Here it is, the new complaint [PDF] Motorola Mobility has lodged with the ITC. There are a zillion attachments, which I'll provide in full as we obtain them. Meanwhile, you can get started. The complaint begins on page 12 of the PDF.
The accused products include Apple's iPod Touch, iPhone 3GS, iPhone 4, iPhone 4S, iPad2, "the new Apple iPad (aka the iPad3), the Mac Pro, iMac, Mac mini, MacBook Pro, and MacBook Air. They ask for the following relief:
In short, it's WWIII in the patent universe. Remember how we used to say that no one would ever be so foolish as to start a patent war, because it'd be destructive to everyone in it? Guess what? Apple decided on going thermonuclear, and here we are. Talk about your infinite loop. How wasteful is this?
- an immediate investigation pursuant to Section 337 of the Tariff Act of 1930;
- setting of a target date of no more than 15 months;
- a hearing to determine if there has been a violation of Section 337;
- a permanent exclusion order directed to products manufactured by Apple, its subsidiaries, related companies and agents, "excluding entry into the United States of wireless communications devices, portable music and data processing devices, computers, and components thereof that infringe;
- that a permanent cease and desist order issue prohibiting Apple and all the rest listed above from "engaging in the importation, sale for importation, marketing and/or advertising, distribution, offering for sale, sale, sale after importation, or other transfer within the United States of wireless communications devices, portable music..." etc.
One thing I discern: do not mess with Google. They have apparently an endless supply of ninja patent lawyers. This filing is by Quinn Emanuel, the same law firm that we've been watching represent Samsung against Apple in California. The mighty John Quinn's law firm, in other words. The complaint is signed by Charles K. Verhoeven.
The patents are:
There are foreign counterparts listed for the patents, and a non-technical description of each one. I'll add the exhibits and appendices as I have them.
- No. 5,883,580, titled "Geographic-Temporal Significant Messaging," which issued on March 16, 1999;
- No. 5,922,047, titled "Apparatus, Method and System for Multimedia Control and Communication," which is
sued on July 13, 1999;
- No. 6,425,002, titled "Apparatus and Method for Handling Dispatching Messages for Various Applications of a Communication Device," which issued on July 23, 2002;
- No. 6,493,673, titled "Markup Language for Interactive Services And Methods Thereof", which issued on December 10, 2001;
- No. 6,983,370, titled "System For Providing Continuity Between Messaging Clients And Method Therefor," which issued on January 3, 2006;
- No. 7,007,064, titled "Method And Apparatus For Obtaining And Managing Wirelessly Communicated Content," which issued on February 28, 2006;
- No. 7,383,983, titled "System And Method For Managing Content Between Devices In Various Domains," which issued on June 10, 2008.
Wow. 187 attachments. That's all I can say. Just wow.
Let's start with the trimmings, which are listed by numbers, which isn't too helpful, but after we get them all listed, we can go through and figure it all out bit by bit:
It may take a few moments for some of them to resolve. This is hot off the griddle. Lots more to come. The complaint, on page 21, lists 5 "confidential" exhibits, which of course we won't be able to obtain.
Update: We're having upload problems with the exhibits, and we haven't yet figured out why, so please be patient. Some of them do resolve now, but quite a few do not. But we will persist until they all work.
And just so you know, if you register, you can gain free access to the documents at the ITC's website. Just go here and sign up for the EDIS program, if you don't want to wait for us to get pulled together, and you can access the documents, using the number of the case to find them.