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Order Granting Motion For Preliminary Injunction - United States ...

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<strong>United</strong> <strong>States</strong> District Court<br />

<strong>For</strong> the Northern District of California<br />

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results as the user types his or her query,” because “[b]y the time of the invention, consumer access<br />

to broadband Internet connections was widespread.” Carbonell Decl. 144. Dr. Carbonell’s<br />

explanation for the supposed obviousness is a non sequitur, and furthermore does not even attempt<br />

to address any of the relevant secondary considerations identified in KSR. See Polish Reply Decl.<br />

99-101 (pointing out deficiencies in Dr. Carbonell’s declaration). Samsung’s evidence in<br />

support of its obviousness defense thus falls far short of raising a substantial question of invalidity<br />

sufficient to overcome the presumption of validity.<br />

In sum, Apple has shown that claims 6 and 19 of the ’604 Patent are likely both valid and<br />

infringed. Apple has therefore shown a likelihood of prevailing on the merits of the ’604 Patent.<br />

2. U.S. Patent No. 5,946,647 (Links for Structures)<br />

U.S. Patent No. 5,946,647 (“the ’647 Patent”), entitled “System and Method for Performing<br />

an Action on a Structure in Computer-Generated Data,” was filed on February 1, 1996, and issued<br />

on August 31, 1999. The ’647 Patent is directed to a computer-based system and method for<br />

detecting structures, such as phone numbers, post-office addresses, and dates, and performing<br />

actions on the detected structures. See ’647 Patent Abstract, 1:8-16. The ’647 Patent sought to<br />

overcome certain deficiencies in the prior art that inhibited a user’s ability to easily perform<br />

different desired actions on information encountered in a given application. Conventional systems<br />

existed to help search a file or document for information using pattern analysis, but upon<br />

identifying such information, the user would have to copy-and-paste that information into whatever<br />

field or application the user wished in order to use the information. ’647 Patent 1:42-50.<br />

The ’647 system relies on an “analyzer server” component that is programmed to recognize<br />

a wide range of data patterns (called “structures” in the patent) in data from a wide range of files,<br />

such as text messages, emails, and web pages. Client applications (e.g., word processors) submit<br />

documents to the analyzer server for detection of structures. After the analyzer server recognizes<br />

structures in a document, it links each structure to operations (called “actions”) commonly<br />

performed on data of that type (such as linking phone numbers to the functions for calling or<br />

storing phone numbers in the address book). It then returns the list of detected structures and links<br />

to the client application.<br />

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Case No.: 12-cv-00630-LHK<br />

ORDER GRANTING MOTION FOR PRELIMINARY INJUNCTION

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