throbber
Cypress Lake Software v. Acer – Infringement Claim Chart – U.S. Patent No. 9,423,923
`
`“Navigation Methods, Systems, and Computer Program Products”
`
`Claim
`
`Acer’s Accused Windows Devices
`
`1. An apparatus, comprising:
`
`a device including at least one
`hardware processor operatively
`coupled to a display and memory,
`
`Each of Acer’s Accused Windows Devices running the Microsoft Windows 10 Operating System is an apparatus
`comprised of a device that includes a hardware processor (e.g., Intel Core i5) coupled to a display (e.g., 14” LCD) and
`memory (RAM and hard drive)—see Exhibit 1, Acer Accused Windows Devices and Specifications; Exhibit 2, Acer
`Accused Windows Device Webpages. The Accused Windows Devices therefore infringe these elements of Claim 1
`of U.S. Patent 9,423,923 literally or, in the alternative, under the doctrine of equivalents.
`
`An Accused Windows Device can store multiple applications (“a plurality of applications”) in its memory—for
`example, an instance of Internet Explorer (“a first application”) and an instance of Google Chrome (“a second
`application”)—and display the first application in a window (“present, utilizing the at least one hardware processor and
`the display, a first visual component of the first application in the plurality of applications”) in an area on the device’s
`screen (e.g., the right side of the screen) (“in a first application region of a presentation space of the display”).
`The Accused Windows Devices therefore infringe these elements literally or, in the alternative, under the doctrine of
`equivalents.
`
`the memory storing a plurality of
`applications including a first
`application and a second
`application, the device configured
`to:
`
`present, utilizing the at least one
`hardware processor and the display,
`a first visual component of the first
`application in the plurality of
`applications, in a first application
`region of a presentation space of
`the display;
`
`Screenshot of a Windows 10 display in Tablet mode showing an Internet Explorer window on the right side of the
`screen.
`
`
`
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`detect, utilizing the at least one
`hardware processor, first user input
`in connection with the first visual
`component of the first application;
`
`An Accused Windows Device can sense when a user want to (“detect, utilizing the at least one hardware processor, [a]
`first user input”) “snap” a window (“in connection with the first visual component of the first application”) to either
`side of the screen. In Tablet mode, a user touches and pulls down the title bar at the top of a window, drags the window
`to the desired side, and releases. A user can also use the mouse, touchpad or other similar pointing device instead of
`the touchscreen. The Accused Windows Devices therefore infringe this element literally or, in the alternative, under
`the doctrine of equivalents.
`
`
`
`See Exhibit B, wikiHow article
`to Use Snap Assist
`titled “4 Ways
`http://www.wikihow.com/Use-Snap-Assist-in-Windows-10.
`
`in Windows,” available at
`
`An Accused Windows Device will then, after the “snapping” of the first application window (“in response to the
`detection of the first user input in connection with the first visual component of the first application”), activate the
`“Snap Assist” feature and display a menu of thumbnails of two (or more) other open application windows (“present,
`utilizing the at least one hardware processor and the display, a representation of a second visual component of the
`second application and a representation of a third visual component of a third application … for navigating to the
`second visual component of the second application, in a second application region in the presentation space of the
`display”) in an area of the screen opposite to where the user snapped the first window (“in a first navigation region of
`the presentation space of the display determined based on the first application region … by determining a first location
`adjacent to a second location of the first visual component”). The Accused Windows Devices therefore infringe these
`elements literally or, in the alternative, under the doctrine of equivalents.
`
`in response to the detection of the
`first user input in connection with
`the first visual component of the
`first application, present, utilizing
`the at least one hardware processor
`and the display, a representation of
`a second visual component of the
`second application and a
`representation of a third visual
`component of a third application, in
`a first navigation region of the
`presentation space of the display
`determined based on the first
`application region, for navigating to
`the second visual component of the
`second application, in a second
`application region in the
`presentation space of the display,
`the first navigation region being
`
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`determined based on the first
`application region by determining a
`first location adjacent to a second
`location of the first visual
`component;
`
`Screenshot of a Windows 10 display in Tablet mode showing a Snap Assist menu with thumbnails of two other
`application windows (“a representation of a second visual component of the second application and a representation of
`a third visual component of a third application”).
`
`
`
`See Exhibit B, wikiHow article
`to Use Snap Assist
`titled “4 Ways
`http://www.wikihow.com/Use-Snap-Assist-in-Windows-10.
`
`
`in Windows,” available at
`
`detect, utilizing the at least one
`hardware processor, second user
`input in connection with the
`
`An Accused Windows Device can then detect (via touchscreen or mouse/touchpad) the user choosing the thumbnail of
`the second application window (“detect, utilizing the at least one hardware processor, [a] second user input in
`connection with the representation of the second visual component of the second application”) from the Snap Assist
`
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`menu (“in the plurality of applications”), and display the second application window in the leftover space on the screen
`(“in response to the detection of the second user input in connection with the representation of the second visual
`component of the second application in the plurality of applications, present, utilizing the at least one hardware
`processor and the display, the second visual component of the second application in the plurality of applications”).
`The Accused Windows Devices therefore infringe these elements literally or, in the alternative, under the doctrine of
`equivalents.
`
`representation of the second visual
`component of the second
`application in the plurality of
`applications; and
`
`in response to the detection of the
`second user input in connection
`with the representation of the
`second visual component of the
`second application in the plurality
`of applications, present, utilizing
`the at least one hardware processor
`and the display, the second visual
`component of the second
`application in the plurality of
`applications;
`
`Screenshot of a Windows 10 display in Tablet mode showing the second application window beside the first.
`
`
`
`
`
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`

`See Exhibit B, wikiHow article
`to Use Snap Assist
`titled “4 Ways
`http://www.wikihow.com/Use-Snap-Assist-in-Windows-10.
`
`in Windows,” available at
`
`An Accused Windows Device displays applications in windows (“the apparatus is configured such that the first visual
`component includes a first window, the second visual component includes a second window, and the third visual
`component includes a third window”), and when invoking Snap Assist, thumbnails of those windows are displayed in
`a menu beside the first application window (“the representation of the second window and the representation of the
`third window are elements of a menu; the menu is presented outside of the first window”). The Accused Windows
`Devices therefore infringe these elements literally or, in the alternative, under the doctrine of equivalents.
`
`wherein the apparatus is configured
`such that the first visual component
`includes a first window, the second
`visual component includes a second
`window, and the third visual
`component includes a third
`window; the representation of the
`second window and the
`representation of the third window
`are elements of a menu;
`
`the menu is presented outside of the
`first window;
`
`Screenshot of a Windows 10 display in Tablet mode showing a Snap Assist menu beside the “snapped” window.
`
`
`
`the menu is moved as a function of
`a movement of the first window;
`
`and the menu is re-sized as a
`function of a re-sizing of the first
`window;
`
`If a user snaps the first window to the left, the Snap Assist menu will move to the right side of the screen (“the menu
`is moved as a function of a movement of the first window”) and, in Tablet mode, a user can re-size the Snap Assist
`menu by selecting and dragging the vertical bar in the middle of the screen to re-size the first window (“and the menu
`is re-sized as a function of a re-sizing of the first window”). The Accused Windows Devices therefore infringe these
`elements literally or, in the alternative, under the doctrine of equivalents.
`
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`Screenshot of a Windows 10 display in Tablet mode showing the first window snapped to the left, putting the Snap
`Assist menu on the right.
`
`
`
`Screenshot of a Windows 10 display in Tablet mode showing how re-sizing the first window also re-sizes the Snap
`Assist menu.
`
`
`
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`wherein the apparatus is configured
`such that the menu is hidden if the
`first window is maximized;
`
`wherein the apparatus is configured
`such that the menu is re-presented
`if the first window is returned to a
`non-maximized state.
`
`An Accused Windows Device will hide the Snap Assist menu if a user maximizes the first window (“the apparatus is
`configured such that the menu is hidden if the first window is maximized”) and re-display it if the user snaps the
`window again (“the menu is re-presented if the first window is returned to a non-maximized state”). The Accused
`Windows Devices therefore infringe these elements literally or, in the alternative, under the doctrine of equivalents.
`
`Screenshot of a Windows 10 display in Tablet mode showing the first window maximized.
`
`
`
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`Screenshot of a Windows 10 display in Tablet mode showing the Snap Assist menu again once the first window is
`snapped again.
`
`
`
`2. An apparatus, comprising:
`
`a device including at least one
`hardware processor operatively
`coupled to a display and memory,
`
`Each of Acer’s Accused Windows Devices running the Microsoft Windows 10 Operating System is an apparatus
`comprised of a device that includes a hardware processor (e.g., Intel Core i5) coupled to a display (e.g., 14” LCD) and
`memory (RAM and hard drive)—see Exhibit 1, Acer Accused Windows Devices and Specifications; Exhibit 2, Acer
`Accused Windows Device Webpages. The Accused Windows Devices therefore infringe these elements of Claim 2
`of U.S. Patent 9,423,923 literally or, in the alternative, under the doctrine of equivalents.
`
`the memory storing a plurality of
`applications including a first
`application and a second
`application, the device configured
`to:
`
`present, utilizing the at least one
`hardware processor and the display,
`a first visual component of the first
`application in the plurality of
`applications, in a first application
`
`An Accused Windows Device can store multiple applications (“a plurality of applications”) in its memory—for
`example, an instance of Internet Explorer (“a first application”) and an instance of Google Chrome (“a second
`application”)—and display the first application in a window (“present, utilizing the at least one hardware processor and
`the display, a first visual component of the first application in the plurality of applications”) in an area on the device’s
`screen (e.g., the right side of the screen) (“in a first application region of a presentation space of the display”).
`The Accused Windows Devices therefore infringe these elements literally or, in the alternative, under the doctrine of
`equivalents.
`
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`region of a presentation space of
`the display;
`
`Screenshot of a Windows 10 display in Tablet mode showing an Internet Explorer window on the right side of the
`screen.
`
`
`
`detect, utilizing the at least one
`hardware processor, first user input
`in connection with the first visual
`component of the first application;
`
`An Accused Windows Device can sense when a user want to (“detect, utilizing the at least one hardware processor, [a]
`first user input”) “snap” a window (“in connection with the first visual component of the first application”) to either
`side of the screen. In Tablet mode, a user touches and pulls down the title bar at the top of a window, drags the window
`to the desired side, and releases. A user can also use the mouse, touchpad or other similar pointing device instead of
`the touchscreen. The Accused Windows Devices therefore infringe this element literally or, in the alternative, under
`the doctrine of equivalents.
`
`See Exhibit B, wikiHow article
`to Use Snap Assist
`titled “4 Ways
`http://www.wikihow.com/Use-Snap-Assist-in-Windows-10.
`
`in Windows,” available at
`
`
`
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`An Accused Windows Device will then, after the “snapping” of the first application window (“in response to the
`detection of the first user input in connection with the first visual component of the first application”), activate the
`“Snap Assist” feature and display a menu of thumbnails of two (or more) other open application windows (“present,
`utilizing the at least one hardware processor and the display, a representation of a second visual component of the
`second application and a representation of a third visual component of a third application … for navigating to the
`second visual component of the second application, in a second application region in the presentation space of the
`display”) in an area of the screen opposite to where the user snapped the first window (“in a first navigation region of
`the presentation space of the display determined based on the first application region … by determining a first location
`adjacent to a second location of the first visual component”). The Accused Windows Devices therefore infringe these
`elements literally or, in the alternative, under the doctrine of equivalents.
`
`in response to the detection of the
`first user input in connection with
`the first visual component of the
`first application, present, utilizing
`the at least one hardware processor
`and the display, a representation of
`a second visual component of the
`second application and a
`representation of a third visual
`component of a third application, in
`a first navigation region of the
`presentation space of the display
`determined based on the first
`application region, for navigating to
`the second visual component of the
`second application, in a second
`application region in the
`presentation space of the display,
`the first navigation region being
`determined based on the first
`application region by determining a
`first location adjacent to a second
`location of the first visual
`component;
`
`Screenshot of a Windows 10 display in Tablet mode showing a Snap Assist menu with thumbnails of two other
`application windows (“a representation of a second visual component of the second application and a representation of
`a third visual component of a third application”).
`
`
`
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`

`See Exhibit B, wikiHow article
`to Use Snap Assist
`titled “4 Ways
`http://www.wikihow.com/Use-Snap-Assist-in-Windows-10.
`
`
`in Windows,” available at
`
`An Accused Windows Device can then detect (via touchscreen or mouse/touchpad) the user choosing the thumbnail of
`the second application window (“detect, utilizing the at least one hardware processor, [a] second user input in
`connection with the representation of the second visual component of the second application”) from the Snap Assist
`menu (“in the plurality of applications”), and display the second application window in the leftover space on the screen
`(“in response to the detection of the second user input in connection with the representation of the second visual
`component of the second application in the plurality of applications, present, utilizing the at least one hardware
`processor and the display, the second visual component of the second application in the plurality of applications”).
`The Accused Windows Devices therefore infringe these elements literally or, in the alternative, under the doctrine of
`equivalents.
`
`detect, utilizing the at least one
`hardware processor, second user
`input in connection with the
`representation of the second visual
`component of the second
`application in the plurality of
`applications; and
`
`in response to the detection of the
`second user input in connection
`with the representation of the
`second visual component of the
`second application in the plurality
`of applications, present, utilizing
`the at least one hardware processor
`and the display, the second visual
`component of the second
`application in the plurality of
`applications;
`
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`

`Screenshot of a Windows 10 display in Tablet mode showing the second application window beside the first.
`
`
`
`See Exhibit B, wikiHow article
`to Use Snap Assist
`titled “4 Ways
`http://www.wikihow.com/Use-Snap-Assist-in-Windows-10.
`
`
`in Windows,” available at
`
`wherein the apparatus is configured
`such that the first visual component
`includes a first window, the second
`visual component includes a second
`window, and the third visual
`
`An Accused Windows Device displays applications in windows (“the apparatus is configured such that the first visual
`component includes a first window, the second visual component includes a second window, and the third visual
`component includes a third window”), and when invoking Snap Assist, thumbnails of those windows are displayed in
`a menu beside the first application window (“the representation of the second window and the representation of the
`
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`third window are elements of a menu; the menu is presented outside of the first window”). The Accused Windows
`Devices therefore infringe these elements literally or, in the alternative, under the doctrine of equivalents.
`
`component includes a third
`window; the representation of the
`second window and the
`representation of the third window
`are elements of a menu;
`
`the menu is presented outside of the
`first window;
`
`Screenshot of a Windows 10 display in Tablet mode showing a Snap Assist menu beside the “snapped” window.
`
`
`
`the menu is moved as a function of
`a movement of the first window;
`
`and the menu is re-sized as a
`function of a re-sizing of the first
`window;
`
`If a user snaps the first window to the left, the Snap Assist menu will move to the right side of the screen (“the menu
`is moved as a function of a movement of the first window”) and, in Tablet mode, a user can re-size the Snap Assist
`menu by selecting and dragging the vertical bar in the middle of the screen to re-size the first window (“and the menu
`is re-sized as a function of a re-sizing of the first window”). The Accused Windows Devices therefore infringe these
`elements literally or, in the alternative, under the doctrine of equivalents.
`
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`

`

`Screenshot of a Windows 10 display in Tablet mode showing the first window snapped to the left, putting the Snap
`Assist menu on the right.
`
`
`
`Screenshot of a Windows 10 display in Tablet mode showing how re-sizing the first window also re-sizes the Snap
`Assist menu.
`
`
`
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`wherein the apparatus is configured
`such that the elements of the menu
`are organized in a uniform grid of
`spaced, rectilinear elements.
`
`An Accused Windows Device renders the Snap Assist menu as rectangular “thumbnails” presented in a row or rows,
`with space between them (“apparatus is configured such that the elements of the menu are organized in a uniform grid
`of spaced, rectilinear elements”). The Accused Windows Devices therefore infringe this element literally or, in the
`alternative, under the doctrine of equivalents.
`
`Screenshot of a Windows 10 display in Tablet mode showing the Snap Assist menu consisting of thumbnails “organized
`in a uniform grid of spaced, rectilinear elements.”
`
`
`
`3. An apparatus, comprising:
`
`a device including at least one
`hardware processor operatively
`coupled to a display and memory,
`
`Each of Acer’s Accused Windows Devices running the Microsoft Windows 10 Operating System is an apparatus
`comprised of a device that includes a hardware processor (e.g., Intel Core i5) coupled to a display (e.g., 14” LCD) and
`memory (RAM and hard drive)—see Exhibit 1, Acer Accused Windows Devices and Specifications; Exhibit 2, Acer
`Accused Windows Device Webpages. The Accused Windows Devices therefore infringe these elements of Claim 3
`of U.S. Patent 9,423,923 literally or, in the alternative, under the doctrine of equivalents.
`
`the memory storing a plurality of
`applications including a first
`application and a second
`application, the device configured
`to:
`
`An Accused Windows Device can store multiple applications (“a plurality of applications”) in its memory—for
`example, an instance of Internet Explorer (“a first application”) and an instance of Google Chrome (“a second
`application”)—and display the first application in a window (“present, utilizing the at least one hardware processor and
`the display, a first visual component of the first application in the plurality of applications”) in an area on the device’s
`screen (e.g., the right side of the screen) (“in a first application region of a presentation space of the display”).
`
`MICROSOFT CORP. EX. 1011
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`

`

`The Accused Windows Devices therefore infringe these elements literally or, in the alternative, under the doctrine of
`equivalents.
`
`present, utilizing the at least one
`hardware processor and the display,
`a first visual component of the first
`application in the plurality of
`applications, in a first application
`region of a presentation space of
`the display;
`
`Screenshot of a Windows 10 display in Tablet mode showing an Internet Explorer window on the right side of the
`screen.
`
`
`
`detect, utilizing the at least one
`hardware processor, first user input
`in connection with the first visual
`component of the first application;
`
`An Accused Windows Device can sense when a user want to (“detect, utilizing the at least one hardware processor, [a]
`first user input”) “snap” a window (“in connection with the first visual component of the first application”) to either
`side of the screen. In Tablet mode, a user touches and pulls down the title bar at the top of a window, drags the window
`to the desired side, and releases. A user can also use the mouse, touchpad or other similar pointing device instead of
`the touchscreen. The Accused Windows Devices therefore infringe this element literally or, in the alternative, under
`the doctrine of equivalents.
`
`
`
`MICROSOFT CORP. EX. 1011
`Page 16 of 79
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`

`

`See Exhibit B, wikiHow article
`to Use Snap Assist
`titled “4 Ways
`http://www.wikihow.com/Use-Snap-Assist-in-Windows-10.
`
`in Windows,” available at
`
`An Accused Windows Device will then, after the “snapping” of the first application window (“in response to the
`detection of the first user input in connection with the first visual component of the first application”), activate the
`“Snap Assist” feature and display a menu of thumbnails of two (or more) other open application windows (“present,
`utilizing the at least one hardware processor and the display, a representation of a second visual component of the
`second application and a representation of a third visual component of a third application … for navigating to the
`second visual component of the second application, in a second application region in the presentation space of the
`display”) in an area of the screen opposite to where the user snapped the first window (“in a first navigation region of
`the presentation space of the display determined based on the first application region … by determining a first location
`adjacent to a second location of the first visual component”). The Accused Windows Devices therefore infringe these
`elements literally or, in the alternative, under the doctrine of equivalents.
`
`in response to the detection of the
`first user input in connection with
`the first visual component of the
`first application, present, utilizing
`the at least one hardware processor
`and the display, a representation of
`a second visual component of the
`second application and a
`representation of a third visual
`component of a third application, in
`a first navigation region of the
`presentation space of the display
`determined based on the first
`application region, for navigating to
`the second visual component of the
`second application, in a second
`application region in the
`presentation space of the display,
`the first navigation region being
`determined based on the first
`application region by determining a
`first location adjacent to a second
`location of the first visual
`component;
`
`Screenshot of a Windows 10 display in Tablet mode showing a Snap Assist menu with thumbnails of two other
`application windows (“a representation of a second visual component of the second application and a representation of
`a third visual component of a third application”).
`
`
`
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`

`

`See Exhibit B, wikiHow article
`to Use Snap Assist
`titled “4 Ways
`http://www.wikihow.com/Use-Snap-Assist-in-Windows-10.
`
`
`in Windows,” available at
`
`An Accused Windows Device can then detect (via touchscreen or mouse/touchpad) the user choosing the thumbnail of
`the second application window (“detect, utilizing the at least one hardware processor, [a] second user input in
`connection with the representation of the second visual component of the second application”) from the Snap Assist
`menu (“in the plurality of applications”), and display the second application window in the leftover space on the screen
`(“in response to the detection of the second user input in connection with the representation of the second visual
`component of the second application in the plurality of applications, present, utilizing the at least one hardware
`processor and the display, the second visual component of the second application in the plurality of applications”).
`The Accused Windows Devices therefore infringe these elements literally or, in the alternative, under the doctrine of
`equivalents.
`
`detect, utilizing the at least one
`hardware processor, second user
`input in connection with the
`representation of the second visual
`component of the second
`application in the plurality of
`applications; and
`
`in response to the detection of the
`second user input in connection
`with the representation of the
`second visual component of the
`second application in the plurality
`of applications, present, utilizing
`the at least one hardware processor
`and the display, the second visual
`component of the second
`application in the plurality of
`applications;
`
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`

`Screenshot of a Windows 10 display in Tablet mode showing the second application window beside the first.
`
`
`
`See Exhibit B, wikiHow article
`to Use Snap Assist
`titled “4 Ways
`http://www.wikihow.com/Use-Snap-Assist-in-Windows-10.
`
`
`in Windows,” available at
`
`wherein the apparatus is configured
`such that the first visual component
`includes a first window, the second
`visual component includes a second
`window, and the third visual
`
`An Accused Windows Device displays applications in windows (“the apparatus is configured such that the first visual
`component includes a first window, the second visual component includes a second window, and the third visual
`component includes a third window”), and when invoking Snap Assist, thumbnails of those windows are displayed in
`a menu beside the first application window (“the representation of the second window and the representation of the
`
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`

`third window are elements of a menu; the menu is presented outside of the first window”). The Accused Windows
`Devices therefore infringe these elements literally or, in the alternative, under the doctrine of equivalents.
`
`component includes a third
`window; the representation of the
`second window and the
`representation of the third window
`are elements of a menu;
`
`the menu is presented outside of the
`first window;
`
`Screenshot of a Windows 10 display in Tablet mode showing a Snap Assist menu beside the “snapped” window.
`
`
`
`the menu is moved as a function of
`a movement of the first window;
`
`and the menu is re-sized as a
`function of a re-sizing of the first
`window;
`
`If a user snaps the first window to the left, the Snap Assist menu will move to the right side of the screen (“the menu
`is moved as a function of a movement of the first window”) and, in Tablet mode, a user can re-size the Snap Assist
`menu by selecting and dragging the vertical bar in the middle of the screen to re-size the first window (“and the menu
`is re-sized as a function of a re-sizing of the first window”). The Accused Windows Devices therefore infringe these
`elements literally or, in the alternative, under the doctrine of equivalents.
`
`MICROSOFT CORP. EX. 1011
`Page 20 of 79
`
`

`

`Screenshot of a Windows 10 display in Tablet mode showing the first window snapped to the left, putting the Snap
`Assist menu on the right.
`
`
`
`Screenshot of a Windows 10 display in Tablet mode showing how re-sizing the first window also re-sizes the Snap
`Assist menu.
`
`
`
`MICROSOFT CORP. EX. 1011
`Page 21 of 79
`
`

`

`wherein the apparatus is configured
`such that the elements of the menu
`are each presented based on a z-
`order attribute of a corresponding
`application.
`
`An Accused Windows Device arranges the Snap Assist thumbnails (“the apparatus is configured such that the elements
`of the menu are each presented”) based on when the application window was last viewed or brought to the foreground
`by the user (“based on a z-order attribute of a corresponding application”)—i.e., the last-viewed application is leftmost
`on the top row of the menu, the application viewed before that is to its right, and so on, with the application viewed
`last placed in the bottom right of the menu (assuming more than one row). The Accused Windows Devices therefore
`infringe this element literally or, in the alternative, under the doctrine of equivalents.
`
`Screenshot of a Windows 10 display showing the Snap Assist menu.
`
`
`
`MICROSOFT CORP. EX. 1011
`Page 22 of 79
`
`

`

`Screenshot of a Windows 10 display showing the Snap Assist menu with the order of the thumbnails changed based
`on when the applications were last viewed.
`
`
`
`Each of Acer’s Accused Windows Devices running the Microsoft Windows 10 Operating System is an apparatus
`comprised of at least one processor (e.g., Intel Core i5) configured to communicate with a display (e.g., 14” LCD),
`at least one input device (mouse, keyboard, touchpad and/or touchscreen), and memory (RAM and hard drive)—see
`Exhibit 1, Acer Accused Windows Devices and Specifications; Exhibit 2, Acer Accused Windows Device Webpages.
`The Accused Windows Devices therefore infringe these elements of Claim 4 of U.S. Patent 9,423,923 literally or, in
`the alternative, under the doctrine of equivalents.
`
`An Accused Windows Device can store multiple applications (“a plurality of applications”) in its memory—for
`example, an instance of Microsoft Word (“a first application”) and an instance of Internet Explorer (“a second
`application”)—and display the first application in a window on the device’s screen (“utilize the display to display a
`first window of the first application”). The Accused Windows Devices therefore infringe these elements literally or, in
`the alternative, under the doctrine of equivalents.
`
`4. An apparatus, comprising:
`
`at least one processor configured
`for communication with:
`
`a display,
`
`at least one input device, and
`
`memory;
`
`utilize the memory to store a
`plurality of applications including a
`first application

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