Free Declaration in Support - District Court of California - California

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EXHIBIT A
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EXHIBIT A
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EXHIBIT B

Preliminary Analysis of Certain Synaptics Patents
Elantech Devices Corp.

Issues
Whether Elantech's products infringe three of Synaptics' patents - 5,543,591 (`591) - 6,380,931 (`931) - 5,943,052 (`052)

Outline of Discussion
Elantech's products
TouchPad: A pointing devices which use the movement of finger on the pad to direct the cursor in the computer

Non-infringement Analysis
Understand claimed inventions Patent by patent, claim by claim analysis

Summary of Preliminary Findings

This is only for settlement discussion
This is only for settlement discussion with Synaptics Distribution of these slides should be limited Should be kept per retention policy

The `591 Patent
Object Position Detector With Edge Motion Feature and Gesture Recognition 8 independent claims(claim 1, 2, 4, 6, 7, 9, 10, and 11) and 3 dependent claims

Elements of Claim 1 in `591 Patent
A method for recognizing a tap gesture made on a touch-sensor pad in a touch-sensing system providing X and Y position information to a host, including the steps of: detecting the occurrence of a tap gesture made by a conductive tapping object on the touch-sensor pad; sending a signal to the host indicating the occurrence of said tap gesture; and sending X and Y position information to said host to substantially cancel out any unintended lateral motion of said tapping object on said touch-sensor pad during said tap gesture.

Preliminary Findings
Elantech's product does not employ the method :" sending X and Y position information to said host to substantially cancel out any unintended lateral motion of said tapping object on said touch-sensor pad during said tap gesture. " Elantech's product does not employ the method as claimed in claim 1 of the `591 patent

Elements of Claim 2 in `591 Patent
A method for recognizing a tap gesture made on a touch-sensor pad in a touch-sensing system providing X and Y position information to a host, including the steps of: detecting the occurrence of a tap gesture made by a tapping object on the touch-sensor pad; detecting in which of a plurality of predefined regions said tap gesture occurred; and sending a signal to the host indicating the occurrence of said tap gesture and in which of said predefined regions on said sensor pad said tap gesture occurred.

Preliminary Findings
Elantech's product does not employ the method :" providing X and Y position information to a host " Elantech's product does not employ the method as claimed in claim 2 of the `591 patent

Elements of Claim 4

in `591 Patent

A method for recognizing a tap gesture made on a touch-sensor pad in a touch-sensing system providing X and Y position information to a host, including the steps of: detecting a presence of a conductive object on the touch-sensor pad; comparing the amount of time said conductive object is present on said touch pad with a reference amount of time; comparing the amount of motion made by said conductive object while it is present on said touch pad with a reference amount of motion; initiating a signal to the host indicating the occurrence of said tap gesture if the amount of time said conductive object is present on said touch pad is less than said reference amount of time and if the amount of motion made by said conductive object while it is present on said touch pad is less than said reference amount of motion, and maintaining said signal for a predetermined period of time; and sending X and Y position information to said host to substantially cancel out any unintended lateral motion of said tapping object on said touch-sensor pad during said tap gesture.

Preliminary Findings
Elantech's product does not employ the method :"sending X and Y position information to said host to substantially cancel out any unintended lateral motion of said tapping object on said touch-sensor pad during said tap gesture." Elantech's product does not employ the method as claimed in claim 4 of the `591 patent

Elements of Claim 6

in `591 Patent

A method for recognizing a double tap gesture made on a touch-sensor pad in a touchsensing system providing X and Y position information to a host, including the steps of: detecting a first presence of a conductive object on the touch-sensor pad; comparing the duration of said first presence with a first reference amount of time: initiating a first signal to the host indicating the occurrence of said gesture if the duration of said first presence is less than said first reference amount of time; terminating said first signal if a second reference amount of time passes before a second presence is detected; detecting a second presence of said conductive object on the touch-sensor pad; comparing the duration of said second presence with a third reference amount of time; terminating said first signal if the duration of said second presence is less than said third reference amount of time; and sending a second signal to said host indicating said second gesture after the termination of said first signal.

Preliminary Findings
Elantech's product does not employ the methods :" providing X and Y position information to a host " Elantech's product does not employ the method as claimed in claim 6 of the `591 patent

Elements of Claim 7

in `591 Patent

A method for recognizing a hop gesture made on a touch-sensor pad in a touch-sensing system providing X and Y position information to a host, including the steps of: detecting a first presence of a conductive object at a first position on the touch-sensor pad; detecting a second presence of said conductive object at a second position on said touchsensor pad; comparing the duration of said second presence to a predetermined time; comparing the amount of time between said first and second presences with a reference amount of time; comparing the distance between said first and second positions with a reference distance; and sending a hop signal to the host indicating the occurrence of said hop gesture if the duration of said second presence is less than said predetermined time, if the amount of time between said first and second presences is less than said reference amount of time, and if the distance between said first and second positions is more than said reference distance.

Preliminary Findings
Elantech's product does not employ the method :"A method for recognizing a hop gesture " Elantech's product does not employ the method as claimed in claim 7 of the `591 patent

Elements of Claim 9

in `591 Patent

A method for recognizing a drag gesture made on a touch-sensor pad in a touch-sensing system providing X and Y position information to a host, including the steps of: detecting a first presence of a conductive object on the touch-sensor pad; comparing the duration of said first presence with a first reference amount of time; initiating a drag gesture signal to the host indicating the occurrence of a gesture if the duration of said first presence is less than said first reference amount of time; detecting a second presence of said conductive object on the touch-sensor pad; comparing the duration between said first presence and second presence with a second reference amount of time; maintaining said drag gesture signal and repeatedly sending X and Y position information to said host for the duration of said second presence if the amount of time between said first presence and second presence is less than said second reference amount of time.

Preliminary Findings
Elantech's product does not employ the method :"maintaining said drag gesture
signal and repeatedly sending X and Y position information to said host "

Elantech's product does not employ the method as claimed in claim 9 of the `591 patent

Elements of Claim 10

in `591 Patent

A method for recognizing a zigzag gesture made on a touch-sensor pad in a touch-sensing system providing X and Y position information to a host, including the steps of: detecting a presence of a first conductive object at a first position on the touch-sensor pad; detecting an apparent increase in size and apparent first change in position of said first conductive object: caused by presence of a second conductive object during said presence of said first conductive object; detecting an apparent decrease in size and apparent second change in position of said first conductive object caused by removal of said second conductive object during said presence of said first conductive object; and sending a zigzag signal to the host if said apparent increase in size of said first conductive object is greater than a first threshold, said apparent change in position of said object is greater than a second threshold, said apparent decrease in size of said first conductive object is greater than a third threshold, and said second change in position is to a position within a threshold distance of said first position.

Preliminary Findings
Elantech's product does not employ the method :"A method for recognizing a zigzag gesture " Elantech's product does not employ the method as claimed in claim 10 of the `591 patent

Elements of Claim 11

in `591 Patent

A method for recognizing a push gesture made on a touch-sensor pad in a touch-sensing system providing X and Y position information to a host, including the steps of: detecting a presence of a conductive object on the touch-sensor pad at a pressure greater than a first threshold; Sending a signal to the host indicating the occurrence of a pushing gesture if the presence of said conductive object on the touch-sensor pad at a pressure greater than said first threshold is detected and setting a virtual mouse button in response thereto; detecting when said pressure of said conductive object falls below a second threshold lower than said first threshold; and sending periodic X and Y position information to said host while said pressure remains above said second threshold; and sending a signal to the host indicating the end of said pushing gesture when said pressure of said conductive object on the touch-sensor pad falls below said second threshold and resetting said virtual mouse button in response thereto.

Preliminary Findings
Elantech's product does not employ the method :"A method for recognizing a push gesture " Elantech's product does not employ the method as claimed in claim 11 of the `591 patent

The `931 Patent
Object Position Detector With Edge Motion Feature and Gesture Recognition 3 independent claims(claim 1, 5, 7) and 4 dependent claims

Elements of Claim 1

in `931 Patent

A method for recognizing a tap gesture made on a touch-sensor pad in a touch sensing system providing X and Y position information to a host, including: detecting a presence of a conductive object on the touch-sensor pad; comparing the amount of time said conductive object is present on said touch pad with a reference amount of time; comparing the amount of motion made by said conductive object while it is present on said touch pad with a reference amount of motion; initiating a signal to the host indicating the occurrence of said tap gesture if the amount of time said conductive object is present on said touch pad is less than said reference amount of time and if the amount of motion made by said conductive object while it is present on said touch pad is less than said reference amount of motion; and maintaining said signal for a predetermined period of time.

Preliminary Findings
Elantech's product does not employ the method :"providing X and Y position information to a host" and "comparing the amount of motion " Elantech's product does not employ the method as claimed in claim 1 of the `931 patent

Elements of Claim 5

in `931 Patent

A method for recognizing a tap gesture made on a touch-sensor pad in a touch sensing system providing X and Y position information to a host, including: detecting the occurrence of a tap gesture made by a tapping object on the touch-sensor pad; detecting in which of at least one corner of the touch-sensor pad said tap gesture occurred; and sending a signal to the host indicating the occurrence of said tap gesture and in which of at least one corner of said touch-sensor pad said tap gesture occurred.

Preliminary Findings
Elantech's product does not employ the method :"providing X and Y position information to a host" and"detecting the occurrence of a tap gesture " for "sending a signal to the host
indicating the occurrence of said tap gesture and in which of at least one corner of the touch-sensor pad "

Elantech's product does not employ the method as claimed in claim 5 of the `931 patent

Elements of Claim 7

in `931 Patent

A method for recognizing a tap gesture made on a touch-sensor pad in a touch sensing system providing X and Y position information to a host, including the steps of: detecting a presence of a conductive object on the touch-sensor pad; comparing the amount of time said conductive object is present on said touch pad with a reference amount of time; comparing the amount of motion made by said conductive object while it is present on said touch pad with a reference amount of motion; initiating a signal to the host indicating the occurrence of said tap gesture if the amount of time said conductive object is present on said touch pad is less than said reference amount of time and if the amount of motion made by said conductive object while it is present on said touch pad is less than said reference amount of motion, and maintaining said signal for a predetermined period of time; and sending X and Y position information to said host to substantially cancel out any unintended lateral motion of said tapping object on said touch-sensor pad during said tap gesture.

Preliminary Findings
Elantech's product does not employ the method :"sending X and Y position
information to said host to substantially cancel out any unintended lateral motion of said tapping object on said touch-sensor pad during said tap gesture. "

Elantech's product does not employ the method as claimed in claim 7 of the `931 patent

The `052 Patent
Method and Apparatus For Scroll Bar Control 2 independent claims(claim 1, 14) and 18 dependent claims

Elements of Claim 1

in `052 Patent

A system for converting user-applied object motion on a cursorcontrol device into graphical user interface window scrolling messages, said system comprising: a cursor-control input device which includes a touchpad in electrical communication with a computer, said input device forwarding data packets to said computer, said input device including a scrolling zone; a data packet processor that generates a plurality of messages in response to object motion applied by the user entirely within said scrolling zone on said input device and causes an active window in said graphical user interface to scroll visual display data in response to said messages sent by said packet processor.

Preliminary Findings
Elantech's product does not include "a data packet processor" Elantech's product does not infringe claim 1 of the `052 patent

Elements of Claim 14

in `052 Patent

A method of converting user-applied object motion on a cursor-control device into graphical user interface window scrolling messages, said method comprising: forwarding a plurality of data packets from a cursor-control input device which includes a touchpad having a scrolling zone to a data packet processor, said data packets representing object motion applied by a user to the input device; generating a plurality of messages in response to the user-applied object motion; forwarding said messages to an application controlling an active window in said graphical user interface; scrolling visual display data in response to said messages sent by packet processor.

Preliminary Findings
Elantech's product does not employ the method :"scrolling
visual display data in response to said messages sent by packet processor. "

Elantech's product does not employ the method as claimed in claim 14 of the `052 patent

Summary of Preliminary Findings
The `591 Patent (Method)
Elantech's product does not employ any method as claimed in any independent claim of the `591 patent Therefore, Elantech's product does not infringe the `591 Patent

Summary of Preliminary Findings (Cont.)
The `931 Patent(Method)
Elantech's product does not employ any method as claimed in any independent claim of the `931 patent Therefore, Elantech's product does not infringe the `931 Patent

Summary of Preliminary Findings (Cont.)
The `052 Patent (System and Method) Elantech's product does not include all elements of claim1 (the only independent system claim) Elantech's product does not employ the method as claimed in claim 14 (the only independent method claim) Therefore, Elantech's product does not infringe the `052 Patent