5/20/2016
`
`IXI’s Supplemental Claim Chart Regarding BlackBerry’s Infringement of U.S. Patent No. 7,552,1241
`Claim 1
`Although the preamble to Claim 1 does not limit the scope of the claim, BlackBerry Relevant Devices2 and/or
`BlackBerry, Google, and/or other Internet servers implementing Natural Language Search Features3 practice a
`method for programming a mobile communication device based on a high-level code comprising operative
`language, as explained below.
`
`1. A method for
`programming a mobile
`communication device
`based on a high-level
`code comprising
`operative language, the
`method comprising:
`
`BlackBerry and/or users program BlackBerry Relevant Devices via Natural Language Search Features using
`natural language, such as naturally spoken or written words, that are high-level code including operative
`language.
`
`For example, as explained by BlackBerry:
`“BlackBerry Assistant … is voice activated when I need it to be, and helps manage simple tasks on my
`device from searching my email and calendar, finding out what’s trending on Twitter, to sending trivia
`night invitations. The more I use it, the more it learns and adapts to me. The more I speak with it, the
`more tuned-in to my queries it gets.”
`
`1 IXI provides these infringement contentions for Defendants BlackBerry Limited and BlackBerry Corporation (collectively, “BlackBerry”). These contentions
`contain diagrams, screenshots, and other documentary evidence by way of example and not by way of limitation. These contentions contain diagrams,
`screenshots, and other documentary evidence by way of example and not by way of limitation. These contentions are based on publicly available information.
`IXI reserves the right to amend these contentions as discovery progresses, in response to BlackBerry’s defenses and any claim construction rulings, and
`otherwise for good cause.
`
`2 “BlackBerry Relevant Devices” include every BlackBerry smartphone, tablet, laptop or other mobile device that includes a Natural Language Search Feature,
`including but not limited to the following: BlackBerry 9620, BlackBerry 9720, Curve 9310, Curve 9315, Curve 9320, Curve 9350/9360/9370, Curve 9380, Z3,
`Z10, Z30, Q5, Q10, Bold 9900, Bold 9930, Bold 9790, Classic, Porsche Design P’9981, Porshe Design P’9982, Porshe Design P’9983, Torch 9810, Torch
`9850/9860, Passport, Priv, Leap, and devices reasonably similar in the operation of Natural Language Search Features.
`
`3 “Natural Language Search Features” includes the BlackBerry Assistant (BlackBerry OS 10.3.1 and later), BlackBerry Universal Search (BlackBerry 6 and
`later), Google Now/Google Search/Google Voice Search, and any counterpart software on BlackBerry, Google, and/or other Internet server, as well as any
`reasonably similar software.
`
`118961506-1
`
`1
`
`Page 1 of 21
`
`GOOGLE EXHIBIT 1010
`
`

`
`5/20/2016
`
`(See BlackBerry’s Webpage, “A Closer Look at BlackBerry 10.3: Introducing BlackBerry Assistant”)i
`
`“New with BlackBerry 10 OS v10.3, BlackBerry® Assistant allows you to manage your email,
`contacts, calendar and other BlackBerry 10 features through voice and text commands. It helps you to
`execute tasks quickly such as responding to important emails, scheduling a meeting or getting
`directions.
`
`BlackBerry Assistant is intelligent enough to respond to you based on your situation. Speak freely to it
`and it will respond in kind. Type a query and it will respond simply with information on the screen.
`When you’re connected to Bluetooth in the car, it knows you can’t look at the screen and will interact
`with you completely eyes and hands free.”
`
`(See BlackBerry’s Webpage, “New Features in Version 10.3.2”)ii
`
`As another example, BlackBerry Universal Search allows for natural language voice and text searching:
`
`“To get started with Universal Search, all you need to do is start typing the search term on the home
`screen, or tap on the magnifying glass icon that appears on the home screen and enter the search term.
`As you are typing your search term you’ll notice that results start showing up right away.”
`
`“If you are using a BlackBerry 7 OS smartphone, after tapping on the magnifying glass you’ll notice a
`microphone icon appear. Tapping on this icon will allow you to perform a voice enabled search instead
`of having to type your search term. In order to use voice search, you’ll need to make sure you have a
`connection to the wireless network.”
`
`(See BlackBerry Help Blog, “How to use Universal Search”)iii
`
`Also, Google Now (which has been merged with the Google Search app since Android 4.1) allows for natural
`language voice and text searching:
`
`“Google Now is an intelligent personal assistant developed by Google. Google Now is available within
`the Google Search mobile application for Android and iOS, as well as the Google Chrome web browser
`on personal computers. Google Now uses a natural language user interface to answer questions, make
`
`118961506-1
`
`2
`
`Page 2 of 21
`
`

`
`5/20/2016
`
`recommendations, and perform actions by delegating requests to a set of web services.”
`
`(See Wikipedia, “Google Now”)iv
`
`“You can use your voice on the Google app or Chrome to do things like search, get directions, and
`create reminders. For example, say ‘Ok Google do I need an umbrella tomorrow’ to see if there's rain
`in the weather forecast.”
`
`(See Google’s Support webpage, “‘Ok Google’ voice search and actions”)v
`
`“From knowing the weather before you start your day, to planning the best route to avoid traffic, or
`even checking your favorite team’s score while they’re playing, get the information you want, when
`you need it.”
`
`(See Google’s webpage, “Google Now – what is it”)vi
`
`Google Now is built into BlackBerry Relevant Devices and operates with BlackBerry, Google, and/or
`other Internet servers
`
`“When you talk to Android’s voice recognition software, the spectrogram of what you've said is
`chopped up and sent to eight different computers housed in Google's vast worldwide army of servers.
`It's then processed, using the neural network models built by Vanhoucke and his team.”
`
`“Basically, using such ample cloud processing power, Google can analyze a ton of patterns - which in
`case of voice are spectograms - and use that to predict new patterns, much like the neurons in the brain
`would reconnect to accomplish new tasks.”
`
`“There are a couple of layers in processing speech. First Google tries to understand the consonants and
`the vowels. That is the foundational layer. Next, it uses those to make intelligent guesses about the
`words. And then higher.”
`
`receiving a high-level
`code comprising one or
`
`(See Phone Area webpage, “The secret of Google's amazing voice recognition revealed: it works like a
`brain”)vii
`BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other Internet servers implementing Natural
`Language Search Features practice the step of receiving a high-level code comprising one or more keywords,
`
`118961506-1
`
`3
`
`Page 3 of 21
`
`

`
`more keywords, wherein
`the high-level code is
`provided by a user of a
`mobile communication
`device to control the
`operation of the mobile
`communication device
`without having to select
`from menu items
`provided by an operating
`system running on the
`mobile communication
`device;
`
`5/20/2016
`
`wherein the high-level code is provided by a user of a mobile communication device to control the operation
`of the mobile communication device without having to select from menu items provided by an operating
`system running on the mobile communication device.
`
`As explained above in the content corresponding to the pre-amble, which is hereby incorporated by reference,
`BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other Internet servers implementing Natural
`Language Search Features receive natural language inquiries from users, such as spoken or written words, that
`are high-level code including operative language with one or more keywords for controlling the operation of
`the BlackBerry Relevant Device.
`
`BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other Internet servers include communication
`interfaces, (e.g., antennae, modems, network cards, and/or transceivers) and/or user interfaces (e.g.,
`touchscreens, keyboards, microphones) for receiving the claimed high-level code. For example, BlackBerry
`Relevant Devices receive high-level code including one or more keyword through Natural Language Search
`Feature inquiries that a user inputs via a touchscreen, keyboard, or microphone. BlackBerry, Google, and/or
`other Internet servers receive the high-level code, depending on its complexity, via communication interfaces,
`such as antennae, modems, network cards, and/or transceivers, over wide area networks (e.g., cellular
`networks), wireless local area networks (e.g., Wi-Fi or Bluetooth networks), and/or the Internet.
`
`BlackBerry Relevant Devices receive high level code from users, without having to select menu items, in a
`variety of ways, such as touching a microphone button and speaking into a microphone, speaking a natural
`language after saying “Ok, Google” or “call BlackBerry Assistant,” typing natural language text into a Google
`search bar widget or other universal search box, long pressing or swiping on the device’s “Home” button and
`speaking in natural language, and/or other input methods particular to a device or operating system.
`
`The operation of a BlackBerry Relevant Device is controlled by high-level code via Natural Language Search
`Features. For example, BlackBerry describes multiple typical commands for controlling the operations of a
`mobile device such as:
`
`• Email
`o Send an email, reply to an email, and search your email messages.
`• BBM
`o Send a BBM message, reply to a BBM message, and search your BBM messages.
`
`118961506-1
`
`4
`
`Page 4 of 21
`
`

`
`5/20/2016
`
`• Phone
`o Make a call by using a contact name or phone number, and check or return your missed calls.
`• Calendar
`o Create a calendar event, edit a calendar event, invite colleagues to a meeting, and search your
`calendar.
`• Knowledge
`o Get answers to thousands of questions with the help of Wolfram Alpha.
`• Text Messaging
`o Send a text message, reply to a text message, and search your text messages.
`• Apps and Settings
`o Open apps and change some of your device settings.
`• Search
`o Search the Internet with your preferred search engine, or search your device by keyword.
`• Navigation
`o Get directions to a specific address, city center, or point of interest.
`• Alarm
`o Set a new alarm, change existing alarms to a new time or frequency, and turn off alarms.
`• Timer
`o Set the timer, and pause, resume, or stop the timer.
`• Facebook
`o Send a Facebook message, search your messages, and update your Facebook status.
`• Twitter
`o Post a tweet, find out what topics are trending, search your Twitter direct messages, and send a
`direct message.
`• Foursquare
`o Check in to your favorite locations with Foursquare.
`• Music
`o Search your music library, play your favorite songs or playlists, and pause, shuffle, or skip
`songs while they play.
`• Reminders
`o Create tasks, notes, and reminders in BlackBerry Remember, and search your tasks, notes, and
`reminders.
`
`118961506-1
`
`5
`
`Page 5 of 21
`
`

`
`5/20/2016
`
`• Weather
`o Check your local forecast, a different city's forecast, and other weather information.
`• Places
`o Find businesses and points of interest nearby, or find businesses and points of interest in a
`different city.
`• Sports
`o Check scores, schedules, standings, and other info for various professional sports leagues in
`North America and Europe.
`• Movies
`o Check movie times for a specific movie, or check what’s playing at a specific theater.
`
`(See BlackBerry’s Help webpage, “Things you can do with the BlackBerry Assistant”)viii
`
`Similarly, Google also describes multiple typical commands for controlling the operations of a BlackBerry
`Relevant Device such as:
`
`• Calendar, alarms, reminders & information
`• Communicate with friends & family
`• Entertainment (music, movies, TV, books & pictures)
`• Directions & travel
`• Facts & quick answers
`• Change your device's settings
`
`(See Google’s Support webpage, “‘Ok Google’ voice search and actions”)ix
`
`Google Now can also be used to manage BlackBerry device local control settings. For example, Google Now
`can be used to control use of Bluetooth, Airplane mode and to screen brightness.
`
`Change your device's settings
`Wi-Fi: "Turn on Wi-Fi" or "Turn off Wi-Fi."
`Bluetooth: "Turn on Bluetooth" or "Turn off Bluetooth."
`Flashlight: "Turn on my flashlight" or "Turn my flashlight off."
`
`118961506-1
`
`6
`
`Page 6 of 21
`
`

`
`(See Google’s Support webpage, “‘Ok Google’ voice search and actions”)x
`
`Natural Language Search Features on BlackBerry Relevant Devices operate without selecting menu items
`provided by an operating system.
`
`For example, BlackBerry Assistant operation is explained by BlackBerry as follows:
`
`5/20/2016
`
`“Open the BlackBerry Assistant
`Do any of the following:
`
`“On the home screen, tap The BlackBerry Assistant icon.
`Press and hold the Mute key on the right side of your device.
`
`“Tip: You can also open the BlackBerry Assistant by typing a request or search term on the home
`screen.
`
`“Open the BlackBerry Assistant when your device is connected to a car
`If your car kit supports hands-free calling and the Phone Book Access Profile (PBAP), you can open
`the BlackBerry Assistant hands-free when your device is connected to a car using Bluetooth
`technology.
`
`“When prompted by your car kit to say a request, say ‘Call BlackBerry Assistant.’
`Say a request that is supported by the BlackBerry Assistant.”
`
`(See BlackBerry’s Webpage, “BlackBerry Passport User Guide”)xi
`
`BlackBerry Universal Search operation is explained as follows:
`
`“To get started with Universal Search, all you need to do is start typing the search term on the home
`screen, or tap on the magnifying glass icon that appears on the home screen and enter the search term.
`As you are typing your search term you’ll notice that results start showing up right away.”
`
`“If you are using a BlackBerry 7 OS smartphone, after tapping on the magnifying glass you’ll notice a
`
`118961506-1
`
`7
`
`Page 7 of 21
`
`

`
`microphone icon appear. Tapping on this icon will allow you to perform a voice enabled search instead
`of having to type your search term. In order to use voice search, you’ll need to make sure you have a
`connection to the wireless network.”
`
`(See BlackBerry Help Blog, “How to use Universal Search”)xii
`
`5/20/2016
`
`Google Now operation is explained by Google as follows:
`
`Change your voice search settings
`
`Open the Google app .
`In the top left corner of the page, touch the Menu icon menu icon > Settings > Voice > "Ok Google"
`Detection.
`From here, you can choose when you want your phone to listen when you say "Ok Google."
`
`Start a voice search
`
`Open the Google app .
`Say "Ok Google" or touch the microphone icon.
`
`parsing the high-level
`code for the keywords to
`recognize the operative
`language associated with
`controlling one or more
`operations of the mobile
`communication device;
`
`(See Google’s Support webpage, “‘Ok Google’ voice search and actions”)xiii
`Depending on the complexity of the high-level code, software on BlackBerry Relevant Devices and/or
`BlackBerry, Google, and/or other Internet servers implementing Natural Language Search Features practice
`the step of parsing the high-level code for the keywords to recognize the operative language associated with
`controlling one or more operations of the mobile communication device as explained above. For example,
`BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other Internet servers parse the high-level
`natural language voice or written words, “please make a phone call to Tom Smith,” for keywords such as
`“call” to recognize the operative language “make a phone call” associated with controlling the voice calling
`operations of the phone.
`
`determining at least one
`
`See also above citations regarding the functionality of the Natural Language Search Features, which are hereby
`incorporated by reference.
`Natural Language Search Feature software on the BlackBerry Relevant Devices and/or BlackBerry, Google,
`
`118961506-1
`
`8
`
`Page 8 of 21
`
`

`
`5/20/2016
`
`operation associated with
`the operative language;
`
`and/or other Internet servers implementing Natural Language Search Features practice the step of determining
`at least one operation associated with the operative language. For example, software on BlackBerry Relevant
`Devices and/or BlackBerry, Google, and/or other Internet servers implementing Natural Language Search
`Features determine that placing a voice call is associated with the operative language “make a phone call.”
`
`determining whether
`high-level code
`comprises keywords
`defining one or more
`relationships and
`conditions corresponding
`to the operative language;
`
`producing an executable
`code that can be executed
`by a microcontroller of
`the mobile
`communication device to
`perform the respective
`operation associated with
`the operative language;
`
`See also above citations regarding the functionality of the Natural Language Search Features, which are hereby
`incorporated by reference.
`Natural Language Search Feature software on the BlackBerry Relevant Devices and/or BlackBerry, Google,
`and/or other Internet servers implementing Natural Language Search Features practice the step of determining
`whether high-level code comprises keywords defining one or more relationships and conditions corresponding
`to the operative language. For example, high-level code may include “remind me when I am near a gas
`station” and the keyword “when” defines a relationship and condition corresponding to the operative language
`– namely, that a reminder will go off only when the BlackBerry Relevant Device is in proximity to a gas
`station. Similarly, high-level code may, for example, include “remind me at 6 p.m. to pick up a pizza.” The
`reminder will conditionally go off only when it is 6 p.m.
`
`See also above citations regarding the functionality of the Natural Language Search Features, which are hereby
`incorporated by reference.
`BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other Internet servers implementing Natural
`Language Search Features software, and or the application or operating system functions that the Natural
`Language Search Features initiate, practice the step of producing an executable code that can be executed by a
`microcontroller of the mobile communication device to perform the respective operation associated with the
`operative language.
`
`BlackBerry Relevant Devices include microcontrollers (e.g., microprocessors, systems on a chip) that execute
`executable code. For example, when the high level code includes the operative language “set my calendar,”
`the Natural Language Search Feature and/or Calendar application produces executable code that can be
`executed by the microprocessor or system on a chip of the BlackBerry Relevant Device to perform the
`associated operation of setting a calendar.
`
`See the above citations regarding the functionality of the Natural Language Search Features, which are hereby
`incorporated by reference.
`
`118961506-1
`
`9
`
`Page 9 of 21
`
`

`
`BlackBerry and Google describe multiple typical BlackBerry Assistant and Google Now commands for
`controlling the operations of a mobile device, as described above.
`
`determining level of
`complexity and
`implementation of the
`high-level code;
`
`Natural Language Search Feature software of BlackBerry Relevant Devices and/or BlackBerry, Google, and/or
`other Internet servers implementing Natural Language Search Features practice the step of determining level
`of complexity and implementation of the high-level code.
`
`See the above citations regarding the functionality of the Natural Language Search Features, which are hereby
`incorporated by reference.
`
`5/20/2016
`
`Natural Language Search Features use a combination of local device processing and internet-based BlackBerry
`and Google servers. More complex requests such as those that may require searching the internet using, for
`example, search engines such as Google are separated from those that may be executed on the user device such
`as device control operations as discussed above.
`
`“When you talk to Android’s voice recognition software, the spectrogram of what you've said is
`chopped up and sent to eight different computers housed in Google's vast worldwide army of servers.
`It's then processed, using the neural network models built by Vanhoucke and his team.
`
`“Basically, using such ample cloud processing power, Google can analyze a ton of patterns - which in
`case of voice are spectograms - and use that to predict new patterns, much like the neurons in the brain
`would reconnect to accomplish new tasks.”
`
`(See Phone Area webpage, “The secret of Google's amazing voice recognition revealed: it works like a
`brain”)xiv
`
`If it is determined that the command is for a simple local device operation, then the device does the processing
`as shown below.
`
`118961506-1
`
`10
`
`Page 10 of 21
`
`

`
`5/20/2016
`
`(See Gadgets Webpage, “Google Now Gets Offline Voice-Command Support for Some Functions”)xv
`
`BlackBerry Assistant allows you to turn off “full assistance mode” allowing for only simple local device
`operations such as dialing phone numbers. More complex commands require full assistance mode and require
`the use of BlackBerry, Google, and/or other Internet servers.
`
`and designating an
`application software to
`process the high level
`code, wherein the high-
`level code comprises at
`least one sentence
`formatted in accordance
`with a first context,
`
`(See BlackBerry Help Webpage, “Turn off full assistance mode”)xvi
`BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other Internet servers implementing Natural
`Language Search Features practice the step of designating an application software to process the high level
`code, wherein the high-level code comprises at least one sentence formatted in accordance with a first context.
`For example, the BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other Internet servers
`implementing Natural Language Search Features designate an application software (e.g., a Natural Language
`Search Feature application) to process the high level code. This Natural Language Search Feature application
`may be on the BlackBerry Relevant Device or may be the counterpart software on BlackBerry, Google, and/or
`other Internet servers.
`
`See the above citations regarding the functionality of the Natural Language Search Features, which are hereby
`incorporated by reference.
`
`wherein the high-level
`code is processed by a
`natural language
`compiler comprised of
`
`BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other Internet servers implementing Natural
`Language Search Features practice the step wherein the high-level code is processed by a natural language
`compiler comprised of one or more modules executed on one or more independent computing systems,
`depending on the level of complexity and the implementation of the high-level code.
`
`118961506-1
`
`11
`
`Page 11 of 21
`
`

`
`5/20/2016
`
`one or more modules
`executed on one or more
`independent computing
`systems, depending on
`the level of complexity
`and the implementation
`of the high-level code,
`
`wherein application
`software is executed on a
`distributed environment
`comprising the mobile
`communication device
`and a network server
`connected to the mobile
`communication device,
`and the application
`software performs the
`parsing and determining
`steps depending on
`implementation,
`
`High-level natural language code, such as spoken or written words, is processed by a natural language
`compiler module included as part of Natural Language Search Feature applications. The Natural Language
`Search Feature applications may be on one or more independent computing systems, such as on the
`BlackBerry Relevant Device and/or a BlackBerry, Google, and/or other Internet server, depending on the
`complexity and implementation of the high-level code.
`
`See the above citations regarding the functionality of the Natural Language Search Features, which are hereby
`incorporated by reference.
`BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other Internet servers implementing Natural
`Language Search Features practice steps wherein application software is executed on a distributed
`environment comprising the mobile communication device and a network server connected to the mobile
`communication device, and the application software performs the parsing and determining steps depending on
`implementation.
`
`See the above citations regarding the functionality of the Natural Language Search Features, which are hereby
`incorporated by reference.
`
`As noted above:
`
`“When you talk to Android’s voice recognition software, the spectrogram of what you've said is
`chopped up and sent to eight different computers housed in Google's vast worldwide army of servers.
`It's then processed, using the neural network models built by Vanhoucke and his team.
`
`“Basically, using such ample cloud processing power, Google can analyze a ton of patterns - which in
`case of voice are spectograms - and use that to predict new patterns, much like the neurons in the brain
`would reconnect to accomplish new tasks.”
`
`and wherein when the
`high-level code
`comprises a complex
`
`(See Phone Area webpage, “The secret of Google's amazing voice recognition revealed: it works like a
`brain”)xvii
`BlackBerry, Google, and/or other Internet servers implementing Natural Language Search Features practice
`the step of wherein when the high-level code comprises a complex structure the parsing and determining steps
`are performed by application software executed on a network server connected to the mobile communication
`
`118961506-1
`
`12
`
`Page 12 of 21
`
`

`
`5/20/2016
`
`structure the parsing and
`determining steps are
`performed by application
`software executed on a
`network server connected
`to the mobile
`communication device,
`
`and when the high-level
`code comprises a less
`complex structure the
`parsing and determining
`steps are performed by
`application software
`executed on the mobile
`communication device.
`
`device.
`
`See the above citations regarding the functionality of the Natural Language Search Features, which are hereby
`incorporated by reference.
`
`For example, natural language that cannot be performed solely on the BlackBerry Relevant Device, such as
`those relating to Internet searches, weather inquiries, etc. are high-level code comprising a complex structure
`and the parsing and determining steps are performed by applications executed on BlackBerry, Google, or other
`Internet servers that are connected to the BlackBerry Relevant Device.
`BlackBerry Relevant Devices implementing Natural Language Search Features practice the step of when the
`high-level code comprises a less complex structure (i.e., one that the device fully execute without the
`assistance of external servers), the parsing and determining steps are performed by application software
`executed on the mobile communication device.
`
`See the above citations regarding the functionality of the Natural Language Search Features, which are hereby
`incorporated by reference.
`
`If it is determined that the natural language is for a simple local device operation, then the device does the
`processing as shown below.
`
`(See Gadgets Webpage, “Google Now Gets Offline Voice-Command Support for Some Functions”)xviii
`
`BlackBerry Assistant allows you to turn off “full assistance mode” allowing for only simple local device
`operations such as dialing phone numbers. More complex commands require full assistance mode and require
`
`118961506-1
`
`13
`
`Page 13 of 21
`
`

`
`the use of BlackBerry, Google, and/or other Internet servers.
`
`2. The method of claim 1,
`wherein said at least one
`sentence comprises one
`or more keywords.
`
`(See BlackBerry Help Webpage, “Turn off full assistance mode”)xix
`Claim 2
`The content corresponding to Claim 1 is hereby incorporated by reference.
`
`BlackBerry Relevant Devices implementing Natural Language Search Features practice the method of claim 1,
`including wherein said at least one sentence comprises one or more keywords.
`
`5/20/2016
`
`3. The method of claim 1,
`wherein the first context
`comprises a natural
`language context.
`
`4. The method of claim 1,
`wherein the high-level
`code is contained in a
`script.
`
`5. The method of claim 4,
`wherein the script is
`written by a user of the
`mobile communication
`device.
`
`118961506-1
`
`For example, as explained above, Natural Language Search Features use natural language, such as spoken or
`written words or sentences, that are high-level code including keywords.
`Claim 3
`The content corresponding to Claim 1 is hereby incorporated by reference.
`
`The BlackBerry Relevant Devices implementing Natural Language Search Features practice the method of
`claim 1, wherein the first context comprises a natural language context. For example, as explained above, the
`first context may be in natural language voice or text.
`
`Claim 4
`The content corresponding to Claim 1 is hereby incorporated by reference.
`
`BlackBerry Relevant Devices implementing Natural Language Search Features practice the method of claim 1,
`wherein the high-level code is contained in a script. For example, the high-level code may be contained in
`written text which is script.
`
`Claim 5
`The content corresponding to Claim 4 is hereby incorporated by reference.
`
`BlackBerry Relevant Devices implementing Natural Language Search Features practice the method of claim 4,
`wherein the script is written by a user of the mobile communication device.
`
`Claim 6
`
`14
`
`Page 14 of 21
`
`

`
`5/20/2016
`
`6. A system for
`programming a mobile
`communication device
`based on a high-level
`code comprising
`operative language, the
`system comprising:
`
`Although the preamble to Claim 6 does not limit the scope of the claim, BlackBerry Relevant Devices and/or
`BlackBerry, Google, and/or other Internet servers implementing Natural Language Search Features are a
`system for programming a mobile communication device based on a high-level code comprising operative
`language as required by this claim.
`
`As explained in Claim 1, BlackBerry and/or users program BlackBerry Relevant Devices via Natural
`Language Search Features using natural language, such as spoken or written words, that are high-level code
`including operative language.
`
`The content corresponding to the preamble of Claim 1 is hereby incorporated by reference.
`
`means for receiving a
`high-level code
`comprising one or more
`keywords, wherein the
`high-level code is
`provided by a user of a
`mobile communication
`device to control the
`operation of the mobile
`communication device
`without having to select
`from menu items
`provided by an operating
`system running on the
`mobile communication
`device;
`
`means for parsing the
`high-level code for the
`
`The BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other Internet servers implementing
`Natural Language Search Features include means for receiving a high-level code comprising one or more
`keywords, wherein the high-level code is provided by a user of a mobile communication device to control the
`operation of the mobile communication device without having to select from menu items provided by an
`operating system running on the mobile communication device.
`
`The content corresponding to the “receiving a high-level code comprising . . . mobile communication device”
`element of Claim 1 is hereby incorporated by reference.
`
`IXI contends that this claim element is not governed by 35 U.S.C. §112(f). A person of ordinary skill in the
`art would immediately recognize the structure of this claim element.
`
`BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other Internet servers include communication
`interfaces, (e.g., antennae, modems, network cards, and/or transceivers) and/or user interfaces (e.g.,
`touchscreens, keyboards, microphones) for receiving the claimed high-level code. For example, BlackBerry
`Relevant Devices receive high-level code including one or more keyword through Natural Language Search
`Feature inquiries that a user inputs via a touchscreen, keyboard, or microphone. BlackBerry, Google, and/or
`other Internet servers receive the high-level code, depending on its complexity, via communication interfaces,
`such as antennae, modems, network cards, and/or transceivers, over wide area networks (e.g., cellular
`networks), wireless local area networks (e.g., Wi-Fi or Bluetooth networks), and/or the Internet.
`Natural Language Search Features on BlackBerry Relevant Devices and/or BlackBerry, Google, and/or other
`Internet servers include means for parsing the high-level code for the keywords to recognize the operative
`
`118961506-1
`
`15
`
`Page 15 of 21
`
`

`
`keywords to recognize
`the operative language
`associated with
`controlling one or more
`operations of the mobile
`communication device;
`
`5/20/2016
`
`language associated with controlling one or more operatio