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HTC's complaint against Apple examined

Okay, we've just gotten the full complaint HTC filed with the International Trade Commission this morning, alleging that the iPhone, iPad, and iPod infringe five of its patents and asking for sales and imports to be halted. What's odd here is that HTC hasn't yet filed a lawsuit in federal court, which could mean a lot of things -- HTC could just be banking on the ITC's somewhat faster process to force Apple's hand, or it could be less sure of its patent claims and avoiding the harsher scrutiny of a courtroom in favor of an administrative decision. We can't say for sure what the reasoning is -- but we can read the ITC complaint and break down the claims, and that's exactly what we're going to do. It's all after the break, grab the PDF or check out the gallery and follow along.

Okay, so HTC's claiming that the iPhone, iPad, and iPod infringe upon five total patents, and ITC complaints are even nice and specific about which claims of the patents are in question. Let's break 'em down:

Patent #6,999,800 - Method for power management of a smartphone: HTC's asserting seven of the 14 claims in this patent, which covers independently switching the phone and PDA subsystems of a smartphone between off, standby, and normal in order to conserve power. This one obviously only concerns the iPhone and potentially the iPad 3G, since this patent only covers devices that have a "mobile phone system" -- the ITC will have to decide if the iPad 3G's data modem falls into that definition.

Patent #5,541,988 - Telephone dialler with a personalized page organization of telephone directory memory: These next three are related, as they were split apart from a single original patent application. '988 here has some 32 claims, of which HTC is only asserting two against Apple -- the first is a speed dial system with open and locked banks of numbers that requires an access control to get at the private bank, and the second involves scanning through a list of stored numbers with a "scan manipulation device." Obviously the ITC will have to decide if the iPhone's screen meets that definition.

Patent #6,058,183 (PDF) - Telephone dialler with a personalized page organization of telephone directory memory: This one also has to do with the phone dialer, obviously -- HTC is alleging three claims out of 32, which covers operating a telephone dialer with memory organized into multiple directories composes of pages, moving between the pages with a "page selection device," scanning through the telephone information on the page, selecting the number, and placing a call or adding a number using the numeric keypad. It's hard to see how the iPod and either iPad fall under some of these claims, since they can't place calls.

Patent #6,320,957
- Telephone dialler with easy access memory: The third of the dialing troika. '957 has 44 total claims, of which HTC alleges Apple infringes eight, covering essentially the same territory as the others: a dialer with memory that's organized into pages that can be accessed by ID numbers that can be displayed on the screen, as well as matching caller ID information to the address book and displaying the names on the screen. Again, it's hard to see how the iPod or either iPad would infringe some of these claims, since they can't place or receive calls.

Patent #7,716,505 (PDF) - Power control methods for a portable electronic device: This one was just granted yesterday -- we get the feeling HTC was waiting on it before filing the ITC complaint. It only has four total claims, and HTC's alleging Apple infringes three. They cover moving data from RAM to flash and cutting power to the RAM, CPU and flash when the battery amount falls below a certain level and restoring operation once the battery is charged back up, and turning back on when an input signal is received. We honestly don't know if Apple's devices work this way, but those are the claims -- and this one could potentially cover the iPod and iPad as well, so we can see why HTC would wait on it to be granted.

Okay, so there are the five. Overall we're going to have to say they don't seem nearly as strong a group as the 20 Apple claimed in its lawsuit, but remember, HTC only has to prove infringement of one of these claims to win the case. We'll see what the ITC has to say, stay tuned.