth and Cellular Transceivers in certain Accused
`Devices may vary from those specified herein, but any such difference is
`immaterial. The above Wi-Fi, Bluetooth and Cellular Transceivers, together
`with other components associated with or physically contained within the
`same physical unit as them, are referred to herein as the “Transceiver
`Modules.”
`
`The Accused Device comprises a wireless intelligent personal network server
`containing a memory.
`
`The Accused Device includes memory in multiple forms, including but not
`limited to RAM (e.g., SDRAM) memory and flash memory components.
`Said components may be integrated with other components, for example,
`with the RAM memory integrated into the processor module.
`
`The RAM memory in the Accused Device is a 1 GB LP DDR2 RAM
`(K3PE7E700M-XGC2) component.
`
`
`
`
`a memory;
`
`
`
`3
`
`Page 00011
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`
`
`
` K3PE7E700M-XGC2 silkscreen label denotes 1 GB LP DDR2 RAM.
`
`
`The flash memory in the Accused Device includes a Samsung
`KMVTU000LM eMMC (16GB)+MDDR(64MB) NAND flash module.
`Samsung offers the Accused Devices with at least the following flash
`memory storage size options: 16GB, 32GB, or 64GB.
`
`
`
`
`
`
` Samsung KMVTU000LM eMMC(16GB)+MDDR(64MB) NAND
`Flash
`
`
`See
`https://www.ifixit.com/Teardown/Samsung+Galaxy+S+III+Teardown/9391.
`
`The specific memory components in certain Accused Devices may vary from
`those specified herein, but any such difference is immaterial. The above
`memory components, together with other components associated with or
`physically contained within the same physical unit as them, are referred to
`herein as the “Memory Modules.”
`
`
`
`4
`
`Page 00012
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`a central processing unit
`(CPU);
`
`Infringement by Galaxy S III
`
`The Accused Device comprises a wireless intelligent personal network server
`containing a CPU.
`
`The CPU in the Accused Device is a Samsung Exynos 4412 quad-core A9
`processor (Quad-core 1.4 GHz Cortex-A9):
`
`
`
`
`
`
`See
`https://www.ifixit.com/Teardown/Samsung+Galaxy+S+III+Teardown/9391.
`
`The specific CPUs in certain Accused Devices may vary from those specified
`herein, but any such difference is immaterial.
`
`The Accused Device comprises a wireless intelligent personal network server
`containing embedded machine language instructions that are executable by
`the CPU for processing downstream data received by the RF receiver to
`provide electronic files to the memory.
`
`Machine language instructions are intrinsic to the functioning of the Galaxy S
`III. The Accused Devices’ internal memory has recorded on it embedded
`machine language instructions (corresponding to Quad-core based
`architecture of the above CPU) that are executed by the above CPU. Said
`machine instructions allow for processing downstream data received on the
`above first wireless communications channel to provide at least one
`electronic file in said memory, including through the features set out below.
`
`Google Play:
`
`The Accused Devices are configured to connect to the internet wirelessly via
`Wi-Fi and cellular connections:
`
`
`a set of embedded machine
`language instructions
`within said personal
`network server, said set of
`embedded machine
`language instructions being
`executable by said CPU for
`processing said downstream
`data to provide at least one
`electronic file in said
`memory; and
`
`
`
`5
`
`Page 00013
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`
`
`
`See Galaxy S III User Guide:
`http://downloadcenter.samsung.com/content/UM/201412/201412090503551
`63/VZW_SCH-i535_GS3_English_User-Manual_KK_NE1_F1_AC.pdf ) (at
`p. 113)
`
`When connected to the internet wirelessly, the Accused Device is able to
`wirelessly download files such as music, images, videos, books, and apps that
`are purchased from the Google Play Store:
`
`
`
`
`
`
`
`
`6
`
`Page 00014
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`
`
`
`See Galaxy S III User Guide:
`http://downloadcenter.samsung.com/content/UM/201412/201412090503551
`63/VZW_SCH-i535_GS3_English_User-Manual_KK_NE1_F1_AC.pdf ) (at
`p. 144)
`
`Said Google Play files may be downloaded via Wi-Fi or via cellular wireless:
`
`
`
`
`
`See Google Play Support page:
`https://support.google.com/googleplay/answer/1134092
`
`As part of the downloading process, the Google Play files received via Wi-Fi
`or cellular transmission (the “downstream data received by the RF receiver”)
`are processed by the CPU using embedded machine language instructions
`and stored in the Accused Device’s memory (i.e., provided to the memory).
`
`Samsung Kies Syncing:
`
`Similarly, electronic files can be downloaded wirelessly from a user’s
`computer and stored on the Accused Devices. Samsung Kies allows a user to
`synchronize electronic files (including music, photos, videos,apps, and other
`types of files) that are stored on the Accused Device to the user’s computer
`
`
`2 References to certain functionality of the Accused Device reflect the configuration in Android
`OS 4.0.4, the operating system provided with the Accused Device at the time of its first sale.
`Similar functionality with different variations that are immaterial for purposes of these
`infringement contentions is found in Accused Devices using updated version of the operating
`system software.
`
`
`
`7
`
`Page 00015
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`wirelessly, that is, to download and update them without the need for a
`specific request for each individual file. Such syncing entails processing of
`downstream data received by the RF receiver by the CPU using embedded
`machine language instructions to provide such files to the memory of the
`Accused Device.
`
`
`
`
`
`See Samsung Kies User Guide:
`http://www.samsung.com/in/support/usefulsoftware/KIES/
`
`Cloud Syncing:
`
`Electronic files can also be “synced,” that is, downloaded wirelessly from a
`user’s computer and/or cloud storage, and stored on the Accused Devices
`using cloud storage services such as Google Drive, Google Photos, DropBox,
`Box or OneDrive. For example, by accessing the Dropbox application from
`the Accused Device, a user is able to sync a wide variety of electronic files
`including photos, videos, and documents. Such syncing entails processing of
`downstream data received by the RF receiver by the CPU using embedded
`machine language instructions to provide such files to the memory of the
`Accused Device.
`
`
`
`
`
`
`
`8
`
`Page 00016
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`See Dropbox Google Play page:
`https://play.google.com/store/apps/details?id=com.dropbox.android.
`
`Such syncing functionality also includes keeping the files stored locally on
`the Accused Device “up-to-date” (i.e., synced) with the version stored in the
`cloud.
`
`
`
`
`
`
`
`See https://www.dropbox.com/help/267?path=mobile.
`
`As another example, in Google Drive or Google Photos, the Accused Device
`is also able to wirelessly sync changes and deletions made to photograph,
`video and other files. Such files may be stored on one or more of the
`Accused Device, a personal computer, a tablet or another device. Such files
`and changes to such files are also downloaded wirelessly and stored on the
`Accused Devices. Such syncing entails processing of downstream data
`received by the RF receiver by the CPU using embedded machine language
`
`
`
`9
`
`Page 00017
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`instructions to provide such files to the memory of the Accused Device.
`
`
`
`
`
`See
`https://support.google.com/photos/answer/6193313?hl=en&ref_topic=61560
`61.
`
`Email and Messages:
`
`The Accused Devices also include the capacity to receive email (including
`attached files) wirelessly via either Wi-Fi or cellular transmission. When
`connected wirelessly via Wi-Fi or cellular wireless, email is “pushed” to the
`Accused Device and changes made to the user’s e-mail on other devices are
`synced:
`
`
`
`
`10
`
`Page 00018
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`
`
`
`See https://support.google.com/mail/answer/2893260?hl=en.
`
`Email messages, along with any attached files, are processed by the CPU
`pursuant to embedded machine language instructions and provided to the
`Accused Device’s memory as files.
`
`The Accused Devices also include the capacity to receive messages
`(including attached or embedded files) wirelessly via Wi-Fi or cellular
`transmission.
`
`
`
`
`11
`
`Page 00019
`
`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`
`
`
`See Galaxy S III User Guide:
`http://downloadcenter.samsung.com/content/UM/201412/201412090503551
`63/VZW_SCH-i535_GS3_English_User-Manual_KK_NE1_F1_AC.pdf ) (at
`p. 88)
`
`Messages, along with any attached files, are processed by the CPU pursuant
`to embedded machine language instructions and provided to the Accused
`Device’s memory as files.
`
`Calendar, Contacts and Other Files:
`
`Similarly, the Accused Devices also include the capacity to receive calendar
`data, contacts, notes, reminders and other types of files (including attached
`files) wirelessly via either Wi-Fi or cellular transmission.3 As with email,
`when connected wirelessly via Wi-Fi or cellular wireless, alterations to and
`deletions of such files are synced with the Accused Device:
`
`
`
`3
`Certain types of files may not be downloaded in this manner in certain versions of
`Android OS.
`
`
`
`12
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`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`
`
`
`See Galaxy S III User Guide:
`http://downloadcenter.samsung.com/content/UM/201412/201412090503551
`63/VZW_SCH-i535_GS3_English_User-Manual_KK_NE1_F1_AC.pdf (at
`p. 51)
`
`
`
`
`
`
`
`
`See Google Calendar Support:
`https://support.google.com/calendar/answer/151674?hl=en&ref_topic=34179
`69
`
`
`
`
`
`
`13
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`Page 00021
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`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`See Google Calendar Support:
`https://support.google.com/calendar/answer/6261951?hl=en&ref_topic=3417
`969
`
`Such files are processed by the CPU pursuant to embedded machine language
`instructions and provided to the Accused Device’s memory as files.
`
`Apps and Other Files:
`
`The above are examples of the types of files that may be downloaded via one
`of the Accused Devices RF transceivers and processed by the CPU using
`embedded machine language instructions to provide electronic files to the
`memory. In addition to native Android operations and the applications
`discussed above, the Accused Device includes the capacity for additional
`“apps,” which are software programs to add functionality to the Accused
`Device. Using such apps, a user of the Accused Device may (either
`automatically or pursuant to a specific request) download data via Bluetooth,
`Wi-Fi or cellular transmission, which is then processed by the CPU pursuant
`to embedded machine language instructions to provide to provide electronic
`files to the memory. Examples of such apps include Facebook, Twitter,
`Angry Birds, WhatsApp, Instagram, and Spotify, but also include millions of
`other apps available in the Google Play Store or in other app marketplaces
`such as the Amazon Appstore.
`
`The above are non-exhaustive examples of the ways in which Accused
`Device processes data received by the Accused Devices’ RF by the CPU
`pursuant to embedded machine language instructions to provide electronic
`files to the Accused Device’s memory. The specific version or provider of
`the e-mail, cloud storage, messaging or calendar applications discussed above
`may vary from those specified herein, but any such difference is immaterial.
`
`The Accused Device comprises a wireless intelligent personal network server
`with said interface, which provides access by an external display device via
`the microUSB connector, and the Wi-Fi, Bluetooth and cellular connections,
`allowing an application on said external display device to pick and open said
`at least one electronic file while said at least one electronic file remains
`resident on the Accused Devices.
`
`
`External display devices may include personal computers or tablets,
`automotive audio systems with displays, peripherals like the Samsung
`Galaxy Gear, or even other smartphones. This list is not exhaustive, and the
`Accused Device is designed to work with myriad display devices.
`
`
`The Accused Device includes multiple physical or wireless connections that
`
`a first interface for allowing
`an application on an
`external display device to
`pick and open said at least
`one electronic file while
`said at least one electronic
`file remains resident on said
`personal network server,
`
`
`
`
`14
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`

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`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`allow for the transmission of above-described electronic files from the
`memory of the Accused Devices to external display devices. Those
`connections include the microUSB connector, and the Wi-Fi, Bluetooth and
`cellular connections enabled by the Wi-Fi, Bluetooth and Cellular
`Transceivers. (Collectively, such connections are referred to herein as the
`“External Connectors.”)
`
`
`The interface of the Accused Devices is implemented by the CPU by way of
`the External Connectors. Samsung has not provided discovery detailing
`such, and Rosetta reserves the right to amend these infringement contentions
`once that information is provided. The functionality provided by the
`operation of the interface in the Accused Devices is observable by the user,
`as described below.
`
`The operation of the interface may include an indication to the CPU and to
`the interconnect that an active communication is available to service from the
`other, handling the sequencing of address, and the movement of the data, any
`required buffering of data, and any direct memory access. Said functionality
`and the implementation thereof would be well understood by one of ordinary
`skill in the art. Other system resources that may be accessed by the interface
`and used in its operations may include the peripheral bridge, peripheral data
`controller, buffering inside peripheral blocks, a bus (composed of address
`bus, data bus and control bus), and small state machines inside the blocks, for
`example, as shown in the following diagram for standard ARM architecture:
`
`
`
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`Page 00023
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`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`
`
`
`
`The basic functioning of the CPU includes provision of an electronic file
`stored in memory in response to a request, that is, the functionality that
`allows for the “pick[ing] and open[ing]” of a file. The Accused Device is
`further configured, however, as described below, in a manner that establishes
`that said basic functionality can be achieved by a variety of external display
`devices, which can pick files (by selection from a list, selection of a next file
`in order, or otherwise) stored in the memory of the Accused Device, and to
`open the files provided to the external display device from the memory of the
`Accused Device.
`
`Bluetooth
`
`The Accused Device allows external display devices to pick and open
`electronic files stored on the Accused Device’s memory in conformance with
`the Bluetooth standard. Such electronic files may include the above-
`described electronic files received by the Accused Device’s RF receivers and
`
`
`
`16
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`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`processed by the CPU to provide them to the Accused Device’s memory, and
`such files may remain resident on the memory of the Accused Devices.
`
`The Accused Device allows for selection of files in conformance with the
`Bluetooth Audio/Video Remote Control Profile, or AVRCP. Applications on
`external devices connected to the Accused Device must include specific
`buttons for the picking and opening of audio/visual files:
`
`
`
`
`
`
`
`See
`https://developer.bluetooth.org/TechnologyOverview/Pages/AVRCP.aspx
`
`The above are examples; other means for picking and opening are also
`available for the Accused Device. The files may be transmitted to the
`external display devices in conformance with the Bluetooth Advanced Audio
`
`
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`17
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`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by Galaxy S III
`
`Distribution Profile (A2DP), which is supported by the Accused Device.
`Transmission via the A2DP protocol does not result in the transfer of the
`original file on the Accused Device itself, or the destruction of such files on
`the Accused Device; the files instead remain resident on the Accused Device.
`
`Examples of such display devices include car audio systems with displays.4
`
`Micro USB:
`
`The Accused Device allows external display devices to pick and open
`electronic files stored on the Accused Devices memory through the devices’
`electrical connector, the microUSB port. Such electronic files may include
`the above-described electronic files received by the Accused Device’s RF
`receivers and processed by the CPU to provide them to the Accused Device’s
`memory, and such files may remain resident on the memory of the Accused
`Devices. Examples include car audio systems with displays connected via
`the microUSB connector.5
`
`Wi-Fi:
`
`The Accused Device allows external display devices to pick and open
`electronic files stored on the Accused Devices memory through Wi-Fi. Such
`electronic files may include the above-described electronic files received by
`the Accused Device’s RF receivers and processed by the CPU to provide
`them to the Accused Device’s memory, and such files may remain resident
`on the memory of the Accused Devices. Examples of such external display
`devices include a personal computer.
`
`File types:
`
`External display devices connected to an Accused Device may pick and open
`myriad file types. Samsung’s product documentation makes clear that audio
`and video files that may be transmitted to an external device include the file
`types that are downloaded through the RF transceivers and processed by the
`CPU to provide files to the Accused Devices as described above, including
`through the Google Play Store, Google Play Music and Dropbox.
`
`
`4
`Such devices may also conform to the Android Auto format, which may provide the
`picking and opening functionality through different protocols. See
`http://developer.android.com/training/auto/audio/index.html and
`http://developer.android.com/reference/android/media/session/MediaSession.html.
`
` 5
`
`Such devices may also conform to the Android Auto format, which may provide the
`
`picking and opening functionality through different protocols.
`
`
`
`18
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`Page 00026
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`

`
`
`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`
`
`Infringement by Galaxy S III
`
`
`
`
`See http://www.samsung.com/global/galaxys3/specifications.html.
`
`Types of external display devices:
`
`Such external display devices may include (a) car and home audio systems,
`(b) wearable devices and other peripherals, and (c) personal computers.
`Again, such devices include software programs, or applications, that enable
`the relevant functionality. The Accused Devices include the capacity to
`allow such external display devices to pick and open one of the above-
`described electronic files. Though they are not themselves claimed,
`examples of such display devices are provided further below.
`
`Car