EXHIBIT E[MARSHMALLOW]
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 1 of 63
`
`GOOGLE EXHIBIT 1025
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 1 of 63
`
`GOOGLE EXHIBIT 1025
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Below is a claim chart identifying specifically where each element of each asserted claim of U.S. Patent No. 9,516,127 is
`found within the Google ’127 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 ’127
`Marshmallow Accused Products.
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`10. A mobile device,
`comprising:
`
`The preamble is not limiting, but to the extent the preamble is found to be a limitation of this claim,
`the Accused Products are mobile devices.
`
`For example, the Google Nexus 6P is a mobile device.
`
`
`
`
`
`
`Page 1 of 62
`
`
`
`
`
`Page 2 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Google Nexus 6P Elegantly designed, pure Android, Google,
`https://www.google.com/nexus/6p/ (last visited Jul. 6, 2017).
`
`Additional Google smartphones and tablets are identified in Schedule G-M.
`
`a memory;
`
`The Accused Products include a memory.
`
`For example, the Google Nexus 6P has several memory configurations, including 32 GB, 64 GB, or
`128 GB of internal memory.
`
`
`See, e.g., Nexus tech specs, Nexus Help,
`https://support.google.com/nexus/answer/6102470?hl=en&ref_topic=3415518 (last visited Jul. 6,
`2017).
`
`The internal memory in the Google Nexus 6P is implemented using Samsung universal flash storage
`(shown in orange below).
`
`
`
`
`
`
`
`Page 2 of 62
`
`Page 3 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`See, e.g., Nexus 6P Teardown, iFixit, https://www.ifixit.com/Teardown/Nexus+6P+Teardown/51660
`(“Samsung KLMBG4END-B0-31 32 GB eMMC 5.0 NAND Flash” is indicated in orange) (last
`visited Jul. 7, 2017).
`
`The “Memory” column in Schedule G-M provides additional examples of memory included in the
`Accused Products.
`
`a processor in communication
`with the memory and
`configured to execute
`instructions stored in the
`memory to:
`
`Each of the Accused Products have a processor in communication with the memory and configured
`to execute instructions stored in the memory.
`
`For example, the Google Nexus 6P has a 2.0 GHz octa-core processor.
`
`
`
`
`
`
`Page 3 of 62
`
`Page 4 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`See, e.g., Nexus 6P – Google, Google, https://www.google.com/nexus/6p (last visited Jul. 6, 2017).
`
`The “Processor” column in Schedule G-M provides examples of processors used in the Accused
`Products.
`
`The processor in each of the Accused Products communicates with the memory and is configured to
`execute instructions stored in the memory, such as the Android operating system.
`
`For example, the random access memory for the Google Nexus 6P (Micron MTS3B384M64D4NK-
`062 3 GB LPDDR4RAM) is layered over its processor (Qualcomm Snapdragon 810). The processor
`is also located adjacent to the internal flash storage (Samsung KLMBG4GEND-B031 32 GB eMMC
`5.0 NAND Flash).
`
`
`
`
`
`Page 4 of 62
`
`Page 5 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`
`See, e.g., Nexus 6P Teardown, iFixit, https://www.ifixit.com/Teardown/Nexus+6P+Teardown/51660
`(“Samsung KLMBG4END-B0-31 32 GB eMMC 5.0 NAND Flash” is indicated in orange) (last
`visited Jul. 7, 2017).
`
`The internal memory of the Accused Products is used to store the operating system and software used
`to operate the features of the phone. The operating system stored in the Accused Products’ internal
`memory is Android Marshmallow. See, e.g., Nexus tech specs, Nexus Help,
`https://support.google.com/nexus/answer/6102470?hl=en&ref_topic=3415518 (last visited Jul. 6,
`2017).
`
`Additional Google smartphones and tablets that have been sold with or upgraded to Android M are
`identified in Schedule G-M.
`
`
`
`
`
`Page 5 of 62
`
`Page 6 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`enter a power save mode
`based on a backlight status
`and sensed motion of a
`mobile device;
`
`Infringement Contentions for Accused Products
`
`The Accused Products are configured, based on instructions stored in the memory, to enter a power
`save mode based on a backlight status and sensed motion of a mobile device.
`
`Android M features a power save mode, called Doze mode. By deferring content requests, the
`Accused Products reduce mobile radio usage, and the mobile devices “last[] up to two times longer in
`standby.” For example, Google demonstrated at its Google I/O 2015 Developer Conference how the
`Doze feature reduces sync activity (i.e. network traffic):
`
`
`
`
`With M, Android uses significant motion detection to learn if a device has been left
`unattended for an extended period of time. In that case, it will exponentially back off
`background activity to go into a deeper sleep state. So what we're doing is we're
`trading off a little bit of app freshness for longer battery life. And we call it dozing.
`
`
`
`
`
`
`
`Page 6 of 62
`
`Page 7 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`Because while the device is asleep, it's still possible for the device to trigger real time
`alarms or to respond to incoming chat requests through high priority messages. So
`how well does this work? Well, we took two Nexus 9s. And we put Lollipop on one
`and M on the other. And then we loaded both up with the same account and lots and
`lots of applications. We put the two devices side by side and measured power. And
`I'm happy to say that we're seeing devices with M lasting up to two times longer in
`standby.
`
`See, e.g., Google Developers, Google I/O 2015 Keynote, YouTube (May 28, 2015),
`https://www.youtube.com/watch?v=7V-fIGMDsmE.
`
`The Accused Products enter Doze mode based on a backlight status and sensed motion of the mobile
`device (e.g., if the device is stationary).
`
`
`
`See, e.g., Optimizing for Doze and App Standby, Android Developers,
`http://developer.android.com/training/monitoring-device-state/doze-standby.html (last visited Jul. 2,
`2017).
`
`To the extent that a “backlight status” is not literally present in the Accused Products, this limitation
`is met under the doctrine of equivalents in various ways. For example, evaluating display power state
`
`
`
`
`
`
`
`Page 7 of 62
`
`Page 8 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`in an Accused Product is equivalent to evaluating backlight status according to the claimed mobile
`device because it performs substantially the same function (determining mobile device screen
`brightness, including whether the mobile device screen is on or off) in substantially the same way
`(receiving an indication through the hardware abstraction layer of the screen brightness level or
`power state) to achieve substantially the same result (mapping the power state of the display
`hardware to one or more values, such as brightness level, “on,” or “off”).
`
`delay a timing of one or more
`triggers for multiple
`applications on the mobile
`device,
`
`The Accused Products are configured, based on instructions stored in the memory, to delay a timing
`of one or more triggers for multiple applications on the mobile device.
`
`The Accused Products use triggers, such as jobs, sync adapters, or system alarms, to help applications
`schedule work.
`
`
`
`
`
`
`Page 8 of 62
`
`Page 9 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Intelligent Job-Scheduling, Android Developers,
`https://developer.android.com/topic/performance/scheduling.html (last visited Jul. 11, 2017).
`
`For example, jobs can be used to schedule tasks to run at, or around, the same time based on specific
`conditions, such as network or idle conditions.
`
`
`
`
`
`
`
`
`Page 9 of 62
`
`Page 10 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`Id.
`
`In addition, system alarms trigger application code to run at a specific time.
`
`
`Id.
`
`For example, Alarm Manager allows alarms to be scheduled based on a particular trigger time.
`
`
`
`
`
`
`
`
`
`
`Page 10 of 62
`
`Page 11 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., AlarmManager, Android Developers,
`https://developer.android.com/reference/android/app/AlarmManager.html (last visited Jul. 7, 2017).
`
`Sync adapters may also be used to schedule tasks that sync data between a mobile device and a
`server.
`
`
`See, e.g., Intelligent Job-Scheduling, Android Developers,
`https://developer.android.com/topic/performance/scheduling.html (last visited Jul. 11, 2017).
`
`
`
`
`
`
`
`
`
`
`Page 11 of 62
`
`Page 12 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`The Accused Products are sold with multiple pre-installed applications that are associated with one or
`more triggers. For example, the Accused Products include Gmail and the Google App, which use
`alarms, jobs, or syncs to perform periodic tasks.
`
`While in Doze mode, the Accused Products are configured to delay a timing of one or more triggers
`for multiple applications on the mobile device. For example, Google’s developer documentation
`states that Doze mode “defers [applications’] jobs, syncs, and standard alarms.”
`
`
`See, e.g., Optimizing for Doze and App Standby, Android Developers,
`http://developer.android.com/training/monitoring-device-state/doze-standby.html (last visited Jul. 11,
`2017).
`
`While in Doze, alarms are deferred to the next maintenance window and sync adapters and jobs are
`not allowed to run.
`
`
`
`
`
`
`
`Page 12 of 62
`
`Page 13 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`Id.
`
`As set forth in Google’s developer materials referred to above, and further clarified in developer
`training videos, “Doze mode delays things like SyncAdapters, JobScheduler, and AlarmManager.”
`
`
`
`
`To achieve this, Doze mode delays things like SyncAdapters, JobScheduler, and
`AlarmManager so that they don’t burn through battery when the user isn't even on the
`device. But to be clear, Doze does not disable these services. They just get deferred to
`a later time.
`
`
`Joanna Smith, Android Marshmallow 6.0: Introduction to Doze Mode, YouTube (Sept. 29, 2015),
`https://www.youtube.com/watch?v= N72ksDKrX6c.
`
`wherein the timing is delayed The Accused Products are configured, based on instructions stored in the memory, to delay the
`
`
`
`
`
`Page 13 of 62
`
`Page 14 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`such that the triggers execute
`within a window of time,
`
`timing such that the triggers execute within a window of time.
`
`For example, the Accused Products are configured to defer the timing of jobs, alarms, and sync
`adapters, such that they execute within a maintenance window (shown below). During this
`maintenance window, the system runs all pending syncs, jobs, and alarms, and lets apps access the
`network.
`
`
`See, e.g., Optimizing for Doze and App Standby, Android Developers
`http://developer.android.com/training/monitoring-device-state/doze-standby.html (last visited Jul. 11,
`2017).
`
`
`
`wherein at least a subset of
`
`In the Accused Products, at least a subset of the triggers are associated with wakelocks.
`
`
`
`
`
`Page 14 of 62
`
`Page 15 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`the triggers are associated
`with wakelocks; and
`
`Infringement Contentions for Accused Products
`
`
`For example, at least a subset of the triggers include system alarms.
`
`
`See, e.g., AlarmManager, Android Developers,
`https://developer.android.com/reference/android/app/AlarmManager.html (last visited Jul. 7, 2017).
`
`System alarms are associated with wakelocks. For example, the Alarm Manager, which is a
`framework component that manages system alarms, holds a CPU wake lock as long as a particular
`alarm receiver’s onReceive() method is executing.
`
`
`
`
`
`
`
`
`Page 15 of 62
`
`Page 16 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., AlarmManager, Android Developers,
`https://developer.android.com/reference/android/app/AlarmManager.html (last visited Jul. 11, 2017).
`
`An individual application responding a trigger may also hold a separate wake lock policy to ensure
`that the phone continues running until a requested service becomes available.
`
`
`
`
`
`
`
`
`Page 16 of 62
`
`Page 17 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Keeping the Device Awake, Android Developers,
`https://developer.android.com/training/scheduling/wakelock.html (last visited Jul. 26, 2017).
`
`
`
`exit the power save mode
`when the backlight of the
`mobile device turns on or
`motion of the mobile device
`
`The Accused Products are configured, based on instructions stored in the memory, to exit the power
`save mode when the backlight of the mobile device turns on or the motion of the mobile device is
`sensed.
`
`
`
`
`
`
`Page 17 of 62
`
`Page 18 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`is sensed.
`
`The Accused Products are configured to exit Doze when the backlight of the mobile device turns on
`(i.e. screen turns on) or the motion of the mobile device is sensed (e.g., user wakes the device by
`moving it).
`
`
`
`
`
`See, e.g., Optimizing for Doze and App Standby, Android Developers,
`http://developer.android.com/training/monitoring-device-state/doze-standby.html (last visited Jul. 2,
`2017).
`
`To the extent that a “backlight” or “backlight status” is not literally present in the Accused Products,
`this limitation is met under the doctrine of equivalents in various ways. For example, evaluating
`display power state in an Accused Product is equivalent to evaluating backlight status according to
`the claimed mobile device because it performs substantially the same function (determining mobile
`device screen brightness, including whether the mobile device screen is on or off) in substantially the
`same way (receiving an indication through the hardware abstraction layer of the screen brightness
`level or power state) to achieve substantially the same result (mapping the power state of the display
`hardware to one or more values, such as brightness level, “on,” or “off”).
`
`11. The mobile device of
`claim 10, wherein the triggers
`include alarms.
`
`In the Accused Products, the triggers include alarms.
`
`As described above, the Accused Products are configured with system alarms that trigger application
`code to run at some point in the future.
`
`
`
`
`
`
`Page 18 of 62
`
`Page 19 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., AlarmManager, Android Developers,
`https://developer.android.com/reference/android/app/AlarmManager.html (last visited Jul. 11, 2017).
`
`The developer documentation for Android instructs that alarms may be scheduled based on a
`particular trigger time.
`
`
`
`
`
`
`
`
`Page 19 of 62
`
`Page 20 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`Id.
`
`
`
`12. The mobile device of
`claim 11, wherein the triggers
`initiate scheduled tasks that
`use a network resource on the
`mobile device.
`
`In the Accused Products, the triggers initiate scheduled tasks that use a network resource on the
`mobile device.
`
`Triggers, such as jobs, syncs, and alarms, initiate scheduled tasks that use a network resource, such as
`the radio, on the mobile device.
`
`For example, a repeating system alarm can be used “to trigger network operations,” such as syncing
`data with a server.
`
`
`
`
`
`
`Page 20 of 62
`
`Page 21 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Scheduling Repeating Alarms, Android Developers,
`https://developer.android.com/training/scheduling/alarms.html#tradeoffs (last visited Jan. 4, 2017).
`
`
`
` A
`
` sync adapter is another type of trigger that initiates scheduled tasks that use network resources in
`response to certain events, such as a new data message, user activity, or the time of day.
`
`
`
`
`Id.
`
` A
`
` sync adapter manages tasks that sync data between a mobile device, like any of the Accused
`Products, and a server.
`
`
`
`
`
`Page 21 of 62
`
`Page 22 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`
`See, e.g., Intelligent Job-Scheduling, Android Developers,
`https://developer.android.com/topic/performance/scheduling.html (Jan. 4, 2017).
`
`
`
` A
`
` job is another example of a trigger that initiates scheduled tasks that use a network resource on the
`mobile device. For example, the Job Scheduler can intelligently schedule network tasks, such as
`updating network resources and downloading information via the mobile radio.
`
`
`
`
`
`
`Page 22 of 62
`
`Page 23 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Intelligent Job-Scheduling, Android Developers,
`https://developer.android.com/topic/performance/scheduling.html (last visited Jan. 4, 2017).
`
`Job Scheduler allows a job’s requirements for network and timing to be specified when it is
`registered.
`
`
`
`
`
`
`
`Page 23 of 62
`
`Page 24 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Intelligent Job-Scheduling, Android Developers,
`https://developer.android.com/topic/performance/scheduling.html (Jan. 4, 2017).
`
`For example, the Job Scheduler may be instructed to run a job when a network (e.g., cellular or WiFi)
`or an unmetered network (e.g., WiFi) is available.
`
`
`
`
`
`
`
`Page 24 of 62
`
`Page 25 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., JobScheduler, Android Developers,
`https://developer.android.com/reference/android/app/job/JobScheduler.html (last visited Oct. 15,
`2015).
`
`
`
`
`
`
`
`Page 25 of 62
`
`Page 26 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`13. The mobile device of
`claim 12, wherein delaying
`the timing also optimizes the
`use of battery, CPU and
`memory resources.
`
`In the Accused Products, delaying the timing also optimizes the use of battery, CPU and memory
`resources.
`
`In Doze mode, the system attempts to conserve battery by restricting applications’ access to network
`and CPU-intensive services. For example, the system defers applications’ jobs, syncs, and standard
`alarms.
`
`
`See, e.g., Optimizing for Doze and App Standby, Android Developers,
`https://developer.android.com/training/monitoring-device-state/doze-standby.html (last visited Jul.
`11, 2017).
`
`Background tasks are allowed to run periodically during maintenance windows. However, over time,
`the system schedules maintenance windows less and less frequently.
`
`
`
`
`
`
`
`Page 26 of 62
`
`Page 27 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`Id.
`
`Thus, delaying the timing of triggers also optimizes the use of memory resources by reducing the
`number of times background tasks are run (fewer executions lead to less memory access).
`
`
`
`14. The mobile device of
`claim 11, wherein the triggers
`execute in alignment with
`each other.
`
`In the Accused Products, the triggers execute in alignment with each other.
`
`For example, while in Doze mode, syncs, jobs, and alarms, execute in alignment with each other
`during a maintenance window.
`
`
`
`
`
`
`Page 27 of 62
`
`Page 28 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Optimizing for Doze and App Standby, Android Developers
`http://developer.android.com/training/monitoring-device-state/doze-standby.html (last visited Jul. 11,
`2017).
`
`In addition, network tasks scheduled using the Android M framework may be deferred and batched
`together, such that they execute opportunistically during a single radio power-on event. For example,
`network tasks scheduled using AlarmManager or JobScheduler may be batched together in order to
`reduce the number of times the device needs to “wake up,” thus minimizing battery use.
`
`
`
`
`
`
`
`
`Page 28 of 62
`
`Page 29 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Alarm Manager, Android Developers,
`https://developer.android.com/reference/android/app/AlarmManager.html (last visited Jan. 4, 2017).
`
`Much like AlarmManager’s inexact alarms, Job Scheduler batches network calls into one call so that
`the mobile device avoids repeatedly paying the energy overhead associated with activating the
`mobile radio each time. For example, Google Project Manager, Megan Desai, stated:
`
`
`
`
`There’s a lot of legitimate times when you need to be connecting to the network or
`keeping a wake lock. So maybe you can coalesce a lot of these activities. If you have a
`lot of network calls in succession, you can group them together into one call, so you
`pay less of that overhead that we just talked about.
`
`
`Google Developers, Google I/O 2014 – Introduction to Project Volta, YouTube (Jun. 26, 2014),
`https://www.youtube.com/watch?v=KzSKIpJepUw.
`
`
`
`
`
`Page 29 of 62
`
`Page 30 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`
`Batching causes the triggers to execute in alignment, as evident from the bottom table in the figure
`below.
`
`
`
`Id.
`
`Google engineer, Matthew Williams, explained how the Android framework consolidates activations
`of the mobile radio by using deferral techniques made possible with the new Job Scheduler API.
`
`
`And let’s see what we got. So immediately, even from a layman’s perspective, the
`
`
`
`
`
`
`
`Page 30 of 62
`
`Page 31 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`bottom table is much cleaner. We don’t have nearly as many wakeups, which indicate
`that when the phone does wake up, you see the mobile network is active. So work is
`being done, and then it goes back to sleep at the end of that. Look at the shape of this
`mobile radio traffic at the bottom. It’s much more compact. There are much fewer of
`these boxes. So we’re paying much less of this overhead penalty per mobile radio
`active transition.
`
`
`Id.
`
`15. The mobile device of
`claim 10, wherein additional
`triggers from an application
`having triggers are not
`delayed.
`
`In the Accused Products, additional triggers from an application having triggers are not delayed.
`
`For example, certain types of triggers, such as an alarm using setExactAndAllowWhileIdle, are
`exempt from low-power idle modes (e.g., Doze) and therefore are not delayed.
`
`
`See, e.g., AlarmManager, Android Developers,
`https://developer.android.com/reference/android/app/AlarmManager.html (last visited Jul. 7, 2017).
`
`Another example of additional application triggers that are not delayed, are triggers from a
`whitelisted application that is “exempt from being subject to Doze.”
`
`
`
`
`
`
`
`
`Page 31 of 62
`
`Page 32 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Power Management, Android Open Source Project,
`https://source.android.com/devices/tech/power/mgmt.html#exempt-apps (last visited Jan. 4, 2017).
`
`Whitelisted applications can use the network and hold partial wake locks. During a partial wake lock,
`a whitelisted application can still respond to some triggers, such as a system broadcast, which are not
`deferred.
`
`However, applications on the Battery Optimizations exceptions whitelist are only partially exempted
`from Doze optimizations. Other triggers, such as jobs and syncs, are deferred and coalesced.
`
`
`
`
`
`
`
`
`Page 32 of 62
`
`Page 33 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`An app that is whitelisted can use the network and hold partial wake locks during
`Doze and App Standby. However, other restrictions still apply to the whitelisted app,
`just as they do to other apps. For example, the whitelisted app’s jobs and syncs are
`deferred (on API level 23 and below), and its regular AlarmManager alarms do not
`fire. An app can check whether it is currently on the exemption whitelist by calling
`isIgnoringBatteryOptimizations().
`
`Optimizing for Doze and App Standby, Android Developers,
`http://developer.android.com/training/monitoring-device-state/doze-standby.html (last visited Jan. 4,
`2017).
`
`In addition, the Accused Products include computer code for additional message-based triggers, such
`as Google Cloud Messaging (GCM) or Firebase Cloud Messaging (FCM). Depending on the priority
`of the message, delivery of the message (and the corresponding trigger) may be immediate or
`deferred.
`
`
`
`
`
`
`Page 33 of 62
`
`Page 34 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., About FCM, Google Firebase, https://firebase.google.com/docs/cloud-messaging/concept-
`options (last visited Jul. 2, 2017).
`
`Google Cloud Messaging and Firebase Cloud Messaging (which replaces GCM) are included in the
`Google Play Services APK.
`
`
`
`
`
`
`
`Page 34 of 62
`
`Page 35 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`Set Up Google Play Services, Google APIs for Android,
`https://developers.google.com/android/guides/setup#ensure_devices_have_the_google_play_services
`_apk (last visited Jul. 1, 2017).
`
`The Google Play services APK contains the individual Google services and runs as a background
`service in the Android OS. Applications interact with the background service through the client
`library and the service carries out the actions on each application’s behalf.
`
`
`
`
`
`
`
`Page 35 of 62
`
`Page 36 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`Overview of Google Play Services, Google APIs for Android,
`https://developers.google.com/android/guides/overview (last visited Jul. 1, 2017).
`
`
`
`
`
`
`
`
`Page 36 of 62
`
`Page 37 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`Id. at Figure 1.
`
`Upon information and belief, the Accused Products are sold with Google Play Services pre-installed.
`
`
`
`
`
`
`
`
`Page 37 of 62
`
`Page 38 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`16. The mobile device of
`claim 10, wherein to enter
`and exit the power save mode
`is further based on a charging
`status of the mobile device.
`
`See, e.g., Google Play Services: What it is and why you need it?, Updato.com,
`http://updato.com/android-apps/google-play-services-need (last visited Jul. 1, 2017).
`
`
`
`Entering and exiting the power save mode on the Accused Products is further based on a charging
`status of the mobile device.
`
`Android documentation explains that “Doze mode does not engage when the device is plugged into a
`power charger.” Power Management, Android Open Source Project,
`https://source.android.com/devices/tech/power/mgmt.html#exempt-apps (last visited Jan. 4, 2017).
`
`In addition, each of the Accused Products exit Doze mode if it is connected to a charger. Google
`states in its developer documentation, “As soon as the user wakes the device by moving it, turning on
`the screen, or connecting a charger, the system exits Doze and all apps return to normal activity.”
`Optimizing for Doze and App Standby, Android Developers,
`http://developer.android.com/training/monitoring-device-state/doze-standby.html (last visited Jan. 4,
`2017).
`
`17. A non-transitory
`
`The Accused Products have a non-transitory computer-readable storage medium storing instructions
`
`
`
`
`
`Page 38 of 62
`
`Page 39 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`computer-readable storage
`medium storing instructions
`that when executed by a
`processor causes the
`processor to:
`
`that may be executed by a processor.
`
`The Accused Products have internal memory used to store the Android Operating system and other
`system and user software.
`
`For example, the Google Nexus 6P has 32 GB, 64 GB, or 128 GB of internal memory.
`
`
`See, e.g., Nexus tech specs, Nexus Help,
`https://support.google.com/nexus/answer/6102470?hl=en&ref_topic=3415518 (last visited Jul. 6,
`2017).
`
`The internal memory in the Google Nexus 6P is implemented using universal flash storage (shown in
`orange below), which is a non-transitory computer readable medium.
`
`
`
`
`
`
`
`Page 39 of 62
`
`Page 40 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`Infringement Contentions for Accused Products
`
`See, e.g., Nexus 6P Teardown, iFixit, https://www.ifixit.com/Teardown/Nexus+6P+Teardown/51660
`(“Samsung KLMBG4END-B0-31 32 GB eMMC 5.0 NAND Flash” is indicated in orange) (last
`visited Jul. 7, 2017).
`
`The “Memory” column in Schedule G-M provides additional examples of non-transitory computer
`readable media included in the Accused Products.
`
`The internal memory of the Accused Products is used to store the operating system and software
`used to operate the features of the phone. The operating system stored in the Accused Products’
`internal memory is Android Marshmallow. See, e.g., Nexus tech specs, Nexus Help,
`https://support.google.com/nexus/answer/6102470?hl=en&ref_topic=3415518 (last visited Jul. 6,
`2017).
`
`Additional Google smartphones and tablets that have been sold with or upgraded to Android M are
`identified in Schedule G-M.
`
`
`
`
`
`Page 40 of 62
`
`Page 41 of 63
`
`
`
`EXHIBIT E[MARSHMALLOW]: INFRINGEMENT CONTENTIONS FOR U.S. PATENT NO. 9,516,127
`
`Claim Language
`
`enter a power save mode
`based on a backlight status
`and sensed motion of a
`mobile device;
`
`Infri
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
