Case 1:12-Cv—01598-UNA Document 1 Filed 11/29/12 Page 1 of 14 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`ARENDI S.A.R.L.,
`
`Plaintiff,
`
`v,
`
`C.A. N0.
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA,
`INC, SAMSUNG TELECOMlVIUNICATIONS
`AMERICA, LLC
`
`Defendants.
`
`:
`
`JURY TRIAL DEMANDED
`
`COMPLAINT
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`Plaintilf Arendi S.A.R.L.
`
`(“Arendi”) for its Complaint against Defendants hereby-
`
`demands a jury trial and alleges as follows:
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`Related Actions
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`1.
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`This case is related to two cases previously consolidated before Judge Stark, 09—
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`cv—OOl 19 (D. Del.) (LPS) and 11-cv—00260 (D. Del.) (LPS), both ofwhich settled after extensive
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`dispositive motion practice. This case is also related to the other actions filed simultaneously by
`
`Arendi today, which involve the same patents-in-suit and common facts.
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`The Parties and Accused Products
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`2.
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`Plaintiff Arendi is a corporation organized under the laws of Luxembourg with its
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`principal place of business in Luxembourg.
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`3.
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`On information and belief, Defendant Samsung Electronics Co., Ltd. (“Samsung
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`Electronics”) is a corporation organized under the laws of the Republic of Korea and has its
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`principal place of business at 1320—10, Seocho 2-dong, Seocho-gu, Seoul 137— 857, Republic of
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`Korea.
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`4.
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`On information and belief, Defendant Samsung Electronics America,
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`Inc.
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`(“Samsung America”) is a New York corporation and has its principal place of business at 85
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`Challenger Road, Ridgefield Park, New Jersey 07660. Samsung America is doing business in
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`this judicial district and its registered agent for service of process is CT Corporation System, 111
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`Eighth Avenue, New York, New York 10011.
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`5.
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`011 information and belief, Defendant Samsung Telecommunications America,
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`LLC (“Samsung Telecommunications”) is a Delaware limited liability company with its
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`principal place of business at 1301 East Lookout Drive, Richardson, Texas 75081. On
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`information and belief, Samsung Telecommunications markets, sells, or offers for sale a variety
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`of personal and business communications devices in the United States and in this judicial district,
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`including cell phones and tablets. Samsung :Electronics, Samsung America and Samsung
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`Telecommunications are collectively referred to herein as “Samsung.”
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`6.
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`Samsmrg transacts substantial business, either directly or through its agents, on an
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`ongoing basis in this judicial district and elsewhere in the United States.
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`7.
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`Samsung makes, uses, imports, offers to sell, and sells (and/or has made, used,
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`imported, offered to sell, and sold) in the United States and in this judicial district, the Samsung
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`B5752, Samsung Galaxy S 11 (Samsung-SGH—1727), Samsung Galaxy Note II (Samsung-SGH—
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`1717), Samsung Tab 2 10.1 (Samsung—SGH—1497) and other mobile phones, smartphones,
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`computers and tablet devices containing the same or similar information handling technology
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`disclosed in the asserted patents described herein (collectively, the “Accused Products”).
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`Nature of the Action
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`8.
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`This is a civil action for infringement of United States Patents No. 7,917,843 (the
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`“‘843 Patent”), No. 7,496,854 (the 6“854 Patent”), and No. 8,306,993 (the “‘993 Patent”). This
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`action arises under the Patent Laws of the United States, 35 U.S.C. § 1 et seq.
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`Jurisdiction and Venue
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`9.
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`This Court has jurisdiction over the subject matter of this action pursuant to 28
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`U.S.C. §§ 1331 and 1338(a).
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`10.
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`Personal jurisdiction is proper in this district because, among other reasons,
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`Samsung has a continuous presence in this District, Samsrrng committed acts of infringement in
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`this District and a substantial part of the events or omissions giving rise to this claim occurred in
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`this District. Samsung placed, and continues to place, Accused Products into the stream of
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`commerce, through an established distribution channel, with the knowledge and/or understanding
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`that such products are used and sold in this District. This causes injury to Arendi in this Disuict.
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`On information and belief, Defendants derive substantial revenue fi‘om the sale of Accused
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`Products distributed within the District, and derive substantial revenue from interstate and
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`international commerce.
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`11.
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`Venue is proper in this district pursuant to 28 U.S.C. §§ 139le) and (c), and
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`1400(b), because Samsung committed acts of infringement in this district and a substantial part
`ofthe events or omissions giving rise to this claim occurred in this District.
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`The Patents-In—Suit
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`12.
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`United States Patent No. 7,917,843, entitled “Method, System and Computer
`
`Readable Medium for Addressing Handling from a Computer Program,” was duly and legally
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`issued on March 29, 2011, by the United States Patent and Trademark Office. A copy of the ‘843
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`Patent is attached hereto as Exhibit A.
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`13.
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`United States Patent No. 7,496,854, entitled “Method, System and Computer
`
`Readable Medium for Addressing Handling from a Computer Program,” was duly and legally
`
`issued on February 24, 2009, by the United States Patent and Trademark Office. A copy of the
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`‘854 Patent is attached hereto as Exhibit B.
`
`14.
`
`United States Patent No. 8,306,993, entitled “Method, System and Computer
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`Readable Medium tbr Addressing Handling from an Operating System,” was duly and legally
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`issued on November 6, 2012, by the United States Patent and Trademark Office. A copy of the
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`‘993 Patent is attached hereto as Exhibit C.
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`15.
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`Arendi is the exclusive owner of all rights, title, and interest in the ‘843 Patent,
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`‘854 Patent, and ‘993 Patent, including the right to bring this suit for injunctive relief and
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`damages.
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`16.
`
`The ‘843 Patent, ‘854 Patent, and ‘993 Patent are valid and enforceable.
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`BACKGROUND
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`17.
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`Arendi filed suit in this District against Microsoft Corporation and Dell Inc. for
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`infringement of the ‘854 Patent on February 24, 2009. 09—cv-00119 (D. Del.) (LPS). Thercase
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`was assigned to the Honorable Leonard P. Stark, who held two Marlqnan Hearings, on February
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`25, 2011 and November 21, 2011, and denied several summary judgment motions. The case was
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`resolved by settlement and dismissed on November 29, 2011.
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`18.
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`Arendi filed suit in this District against Microso-- Corporation for infringement of
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`the ‘843 Patent on March 29, 2011. 11—cv—00260 (D. Del.) (LPS). The case was assigned to the
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`Honorable Leonard P. Stark, who consolidated the 11—cv-260 case with the above—referenced
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`case 011 May 10, 2011. After Judge Stark held a Markman Hearing on November 21, 2011, this
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`case was also resolved by settlement and dismissed on November 29, 201 l.
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`COUNT I
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`(Infringement of United States Patent No. 7,917,843)
`
`19.
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`The preceding paragraphs are incorporated by reference as if stated fully herein.
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`20.
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`Samsung has infringed and continues to infringe the ‘843 patent under 35 U.S.C.
`
`§ 271, including but not limited to claims 1 and 23, literally or under the doctrine of equivalents,
`
`by making, using, selling, and/or offering for sale in the United States, and/or importing into the
`
`United States, Accused Products, Without authorization. On information and belief, Samsung
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`has also infiinged and continues to infringe at least claims 2, 8, 13, 14, 15, 16, 17, 20, 21, 23, 24,
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`30, 35, 36, 37, 38, 39, 42, 43 of the ‘843 patent under 35 U.S.C. § 271, literally or under the
`
`doctrine of equivalents, by making, using, selling, and/or offering for sale in the United States,
`
`and/or importing into the United States, Accused Products, without authorization.
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`21.
`
`Samsung’s acts of mfiingement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsmig the damages it has sustained as a result of Defendants’
`
`wrongful acts in an amount subject to proof at trial. Samsung’s infringement of Arendi’s
`
`exclusive rights under the ‘843 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infringement is
`
`enjoined by this Court.
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`22.
`
`In addition to the foregoing and/or in the alternative, third parties, including
`
`Samsung’s customers, have infringed, and continue to infringe, one or more claims of the ‘843
`
`patent under 35 U.S.C. § 271 by making, using, selling, and/or offering for sale in the United
`
`States, and/or importing into the United States, Accused Products.
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`23.
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`Samsung has had knowledge of and notice of the ‘843 patent and its infringement
`
`at least since the filing of this complaint.
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`24.
`
`To the extent Samsung continues to sell or otherwise supply Accused Products
`
`after the filing of this complaint, Samsung is inducing infringement of one or more claims of the
`
`‘843 patent under 35 U.S.C. § 271 (b), including on information and belief at least the claims set
`
`forth above. Samsung is actively, knowingly, and intentionally inducing infringement of the
`
`‘843 patent by practicing the methods set forth therein and by selling, offering to sell and/or
`
`importing into the United States the Accused Products after the filing of this complaint; with the
`
`knowledge and specific intent that third parties, including its customers, will continue to — either
`
`alone or in combination with Samsung — practice the patented methods, and use, sell, offer for
`
`sale, and/or import the Accused Products supplied by Samsung to infringe the ‘843 patent; and
`
`with the knowledge and specific intent to encourage and facilitate the infringement through the
`
`dissemination of the Accused Products and/or the creation and dissemination of promotional and
`
`marketing materials, supporting materials,
`
`instructions, product manuals, and/or technical
`
`information relating to the Accused Products and infringing uses thereof.
`
`25.
`
`Samsung’s acts of induced infringement have caused damage to Arendi and
`
`Arendi
`
`is entitled to recover fi‘om Samsung the damages it has sustained as a result of
`
`Defendants’ wrongful acts in an amount subject
`
`to proof at
`
`trial.
`
`Samsung’s induced
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`infringement of Arendj’s exclusive rights under the ‘843 patent have damaged, and continue to
`
`damage, Arendi, causing irreparable harm for which there is no adequate remedy at iaw, unless
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`the infi‘ngement is enjoined by this Court.
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`26.
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`In addition to the foregoing and/or in the alternative, at least since the filing of
`
`this complaint, Samsung has knowingly contributed to the infringement of one or more claims of
`
`the ‘843 patent under 35 U.S.C. § 271(c).
`
`27.
`
`To the extent SamSung continues to sell or otherwise supply Accused Products afier
`
`the filing of this complaint, Samsung is contributing to the infiingernent of one or more claims of
`
`the ‘843 patent by third parties, under 35 U.S.C. § 271(c), including on information and belief at
`
`least the claims set forth above. Samsung is actively, knowingly, and intentionally contributing
`
`to the infringement of the “843 patent by selling, offering to sell and/or importing into the United
`
`States Accused Products after the filing of this complaint; with the knowledge that the Accused
`
`Products are especially designed or adapted to operate in a manner that infringes the “843 Patent;
`
`With the knowledge that third parties, including its customers, will continue to — either alone or in
`
`combination with Samsung — practice the patented methods; and with the knowledge that the
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`infiinging information handling technology in the Accused Products is not a staple article of
`
`commerce suitable for substantial noninfiinging use.
`
`28.
`
`Samsung’s acts of contributory infringement have caused damage to Arendi and
`
`Arendi
`
`is entitled to recover from Samsung the damages it has sustained as a result of
`
`Defendants’ wrongful acts in an amount subject to proof at trial.
`
`Samsung’s contributory
`
`infringement of Arendi’s exclusive rights under the ‘843 patent have damaged, and continue to
`
`damage, Arendi, causing irreparable harm for which there is no adequate remedy at law, unless
`
`the infringement is enjoined by this Court.
`
`will
`
`(Infringement of United States Patent No. 7,496,854)
`
`29.
`
`The preceding paragraphs are incorporated by reference as if stated fully herein.
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`30.
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`Samsung has infringed and continues to infiinge the ‘854 Patent under 35 U.S.C.
`
`§ 271, including but not limited to claims 57, 73, and 79, literally or under the doctrine of
`
`equivalents, by making, using, selling, and/or offering for sale in the United States, and/or
`
`importing into the United States, Accused Products, without authorization. On information and
`
`belief, Samsung has also infringed and continues to infringe at least claims 19, 20, 22, 23, 24, 25,
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`26, 28, 29, 30, 31, 32, 34, 35, 60, 61, 62, 63, 64, 65, 72, 76, 77, 78, 82, 83, and 84 ofthe ‘854
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`patent under 35 U.S.C. § 271, literally or under the doctrine of equivalents, by making, using,
`
`selling, and/or offering for sale in the United States, and/or importing into the United States,
`
`Accused Products, Without authorization
`
`31.
`
`Samsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Dcfcndants’
`
`wrongful acts in an amount subject to proof at trial.
`
`Samsung’s infiingement of Arendi’s
`
`exclusive rights under the ‘854 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infiingement is
`
`enjoined by this Court.
`
`32.
`
`In addition to the foregoing and/or in the alternative, third parties, including
`
`Samsung’s customers, have infringed, and continue to infringe, one or more claims of the ‘854
`
`patent under 35 U.S.C. § 271 by making, using, selling, and/or offering for sale in the United
`
`States, and/or importing into the United States, Accused Products.
`
`33.
`
`Samsung has had knowledge of and notice of the ‘854 patent and its infringement
`
`"t least since the filing of this complaint.
`
`34.
`
`To the extent Samsung continues to sell or otherwise supply Accused Products
`
`after the filing of this complaint, Samsung is inducing infringement of one or more claims of the
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`‘854 patent under 35 U.S.C. § 271, including on information and belief at least the claims set
`
`forth above. Samsung is actively, knowingly, and intentionally inducing infringement of the
`
`‘854 patent by practicing the methods set forth therein and by selling, offering to sell and/or
`
`importing into the United States Accused Products after the filing of this complaint; with the
`
`knowledge and specific intent that third parties, including its customers, will continue to — either
`
`alone or in combination with Samsung — practice the patented methods, and use, sell, offer for
`
`sale, and/or import the Accused Products supplied by Samsung to infringe the ‘854 patent; and
`
`with the knowledge and specific intent to encourage and facilitate the infringement through the
`
`dissemination of the Accused Products and/or the creation and dissemination of promotional and
`
`marketing materials, supporting materials,
`
`instructions, product manuals, and/or technical
`
`information relating to the Accused Products and infringing uses thereof.
`
`35.
`
`Samsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants’
`
`wrongful acts in an amount subject to proof at trial. Samsung’s infringement of Arendi’s
`
`exclusive rights under the ‘8547 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infringement is
`
`enjoined by this Court.
`
`36.
`
`In addition to the foregoing and/or in the alternative, at least since the filing of
`
`this complaint, Samsung has knowingly contributed to the infringement of one or more claims of
`
`the ‘854 patent under 35 U.S.C. § 271(c).
`
`the filing of this complaint, Samsung is contributing to the infi'ingement of one or more claims of
`
`the ‘854 patent by third parties, under 35 U.S.C. § 271(c), including on information and belief at
`
`least the claims set forth above. Samsung is actively, knowingly, and intentionally contributing
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`9
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`to the infringement ofthe ‘854 patent by selling, offering to sell and/or importing into the United
`
`States Accused Products after the filing of this complaint; with the knowledge that the Accused
`
`Products are especially designed or adapted to operate in a manner that infringes the ‘854 Patent;
`
`with the knowledge that third parties, including its customers, will continue to — either alone or in
`
`combination with Samsung — practice the patented methods; and with the knowledge that the
`
`infiinging information handling technology in the Accused Products is not a staple article of
`
`commerce suitable for substantial noninfiinging use.
`
`38.
`
`Samsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants’
`
`wrongful acts in an amount subject to proof at trial.
`
`Samsung‘s infringement of Arendi’s
`
`exclusive rights under the ‘854 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infiingement is
`
`enjoined by this Court.
`
`COUNT III
`
`(Infringement of United States Patent No. 8,306,993)
`
`39.
`
`The preceding paragraphs are incorporated by reference as if stated fully herein.
`
`40.
`
`Samsung has infringed and continues to infringe the ‘993 Patent under 35 U.S.C.
`
`§ 271, including but not limited to claims 1, 9 and 17, literally or under the doctrine of
`
`equivalents, by making, using, selling, and/or offering for sale in the United States, and/or
`
`importing into the United States, Accused Products, without authorization. On information and
`
`belief, Samsung has also mfiinged and continues to infringe at least claims 2, 4, 5, 6, 7, 8, 10, 12,
`
`13, 14, 15, 16, 18, 20, 21, 24, 22, and 23 of the ‘993 patent under 35 U.S.C. § 271, literally or
`
`under the doctrine of equivalents, by making, using, selling, and/or offering for sale in the United
`
`States, and/or importing into the United States, Accused Products, without authorization.
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`10
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`41.
`
`Samsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants’
`
`wrongful acts in an amount subject to proof at trial.
`
`Samsung’s infringement of Arendi’s
`
`exclusive rights under the ‘993 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infringement is
`
`enjoined by this Court.
`
`42.
`
`In addition to the foregoing and/or in the alternative, third parties, including
`
`SamSung’s customers, have infringed, and continue to infringe, one or more claims of the ‘993
`
`patent under 35 U.S.C. § 271 by making, using, selling, and/or offering for sale in the United
`
`States, and/or importing into the United States, Accused Products.
`
`43.
`
`Samsung has had knowledge of and notice of the ‘993 patent and its infringement
`
`at least since the filing of this complaint.
`
`44.
`
`To the extent Samsung continues to sell or otherwise supply Accused Products
`
`after the filing of this complaint, Samsung is inducing infiingement of one or more claims of the
`
`“993 patent under 35 U.S.C. § 271, including on information and belief at least the claims set
`
`forth above. Samsung is actively, knowingly, and intentionally inducing infringement of the
`
`“993 patent by practicing the methods set forth therein and by selling, offering to sell and/or
`
`importing into the United States Accused Products after the filing of this complaint; with the
`
`knowledge and specific intent that third parties, including its customers, will continue to w either
`
`alone or in combination with Samsung — practice the patented methods, and use, sell, offer for
`
`sale, and/or impcit the Accused Products supplied by Samsung to infi'inge the ‘993 patent; and
`
`with the knowledge and specific intent to encourage and facilitate the infringement through the
`
`dissemination of the Accused Products and/or the creation and dissemination of promotional and
`
`11
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`marketing materials, supporting materials,
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`instructions, product manuals, and/or technical
`
`information relating to the Accused Products and infringing uses thereof.
`
`45.
`
`Samsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants’
`
`wrongful acts in an amount subject to proof at trial.
`
`Samsung’s infringement of Arendi’s
`
`exclusive rights under the “993 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infringement is
`
`enjoined by this Court.
`
`46.
`
`In addition to the foregoing and/or in the alternative, at least since the filing of
`
`this complaint Samsung has knowingly contributed to the infringement of one or more claims of
`
`the ‘993 patent under 35 U.S.C. § 271(0).
`
`47.
`
`To the extent Samsung continues to sell or otherwise supply Accused Products after
`
`the filing of this complaint, Samsung is contributing to the infringement of one or more claims of
`
`the ‘993 patent by third parties, under 35 U.S.C. § 271(c), including on information and belief at
`
`least the claims set forth above. Samsung is actively, knowingly, and intentionally contributing
`
`to the infringement of the ‘993 patent by selling, offering to sell andfor importing into the United
`
`States Accused Products afier the filing of this complaint; with the knowledge that the Accused
`
`Products are especially designed or adapted to operate in a manner that infringes the ‘993 Patent;
`
`with the knowledge that third parties, including its customers, will continue to e either alone or in
`
`combination with Samsung — practice the patented methods; and with the knowledge that the
`
`mfiinging information handling technology in the Accused Products is not a staple article of
`
`commerce suitable for substantial noninfiinging use.
`
`48.
`
`Samsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants”
`
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`wrougful acts in an amount subject to proof at trial.
`
`Samsung’s infringement of Arendi’s
`
`exclusive rights under the ‘993 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infringement is
`
`enjoined by this Court.
`
`Prayer for Refief
`
`WHEREFORE, Arendi prays for judgment as follows:
`
`A.
`
`B.
`
`Declaring that Sarnsung has infringed the ‘843, ‘854 and ‘993 Patents;
`
`Awarding the damages arising out of Samsung’s infringement of the ‘843, ‘854,
`
`and ‘993 Patents, including enhanced damages pursuant to 35 U.S.C. § 284, to Arendi, together
`
`with prejudgment and post—judgment interest, in an amount according to proof;
`
`C.
`
`Permanently enjoining Samsung, its officers, agents, and employees, and those
`
`persons in active concert or participation with any of them, and its successors and
`
`assigns,
`
`from infi’ingement,
`
`inducement of infringement, and contributory
`
`infiingement of the ’843, ‘854 and ‘993 Patents, including but not limited to
`
`making, using, selling, and/or offering for sale within the United States, and/or
`
`importing in the United States, any devices, products, software, or methods that
`
`infringe the ‘843, “854 and :993 Patents before the expiration of these patents;
`
`D.
`
`Awarding attorney’s fees to Arendi pursuant to 35 U.S.C. § 285 or as otherwise
`
`permitted by law;
`
`E.
`
`Awarding such other costs and fiirther relief as the Court may deem just and
`
`13
`
`Arendi S.A.R.L.-Ex.2002
`Page 13 of 115
`
`Arendi S.A.R.L.-Ex.2002
`Page 13 of 115
`
`

`

`Case 1:12-cv-01598-UNA Document 1 Filed 11/29/12 Page 14 of 14 PageID #: 14
`
`W2
`
`Arendi hereby demands a trial by jury on all issues so triable.
`
`PROCTOR HEYMAN LLP
`
`/s/ Neal C. Belgam
`Neal C. Belgam (# 2721)
`E-mail: nbelgam@proctorheyman.com
`Melissa N. Donirnirski (# 4701)
`E—mail: mdonimirski@proctorheymar1.eom
`Dawn Kurtz Crompton (# 5579)
`E—mail: dcrompton@proctorheyman.com
`300 Delaware Avenue, Suite 200
`
`Wilmington, DE 19801
`(302) 472—7300
`
`Attorneys for Plaintiff Arendi S.A.R.L.
`
`OF COUNSEL:
`
`SUSMAN GODFREY, L.L.P.
`Stephen D. Susman
`E—mail: ssusman@susmangodfrey.com
`Seth D. Ard
`
`E-mail: sard@susmangodfrey.com
`560 Lexington Avenue, 15th Floor
`New York, NY 10022
`(212) 336-8330
`
`SUSMAN GODFREY, L.L.P.
`
`Harry P. Susman
`E—mail: hsusman@susmangodfrey.corn
`Lexie G. White
`
`E—mail: lwhite@susmangodfrey.com
`1000 Louisarma Street, Suite 5100
`Houston, TX 77002
`212-651-9366
`
`Dated: November 29, 2012
`
`14
`
`Arendi S.A.R.L.-Ex.2002
`Page 14 of 115
`
`Arendi S.A.R.L.-Ex.2002
`Page 14 of 115
`
`

`

`Case 1:12-cv-01598-UNA Document 1-1 Filed 11/29/12 Page 1 of 32 PagelD #: 15
`
`Exhibit A
`
`Arendi S.A.R.L.-Ex.2002
`Page 15 of 115
`
`Arendi S.A.R.L.-Ex.2002
`Page 15 of 115
`
`

`

`Case 1: 12-c—v--01598- UNA Document 1- 1 Filed 11/29/12 Pa e 2 of 32 Pa
`
`elD #: 16
`
`HlllllllllllllllllllIlllllllllllllllllllillllllllllllllllllllllllllllll
`
`USOO7917843B2
`
`(12) United States Patent
`Hedloy
`
`US 7,917,843 B2
`(10) Patent N0.:
`*Mar. 29, 2011
`(45) Date of Patent:
`
`(54) NIETHOD, SYSTEMAND COWUTER
`READABLE MEDIUM FOR ADDRESSING
`HANDLING FROM A COMPUTER PROGRAM
`
`EP
`
`(75)
`
`Inventor: Atle Hedley, Madrid (ES)
`
`(73) Assignee: Arendi S.A.R.L., Luxembourg (LU)
`
`( * ) Notice:
`
`Subject to any disclaimer, the term ofthis
`patent is extended or adjusted under 35
`U.S.C. 154(b) by 394 days.
`
`This patent is subject to a terminal dis~
`claimer.
`
`(21) App]. No; 1211824148
`
`(22) Filed:
`
`Jul. 29, 2008
`
`(65)
`
`Prior Publication Data
`US 2008/0313159 A1
`Dec. 18, 2008
`
`Related US. Application Data
`
`(63) Continuation of application No. 09/923,134, filed on
`Aug. 6, 2001, now Pat. No. 7,496,854, which is a
`continuation of application No. 09/189,626, filed on _
`Nov. 10, 1998, now Pat. No. 6,323,853.
`
`(30)
`
`Foreign Application Priority Data
`
`Sep. 3, 1998
`
`(N0) ........................................ 984066
`
`(51)
`
`1111.0.
`G06F17/00
`(52) U.S.Cl.
`
`(2006.01)
`715/230; 715/234; 715/711; 715/752;
`715/825; 715/853
`715/230
`(58) Field of Classification Search
`See application file for complete search history.
`
`(56)
`
`References Cited
`
`U.S. PATENT DOCUMENTS
`3,350,695 A
`10/1957 Kaufman 6t 31.
`(Continued)
`
`340/1725
`
`FOREIGN PATENT DOCUMENTS
`0 093 250 A2
`9/1983
`
`(Continued)
`
`OTHER PUBLICATIONS
`
`PeIson at 21.1., “Special Edition Using Microsoft Word 97” by Que
`Publisher Pub. date Dec. 16, 1996. pp. 475—514.‘
`
`(Continued)
`
`Primary Examiner — Doug Hutton
`Assistant Examiner — Quoc A Tran
`(74) Attorney, Agent, or Firm — Sunstein Kann Murphy &
`Timbers LLP
`
`(57)
`
`ABSTRACT
`
`A method, system and computer readable medium for pro-
`viding for providing a function item, such as a key, button,
`icon, or menu, tied to a user operation in a computer, whereby
`a single click on the Motion ital in a window or program on
`a computer screen, or one single selection in a menu in a
`program, initiates retrieval of name and addresses and/or
`other person or company related information, while the user
`works simultaneously in another program, e.g., a word pro-
`cessor. The click on the function item initiates a program
`connected to the button to search a database or file available
`on or through the computer, containing the person, company
`oraddress related data, in orderto look up data corresponding
`to What the user types, or partly typed, e.g., name and/or
`address in the word processor; the correct data from the data—
`base, data related to the typed data, e.g., the name of the
`person, company, or the traditional or electronic address, or
`other person, or company, or address related data, and alter-
`natively the persons, companies, or addresses, are displayed
`and possibly entered into the word processor, if such related
`data exists.
`
`44 Claims, 14 Drawing Sheets
`
`
`W Wit-lord Dohlrmnfl
`EEEl
`
`
`!EIE1
`
`
`I“
`
`
`Im=_MNWMIZI
`_'1'1‘1‘24~3’I’4‘1-5-l-6-l-1-I a I9 l‘10'I'11' 14241313 “fill-15H
`
`
`
`
`__
`
`
`
`to
`£111ve
`
`42
`
`I
`
`117:3
`
`‘I'fi‘l‘fi‘l'l'l'Z'l'1'l'
`
`
`:IEEl-lu-m Ii. ...uum: ..,-e
`
`Arendi S.A.R.L.—Ex.2002
`Page 16 of 115
`
`Arendi S.A.R.L.-Ex.2002
`Page 16 of 115
`
`

`

`Case 1:12-cv-01598-UNA Document 1-1 Filed 11/29/12 Page 3 of 32 PagelD #: 17
`
`US 7,917,843 B2
`
`Page2
`
`
`
`772000 Horviiz
`7097203
`5,085,225 A
`772000 Rel/1555151.
`.7077102
`5,092,074 A
`
`8/2000 “0111011135...“
`' 709/202
`6,103,586 A.
`1172000 Papiemiaketal.
`... 705710
`6,151,584 A
`
`. 705/408
`172001 Reiter .
`5,178,411 Bl
`
`. 709/223
`172001 Horvitz ..
`5,182,133 B1
`2/2001 Light at 51.
`.
`, 707/505
`6,192,380 B1
`
`372001 311115151.
`..
`705714
`5,208,975 B1
`572001 Horvitzetal.
`.
`705/11
`6,233,570 B1
`
`672001 Witeketal.
`705/14
`5,253,188 131
`
`772001 How/12 etal.
`.
`.. 706/60
`6,260,035 B1
`. 345/337
`772001 Horvilz 5151.
`5,262,730 B1
`
`.
`972001 R0111 etal.
`705/27
`6,285,987 B1
`..
`. 707/201
`1072001 11511155151.
`6,304,881 B1
`
`102001 Landsmanetal.
`. 707/513
`6,317,751 B1
`
`. 3457339
`1172001 Hedloy .........
`6,323,853 B1
`
`. 4357108
`172002 0515515151.
`6,338,957 B2
`379735502
`4/2002 811511515151.
`6,373,940 BZ
`472002 Hachamovitchetal.
`..7077534
`5,377,965 B1
`... 705/14
`572002 Anglesetal.
`5,385,592 Bl
`
`. 707/507
`772002 Nishiyama 5151
`5,421,693 Bl
`
`., 706710
`12/2002 Abu—Hakima
`6,499,021 131
`
`. 7157507
`11/2003 K5medyetal.
`5,551,217 Bl
`
`.455/415
`572004 Choweta1...
`5,738,615 Bl
`
`. 455/466
`1172004 Helferich..
`6,826,407 B1
`
`572005 Merrimanetal
`705114
`7,039,599 B2
`
`.707/4
`572006 LandetaI.
`7,051,019 Bl
`70776
`1172005 [(51155 2151.
`7,135,853 Bl
`
`70771041
`12/2006 Torres
`7,155,451 B1
`__ 715/507
`5/2007 Snapperetal
`7,216,292 B1
`
`707/10
`9/2007 Hadley"
`7,272,604 B1
`.. 715/780
`
`fl2009 Hcdloy .
`7,496,854 B2
`707/10
`3/2009 Gropper
`7,505,974 132
`
`.. 707/200
`3/2009 Celik
`7,509,349 132
`
`5/2002 Hedloy .
`2002/0054092 A1
`
`12/2002 Lyfleet a1.
`2002/0188683 A1
`2/2003 Shanahanetal.
`2003/0033288 A1
`
`I: 707/4
`3/2006 Bockingetal.
`2006/0047644 A1
`707/10
`10/2007 Hedloy .....
`2007/0244907 A1
`.. 70773
`
`12/2008 Hadley ,
`2008/0313159 A1
`8/2010 Hadley .
`2010/0211600 A2'F
`
`11/2010 Hadley
`2010/0281354 A1
`....1: 7157220
`FOREIGN PATENT DOCUMENTS
`1 630 642
`3/2006
`2196454
`4/1988
`2 318 703
`4/1998
`W0 97/211831
`6/1997
`WO 98/16890
`4/1998
`WO 98/19259
`5/1998
`WO 98/34391
`8/1998
`
`EP
`GB
`GB
`W0
`W0
`W0
`W0
`
`OTHER PUBLICATIONS
`
`Plotkin, David, AddressforSuccms, Bay Area Computer Currents, p.
`35-38, M51. 21, 1995.
`CTAGSG) Manual Page.
`Wilson, Eve, Guiding Lawers: M’apping Law into Hypertext, Arti-
`ficial Intelligence Review 6, pp. 161-189, 1992.
`MacWEEK Report, Aug. 8, 1995.
`Langbmg, Mike, Show ofPotential App/e Bred/:5 New Ground by
`Displaying What ’5 on its Drawing Board 'Innovation is at the Heart
`ofMat We Do', San Jose Mercury News, Aug. 7, 1996, 13. 1C.
`Anind K. Day, ct 711., Cybem’Desk: The Use of Perception in Context»
`Aware Computing, PUI kasllop Submission, Proc. of 1997 Work-
`shop on Perceptual User Interfhcw (PUI ’97), pp. 26-27, Oct, 1997