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`Via Email (mshanahan@generalpatent.com)
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`December 8, 2016
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`Michael E. Shanahan
`Vice President & General Counsel
`General Patent Corporation
`Montebello Park
`75 Montebello Road
`Suffern, NY 10901-3746
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`Re:
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`Bradium Technologies LLC Patent Portfolio
`
`Dear Michael,
`
`I write to you to follow up on our recent conversations and respond to the presentation you pro-
`vided in your August 15, 2016 email to me. The presentation includes a claim chart asserting that
`claim 2 of U.S. Patent No. 7,139,794 covers Apple Maps. Your April 19, 2016 letter further asserts
`that the use of Apple Maps infringes Claims 1, 3, 4, 5, 6, 7, 9 and 12 of U.S. Patent No. 7,908,343,
`Claim 1 of the ‘794 patent, Claim 1 of U.S. Patent No. 9,253,239, and Claims 8 and 15 of U.S. Patent
`No. 8,924,506. However, you have not provided any claim charts or explanation of why you believe
`Apple infringes those claims.
`
`Apple respects the valid intellectual property rights of third parties. We have carefully considered
`the information you have provided, but as explained below we do not believe that a license is re-
`quired. This letter sets forth a high-level summary of our investigation, and we reserve any omitted
`non-infringement, invalidity, or other defenses in the interests of brevity.
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`As an initial matter, Bradium has asserted infringement against Microsoft, who then initiated Inter
`Partes Reviews (IPRs) for all four of the patents. Moreover, it is our understanding that the PTO has
`already instituted IPRs for the ‘794, ‘343, and ‘506 patents, and the IPR for the ‘239 patent is still un-
`der review by the PTO. We have reviewed the prior art cited by the IPRs and do not see how the
`claims of the patents identified by Bradium are distinguishable from the cited art. Therefore, we be-
`lieve the claims are invalid.
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`Aside from the prior art cited in the IPRs, there is a host of other invalidating prior art. For example,
`years before the Bradium patents, Eastman Kodak developed FlashPix technology in collaboration
`with Hewlett-Packard, Live Picture, Inc., and Microsoft to run on HP and other computers running,
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`
`
`Apple
`1 Infinite Loop, MS 169-3IPL
`Cupertino, CA 95014
`T 408 862-1377
`E jlasker@apple.com
`www.apple.com
`
`Bradium Exhibit 2050
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 1 of 3
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`among others, the Windows OS. FlashPix was a well-known image format for presenting high reso-
`lution images to viewers over the Internet, as well as for desktop applications. In 1996, more than 4
`years before the earliest claimed priority date of the Bradium patents, Eastman Kodak published a
`specification (“FlashPix Format Specification Version 1.0”) and a White Paper (“FlashPix format and
`Architecture White Paper”) describing the technology. Both are attached herein.
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`As stated in the White Paper, “FlashPix files are stored at multiple independent resolutions” where
`“each resolution is sub-divided into square tiles.” White Paper, p. 16. The FlashPix technology in-
`cluded update image parcels that comprised an array of tiles for each of several independent image
`resolutions. FlashPix files were also designed to be accessed over the Internet (“The FlashPix format
`will enable interactive Web pages that provide rapid pans, zooms, and access to images for display
`or high-resolution printing”), which resulted in issuing requests to a server for update image parcels
`and receiving, and displaying them.
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`On the server, the image tiles are processed to obtain a series of K1-N of derivative images of pro-
`gressively lower image resolution:
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`The hierarchy is created by starting with the highest resolution level, determined by
`the resolution level(s) of the capture device. To create each consecutive lower level in
`the hierarchy, FlashPix-optimized applications and peripherals decimate the image in
`half vertically and horizontally. The hierarchy stops when the image can be fully repre-
`sented in a single tile, 64 pixels square.
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`White Paper, p. 20. As stated, each resolution differs from the higher by a power of 2, and each tile
`size is 64x64 pixels. Additionally, the White Paper discloses use of JAVA and Netscape Navigator
`plug-ins for displaying images in FlashPix format. Id. at 19.
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`The White Paper further describes that each FlashPix parcel may be compressed (optional JPEG or
`color compression), and the array of tiles can be independent of the pixel resolution. Id. at 22. The
`systems described in the White Paper could be implemented using HP computers, which were
`known to run Windows OS and Netscape Navigator, and all of which were multi-threaded machines,
`operating systems, and/or browsers.
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`The above-mentioned art demonstrates that the technology claimed in the patents identified by
`Bradium was well known in the art, thus rendering those patents invalid.
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`2
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`Bradium Exhibit 2050
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 2 of 3
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`For at least the exemplary reasons set forth above, Apple does not believe that a license is required.
`If you disagree, please provide us with a detailed explanation of how the claims of the patents have
`applicability to any Apple product or service, and how the patents are not invalid over the prior art.
`Absent further information from you, we will consider this matter closed.
`
`Sincerely,
`
`
`Jeffrey V. Lasker
`Senior Counsel, IP Transactions
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`3
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`Bradium Exhibit 2050
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 3 of 3
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