Bradium Techs. LLC v. Microsoft Corp, No. 15-cv-3 l-RGA (D. Del.)
`INITIAL CLAIM CHART. PURSUANT TO SCHEDULING ORDER (D.I. 43, l.e)
`
`Microsoft Bing Mapsa Bing Search: and Bing Maps Preview
`
`1
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`Ref.
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`1
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`US. Patent No.
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`7,908,343
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`2
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`MicrosoftBing Maps, Bing Search, and Bing Maps Prevrew
`
`A method of retrieving
`large-scale images over
`network
`communications
`
`As explained below, Bing Maps, operating on an Android device, such as a smart phone,
`requests, receives, and displays Bing Maps map tiles based on a user’s image viewpoint.
`Fruther. as explained below, Microsoft sewers process Bing Maps map tiles in an infringing
`manner.
`
`256 x 256 Pixels (required)
`
`channels for display on
`
`commrmication
`bandwidth computer
`device, said method
`
`comprising:
`
`To the extent the preamble is limiting,3 Bing Maps as accessed via, for example. an Android
`device provides a method of retrieving large-scale images over network communications
`channels for display on a limited cormmmication bandwidth computer device.
`
`Bing Maps provides and displays, for example, a world map that users can directly
`manipulate and zoom. E.g., Joe Schwartz, Bing Maps Tile System, MICROSOFT,
`https://msdn.microsofi.com/en-us/library/bb259689.aspx (last visited Apr. 29. 2016) (“Bing
`Maps Tile Svstem”).
`
`Folders, Tiles, and File Size by Zoom Level
`for a Sample Bing Maps Custom Tile Layer
`(1m Orthoimage Mosaic of a US State)
`(see Technical Guroe entitled
`filesets Understanding Sizes;
`Source image size:
`352 GB (uncompressed)
`Image area:
`109,185 square kilometers
`Tile Size;
`Tile Formats:
`
`JPEG o PNG for edgetlles
`
`1 These charts are initial claim charts. Bradium is engaged in ongoing discovery and reserves the right to supplement or amend these charts as the case develops.
`Microsoft has yet to provide any version information on the accused products. despite Bradium's requests served on February 9. 2016. Microsoft has further
`provided inadequate core technical documents to describe the functionality of all of the Accused Products. Bradium has not yet had an opportunity to review
`H
`I“o‘=c
`II‘.‘O“
`
`
`
`2 This chart uses an Android device for exemplary purposes. but the chart also applies to all other implementations of the Accused Products during the damages
`period. including without limitation all versions of Bing Maps as accessed. for example. on an Android. iOS. Windows. or other mobile device. all versions of
`Bing Search. including. for example as an application or website on an Android. iOS. Windows. or other mobile device. and all versions of the Bing Maps
`Preview app, operating, for example, as a Microsofi Windows application. This chart includes the Accused Products operating as a first party website or
`application and as operating through the website or application of a Microsoft customer who has contracted to use Bing Maps. for example by using a Bing Maps
`API or registerin as a b2b Bin Ma 5 client.
`
`Microsoft Corp. Exhibit 1072
`
`

`

`Bradimn Techs. LLC v. Microsoft Corp, No. 15-cv-31-RGA (D. Del.)
`INITIAL CLAIM CHART, PURSUANT TO SCHEDULING ORDER (D.I. 43. l.e)
`
`1;: Claim
`
`U'%;;;3113N0'
`
`Microsoft Bing Maps, Bing Search, and Bing Maps Preview2
`
`multi-threading on the
`computer device using
`the update data parcel to
`display the image.
`
`For example, based on packet capture of a web browser accessing Bing Maps, multiple
`threads appear to be imming at a time to request and process update packets. Multiple
`requests are sent before any data is returned or rendered.
`
`
`
`Further, the Android operating system, for example, supports multithreading. E.g. , Sending
`Operations to Multiple Threads, Android, http://developer.android.com/training/multiple-
`threads/index.html.
`
`13
`
`A display system for
`displaying a large-scale
`image retrieved over a
`
`said display
`system comprising:
`
`To the extent the preamble is limiting, a display system (for example on an Android device)
`in combination with Bing Maps provides a system for displaying large-scale images
`retrieved over limited bandwidth communications channels. Microsoft induces
`infiingement of this system because Microsoft has intended, and continues to intend, to
`cause end users to use at least Bing Maps in a manner covered by one or more claims of the
`’343 patent.
`
`Bing Maps provides and displays, for example, a world map that users can directly
`manipulate and zoom. E.g, Joe Schwartz, Bing Maps Tile Svstem, MICROSOFT,
`https://msdn.microsoft.com/en-us/library/be59689.aspx (last Visited Apr. 29, 2016) (“Bing
`Maps Tile Svsrem”).
`
`Folders. Tiles, and File Size by Zoom Level
`for a Sample Bing Maps Custom Tile Layer
`(1-m Orthoimage Mosaic of a US State)
`(see Technical Gunde entitled
`Vilesets Understanding SIZES]
`Source image size:
`352 GB (uncompressed)
`
`Image area:
`Tile Size:
`
`109,185 square KllOfl‘lElEfS
`256 x 256 Pixels (required)
`
`Tile Formats:
`
`JPEG o PNG tor edge tiles
`
`See also, e.g., MSFT-BRAD-000103l at 3 (0001033) (appearing to show image data size
`for a sample source image of the United States).
`
`Microsoft provides and displays Bing Maps through, for example, a web browser for use on
`
`a user computing device such as an Android device connected to a network communication
`
`Microsoft Corp. Exhibit 1072
`
`

`

`Bradium Techs. LLC v. [Microsoft Corp.. No. lS-cv—3 l-RGA (D. Del.)
`INITIAL CLADVI CHART. PURSUANT TO SCHEDULING ORDER (D.I. 43. 1.e)
`
`Ref.
`.
`No. Claim
`
`US. Patent No.
`7,908,343
`
`.
`.
`.
`.
`.
`Microsoft Bing Maps, Bing Search, and Bmg Maps Prev1ew
`channel such as, for example, the Internet.
`L11”
`
`2
`
`0 wwwhlng cum
`
`
`
`5‘0 01m
`
`Brooklyn
`
`Goveruws
`Island
`
`0
`
`.
`
`., Screen Ca t1u‘e showing wwwbin
`
`Microsoft Corp. Exhibit 1072
`
`