The expert report of Ravin Balakrishnan, PH.D. regarding infringement of the ‘381 patent was filed on Monday. In the report Professor Balakrishnan detailed how the patent works and the measures Samsung took to implement the patent in their products.
The ‘381 Patent is commonly known as the ‘Scrolling and rubber banding effect’ patent. Samsung is charged with infringing Claim 1 of the ’381 Patent.
Claim 1 of the ’381 patent declares:
A computer-implemented method, comprising:
[a] at a device with a touch screen display:
[b] displaying a first portion of an electronic document;
[c] detecting a movement of an object on or near the touch screen display; in response to detecting the movement, translating the electronic document displayed on the touch screen display in a first direction to display a second portion of the electronic document, wherein the second portion is different from the first portion;
[d] in response to an edge of the electronic document being reached while translating the electronic document in the first direction while the object is still detected on or near the touch screen display: displaying an area beyond the edge of the document, and displaying
Highlights from Professor Balakrishnan report:
- Based on my examination of the aforementioned Apple products, I conclude that they practice the asserted apparatus and system claims of the ’381 patent, and their ordinary and intended use practices the asserted method claims of the ’381 patent. I have examined portions of the source code for Apple’s iOS version 4.1 operating system and confirmed the behavior I saw on the iPhone 4 in the following source code modules: the UIScrollView class or subclass (for example, UIWebBrowserView and UIWebDocumentView); the touch panel (e.g., Grape) driver; UIKit classes; IOKit classes; SBHIDinterface.m; the SpringBoard application; and UIPanGestureRecognizer class or subclasses.
- In attempts to scroll the electronic document beyond its edge, the iPhone 4 displays an area beyond the edge of the electronic document along with a third smaller portion of the electronic document. When the user lifts his finger from the touch screen, the electronic document moves back into place to fill the screen, and a fourth portion of the electronic document different from the first portion is displayed.
- I have also reviewed a number of documents produced by Samsung in this litigation, including analyses of features in Apple products and email messages. Based on my review of these documents, it appears that Samsung studied a number of Apple products that embody the asserted claims of the ‘381 patent, recognized the benefits of the ’381 patent, and implemented the features of the ’381 patent in Samsung products.
- As just one example, in the document titled “Behold3 Usability Evaluation Results” (SAMNDCA00508318 – 508411), Samsung evaluated its Behold3 phone against Apple’s iPhone. This evaluation concluded that Samsung’s “Behold3 [was] shown inferior to Apple’s iPhone in both the task success rate (68.5%) and satisfaction score (86).”
- On a page titled “Aesthetics_Browsing,” the document notes that the iPhone has “a ‘bouncing’ visual effect,” which “generates fun for the user,” while the Behold3 has “no visual effect” when “a web page is dragged to its endpoint.” (SAMNDCA00508383.).
- Samsung appears to have understood at least part of the purpose and value of the rubber banding feature of the ’381 patent, which were to provide a natural, intuitive experience for the user.
EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Source: USCourts
