throbber
EXHIBIT A[LOLLIPOP]
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`GOOGLE EXHIBIT 1036
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`

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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Below is a claim chart identifying specifically where each element of each asserted claim of U.S. Patent No. 8,811,952 is
`found within the Google ’952 Lollipop Accused Products (also referred to in this chart as “Accused Products”). All references to
`specific products—including the Google Lollipop products described in Schedule G-L, and their corresponding features—are merely
`exemplary in nature. Accordingly, neither the claim chart nor the contentions are limited to just those specific examples provided in
`the chart and Schedule G-L. Rather, the claim chart is representative of the contentions as to all of the Google ’952 Lollipop Accused
`Products.
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`26. A mobile device located
`in a mobile network,
`comprising:
`
`The preamble is not limiting, but to the extent that it is determined to be a limitation of this claim, the
`Accused Products are mobile devices located in a mobile network.
`
`Each of the exemplary Accused Products identified in Schedule G-L are mobile devices.
`
`As an example, the Nexus 6 smartphone is a mobile device.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`See, e.g., Motorola Nexus 6 Unlocked 32GB, Amazon, https://www.amazon.com/Motorola-
`Unlocked-Cellphone-Midnight-Warranty/dp/B00R1984DI/ref=sr_1_1?tag=at88-
`20&s=wireless&ie=UTF8&qid=1441364563&sr=1-
`1&keywords=nexus+6&pebp=1441364568202&perid=1WFEYBJPEA6K1P3GH9HG (last visited
`July 8, 2017).
`
`As another example, the Nexus 9 tablet is a mobile device.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Google Nexus 9 Specs and Reviews, HTC, http://www.htc.com/us/tablets/nexus-9 (last
`visited July 8, 2017).
`
`The Accused Products are located in a mobile network (e.g., cellular network, WiFi network, etc.).
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`The “Network” column in Schedule G-L provides an identification of the network operability for
`certain exemplary Accused Products.
`
`As an example, the Nexus 6 smartphone supports/is compatible with a variety of cellular networks,
`including GSM, WCDMA, and LTE.
`
`
`See, e.g., Nexus 6 review: Google goes all-in, Android Authority,
`http://www.androidauthority.com/nexus-6-review-566046 (last visited July 8, 2017).
`
`As another example, the Nexus 9 tablet is compatible with LTE cellular networks.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`See, e.g., Google Nexus 9 Specs and Reviews, HTC, http://www.htc.com/us/tablets/nexus-9 (last
`visited July 8, 2017).
`
`In addition, many Accused Products support/are compatible with WiFi.
`
`For example, the Nexus 6 smartphone is compatible with the 802.11 a/b/g/n/ac WiFi standards.
`
`
`See, e.g., Nexus 6 review: Google goes all-in, Android Authority,
`http://www.androidauthority.com/nexus-6-review-566046 (last visited July 8, 2017).
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`As another example, the Nexus 9 tablet is compatible with WiFi networks.
`
`
`a processor configured to:
`
`
`See, e.g., Google Nexus 9 Specs and Reviews, HTC, http://www.htc.com/us/tablets/nexus-9 (last
`visited July 8, 2017).
`
`
`The Accused Products have a processor.
`
`The “Processor” column in Schedule G-L provides an identification of the processor included in
`certain exemplary Accused Products.
`
`As an example, the Nexus 6 smartphone has a 2.5GHz Qualcomm Snapdragon 805, quad-core
`processor.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Nexus 6 review: Google goes all-in, Android Authority,
`http://www.androidauthority.com/nexus-6-review-566046 (last visited July 8, 2017).
`
`As another example, the Nexus 9 tablet has a 2.3GHz NVIDIA Tegra K1 processor.
`
`
`
`
`exchange transactions with a
`client operating in a network
`through a connection
`provided through a server
`coupled to the client;
`
`
`See, e.g., Google Nexus 9 Specs and Reviews, HTC, http://www.htc.com/us/tablets/nexus-9 (last
`visited July 8, 2017).
`
`
`The Accused Products include a processor configured to exchange transactions with a client
`operating in a network through a connection provided through a server coupled to the client.
`
`Each of the exemplary Accused Products identified in Schedule G-L were sold with or upgraded to
`the Android Lollipop operating system.
`
`For example, the Nexus 6 smartphone includes the Android Lollipop operating system.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Nexus 6 review: Google goes all-in, Android Authority,
`http://www.androidauthority.com/nexus-6-review-566046 (last visited July 8, 2017).
`
`As another example, the Nexus 9 tablet includes the Android Lollipop operating system.
`
`
`
`
`
`See, e.g., Google Nexus 9 Specs and Reviews, HTC, http://www.htc.com/us/tablets/nexus-9 (last
`visited July 8, 2017).
`
`The Accused Products, with Android Lollipop operating system, include several built-in software
`applications for which the processor is configured to exchange transactions with a client operating in
`a network through a connection provided through a server coupled to the client. As an example, the
`Accused Products include the Google Gmail application.
`
`For example, the Nexus 6 smartphone includes several built-in software applications such as the
`Google Gmail application.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Nexus 6 review: Google goes all-in, Android Authority,
`http://www.androidauthority.com/nexus-6-review-566046 (last visited July 8, 2017).
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`
`
`See, e.g., Nexus 6 User Manual, GSM Arc, http://www.gsmarc.com/motorola/nexus-6/manual (last
`visited July 25, 2017).
`
`
`As another example, the Nexus 9 tablet includes several built-in software applications such as the
`Google Gmail application.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Google Nexus 9 Specs and Reviews, HTC, http://www.htc.com/us/tablets/nexus-9 (last
`visited July 8, 2017).
`
`The Accused Products exchange transactions with a client through a connection provided by a server.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`The Accused Products exchange transactions with a client through a connection provided by a server.
`For example, the Accused Products exchange transactions relating to the Gmail application with
`clients, such as the Gmail software running on Google servers. These transactions are routed through
`a variety of servers, such as servers in the network or in Google’s infrastructure.
`
`
`See, e.g., Google Architecture – Breaking it Open, Aditi Technologies,
`https://www.slideshare.net/AditiTechnologies/google-architecture-breaking-it-
`open?next_slideshow=1 (last visited July 24, 2017).
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`
`See, e.g., Google Architecture – Breaking it Open, Aditi Technologies,
`https://www.slideshare.net/AditiTechnologies/google-architecture-breaking-it-
`open?next_slideshow=1 (last visited July 24, 2017).
`
`For example, Google servers have a Redhat Linux-based software (identified below as RHEL 2.6 x
`PAE) running on the servers.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`See, e.g., Google Architecture – Breaking it Open, Aditi Technologies,
`https://www.slideshare.net/AditiTechnologies/google-architecture-breaking-it-
`open?next_slideshow=1 (last visited July 24, 2017).
`
`
`automatically send
`synchronization requests
`
`The Accused Products include a processor configured to automatically send synchronization requests
`from the mobile device to the network on a periodic basis; wherein, the periodicity of the
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
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`from the mobile device to the
`network on a periodic basis;
`wherein, the periodicity of
`the synchronization requests
`occur at a frequency
`determined according to
`remaining battery power on
`the mobile device;
`
`synchronization requests occur at a frequency determined according to remaining battery power on
`the mobile device.
`
`For example, the Accused Products, with the Android Lollipop operating system, automatically send
`synchronization requests relating to the Gmail application from the mobile device to the network on a
`periodic basis.
`
`As one example, the Google Nexus 6 smartphone can automatically send synchronization requests
`relating to the Gmail application from the mobile device to the network every 15 minutes.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Motorola Nexus 6 Simulator, Verizon Wireless,
`https://www.verizonwireless.com/simulator/Google/nexus_6_mm/index.php#FEATURE_EMAIL_P
`ERSONAL (last visited July 10, 2017).
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`The Gmail application on each of the Accused Products, including the Google Nexus 9 tablet,
`operates in substantially the same manner as described above because the Google Gmail application
`operates in substantially the same manner on all Google mobile devices with Android Lollipop
`operating system.
`
`Generally, synchronization—the process of causing information to remain identical in more than one
`location—can be accomplished in two ways: “push” and “sync” (aka “pull”). The difference between
`“push” and “sync” or “pull” is well known in the industry.” See, e.g., P. Bellavista et al., The
`Handbook of Mobile Middleware, Auerbach Publications (2007) (“In the server push model, the
`server periodically initiates and synchronizes with mobile clients…In the client pull model, a client
`specifically requests synchronization from a server.”); see also, “Sync Push” vs. “Sync Pull” vs.
`“Sync Pull Notify”, IBM, https://www.ibm.com/support/knowledgecenter/en/SSPK3V_7.0.0/
`com.ibm.swg.im.soliddb.replication.doc/doc/push.vs.pull.vs.pullnotify.html (last visited July 19,
`2017) (confirming that the “pull” approach is that the replica requests the data and that the “push”
`approach is that the master sends the data to the replica at a time chosen by the master). Thus, the
`“sync frequency” setting on the Gmail application refers to the frequency at which synchronization
`requests are sent from the mobile device to the network relating to the Gmail application.
`
`The periodicity of the synchronization requests from the Accused Products occur at a frequency
`determined according to remaining battery power on the mobile device.
`
`As one example, the Accused Products include “battery saver” mode. When the Accused Products
`enter “battery saver” mode, background synchronization requests are blocked. As a result, the
`periodicity of synchronization requests from the Accused Products is reduced.
`
`For example, the Nexus 6 smartphone includes “battery saver” mode.
`
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`See, e.g., How to turn power saving mode on and off on my Motorola Nexus 6, Bell,
`http://support.bell.ca/Mobility/Smartphones_and_mobile_internet/Nexus-
`6.how_to_turn_power_saving_mode_on_and_off_on_my (last visited July 10, 2017).
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`See, e.g., Nexus 6 User Manual, GSM Arc, http://www.gsmarc.com/motorola/nexus-6/manual (last
`visited July 10, 2017).
`
`As another example, the Nexus 9 tablet includes “battery saver mode.”
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., First 15 things you should do with the Nexus 9, Phandroid,
`http://phandroid.com/2014/11/17/nexus-9-tips-and-tricks/ (last visited July 25, 2017).
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Nexus 9 Tips and Tricks, Android Authority, http://www.androidauthority.com/nexus-9-
`tips-tricks-584050 (last visited July 10, 2017).
`
`The “battery saver mode” on the Accused Products can turn on automatically based on the remaining
`battery power.
`
`For example, the “battery saver mode” on the Google Nexus 6 smartphone can turn on automatically
`based on remaining battery power.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Use battery saver mode - Nexus Help, Google,
`https://support.google.com/nexus/answer/6187458?hl=en&ref_topic=6126554 (last visited July 7,
`2017).
`
`As another example, the “battery saver mode” on the Google Nexus 9 tablet can turn on
`automatically based on remaining battery power.
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., First 15 things you should do with the Nexus 9, Phandroid,
`http://phandroid.com/2014/11/17/nexus-9-tips-and-tricks/ (last visited July 25, 2017).
`
`When the Accused Products enter “battery saver mode,” the frequency of background tasks such as
`automatically synchronizing applications is reduced. For example, in “battery saver mode,” the
`Gmail application will not automatically synchronize on a periodic basis. Instead, the user must open
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`the application in order to synchronize.
`
`For example, “battery saver mode” limits device performance and restricts location services and
`most background data. “Email, Messages, and other apps that rely on syncing may not be updated
`unless you open them.”
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`See, e.g., How to turn power saving mode on and off on my Motorola Nexus 6, Bell,
`http://support.bell.ca/Mobility/Smartphones_and_mobile_internet/Nexus-
`6.how_to_turn_power_saving_mode_on_and_off_on_my (last visited July 10, 2017).
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., First 15 things you should do with the Nexus 9, Phandroid,
`http://phandroid.com/2014/11/17/nexus-9-tips-and-tricks/ (last visited July 25, 2017).
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Use battery saver mode - Nexus Help, Google,
`https://support.google.com/nexus/answer/6187458?hl=en&ref_topic=6126554 (last visited July 7,
`2017).
`
`The Accused Products include the Android Lollipop operating system. In the power save mode that is
`part of the Android Lollipop operating system, “applications should reduce their functionality in
`order to conserve battery as much as possible.”
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., PowerManager, Android Developers, https://developer.android.com/reference/android/
`os/PowerManager.html (last visited July 2, 2017).
`
`The following exemplary source code confirms that for the Accused Products, with Android Lollipop
`operating system, background synchronization requests are blocked when the device enters Power
`Save Mode. As a result, the periodicity of the synchronization requests is reduced based on the
`remaining battery power on the mobile device. For example, the “powerManagerService” class
`makes the “updateLowPowerModeLocked” call when the battery level falls below a threshold.
`
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`Claim Language
`
`Infringement Contentions for Accused Products
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`PowerManagerService.java, Google Git, at lines 675-713,
`https://android.googlesource.com/platform/frameworks/base/+/android-
`5.0.0_r1/services/core/java/com/android/server/power/PowerManagerService.java (last visited
`August 25, 2017).
`
`When low power mode is entered, network access for background applications is disabled.
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`NetworkPolicyManagerService.java, Google Git, at lines 1993-2040,
`https://android.googlesource.com/platform/frameworks/base/+/android-
`5.0.0_r1/services/core/java/com/android/server/net/NetworkPolicyManagerService.java (last visited
`August 25, 2017).
`
`The “mRestrictPower” variable above is set to “mPowerManagerInternal” in the “systemReady”
`function.
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`Claim Language
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`Infringement Contentions for Accused Products
`
`and exchange
`synchronization
`communications with the
`client over the connection
`after sending each
`synchronization request.
`
`Id. at 372.
`
`
`
`
`The Accused Products include a processor configured to exchange synchronization communications
`with the client over the connection after sending each synchronization request.
`
`For example, the Accused Products, such as the Nexus 6 smartphone and Nexus 9 tablet, exchange
`synchronization communications with the Gmail client over a connection after sending a Gmail
`synchronization request.
`
`After a synchronization request is sent to the Gmail client, synchronization communications related
`to the Gmail application are exchanged between the Accused Products and the Gmail client over the
`connection. This occurs, for example, when the Accused Products download a new email from the
`Gmail client.
`
`For example, the Accused Products exchange synchronization communications related to the Gmail
`application with the Gmail client over the connection when the Gmail application makes the GET
`userId/history call.
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Gmail API Reference, Google Developers, https://developers.google.com/gmail/api/
`v1/reference (last visited July 2, 2017).
`
`The Gmail application can be synchronized via a “full synchronization” or a “partial
`synchronization.”
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Synchronizing Clients with Gmail, Google Developers,
`https://developers.google.com/gmail/api/guides/sync (last visited July 19, 2017).
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`
`See, e.g., Synchronizing Clients with Gmail, Google Developers,
`https://developers.google.com/gmail/api/guides/sync (last visited July 19, 2017).
`
`
`
`
`27. The mobile device of
`claim 26, wherein, the
`synchronization request from
`the mobile device to the
`client is in response to a
`received synchronization
`trigger.
`
`
`The Accused Products comprise the mobile device of claim 26, wherein the synchronization requests
`from the mobile device to the client are in response to a received synchronization trigger.
`
`For example, the Accused Products, such as the Nexus 6 smartphone and Nexus 9 tablet, send
`synchronization requests from the mobile device to the Gmail client related to the Gmail application
`in response to a received synchronization trigger.
`
`As one example, the Accused Products send a synchronization request relating to the Gmail
`application to the Gmail client when a user opens the Gmail application and pulls down from the top
`of the inbox.
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Change your Gmail settings, Google Support, https://support.google.com/mail/answer/
`6562?hl=en&ref_topic=3394219&co=GENIE.Platform%3DAndroid&oco=1 (last visited July 2,
`2017).
`
`As another example, the Accused Products can send synchronization requests related to the Gmail
`application from the mobile device to the network on a periodic basis (e.g., every 15 minutes). When
`this period of time lapses, an alarm (trigger) causes the Accused Products to send a synchronization
`request from the mobile device to the Gmail client.
`
`
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Motorola Nexus 6 Simulator, Verizon Wireless,
`https://www.verizonwireless.com/simulator/Google/nexus_6_mm/index.php#FEATURE_EMAIL_P
`ERSONAL (last visited July 10, 2017).
`
`
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`
`28. The mobile device of
`claim 26, wherein, the mobile
`device synchronizes more
`frequently when a larger
`amount of battery power is
`remaining compared to when
`a smaller amount of battery
`power is remaining.
`
`The Accused Products comprise the mobile device of claim 26, wherein the mobile device
`synchronizes more frequently when a larger amount of battery power is remaining compared to when
`a smaller amount of battery power is remaining.
`
`For example, the Accused Products, such as the Nexus 6 smartphone and Nexus 9 tablet, include a
`“battery saver mode.” As described in more detail above, the Accused Products enter “battery saver
`mode” when the remaining battery power drops below a certain level (such as 5% or 15%).
`
`
`See, e.g., Use battery saver mode - Nexus Help, Google,
`https://support.google.com/nexus/answer/6187458?hl=en&ref_topic=6126554 (last visited July 7,
`2017).
`
`
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`
`See, e.g., First 15 things you should do with the Nexus 9, Phandroid,
`http://phandroid.com/2014/11/17/nexus-9-tips-and-tricks/ (last visited July 25, 2017).
`
`As discussed in more detail above, “battery saver mode” conserves battery power by limiting CPU
`performance. One way it does so is to reduce the frequency of background synchronization requests
`
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`by applications, including the Gmail application.
`
`For example, “battery saving mode” restricts “location services and most background data.” “Email,
`Messages, and other apps that rely on syncing may not be updated unless you open them.” In other
`words, the Accused Products synchronize more frequently when a larger amount of battery power is
`remaining (not in battery saving mode) than when a smaller amount of battery power is remaining (in
`battery saving mode).
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`See, e.g., How to turn power saving mode on and off on my Motorola Nexus 6, Bell,
`http://support.bell.ca/Mobility/Smartphones_and_mobile_internet/Nexus-
`6.how_to_turn_power_saving_mode_on_and_off_on_my (last visited July 10, 2017).
`
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., First 15 things you should do with the Nexus 9, Phandroid,
`http://phandroid.com/2014/11/17/nexus-9-tips-and-tricks/ (last visited July 25, 2017).
`
`
`
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Use battery saver mode - Nexus Help, Google,
`https://support.google.com/nexus/answer/6187458?hl=en&ref_topic=6126554 (last visited July 7,
`2017).
`
`In the power save mode that is part of the Android Lollipop operating system, “applications should
`reduce their functionality in order to conserve battery as much as possible.”
`
`
`
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
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`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., PowerManager, Android Developers, https://developer.android.com/reference/android/
`os/PowerManager.html (last visited July 2, 2017).
`
`Thus, the Accused Products synchronize more frequently when a larger amount of battery power is
`remaining compared to when a smaller amount of battery power is remaining.
`
`
`
`
`The Accused Products comprise the mobile device of claim 26, wherein the mobile device identifies
`or determines its remaining battery power.
`
`The Accused Products, such as the Nexus 6 smartphone and Nexus 9 tablet, identify/determine
`remaining battery power.
`
`For example, the Nexus 6 smartphone includes a battery percentage feature that displays “the battery
`charge percentage next to the battery icon on the Status bar” of phone’s display.
`
`
`30. The mobile device of
`claim 26, wherein, the mobile
`device identifies or
`determines its remaining
`battery power.
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`See, e.g., Nexus 6 User Manual, GSM Arc, http://www.gsmarc.com/motorola/nexus-6/manual (last
`visited July 10, 2017).
`
`As another example, the Nexus 9 tablet includes a battery percentage feature that displays the battery
`charge percentage to the user, for example, on the “Battery” settings page.
`
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., First 15 things you should do with the Nexus 9, Phandroid,
`http://phandroid.com/2014/11/17/nexus-9-tips-and-tricks/ (last visited July 25, 2017).
`
`
`
`
`
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`EXHIBIT A[LOLLIPOP]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`Each of the Accused Products include the Android Lollipop operating system. The Android Lollipop
`operating system provides functionality for determining the current battery level.
`
`
`See, e.g., Monitoring the Battery Level and Charging State, Android Developers,
`https://developer.android.com/training/monitoring-device-state/battery-monitoring.html (last visited
`July 2, 2017).
`
`As another example, the “power saving mode” on the Accused Products can turn on automatically
`based on the remaining battery power, as described in more detail above with respect to claim 26. As
`a result, the Accused Products identify or determine the remaining battery power.
`
`
`
`Page 47 of 47
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`
`
`
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`EXHIBIT A[MARSHMALLOW]
`EXHIBIT A[MARSHMALLOW]
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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`EXHIBIT A[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Below is a claim chart identifying specifically where each element of each asserted claim of U.S. Patent No. 8,811,952 is
`found within the Google ’952 Marshmallow Accused Products (also referred to in this chart as “Accused Products”). All references to
`specific products—including the Google Marshmallow products described in Schedule G-M, and their corresponding features—are
`merely exemplary in nature. Accordingly, neither the claim chart nor the contentions are limited to just those specific examples
`provided in the chart and Schedule G-M. Rather, the claim chart is representative of the contentions as to all of the Google ’952
`Marshmallow Accused Products.
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`26. A mobile device located
`in a mobile network,
`comprising:
`
`The preamble is not limiting, but to the extent that it is determined to be a limitation of this claim, the
`Accused Products are mobile devices located in a mobile network.
`
`Each of the exemplary Accused Products identified in Schedule G-M are mobile devices.
`
`As an example, the Google Nexus 5X smartphone is a mobile device.
`
`
`
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`EXHIBIT A[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`See, e.g., Nexus 5X – Google, Google, https://www.google.com/nexus/5x/ (last visited July 25, 2017).
`
`
`
`
`
`Page 2 of 50
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`EXHIBIT A[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`As another example, the Nexus 9 tablet is a mobile device.
`
`
`
`See, e.g., Google Nexus 9 Specs and Reviews, HTC, http://www.htc.com/us/tablets/nexus-9 (last
`visited July 8, 2017).
`
`The Accused Products are located in a mobile network (e.g., cellular network, WiFi network, etc.).
`
`
`
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`EXHIBIT A[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 8,811,952
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`The “Network” colu

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