UNITED STATES DISTRICT COURT FOR
`THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`ROSETTA-WIRELESS CORP., an Illinois
`Corporation,
`
`Plaintiff
`
`v.
`
`APPLE INC., a California Corporation
`
`Defendant.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Civil Action No. lS-cv-00799
`
`Honorable Judge Joan H. Lefkow
`
`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 Apple that
`
`may affect Rosetta's infringement contentions. Not all information about the Accused
`
`Instrumentalities is publicly available. Further, Rosetta understands that Apple intends to release
`
`products in the future that infringe the asserted claims.
`
`Accordingly, Rosetta's investigation into Apple'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
`
`Apple Exhibit 1059.001
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`I.
`
`INITIAL INFRINGEMENT CONTENTIONS
`
`A. Local Patent Rules 2.2(a) - Asserted Claims
`
`Apple is liable under 35 U.S.C. § 271(a) for infringement of claims 1-2,4-6, 8-9,58-59,
`
`and 62-630fUnited States Patent No. 7,149,511 (the "'511 Patent") (infringement claim charts
`
`attached as Exhibit A). 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 following Accused Instrumentalities infringe the asserted claims:
`
`•
`
`•
`
`•
`
`•
`
`iPhone 5
`
`iPhone 5c
`
`iPhone 5s
`
`iPhone 6
`
`•
`
`•
`
`•
`
`iPhone 6 Plus
`
`iPhone 6s
`
`iPhone 6s Plus
`
`Exhibit A discloses which claims of each asserted patent that each Accused
`
`Instrumentality infringes based on Rosetta's investigation thus far. Rosetta further accuses any
`
`other Apple products that Apple 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 Apple. Accordingly, Rosetta reserves its right to supplement this disclosure to
`
`include any additional Apple 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 Apple products through discovery (which is in
`
`its early stages) and its continuing investigation.
`
`2
`
`Apple Exhibit 1059.002
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`C. Local Patent Rules 2.2(c) - Claim Charts for the Accused Instrumentalities
`
`Attached as Exhibit A 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.
`
`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 ofthe 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, Apple had knowledge of the '511 Patent no later than
`
`January 27,2015, yet Apple has continued to infringe said patent. The infringement of the '511
`
`Patent by Apple 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
`
`3
`
`Apple Exhibit 1059.003
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`incurred in prosecuting this action under 35 U.S.C. § 285. Rosetta intends to amend its
`
`complaint to allege post-filing willful infringement.
`
`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.
`
`Date: December 14,2015
`
`. el A. Zah
`D
`r (pro hac vice)
`-~ Michael N g (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.
`
`RolfO. 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.
`
`4
`
`Apple Exhibit 1059.004
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on December 14,2015, I served Rosetta-Wireless Corporation's Initial
`
`Infringement Contentions upon counsel for Apple Inc. by email.
`
`5
`
`Apple Exhibit 1059.005
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`
`
`EXHIBIT A
`
`Apple Exhibit 1059.006
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`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;
`
`iPhone 5 Claim Chart
`
`
`
`Infringement by iPhone 5
`
`The Apple iPhone 5 (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
`(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 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 UMTS/HSPA+/DC-HSDPA, GSM/EDGE, LTE, and/or CDMA EV-
`DO Rev. A and Rev. B.
`
`
`
`
`1
`
`Apple Exhibit 1059.007
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`
`
`
`See https://support.apple.com/kb/SP655. 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 UMTS/HSPA+/DC-HSDPA, GSM/EDGE, LTE, and/or
`CDMA EV-DO Rev. A and Rev. B transceiver (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 a Qualcomm RTR8600 Multi-band/mode RF
`transceiver that comprises the Cellular Transceiver, and a Murata 339S0171
`(based on a Broadcom BCM4334 chip) module that comprises the Wi-Fi and
`Bluetooth Transceivers.
`
` Qualcomm RTR8600 Multi-band/mode RF transceiver.
`
`
`
`
`
`
`
`
`
`
`1 Transceivers are capable of both transmission and reception, and therefore comprise a
`“receiver.”
`
`
`
`2
`
`Apple Exhibit 1059.008
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`a memory;
`
`
` Murata 339S0171 (based on Broadcom BCM4334) Wi-Fi/Bluetooth
`module.
`
`
`See https://www.ifixit.com/Teardown/iPhone+5+Teardown/10525.
`
`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 Elpida B8164B3PM LP
`DDR2 SDRAM or a Samsung K3PE7E700F-XGC2 DRAM component:
`
`
`
`
`
`
`3
`
`
`
`Apple Exhibit 1059.009
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`
` B8164B3PM silkscreen label denotes 1GB Elpida LP DDR2
`SDRAM.
`
`
`
`The flash memory in the Accused Device includes a Hynix H2JTDG2MBR
`128 Gb (16 GB) NAND flash module. Apple offers the Accused Devices
`with at least the following flash memory storage size options: 16GB, 32GB,
`or 64GB.
`
`
`
`
`
`
` Hynix H2JTDG2MBR 128 Gb (16 GB) NAND flash
`
`
`See https://www.ifixit.com/Teardown/iPhone+5+Teardown/10525.
`
`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.”
`
`The Accused Device comprises a wireless intelligent personal network server
`containing a CPU.
`
`The CPU in the Accused Device is an Apple A6 (Dual-core 1.3 GHz Swift
`(ARM v7-based):
`
`
`a central processing unit
`(CPU);
`
`
`
`4
`
`Apple Exhibit 1059.010
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`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
`
`
`
`
`The specific CPUs in certain Accused Devices may vary from those specified
`herein, but any such difference is immaterial.
`
`See https://www.ifixit.com/Teardown/iPhone+5+Teardown/10525. See also
`http://www.gsmarena.com/apple_iphone_5-4910.php.
`
`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 iPhone
`5. The Accused Devices’ internal memory has recorded on it embedded
`machine language instructions (corresponding to the Swift ARMv7-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.
`
`iTunes Store:
`
`The Accused Devices are configured to connect to the internet wirelessly via
`Wi-Fi and cellular connections:
`
`
`
`
`
`
`5
`
`Apple Exhibit 1059.011
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`
`See iOS 6 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1658/en_US/iphone_io
`s6_user_guide.pdf, at p. 13. 2
`
`See also iOS 7 User Guide:
`https://manuals.info.apple.com/en US/iphone ios7 user guide.pdf, at p. 16.
`
`See also iOS 8 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1565/en_US/iphone_us
`er guide.pdf, at p. 17.
`
`See also iOS 9 Online User Guide:
`http://help.apple.com/iphone/9/?lang=en#/iph1b489c85f.
`
`When connected to the internet wirelessly, the Accused Device are able to
`wirelessly download files such as music, photos, videos, podcasts and apps
`that are purchased from the iTunes Store:
`
`
`
`2
`References to certain functionality of the Accused Device reflect the configuration in iOS
`6, 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.
`
`
`
`6
`
`Apple Exhibit 1059.012
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`.
`
`
`
`
`See iOS 6 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1658/en_US/iphone_io
`s6_user_guide.pdf, at p. 94.
`
`See also iOS 7 User Guide:
`https://manuals.info.apple.com/en_US/iphone_ios7_user_guide.pdf, at p.
`101.
`
`See also iOS 8 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1565/en US/iphone us
`er guide.pdf, at p. 118.
`
`
`
`7
`
`Apple Exhibit 1059.013
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`
`See also iOS 9 Online User Guide:
`http://help.apple.com/iphone/9/?lang=en#/iph3df0adef.
`
`Said iTunes files may be downloaded via Wi-Fi or via cellular wireless:
`
`
`
`
`See iOS 6 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1658/en US/iphone io
`s6 user guide.pdf, at p. 95.
`
`See also iOS 7 User Guide:
`https://manuals.info.apple.com/en_US/iphone_ios7_user_guide.pdf, at p.
`102.
`
`See also iOS 8 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1565/en_US/iphone_us
`er_guide.pdf, at p. 120.
`
`See also iOS 9 Online User Guide:
`http://help.apple.com/iphone/9/?lang=en#/iph17ff8a531.
`
`As part of the downloading process, the iTunes 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).
`
`iTunes Syncing:
`
`Similarly, electronic files can be downloaded wirelessly3 from a user’s
`computer and stored on the Accused Devices. iTunes allows a user to “sync”
`electronic files (including music, photos, videos, podcasts, apps, and other
`types of files) that are stored on a user’s computer to the Accused Device
`wirelessly, that is, to download 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.
`
`
`3
`In iOS6, wireless syncing was limited to Wi-Fi, but in subsequent versions of iOS, which
`may be installed on certain Accused Devices, syncing can take place over a cellular connection
`as well.
`
`
`
`8
`
`Apple Exhibit 1059.014
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`
`
`Infringement by iPhone 5
`
`
`
`
`See iOS 6 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1658/en_US/iphone_io
`s6_user_guide.pdf, at p. 14.
`
`See also iOS 7 User Guide:
`https://manuals.info.apple.com/en_US/iphone_ios7_user_guide.pdf, at p. 17.
`
`See also iOS 8 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1565/en US/iphone us
`er guide.pdf, at p. 19.
`
`See also iOS 9 Online User Guide:
`http://help.apple.com/iphone/9/?lang=en#/iph2b72fba0.
`
`
`
`
`
`See iOS 6 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1658/en_US/iphone_io
`s6_user_guide.pdf, at p. 16.
`
`See also iOS 7 User Guide:
`https://manuals.info.apple.com/en US/iphone ios7 user guide.pdf, at p. 17.
`
`See also iOS 8 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1565/en US/iphone us
`er guide.pdf, at p. 20.
`
`See also iOS 9 Online User Guide:
`http://help.apple.com/iphone/9/?lang=en#/iph3c796484.
`
`
`
`9
`
`Apple Exhibit 1059.015
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`
`iCloud:
`
`Electronic files can also be “synced,” that is, downloaded wirelessly4 from a
`user’s computer and/or “cloud” storage, and stored on the Accused Devices
`using iCloud. iCloud allows a user to sync a wide variety of electronic files
`including “music, photos, calendars, contacts, documents, and more.” 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 iOS 6 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1658/en US/iphone io
`s6 user guide.pdf, at p. 14.
`
`See also iOS 7 User Guide:
`https://manuals.info.apple.com/en_US/iphone_ios7_user_guide.pdf, at p. 17.
`
`See also iOS 8 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1565/en_US/iphone_us
`er_guide.pdf, at p. 18.
`
`See also iOS 9 Online User Guide:
`http://help.apple.com/iphone/9/?lang=en#/iph2b72fba0.
`
`
`
`4
`In iOS6 syncing was limited to Wi-Fi, but in subsequent versions of iOS, which may be
`installed on certain Accused Devices, syncing can take place over a cellular connection as well.
`
`
`
`10
`
`Apple Exhibit 1059.016
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`
`
`
`See iOS 6 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1658/en_US/iphone_io
`s6_user_guide.pdf, at p. 15.
`
`
`See also iOS 7 User Guide:
`https://manuals.info.apple.com/en US/iphone ios7 user guide.pdf, at p. 17.
`
`See also iOS 8 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1565/en_US/iphone_us
`er guide.pdf, at p. 18.
`
`See also iOS 9 Online User Guide:
`
`
`
`11
`
`Apple Exhibit 1059.017
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`http://help.apple.com/iphone/9/?lang=en#/iph3c79652c.
`
`One feature of iCloud is the syncing of photographs using Photo Stream.
`Photo Stream syncs electronic photograph files that are stored on a user’s
`personal computer, other iOS device, or even from the account of another
`user. Such photographic files are 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
`instructions to provide such files to the memory of the Accused Device.
`
`
`
`
`
`
`See iOS 6 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1658/en_US/iphone_io
`s6_user_guide.pdf, at p. 71.
`
`See also iOS 7 User Guide:
`https://manuals.info.apple.com/en US/iphone ios7 user guide.pdf, at p. 75.
`
`See also iOS 8 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1565/en_US/iphone_us
`er guide.pdf, at p. 89.
`
`See also iOS 9 Online User Guide:
`http://help.apple.com/iphone/9/?lang=en#/iphbfeb468fc.
`
`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
`
`
`
`12
`
`Apple Exhibit 1059.018
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`Accused Device, which alternatively can be set to “fetch” email on the user’s
`command:
`
`
`
`
`
`See iOS 6 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1658/en_US/iphone_io
`s6_user_guide.pdf, at p. 54.
`
`See also iOS 7 User Guide:
`https://manuals.info.apple.com/en US/iphone ios7 user guide.pdf, at p. 54.
`
`See also iOS 8 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1565/en US/iphone us
`er guide.pdf, at p. 62.
`
`See also iOS 9 Online User Guide:
`http://help.apple.com/iphone/9/?lang=en#/iph5ca4d6a69.
`
`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.
`
`
`
`
`13
`
`Apple Exhibit 1059.019
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`
`
`
`
`See iOS 6 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1658/en US/iphone io
`s6 user guide.pdf, at p. 64.
`
`See also iOS 7 User Guide:
`https://manuals.info.apple.com/en_US/iphone_ios7_user_guide.pdf, at p. 67.
`
`See also iOS 8 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1565/en_US/iphone_us
`er_guide.pdf, at p. 78.
`
`
`
`
`14
`
`Apple Exhibit 1059.020
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`See also iOS 9 Online User Guide:
`http://help.apple.com/iphone/9/?lang=en#/iph3d039b67.
`
`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.5 As with email,
`when connected wirelessly via Wi-Fi or cellular wireless, such files are
`“pushed” to the Accused Device, which alternatively can be set to “fetch”
`such data on the user’s command:
`
`
`
`
`
`See iOS 6 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1658/en US/iphone io
`s6 user guide.pdf, at p. 54.
`
`See also iOS 7 User Guide:
`https://manuals.info.apple.com/en_US/iphone_ios7_user_guide.pdf, at p. 54.
`
`See also iOS 8 User Guide:
`https://manuals.info.apple.com/MANUALS/1000/MA1565/en_US/iphone_us
`er_guide.pdf, at p. 62.
`
`See also iOS 9 Online User Guide:
`http://help.apple.com/iphone/9/?lang=en#/iph5ca4d6a69.
`
`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
`
`
`5
`Certain types of files may not be downloaded in this manner in certain versions of iOS.
`
`
`
`15
`
`Apple Exhibit 1059.021
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`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,
`
`
`embedded machine language instructions to provide electronic files to the
`memory. In addition to native iOS operations, the Accused Device includes
`the capacity for “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 distributed by Apple in its App Store.
`
`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 Accused Device comprises a wireless intelligent personal network server
`with said interface, which provides access by an external display device via
`the Lightning 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, digital media players like the Apple
`TV (when connected to a television or containing their own displays),
`peripherals like the Apple Watch, 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
`allow for the transmission of above-described electronic files from the
`memory of the Accused Devices to external display devices. Those
`connections include the Lightning 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. Apple 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.
`
`
`
`16
`
`Apple Exhibit 1059.022
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`
`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:
`
`
`
`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
`
`
`
`
`
`17
`
`Apple Exhibit 1059.023
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`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
`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. Apple directs
`that applications on external devices connected to the Accused Device must
`include specific buttons for the picking and opening of audio/visual files:
`
`
`2.2.4 Audio/Video Remote Control Profile (AVRCP)
`To support the Audio/Video Remote Control Profile , a accessory that is compatible
`with an Apple product should support the buttons and operations listed in this
`section.
`
`2.2.4.1 Supported Buttons
`
`Every accessory that is compatible with an Apple product and supports the
`Audio/Video Remote Control Profile should use separate button commands to play
`and pause instead of toggling the play or pause state.
`
`2.2.4.2 Supported Operations
`
`Apple products support the following operation_IDs in Pass Through commands:
` Play
` Stop
` Pause
` Fast Forward
` Rewind
` Forward
` Backward
`
`
`See Bluetooth Accessory Design Guidelines for Apple Products
`https://developer.apple.com/hardwaredrivers/BluetoothDesignGuidelines.pdf,
`p. 13. The above are examples; other means for picking and open are also
`available for AVRCP devices. The files may be transmitted to the external
`display devices in conformance with the Bluetooth Advanced Audio
`Distribution Profile (A2DP), which is supported by the Accused Device.
`Transmission via the A2DP protocol does not result in the transfer of the
`
`
`
`18
`
`Apple Exhibit 1059.024
`
`Samsung et al. v. Rosetta-Wireless
`IPR2016-00622
`
`

`
`Claim 1 of U.S. Patent No.
`7,149,511
`
`Infringement by iPhone 5
`
`original file on the Accused Device itself, or the destruction of such fi