EXHIBIT C1 PAGE 1 OF 27
`SMITH INTERFACE TECHNOLOGIES, LLC’S
`PATENT L.R. 3.1 PRELIMINARY INFRINGEMENT CONTENTIONS
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`EXHIBIT C1 - U.S. Patent No. 10,936,114 (Apple Watch)
`Claims 1, 27, 30, and 32
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`Smith Interface Technologies, LLC (“Smith Interface”) accuses Apple of infringing claims 1, 27, 30, and 32 of U.S. Patent No. 10,936,114
`(hereinafter “the ’114 Patent”). Smith Interface provides the following claim chart. See Exhibit C1.
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`This claim chart identifies specifically where each element of each Asserted Claim is found within each Accused Instrumentality and
`provides Apple’s notice of identified instrumentalities (including “the Accused System”) that incorporate or reflect the recited claim elements.
`This claim chart is not intended to be an expert report on infringement or provide detailed analysis of the claim terms or infringement. This claim
`chart includes information related to an assertion of infringement with respect to the *114 Patent Accused Products identified, including diagrams,
`web page screenshots, and other documentary evidence by way of example and not by way of limitation.
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`The Asserted Claims include elements that are implemented, at least in part, by instrumentalities described in confidential information not
`accessible to Plaintiff. In some instances, the precise processes and algorithms used are, at least in part, not publicly available. An analysis of
`Apple’s (or other third parties’) technical documentation and/or software source code may be necessary to more fully identify all infringing
`features and functionality. Accordingly, Smith Interface reserves the right to supplement these contentions once such information is made available
`to Smith Interface. Furthermore, Smith Interface reserves the right to revise these contentions, as appropriate, upon issuance of the Court’s Claim
`Construction Order.
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`The claim chart refers to the Accused System and the aforementioned products are included in (or can operate in conjunction with) the
`Accused System, as noted in the claim chart. To the extent the below claim chart relies on evidence for the Accused System, Smith Interface
`asserts that, on information and belief, any similarly-functioning system also infringe the charted claim. Smith Interface reserves the right to
`amend these infringement contentions with other products made, used, sold, imported, or offered for sale by Apple. Smith Interface also reserves
`the right to amend these infringement contentions by citing other claims of the *114 Patent, not listed in the claim chart, that are infringed by the
`Accused System. Smith Interface further reserves the right to amend these infringement contentions by adding, subtracting, or otherwise modifying
`content in the “Accused System” section.
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`To the extent there are any differences between the accused instrumentalities and the following claim elements, any such differences are
`insubstantial and are alleged to infringe under the doctrine of equivalents.
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`APPLE 1026
`Apple v. Smith Interface
`1 IPR2024-01091
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`EXHIBIT C1
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`PAGE 2 OF 27
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`Claim
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`Claim Elements
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`Exemplary Accused System (Apple Watch Series 8, WatchOS 9)
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`11
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`(a) An apparatus,
`comprising:
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`at least one non-transitory
`memory storing
`instructions and a
`plurality of applications;
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`a touch screen; and
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`one or more processors in
`communication with the
`at least one non-transitory
`memory and the touch
`screen, wherein the one or
`more processors execute
`the instructions to:
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`Apple Watch series 8 devices comprise at least one non-transitory memory storing instructions and a
`plurality of applications; a touch screen (e.g., Always-On Retina display, etc.); and one or more
`processors (e.g., S8 SiP with 64-bit dual-core processor, etc.) in communication with the at least one non-
`transitory memory and the touch screen.
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`See the evidence above and below, for example:
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`! Each element of the independent claims incorporates all elements of the independent claim. For example, any evidence provided in claim 1
`element (a) incorporates all claim elements 1(b)-(f).
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`EXHIBIT C1 PAGE 3 OF 27
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`Always-On Retina display
`Up to 1000 nits brightness
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`S8 SiP with 64-bit dual-core
`processor
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`https://www.apple.com/watch/compare/
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`(b) display, via the touch | Apple Watch series 8 devices are designed to display, via the touch screen (e.g., Always-On Retina
`screen, an object and at display, etc.), an object (e.g., one or more controls of Apple Watch face, etc.) and at least a portion of an
`least a portion of an interface (e.g., Apple Watch face, etc.);
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`interface;
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`See the evidence above and below, for example:
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`EXHIBIT C1 PAGE 4 OF 27
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`(c) detect a gesture on the | Apple Watch series 8 devices are designed to detect a gesture on the touch screen (e.g., Always-On
`touch screen on the Retina display, etc.) on the object (e.g., one or more controls of Apple Watch face, etc.),
`object;
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`See the evidence above and below, for example:
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`PAGE 5 OF 27
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`(d) when a magnitude of a
`duration of the gesture
`being detected on the
`touch screen on the object
`is less than a first
`magnitude threshold,
`perform an operation;
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`Apple Watch series 8 devices are designed to, when a magnitude of a duration of the gesture being
`detected on the touch screen (e.g., Always-On Retina display, etc.) on the object (e.g., one or more
`controls of Apple Watch face, etc.) is less than a first magnitude threshold, perform an operation;
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`See the evidence above and below, for example:
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`EXHIBIT C1 PAGE 6 OF 27
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`(e) when the magnitude of | Apple Watch series 8 devices are designed to, when the magnitude of the duration of the gesture being
`the duration of the gesture | detected on the touch screen (e.g., Always-On Retina display, etc.) on the object (e.g., one or more
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`being detected on the controls of Apple Watch face, etc.) is greater than the first magnitude threshold, perform a scaling in
`touch screen on the object | connection with at least the object, where the scaling includes a reduction in a size such that the size is
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`is greater than the first inversely related to the magnitude of the duration of the gesture being detected on the touch screen on the
`magnitude threshold, object;
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`perform a scaling in
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`connection with at least See the evidence above and below, for example:
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`the object, where the
`scaling includes a
`reduction in a size such
`that the size is inversely
`related to the magnitude
`of the duration of the
`gesture being detected on
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`EXHIBIT C1
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`PAGE 7 OF 27
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`the touch screen on the
`object; and
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`(f) when the magnitude of
`the duration of the gesture
`being detected on the
`touch screen on the object
`is greater than a second
`magnitude threshold,
`perform another
`operation.
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`Apple Watch series 8 devices are designed to, when the magnitude of the duration of the gesture being
`detected on the touch screen (e.g., Always-On Retina display, etc.) on the object (e.g., one or more
`controls of Apple Watch face, etc.) is greater than a second magnitude threshold, perform another
`operation.
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`See the evidence above and below, for example:
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`EXHIBIT C1
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`PAGE 8 OF 27
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`Infograph
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`(a) An apparatus,
`comprising:
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`at least one non-transitory
`memory storing
`instructions and a
`plurality of applications;
`
`a touch screen; and
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`one or more processors in
`communication with the at
`least one non-transitory
`memory and the touch
`screen, wherein the one or
`more processors execute
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`Apple Watch series 8 devices comprise at least one non-transitory memory storing instructions and a
`plurality of applications, a touch screen (e.g., Always-On Retina display, etc.); and one or more
`processors (e.g., S8 SiP with 64-bit dual-core processor, etc.) in communication with the at least one non-
`transitory memory and the touch screen, wherein the one or more processors execute the instructions to
`cause the apparatus to:
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`EXHIBIT C1 PAGE 9 OF 27
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`the instructions to cause
`the apparatus to:
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`Always-On Retina display
`Up to 1000 nits brightness
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`S8 SiP with 64-bit dual-core
`processor
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`https://www.apple.com/watch/compare/
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`(b) display an object on at | Apple Watch series 8 devices are designed to display an object (e.g., one or more controls of Apple
`least a portion of an Watch face, etc.) on at least a portion of an interface (e.g., Apple Watch face, etc.).
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`interface;
`See the evidence above and below, for example:
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`EXHIBIT C1 PAGE 10 OF 27
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`(c) detect a gesture via the | Apple Watch series 8 devices are designed to detect a gesture via the touch screen (e.g., Always-On
`touch screen on the Retina display, etc.) on the object (e.g., one or more controls of Apple Watch face, etc.).
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`object;
`See the evidence above and below, for example:
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`EXHIBIT C1 PAGE 11 OF 27
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`(d) perform a first Apple Watch series 8 devices are designed to perform a first function in a first touch state.
`function in a first touch
`state; See the evidence above and below, for example:
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`EXHIBIT C1 PAGE 12 OF 27
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`< Today 9:40
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`London
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`5:40PM
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`:a. 4:56AM
`& 9:15pPM
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`(e) perform a second Apple Watch series 8 devices are designed to perform a second function in a second touch state.
`function in a second touch
`state; and See the evidence above and below, for example:
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`EXHIBIT C1 PAGE 13 OF 27
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`Infograph
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`(f) during detection of at | Apple Watch series 8 devices are designed to, during detection of at least a portion of the gesture and
`least a portion of the based on a change in a duration of the gesture being detected via the touch screen (e.g., Always-On
`gesture and based on a Retina display, etc.) on the object (e.g., one or more controls of Apple Watch face, etc.), perform a scale
`change in a duration of the | operation in connection with the at least portion of the interface (e.g., Apple Watch face, etc.), where the
`gesture being detected via | scale operation includes a reduction in a size that is inversely related to the duration of the gesture being
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`the touch screen on the detected via the touch screen on the object.
`object, perform a scale
`operation in connection See the evidence above and below, for example:
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`with the at least portion of
`the interface, where the
`scale operation includes a
`reduction in a size that is
`inversely related to the
`duration of the gesture
`being detected via the
`touch screen on the object.
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`EXHIBIT C1
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`PAGE 14 OF 27
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`30
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`(a) An apparatus,
`comprising:
`
`at least one non-transitory
`memory storing
`instructions and a plurality
`of applications;
`
`a touch screen;
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`a vibrator; and
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`one or more processors in
`communication with the at
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`least one non-transitory
`memory, the touch screen,
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`Apple Watch series 8 devices comprise at least one non-transitory memory storing instructions and a
`plurality of applications; a touch screen (e.g., Always-On Retina display, etc.); a vibrator, and one or
`more processors (e.g., S8 SiP with 64-bit dual-core processor, etc.) in communication with the at least
`one non-transitory memory, the touch screen, and the vibrator.
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`See the evidence above and below, for example:
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`PAGE 15 OF 27
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`and the vibrator, wherein
`the one or more
`processors execute the
`instructions to cause the
`apparatus to:
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`Always-On Retina display
`Up to 1000 nits brightness
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`S8 SiP with 64-bit dual-core
`processor
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`https://www.apple.com/watch/compare/
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`EXHIBIT C1 PAGE 16 OF 27
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`Manage Apple Watch Haptic Alerts
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`1. Open the Settings app.
`2. Scroll down and tap Sounds & Haptics.
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`3. Turn Haptic Alerts on or off.
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`Haptic Alerts
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`Default
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`Prominent
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`https://support.apple.com/en-us/HT204793
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`EXHIBIT C1 PAGE 17 OF 27
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`(b) display a first object Apple Watch series 8 devices are designed to display a first object (e.g., one or more controls of Apple
`and at least one other Watch face, etc.) and at least one other object.
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`object;
`See the evidence above and below, for example:
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`(c) detect a gesture on the | Apple Watch series 8 devices are designed to detect a gesture on the touch screen (e.g., Always-On
`touch screen on the first Retina display, etc.) on the first object (e.g., one or more controls of Apple Watch face, etc.).
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`object;
`See the evidence above and below, for example:
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`EXHIBIT C1 PAGE 18 OF 27
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`(d) during detection of at | Apple Watch series 8 devices are designed such that, during detection of at least a portion of the gesture
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`least a portion of the before a completion thereof is detected, perform a scale operation, based on a change in a duration of the
`gesture before a gesture being detected on the touch screen (e.g., Always-On Retina display, etc.) on the first object (e.g.,
`completion thereof is one or more controls of Apple Watch face, etc.), on at least the at least one other object, where the scale
`detected, perform a scale | operation includes a reduction in a size that is inversely related to the duration of the gesture being
`operation, based on a detected on the touch screen on the first object.
`
`change in a duration of the
`gesture being detected on | See the evidence above and below, for example:
`the touch screen on the
`first object, on at least the
`at least one other object,
`where the scale operation
`includes a reduction in a
`size that is inversely
`related to the duration of
`the gesture being detected
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`EXHIBIT C1 PAGE 19 OF 27
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`on the touch screen on the
`first object; and
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`o
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`O 27
`P ODAY o 4, N,
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`NN
`S 'p.Q
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`N
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`(e) after at least a portion | Apple Watch series 8 devices are designed to, after at least a portion of the scale operation, vibrate the
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`of the scale operation, apparatus and perform an action.
`vibrate the apparatus and
`perform an action. See the evidence above and below, for example:
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`EXHIBIT C1 PAGE 20 OF 27
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`Manage Apple Watch Haptic Alerts
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`1. Open the Settings app.
`2. Scroll down and tap Sounds & Haptics.
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`3. Turn Haptic Alerts on or off.
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`Haptic Alerts
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`Default
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`Prominent
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`https://support.apple.com/en-us/HT204793
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`20
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`EXHIBIT C1
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`PAGE 21 OF 27
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`Infograph
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`. 7
`°T00AY * ‘m\
`S 0
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`32
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`(a) An apparatus,
`comprising:
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`Apple Watch series 8 devices comprise at least one non-transitory memory storing instructions and a
`plurality of applications; a touch screen (e.g., Always-On Retina display, etc.); and one or more
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`EXHIBIT C1 PAGE 22 OF 27
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`at least one non-transitory | processors (e.g., S8 SiP with 64-bit dual-core processor, etc.) in communication with the at least one non-
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`memory storing transitory memory and the touch screen.
`instructions and a plurality
`of applications; See the evidence above and below, for example:
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`a touch screen; and
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`one or more processors in
`communication with the at
`least one non-transitory
`memory and the touch
`screen, wherein the one or
`more processors execute
`the instructions to:
`
`Always-On Retina display
`Up to 1000 nits brightness
`
`S8 SiP with 64-bit dual-core
`processor
`
`https://www.apple.com/watch/compare/
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`EXHIBIT C1 PAGE 23 OF 27
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`(b) display, via the touch | Apple Watch series 8 devices are designed to display, via the touch screen (e.g., Always-On Retina
`screen, a first object and at | display, etc.), a first object (e.g., one or more controls of Apple Watch face, etc.) and at least one other
`least one other object; object.
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`See the evidence above and below, for example:
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`(c) detect at least one Apple Watch series 8 devices are designed to detect at least one component of a gesture on the touch
`component of a gesture on | screen on the first object (e.g., one or more controls of Apple Watch face, etc.).
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`the touch screen on the
`first object; See the evidence above and below, for example:
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`EXHIBIT C1 PAGE 24 OF 27
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`(d) when a first Apple Watch series 8 devices are designed such that when a first component of the gesture is detected
`component of the gesture | where a magnitude of a duration of the gesture being detected on the touch screen (e.g., Always-On
`is detected where a Retina display, etc.) on the first object (e.g., one or more controls of Apple Watch face, etc.) is less than a
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`magnitude of a duration of | first magnitude threshold, perform a function upon a cessation of the gesture being detected.
`the gesture being detected
`on the touch screen on the | See the evidence above and below, for example:
`first object is less than a
`first magnitude threshold,
`perform a function upon a
`cessation of the gesture
`being detected;
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`EXHIBIT C1
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`PAGE 25 OF 27
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`O y )’o
`'o"\,‘()DAY ’ +7ao~
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`e
`S®
`A
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`004>
`(i
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`(e) when a second
`component of the gesture
`is detected where the
`magnitude of the duration
`of the gesture being
`detected on the touch
`screen on the first object
`is greater than the first
`magnitude threshold,
`perform a scale operation
`for the at least one other
`object, where the scale
`operation includes a
`reduction in a size so as to
`be inversely related to the
`
`Apple Watch series 8 devices are designed such that when a second component of the gesture is detected
`where the magnitude of the duration of the gesture being detected on the touch screen (e.g., Always-On
`Retina display, etc.) on the first object (e.g., one or more controls of Apple Watch face, etc.) is greater
`than the first magnitude threshold, perform a scale operation for the at least one other object, where the
`scale operation includes a reduction in a size so as to be inversely related to the magnitude of the
`duration of the gesture being detected on the touch screen on the first object.
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`See the evidence above and below, for example:
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`EXHIBIT C1 PAGE 26 OF 27
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`magnitude of the duration
`of the gesture being
`detected on the touch
`screen on the first object;
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`and
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`(f) when a third Apple Watch series 8 devices are designed such that when a third component of the gesture is detected
`component of the gesture | where the magnitude of the duration of the gesture being detected on the touch screen (e.g., Always-On
`is detected where the Retina display, etc.) on the first object (e.g., one or more controls of Apple Watch face, etc.) is greater
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`magnitude of the duration | than a second magnitude threshold, perform another function.
`of the gesture being
`detected on the touch See the evidence above and below, for example:
`screen on the first object
`is greater than a second
`magnitude threshold,
`perform another function.
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`EXHIBIT C1
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`PAGE 27 OF 27
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`Infograph
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