Exhibit O

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

EXHIBIT A-1

Invalidity of U.S. Patent No. 8,589,541 in view of U.S. Patent Pub. No. 2008/0160958 (“Abichandani”)

U.S. Patent Publication No. 2008/0160958 (“Abichandani”) was published on July 3, 2008 and therefore constitutes prior art under at least 35 

U.S.C. §§ 102(a), (b), and/or (e) as to the Asserted Claims of U.S. Pat. No. 8,589,541 (“the ’541 Patent”). Abichandani anticipates and/or renders 

obvious the Asserted Claims, either alone or in combination with one or more references identified in Defendants’ Cover Pleading. 

To the extent Plaintiff argues that Abichandani does not disclose any element below, a person of ordinary skill in the art would have found it 

obvious in view of Abichandani alone, with the knowledge of a person of ordinary skill in the art, and/or in view of the prior art systems and 

references disclosed in § II of Defendants’ Invalidity Contentions and the exemplary citations and commentary provided for this claim in Exhibits 

A-2 to A-25 and Appendix A-A thereto. A person of ordinary skill in the art would have been motivated to combine and would have a reasonable 

expectation of success in combining these references because the cited references relate to the same technical field as Abichandani (i.e., network 

and device management). 

The chart below provides representative examples of where each element is found within Abichandani. Citations are meant to be exemplary, not 

exhaustive, and Defendants reserve the right to identify and discuss additional portions of the reference in support of its contentions and/or to rebut 

arguments made by Plaintiff. Citations to figures, drawings, tables, and the like include reference to any accompanying or related text. All 

internal cross references are meant to incorporate the cross-referenced material as if fully set forth therein. 

It is Defendants’ position that Plaintiff’s Disclosure of Asserted Claims and Infringement Contentions have not established that any accused 

product or service infringes any valid claim. Thus, Defendants’ statements below should not be treated as an admission, implication, or suggestion 

that Defendants agree with Plaintiff regarding either the scope, construction, or interpretation of any of the Asserted Claims of the infringement 

theories advanced by Plaintiff in its Preliminary Infringement Contentions, including whether any Asserted Claims satisfies 35 U.S.C. §§ 101 or

112. In certain cases, Defendants specify non-limiting examples of where its application of the prior art is based on Plaintiff’s apparent 

application of the claim element. These statements are not intended to suggest that Defendants agree with Plaintiff’s application of any claim 

term, suggest a proposed construction at this stage of the case, or suggest that construction is needed, as the parties are not required to exchange 

terms for construction or proposed constructions until a later date. 

Plaintiff has yet to identify of the Asserted Claims that it contends is not anticipated and/or rendered obvious by Abichandani. Defendants 

therefore expressly reserve the right to respond to any such contention, including by identifying additional obviousness combinations, if Plaintiff 

makes any such contention.

Where Defendants state that Abichandani “discloses” a limitation, that disclosure may be express, implicit, and/or inherent. 

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani 

U.S. Patent No. US 8,589,541 (the “’541 Patent”)

Claim Language Exemplary Disclosure of Abichandani

1. A non-transitory computer-readable 

storage medium storing machineexecutable instructions that, when 

executed by one or more processors of a 

wireless end-user device, cause the one or 

more processors to: 

To the extent the preamble may be limiting, Abichandani discloses the preamble. For example: 

[Abstract] A system and method are described whereby a mobile device controls access to mobile 

applications based on access conditions associated with a current access network. To prevent mobile 

applications from running when the access conditions are not suitable, the mobile device includes a policy 

database used to store a list of access conditions that are inappropriate for launching the installed 

applications. The access conditions are based on the type of the current access network used by the mobile 

device for launching or maintaining the requested application session. The access conditions indicate whether 

the mobile device is currently accessing its home network or roaming on another provider's network. 

Similarly, the access conditions indicate the type of network access interface used by the current network to 

provide the data connection necessary to run the requested application. The policy database correlates 

predetermined actions with the access conditions associated with a given application session. 

[0004] Embodiments of the invention are used to provide a system and method for controlling access to 

mobile applications from the mobile device based on access conditions associated with a current access 

network, To prevent one or more applications or services from running when the access conditions are not 

suitable, the memory of the mobile device includes a policy or application access database, which is used to 

store a list of access conditions that are inappropriate for launching the installed applications. In 

embodiments, the access conditions are based on the type of the current access network used by the mobile 

device for launching or maintaining the requested application session. For example, the access conditions 

may indicate whether the mobile device is currently accessing its home network or roaming on another 

provider's network. Similarly, the access conditions may indicate the type of network access interface used by 

the current network to provide the data connection necessary to run the requested application. The policy 

database correlates predetermined actions with current status of access conditions associated with a given 

application session. In one embodiment, when the mobile device accesses a network having an access 

technology specification with insufficient data handling capabilities for the requested application, the mobile 

device denies access to the data-intensive application or service specified in the policy database. Similarly, to 

avoid unwanted roaming charges, the mobile device's policy database includes instructions to suspend any 

scheduled firmware updates via a firmware over the air (FOTA) application until the mobile device returns to 

its home network.

[0005] In one aspect of the invention, a method is provided for controlling access to an application, the 

application capable of running on a mobile device by connecting to an access network, the method 

comprising registering the application with the mobile device, populating a record on the mobile device, the 

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record specifying one or more conditions for controlling access to the application, the one or more conditions 

associated with the access network, monitoring the one or more conditions, and controlling access to the 

application from the mobile device based on the one or more conditions.

[0006] In another aspect of the invention, a mobile device is provided, the mobile device capable of running 

an application by connecting to an access network, the mobile device comprising a processor, a wireless 

interface for connecting to the access network, and a computer readable medium having thereon instructions 

for registering the application with the mobile device, populating a record on the mobile device, the record 

specifying one or more conditions for controlling access to the application, the one or more conditions 

associated with the access network, monitoring the one or more conditions, and controlling access to the 

application from the mobile device based on the one or more conditions.

[0007] In still another aspect of the invention, a system is provided for controlling access to an application, 

the application capable of running on a mobile device by connecting to an access network, the system 

comprising (a) the mobile device capable of storing a record for specifying one or more conditions for 

controlling access to the application, the one or more conditions associated with the access network, the 

mobile device comprising an access network monitor module configured to monitor the one or more 

conditions, and an application manager module configured to control access to the application from the 

mobile device based on the one or more conditions reported by the access network monitor module, and (b) a 

device management server having a management connection to the mobile device for populating the record.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) identify a service usage activity of the 

wireless end-user device, the service 

usage activity being associated with a first 

software component of a plurality of 

software components on the wireless enduser device, the service usage activity 

comprising one or more prospective or 

successful communications over a 

wireless network; 

Abichandani discloses this limitation. For example:

[Abstract] A system and method are described whereby a mobile device controls access to mobile 

applications based on access conditions associated with a current access network. To prevent mobile 

applications from running when the access conditions are not suitable, the mobile device includes a policy 

database used to store a list of access conditions that are inappropriate for launching the installed 

applications. The access conditions are based on the type of the current access network used by the mobile 

device for launching or maintaining the requested application session. The access conditions indicate whether 

the mobile device is currently accessing its home network or roaming on another provider's network. 

Similarly, the access conditions indicate the type of network access interface used by the current network to 

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provide the data connection necessary to run the requested application. The policy database correlates 

predetermined actions with the access conditions associated with a given application session.

[0004] Embodiments of the invention are used to provide a system and method for controlling access to 

mobile applications from the mobile device based on access conditions associated with a current access 

network, To prevent one or more applications or services from running when the access conditions are not 

suitable, the memory of the mobile device includes a policy or application access database, which is used to 

store a list of access conditions that are inappropriate for launching the installed applications. In 

embodiments, the access conditions are based on the type of the current access network used by the mobile 

device for launching or maintaining the requested application session. For example, the access conditions 

may indicate whether the mobile device is currently accessing its home network or roaming on another 

provider's network. Similarly, the access conditions may indicate the type of network access interface used by 

the current network to provide the data connection necessary to run the requested application. The policy 

database correlates predetermined actions with current status of access conditions associated with a given

application session. In one embodiment, when the mobile device accesses a network having an access 

technology specification with insufficient data handling capabilities for the requested application, the mobile 

device denies access to the data-intensive application or service specified in the policy database. Similarly, to 

avoid unwanted roaming charges, the mobile device's policy database includes instructions to suspend any 

scheduled firmware updates via a firmware over the air (FOTA) application until the mobile device returns to 

its home network.

[0005] In one aspect of the invention, a method is provided for controlling access to an application, the 

application capable of running on a mobile device by connecting to an access network, the method 

comprising registering the application with the mobile device, populating a record on the mobile device, the 

record specifying one or more conditions for controlling access to the application, the one or more conditions 

associated with the access network, monitoring the one or more conditions, and controlling access to the 

application from the mobile device based on the one or more conditions.

[0006] In another aspect of the invention, a mobile device is provided, the mobile device capable of running 

an application by connecting to an access network, the mobile device comprising a processor, a wireless 

interface for connecting to the access network, and a computer readable medium having thereon instructions 

for registering the application with the mobile device, populating a record on the mobile device, the record 

specifying one or more conditions for controlling access to the application, the one or more conditions 

associated with the access network, monitoring the one or more conditions, and controlling access to the 

application from the mobile device based on the one or more conditions.

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[0007] In still another aspect of the invention, a system is provided for controlling access to an application, 

the application capable of running on a mobile device by connecting to an access network, the system 

comprising (a) the mobile device capable of storing a record for specifying one or more conditions for 

controlling access to the application, the one or more conditions associated with the access network, the 

mobile device comprising an access network monitor module configured to monitor the one or more 

conditions, and an application manager module configured to control access to the application from the 

mobile device based on the one or more conditions reported by the access network monitor module, and (b) a 

device management server having a management connection to the mobile device for populating the record.

[0013] Turning to FIG. 1, an implementation of a system contemplated by an embodiment of the invention is 

shown with reference to a mobile network environment. In the illustrated embodiment, the user device 100 is 

a mobile device, such as a wireless telephone or a portable computer capable of launching an application by 

connecting to an application server 106 via one or more access networks 102, 104. The application server 106 

is responsible for content delivery to the one or more applications running on a mobile device 100. For 

example, when the mobile device 100 includes a multimedia streaming application, the application server 106 

employs a Real-Time Transfer Protocol (RTP) to stream the requested content to the multimedia streaming 

application launched on the mobile device 100. In this embodiment, the application server 106 is part of a 

core network 108, which is an IP Multimedia Services (IMS) network responsible for session control and 

Quality of Service (QoS) management of ongoing application sessions. Alternately, the application server 

106 is located outside of the core network 108, whereby the core network 108 connects to the application 

server 106 via the Internet 110. In embodiments where the IMS core network 108 is not implemented, the 

application server 106 may be part of one of the access networks 102, 104, for example, or it may connect to 

the access networks 102, 104 via the Internet 110.

[0014] As illustrated in FIG. 1, the access networks 102, 104 interface with the mobile device 100 in 

accordance with a network interface specification 112. Preferably, the network interface specification 112 

complies with one or more wireless access standards, each having corresponding data handling capabilities, 

such as average and maximum uplink/downlink throughput speeds. In embodiments, the wireless network 

standards include CDMA 2000 1X, 1xEV-DO, 1xEV-DV, EDGE, and HSPDA network technologies, or 

combinations thereof In order to launch the application 106, the mobile device 100 typically accesses its 

home network 102. However, when the access network 102 is not available, such as when the mobile device 

100 travels outside of its home coverage area, the mobile device 100 is capable of launching the application 

106 via a roaming network 104.

[0015] Turning to FIG. 2, embodiments of the mobile device 200 and networks 214, 220 are provided in 

accordance with an embodiment of the present invention, wherein the mobile device 200 controls access to 

one or more applications 202-206 based on access conditions associated with the access networks 214, 220. 

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The mobile device 200 is capable of launching one or more applications 202-206 from its memory. The 

applications 202-206 include multimedia, voice, email, instant messaging, text messaging, firmware update, 

or any other applications or services requiring access to the home network 214 or roaming network 220 to 

establish an application session. In the illustrated embodiment, the memory of the mobile device 200 includes 

a Firmware Update Over the Air (FOTA) application 202, a Voice over IP (VoIP) application 204, and a 

video streaming application 206.

[0016] To prevent one or more applications or services 202-206 from running when the access conditions are 

not suitable, the memory of the mobile device 200 includes a policy or application access database 212, 

which is used to store a list of access conditions that are inappropriate for launching the applications 202-206. 

Specifically, the access conditions are based on the type of the current access network used by the mobile 

device 200 for launching or maintaining the requested application session 202-206. For example, the access 

conditions may indicate whether the mobile device is currently accessing its home network 214 or roaming 

on the network 220. Similarly, the access conditions may indicate the type of network access interface or 

standard used by the current network 214, 220 to provide data connection necessary to run the application 

202-206. The following table illustrates an example of the policy database 212 having a list of applications 

and corresponding access conditions, which in this embodiment are designated as inappropriate for allowing 

access to the listed applications or services.

[0017] Alternatively, the database 212 may contain a list of application/access condition pairs under which 

access to the requested applications or services is allowed. In embodiments, the policy database 212 includes 

application types, such as “video streaming” and/or associated application names, such as “Windows Media 

Player,” for example. As illustrated above, the policy database 212 correlates predetermined actions with 

current status of access conditions associated with a given application session. When the mobile device 200 

registers with an access network having a network access technology specification 222 with insufficient data 

handling capabilities for the requested application, the mobile device 200 is instructed to deny access to a 

data-intensive application or service specified in the database or lookup table 212. For example, the mobile 

device 200 is instructed to deny access to a video streaming or VoIP application session when the access 

conditions indicate that the mobile device 200 is currently using a CDMA 2000 1x network access 

technology. This avoids unnecessary use of network resources which, under current access conditions, are 

incapable of providing a satisfying user experience for the desired application. On the other hand, if the 

current access conditions do not match those in the policy database 212, such as when the mobile device 200 

is registered with an EVDO access network, a user is granted full access to the desired video streaming or 

VoIP applications. Similarly, to avoid unwanted roaming charges, the policy database 212 includes 

instructions to suspend any scheduled firmware updates via a FOTA application until the mobile device 200 

returns to the home network 214.

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[0018] Preferably, the policy database 212 is populated by a network provider using conventional Over the 

Air Device Management (OTA DM) technology to provide the network operator with full control over the 

contents of the database 212. In an embodiment, the policy database 212 is centrally populated, distributed, 

and updated over the air for each mobile device 200 via a management console 218 connected to a device 

management server 216. The network provider may choose to distribute the policy database 212 according to 

different classes of mobile devices 200, wherein each device class designates the types of access networks 

accessible to the device 200, as well as the types of applications installed in its memory. The management 

console 218, as well as the device management server 216, are located within the home access network 214 

or may be collocated with the network administration equipment at a network operations center (NOC) or at a 

mobile switching center (MSC), for example.

[0019] As further illustrated in FIG. 2, to gain access to the network resources, the application 202-206 

registers with an application manager 210. Specifically, when a user attempts to launch an application 202-

206, the application 202-206 supplies its name and/or type information to the application manager 210, 

which, in turn, receives an input of the monitored access conditions from the access network monitor 208. 

The application manager 210 queries the policy database 212 for the corresponding application/access 

condition entry and denies access to the application if a match is found. Otherwise, the mobile device 200 

initiates the application session over the current access network 214, 220. In a further embodiment, the access 

network monitor 208 continues to report the changes in current access conditions during the application 

session to allow the application manager 210 to terminate the application when a change in the access 

conditions matches an entry in the policy database 212.

[0020] In this embodiment, the application manager 210 and the access network monitor 208 are 

implemented as Binary Runtime Environment for Wireless (BREW) software modules exposing standard 

interfaces for interaction with other software components of the mobile device 200 via an application 

programming interface (API). Other embodiments of the application manager 210 and access network 

monitor 208 include using a Java-based implementation capable of running on a plurality of mobile phone 

operating systems, such as Symbian, Windows Mobile Edition, or Palm, for example.

[0021] Turning to FIG. 3, an embodiment of a method for controlling access to applications from a mobile 

device 200 is illustrated with reference to an exemplary message flow scenario. In step 300, the device 

management server 216 updates the policy database 212 when new applications or services are introduced by 

the network operator or pursuant to setting up a new customer account. In step 302, when the user requests to 

launch a video streaming application 206, the application 206 registers with the application manager 210 by 

providing it with its name and/or type information, such as “Windows Media Player”/“video streaming,” for 

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example. This prompts the application manager 2 10 to request and receive the current access condition 

information from the access network monitor 208, steps 304-306. In this embodiment, the access condition 

information includes information regarding the current access network, such as roaming status and 

compatible network access technology. In steps 308-310, based on the received application information, the 

application manager 210 requests and receives one or more entries from the policy database 212 indicating 

which access conditions preclude the establishment of an application session for the application 206. In step 

312, the application manager allows the user to launch the requested application if the current access 

conditions do not match any of the entries returned by the policy database 212 that require denial or 

suspension of access to the application. In this embodiment, upon establishment of the application session, 

the access network monitor 208 continuously monitors any changes in the current access conditions. 

Therefore, when, in step 314, the access network monitor 208 detects a change in the access conditions, for 

example when the mobile device 200 migrates from an EVDO to a CDMA 2000 1X access network overlay, 

it notifies the application manager 210 accordingly. Since this change in the access conditions matches an 

entry received from the policy database 212 requiring denial of access to the application, the application 

manager 210, in step 316, sends an event to the application 206 ending the current application session by 

forcing it to quit.

See Figs. 1, 2 & 3. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) determine whether the service usage 

activity comprises a background activity;

Abichandani discloses this limitation. For example:

[Abstract] A system and method are described whereby a mobile device controls access to mobile 

applications based on access conditions associated with a current access network. To prevent mobile 

applications from running when the access conditions are not suitable, the mobile device includes a policy 

database used to store a list of access conditions that are inappropriate for launching the installed 

applications. The access conditions are based on the type of the current access network used by the mobile 

device for launching or maintaining the requested application session. The access conditions indicate whether 

the mobile device is currently accessing its home network or roaming on another provider's network. 

Similarly, the access conditions indicate the type of network access interface used by the current network to 

provide the data connection necessary to run the requested application. The policy database correlates 

predetermined actions with the access conditions associated with a given application session.

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[0004] Embodiments of the invention are used to provide a system and method for controlling access to 

mobile applications from the mobile device based on access conditions associated with a current access 

network, To prevent one or more applications or services from running when the access conditions are not 

suitable, the memory of the mobile device includes a policy or application access database, which is used to 

store a list of access conditions that are inappropriate for launching the installed applications. In 

embodiments, the access conditions are based on the type of the current access network used by the mobile 

device for launching or maintaining the requested application session. For example, the access conditions 

may indicate whether the mobile device is currently accessing its home network or roaming on another 

provider's network. Similarly, the access conditions may indicate the type of network access interface used by 

the current network to provide the data connection necessary to run the requested application. The policy 

database correlates predetermined actions with current status of access conditions associated with a given 

application session. In one embodiment, when the mobile device accesses a network having an access 

technology specification with insufficient data handling capabilities for the requested application, the mobile 

device denies access to the data-intensive application or service specified in the policy database. Similarly, to 

avoid unwanted roaming charges, the mobile device's policy database includes instructions to suspend any 

scheduled firmware updates via a firmware over the air (FOTA) application until the mobile device returns to 

its home network.

[0005] In one aspect of the invention, a method is provided for controlling access to an application, the 

application capable of running on a mobile device by connecting to an access network, the method 

comprising registering the application with the mobile device, populating a record on the mobile device, the 

record specifying one or more conditions for controlling access to the application, the one or more conditions 

associated with the access network, monitoring the one or more conditions, and controlling access to the 

application from the mobile device based on the one or more conditions.

[0006] In another aspect of the invention, a mobile device is provided, the mobile device capable of running 

an application by connecting to an access network, the mobile device comprising a processor, a wireless 

interface for connecting to the access network, and a computer readable medium having thereon instructions 

for registering the application with the mobile device, populating a record on the mobile device, the record 

specifying one or more conditions for controlling access to the application, the one or more conditions 

associated with the access network, monitoring the one or more conditions, and controlling access to the 

application from the mobile device based on the one or more conditions.

[0007] In still another aspect of the invention, a system is provided for controlling access to an application, 

the application capable of running on a mobile device by connecting to an access network, the system 

comprising (a) the mobile device capable of storing a record for specifying one or more conditions for 

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controlling access to the application, the one or more conditions associated with the access network, the 

mobile device comprising an access network monitor module configured to monitor the one or more 

conditions, and an application manager module configured to control access to the application from the 

mobile device based on the one or more conditions reported by the access network monitor module, and (b) a 

device management server having a management connection to the mobile device for populating the record.

[0013] Turning to FIG. 1, an implementation of a system contemplated by an embodiment of the invention is 

shown with reference to a mobile network environment. In the illustrated embodiment, the user device 100 is 

a mobile device, such as a wireless telephone or a portable computer capable of launching an application by 

connecting to an application server 106 via one or more access networks 102, 104. The application server 106 

is responsible for content delivery to the one or more applications running on a mobile device 100. For 

example, when the mobile device 100 includes a multimedia streaming application, the application server 106 

employs a Real-Time Transfer Protocol (RTP) to stream the requested content to the multimedia streaming 

application launched on the mobile device 100. In this embodiment, the application server 106 is part of a 

core network 108, which is an IP Multimedia Services (IMS) network responsible for session control and 

Quality of Service (QoS) management of ongoing application sessions. Alternately, the application server 

106 is located outside of the core network 108, whereby the core network 108 connects to the application 

server 106 via the Internet 110. In embodiments where the IMS core network 108 is not implemented, the 

application server 106 may be part of one of the access networks 102, 104, for example, or it may connect to 

the access networks 102, 104 via the Internet 110.

[0014] As illustrated in FIG. 1, the access networks 102, 104 interface with the mobile device 100 in 

accordance with a network interface specification 112. Preferably, the network interface specification 112 

complies with one or more wireless access standards, each having corresponding data handling capabilities, 

such as average and maximum uplink/downlink throughput speeds. In embodiments, the wireless network 

standards include CDMA 2000 1X, 1xEV-DO, 1xEV-DV, EDGE, and HSPDA network technologies, or 

combinations thereof In order to launch the application 106, the mobile device 100 typically accesses its 

home network 102. However, when the access network 102 is not available, such as when the mobile device 

100 travels outside of its home coverage area, the mobile device 100 is capable of launching the application 

106 via a roaming network 104.

[0015] Turning to FIG. 2, embodiments of the mobile device 200 and networks 214, 220 are provided in 

accordance with an embodiment of the present invention, wherein the mobile device 200 controls access to 

one or more applications 202-206 based on access conditions associated with the access networks 214, 220. 

The mobile device 200 is capable of launching one or more applications 202-206 from its memory. The 

applications 202-206 include multimedia, voice, email, instant messaging, text messaging, firmware update, 

or any other applications or services requiring access to the home network 214 or roaming network 220 to 

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establish an application session. In the illustrated embodiment, the memory of the mobile device 200 includes 

a Firmware Update Over the Air (FOTA) application 202, a Voice over IP (VoIP) application 204, and a 

video streaming application 206.

[0016] To prevent one or more applications or services 202-206 from running when the access conditions are 

not suitable, the memory of the mobile device 200 includes a policy or application access database 212, 

which is used to store a list of access conditions that are inappropriate for launching the applications 202-206. 

Specifically, the access conditions are based on the type of the current access network used by the mobile 

device 200 for launching or maintaining the requested application session 202-206. For example, the access 

conditions may indicate whether the mobile device is currently accessing its home network 214 or roaming 

on the network 220. Similarly, the access conditions may indicate the type of network access interface or 

standard used by the current network 214, 220 to provide data connection necessary to run the application 

202-206. The following table illustrates an example of the policy database 212 having a list of applications 

and corresponding access conditions, which in this embodiment are designated as inappropriate for allowing 

access to the listed applications or services.

[0017] Alternatively, the database 212 may contain a list of application/access condition pairs under which 

access to the requested applications or services is allowed. In embodiments, the policy database 212 includes 

application types, such as “video streaming” and/or associated application names, such as “Windows Media 

Player,” for example. As illustrated above, the policy database 212 correlates predetermined actions with 

current status of access conditions associated with a given application session. When the mobile device 200 

registers with an access network having a network access technology specification 222 with insufficient data 

handling capabilities for the requested application, the mobile device 200 is instructed to deny access to a 

data-intensive application or service specified in the database or lookup table 212. For example, the mobile 

device 200 is instructed to deny access to a video streaming or VoIP application session when the access 

conditions indicate that the mobile device 200 is currently using a CDMA 2000 1x network access 

technology. This avoids unnecessary use of network resources which, under current access conditions, are 

incapable of providing a satisfying user experience for the desired application. On the other hand, if the 

current access conditions do not match those in the policy database 212, such as when the mobile device 200 

is registered with an EVDO access network, a user is granted full access to the desired video streaming or 

VoIP applications. Similarly, to avoid unwanted roaming charges, the policy database 212 includes 

instructions to suspend any scheduled firmware updates via a FOTA application until the mobile device 200 

returns to the home network 214.

[0018] Preferably, the policy database 212 is populated by a network provider using conventional Over the 

Air Device Management (OTA DM) technology to provide the network operator with full control over the 

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contents of the database 212. In an embodiment, the policy database 212 is centrally populated, distributed, 

and updated over the air for each mobile device 200 via a management console 218 connected to a device 

management server 216. The network provider may choose to distribute the policy database 212 according to 

different classes of mobile devices 200, wherein each device class designates the types of access networks 

accessible to the device 200, as well as the types of applications installed in its memory. The management 

console 218, as well as the device management server 216, are located within the home access network 214 

or may be collocated with the network administration equipment at a network operations center (NOC) or at a 

mobile switching center (MSC), for example.

[0019] As further illustrated in FIG. 2, to gain access to the network resources, the application 202-206 

registers with an application manager 210. Specifically, when a user attempts to launch an application 202-

206, the application 202-206 supplies its name and/or type information to the application manager 210, 

which, in turn, receives an input of the monitored access conditions from the access network monitor 208. 

The application manager 210 queries the policy database 212 for the corresponding application/access 

condition entry and denies access to the application if a match is found. Otherwise, the mobile device 200 

initiates the application session over the current access network 214, 220. In a further embodiment, the access 

network monitor 208 continues to report the changes in current access conditions during the application 

session to allow the application manager 210 to terminate the application when a change in the access 

conditions matches an entry in the policy database 212.

[0020] In this embodiment, the application manager 210 and the access network monitor 208 are 

implemented as Binary Runtime Environment for Wireless (BREW) software modules exposing standard 

interfaces for interaction with other software components of the mobile device 200 via an application 

programming interface (API). Other embodiments of the application manager 210 and access network 

monitor 208 include using a Java-based implementation capable of running on a plurality of mobile phone 

operating systems, such as Symbian, Windows Mobile Edition, or Palm, for example.

[0021] Turning to FIG. 3, an embodiment of a method for controlling access to applications from a mobile 

device 200 is illustrated with reference to an exemplary message flow scenario. In step 300, the device 

management server 216 updates the policy database 212 when new applications or services are introduced by 

the network operator or pursuant to setting up a new customer account. In step 302, when the user requests to 

launch a video streaming application 206, the application 206 registers with the application manager 210 by 

providing it with its name and/or type information, such as “Windows Media Player”/“video streaming,” for 

example. This prompts the application manager 2 10 to request and receive the current access condition 

information from the access network monitor 208, steps 304-306. In this embodiment, the access condition 

information includes information regarding the current access network, such as roaming status and 

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compatible network access technology. In steps 308-310, based on the received application information, the 

application manager 210 requests and receives one or more entries from the policy database 212 indicating 

which access conditions preclude the establishment of an application session for the application 206. In step 

312, the application manager allows the user to launch the requested application if the current access 

conditions do not match any of the entries returned by the policy database 212 that require denial or 

suspension of access to the application. In this embodiment, upon establishment of the application session, 

the access network monitor 208 continuously monitors any changes in the current access conditions. 

Therefore, when, in step 314, the access network monitor 208 detects a change in the access conditions, for 

example when the mobile device 200 migrates from an EVDO to a CDMA 2000 1X access network overlay, 

it notifies the application manager 210 accordingly. Since this change in the access conditions matches an 

entry received from the policy database 212 requiring denial of access to the application, the application 

manager 210, in step 316, sends an event to the application 206 ending the current application session by 

forcing it to quit.

See Figs. 1, 2 & 3. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(c) determine at least an aspect of a policy 

based on a user input obtained through a 

user interface of the wireless end-user 

device or based on information from a 

network element, the policy to be applied 

if the service usage activity is the 

background activity, the policy at least for 

controlling the service usage activity;

Abichandani discloses this limitation. For example:

[Abstract] A system and method are described whereby a mobile device controls access to mobile 

applications based on access conditions associated with a current access network. To prevent mobile 

applications from running when the access conditions are not suitable, the mobile device includes a policy 

database used to store a list of access conditions that are inappropriate for launching the installed 

applications. The access conditions are based on the type of the current access network used by the mobile 

device for launching or maintaining the requested application session. The access conditions indicate whether 

the mobile device is currently accessing its home network or roaming on another provider's network. 

Similarly, the access conditions indicate the type of network access interface used by the current network to 

provide the data connection necessary to run the requested application. The policy database correlates 

predetermined actions with the access conditions associated with a given application session.

[0004] Embodiments of the invention are used to provide a system and method for controlling access to 

mobile applications from the mobile device based on access conditions associated with a current access 

network, To prevent one or more applications or services from running when the access conditions are not 

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suitable, the memory of the mobile device includes a policy or application access database, which is used to 

store a list of access conditions that are inappropriate for launching the installed applications. In 

embodiments, the access conditions are based on the type of the current access network used by the mobile 

device for launching or maintaining the requested application session. For example, the access conditions 

may indicate whether the mobile device is currently accessing its home network or roaming on another 

provider's network. Similarly, the access conditions may indicate the type of network access interface used by 

the current network to provide the data connection necessary to run the requested application. The policy 

database correlates predetermined actions with current status of access conditions associated with a given 

application session. In one embodiment, when the mobile device accesses a network having an access 

technology specification with insufficient data handling capabilities for the requested application, the mobile 

device denies access to the data-intensive application or service specified in the policy database. Similarly, to 

avoid unwanted roaming charges, the mobile device's policy database includes instructions to suspend any 

scheduled firmware updates via a firmware over the air (FOTA) application until the mobile device returns to 

its home network.

[0005] In one aspect of the invention, a method is provided for controlling access to an application, the 

application capable of running on a mobile device by connecting to an access network, the method 

comprising registering the application with the mobile device, populating a record on the mobile device, the 

record specifying one or more conditions for controlling access to the application, the one or more conditions 

associated with the access network, monitoring the one or more conditions, and controlling access to the 

application from the mobile device based on the one or more conditions.

[0006] In another aspect of the invention, a mobile device is provided, the mobile device capable of running 

an application by connecting to an access network, the mobile device comprising a processor, a wireless 

interface for connecting to the access network, and a computer readable medium having thereon instructions 

for registering the application with the mobile device, populating a record on the mobile device, the record 

specifying one or more conditions for controlling access to the application, the one or more conditions 

associated with the access network, monitoring the one or more conditions, and controlling access to the 

application from the mobile device based on the one or more conditions.

[0007] In still another aspect of the invention, a system is provided for controlling access to an application, 

the application capable of running on a mobile device by connecting to an access network, the system 

comprising (a) the mobile device capable of storing a record for specifying one or more conditions for 

controlling access to the application, the one or more conditions associated with the access network, the 

mobile device comprising an access network monitor module configured to monitor the one or more 

conditions, and an application manager module configured to control access to the application from the 

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

mobile device based on the one or more conditions reported by the access network monitor module, and (b) a 

device management server having a management connection to the mobile device for populating the record.

[0013] Turning to FIG. 1, an implementation of a system contemplated by an embodiment of the invention is 

shown with reference to a mobile network environment. In the illustrated embodiment, the user device 100 is 

a mobile device, such as a wireless telephone or a portable computer capable of launching an application by 

connecting to an application server 106 via one or more access networks 102, 104. The application server 106 

is responsible for content delivery to the one or more applications running on a mobile device 100. For 

example, when the mobile device 100 includes a multimedia streaming application, the application server 106 

employs a Real-Time Transfer Protocol (RTP) to stream the requested content to the multimedia streaming 

application launched on the mobile device 100. In this embodiment, the application server 106 is part of a 

core network 108, which is an IP Multimedia Services (IMS) network responsible for session control and 

Quality of Service (QoS) management of ongoing application sessions. Alternately, the application server 

106 is located outside of the core network 108, whereby the core network 108 connects to the application 

server 106 via the Internet 110. In embodiments where the IMS core network 108 is not implemented, the 

application server 106 may be part of one of the access networks 102, 104, for example, or it may connect to 

the access networks 102, 104 via the Internet 110.

[0014] As illustrated in FIG. 1, the access networks 102, 104 interface with the mobile device 100 in 

accordance with a network interface specification 112. Preferably, the network interface specification 112 

complies with one or more wireless access standards, each having corresponding data handling capabilities, 

such as average and maximum uplink/downlink throughput speeds. In embodiments, the wireless network 

standards include CDMA 2000 1X, 1xEV-DO, 1xEV-DV, EDGE, and HSPDA network technologies, or 

combinations thereof In order to launch the application 106, the mobile device 100 typically accesses its 

home network 102. However, when the access network 102 is not available, such as when the mobile device 

100 travels outside of its home coverage area, the mobile device 100 is capable of launching the application 

106 via a roaming network 104.

[0015] Turning to FIG. 2, embodiments of the mobile device 200 and networks 214, 220 are provided in 

accordance with an embodiment of the present invention, wherein the mobile device 200 controls access to 

one or more applications 202-206 based on access conditions associated with the access networks 214, 220. 

The mobile device 200 is capable of launching one or more applications 202-206 from its memory. The 

applications 202-206 include multimedia, voice, email, instant messaging, text messaging, firmware update, 

or any other applications or services requiring access to the home network 214 or roaming network 220 to 

establish an application session. In the illustrated embodiment, the memory of the mobile device 200 includes 

a Firmware Update Over the Air (FOTA) application 202, a Voice over IP (VoIP) application 204, and a 

video streaming application 206.

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[0016] To prevent one or more applications or services 202-206 from running when the access conditions are 

not suitable, the memory of the mobile device 200 includes a policy or application access database 212, 

which is used to store a list of access conditions that are inappropriate for launching the applications 202-206. 

Specifically, the access conditions are based on the type of the current access network used by the mobile 

device 200 for launching or maintaining the requested application session 202-206. For example, the access 

conditions may indicate whether the mobile device is currently accessing its home network 214 or roaming 

on the network 220. Similarly, the access conditions may indicate the type of network access interface or 

standard used by the current network 214, 220 to provide data connection necessary to run the application 

202-206. The following table illustrates an example of the policy database 212 having a list of applications 

and corresponding access conditions, which in this embodiment are designated as inappropriate for allowing 

access to the listed applications or services.

[0017] Alternatively, the database 212 may contain a list of application/access condition pairs under which 

access to the requested applications or services is allowed. In embodiments, the policy database 212 includes 

application types, such as “video streaming” and/or associated application names, such as “Windows Media 

Player,” for example. As illustrated above, the policy database 212 correlates predetermined actions with 

current status of access conditions associated with a given application session. When the mobile device 200 

registers with an access network having a network access technology specification 222 with insufficient data 

handling capabilities for the requested application, the mobile device 200 is instructed to deny access to a 

data-intensive application or service specified in the database or lookup table 212. For example, the mobile 

device 200 is instructed to deny access to a video streaming or VoIP application session when the access 

conditions indicate that the mobile device 200 is currently using a CDMA 2000 1x network access 

technology. This avoids unnecessary use of network resources which, under current access conditions, are 

incapable of providing a satisfying user experience for the desired application. On the other hand, if the 

current access conditions do not match those in the policy database 212, such as when the mobile device 200 

is registered with an EVDO access network, a user is granted full access to the desired video streaming or 

VoIP applications. Similarly, to avoid unwanted roaming charges, the policy database 212 includes 

instructions to suspend any scheduled firmware updates via a FOTA application until the mobile device 200 

returns to the home network 214.

[0018] Preferably, the policy database 212 is populated by a network provider using conventional Over the 

Air Device Management (OTA DM) technology to provide the network operator with full control over the 

contents of the database 212. In an embodiment, the policy database 212 is centrally populated, distributed, 

and updated over the air for each mobile device 200 via a management console 218 connected to a device 

management server 216. The network provider may choose to distribute the policy database 212 according to 

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

different classes of mobile devices 200, wherein each device class designates the types of access networks 

accessible to the device 200, as well as the types of applications installed in its memory. The management 

console 218, as well as the device management server 216, are located within the home access network 214 

or may be collocated with the network administration equipment at a network operations center (NOC) or at a 

mobile switching center (MSC), for example.

[0019] As further illustrated in FIG. 2, to gain access to the network resources, the application 202-206 

registers with an application manager 210. Specifically, when a user attempts to launch an application 202-

206, the application 202-206 supplies its name and/or type information to the application manager 210, 

which, in turn, receives an input of the monitored access conditions from the access network monitor 208. 

The application manager 210 queries the policy database 212 for the corresponding application/access 

condition entry and denies access to the application if a match is found. Otherwise, the mobile device 200 

initiates the application session over the current access network 214, 220. In a further embodiment, the access 

network monitor 208 continues to report the changes in current access conditions during the application 

session to allow the application manager 210 to terminate the application when a change in the access 

conditions matches an entry in the policy database 212.

[0020] In this embodiment, the application manager 210 and the access network monitor 208 are 

implemented as Binary Runtime Environment for Wireless (BREW) software modules exposing standard 

interfaces for interaction with other software components of the mobile device 200 via an application 

programming interface (API). Other embodiments of the application manager 210 and access network 

monitor 208 include using a Java-based implementation capable of running on a plurality of mobile phone 

operating systems, such as Symbian, Windows Mobile Edition, or Palm, for example.

[0021] Turning to FIG. 3, an embodiment of a method for controlling access to applications from a mobile 

device 200 is illustrated with reference to an exemplary message flow scenario. In step 300, the device 

management server 216 updates the policy database 212 when new applications or services are introduced by 

the network operator or pursuant to setting up a new customer account. In step 302, when the user requests to 

launch a video streaming application 206, the application 206 registers with the application manager 210 by 

providing it with its name and/or type information, such as “Windows Media Player”/“video streaming,” for 

example. This prompts the application manager 2 10 to request and receive the current access condition 

information from the access network monitor 208, steps 304-306. In this embodiment, the access condition 

information includes information regarding the current access network, such as roaming status and 

compatible network access technology. In steps 308-310, based on the received application information, the 

application manager 210 requests and receives one or more entries from the policy database 212 indicating 

which access conditions preclude the establishment of an application session for the application 206. In step 

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312, the application manager allows the user to launch the requested application if the current access 

conditions do not match any of the entries returned by the policy database 212 that require denial or 

suspension of access to the application. In this embodiment, upon establishment of the application session, 

the access network monitor 208 continuously monitors any changes in the current access conditions. 

Therefore, when, in step 314, the access network monitor 208 detects a change in the access conditions, for 

example when the mobile device 200 migrates from an EVDO to a CDMA 2000 1X access network overlay, 

it notifies the application manager 210 accordingly. Since this change in the access conditions matches an 

entry received from the policy database 212 requiring denial of access to the application, the application 

manager 210, in step 316, sends an event to the application 206 ending the current application session by 

forcing it to quit.

See Figs. 1, 2 & 3. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(d) and if it is determined that the service 

usage activity is the background activity, 

apply the policy.

Abichandani discloses this limitation. For example:

[Abstract] A system and method are described whereby a mobile device controls access to mobile 

applications based on access conditions associated with a current access network. To prevent mobile 

applications from running when the access conditions are not suitable, the mobile device includes a policy 

database used to store a list of access conditions that are inappropriate for launching the installed 

applications. The access conditions are based on the type of the current access network used by the mobile 

device for launching or maintaining the requested application session. The access conditions indicate whether 

the mobile device is currently accessing its home network or roaming on another provider's network. 

Similarly, the access conditions indicate the type of network access interface used by the current network to 

provide the data connection necessary to run the requested application. The policy database correlates 

predetermined actions with the access conditions associated with a given application session.

[0004] Embodiments of the invention are used to provide a system and method for controlling access to 

mobile applications from the mobile device based on access conditions associated with a current access 

network, To prevent one or more applications or services from running when the access conditions are not 

suitable, the memory of the mobile device includes a policy or application access database, which is used to 

store a list of access conditions that are inappropriate for launching the installed applications. In 

embodiments, the access conditions are based on the type of the current access network used by the mobile 

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

device for launching or maintaining the requested application session. For example, the access conditions 

may indicate whether the mobile device is currently accessing its home network or roaming on another 

provider's network. Similarly, the access conditions may indicate the type of network access interface used by 

the current network to provide the data connection necessary to run the requested application. The policy 

database correlates predetermined actions with current status of access conditions associated with a given 

application session. In one embodiment, when the mobile device accesses a network having an access 

technology specification with insufficient data handling capabilities for the requested application, the mobile 

device denies access to the data-intensive application or service specified in the policy database. Similarly, to 

avoid unwanted roaming charges, the mobile device's policy database includes instructions to suspend any 

scheduled firmware updates via a firmware over the air (FOTA) application until the mobile device returns to 

its home network.

[0005] In one aspect of the invention, a method is provided for controlling access to an application, the 

application capable of running on a mobile device by connecting to an access network, the method 

comprising registering the application with the mobile device, populating a record on the mobile device, the 

record specifying one or more conditions for controlling access to the application, the one or more conditions 

associated with the access network, monitoring the one or more conditions, and controlling access to the 

application from the mobile device based on the one or more conditions.

[0006] In another aspect of the invention, a mobile device is provided, the mobile device capable of running 

an application by connecting to an access network, the mobile device comprising a processor, a wireless 

interface for connecting to the access network, and a computer readable medium having thereon instructions 

for registering the application with the mobile device, populating a record on the mobile device, the record 

specifying one or more conditions for controlling access to the application, the one or more conditions 

associated with the access network, monitoring the one or more conditions, and controlling access to the 

application from the mobile device based on the one or more conditions.

[0007] In still another aspect of the invention, a system is provided for controlling access to an application, 

the application capable of running on a mobile device by connecting to an access network, the system 

comprising (a) the mobile device capable of storing a record for specifying one or more conditions for 

controlling access to the application, the one or more conditions associated with the access network, the 

mobile device comprising an access network monitor module configured to monitor the one or more 

conditions, and an application manager module configured to control access to the application from the 

mobile device based on the one or more conditions reported by the access network monitor module, and (b) a 

device management server having a management connection to the mobile device for populating the record.

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[0013] Turning to FIG. 1, an implementation of a system contemplated by an embodiment of the invention is 

shown with reference to a mobile network environment. In the illustrated embodiment, the user device 100 is 

a mobile device, such as a wireless telephone or a portable computer capable of launching an application by 

connecting to an application server 106 via one or more access networks 102, 104. The application server 106 

is responsible for content delivery to the one or more applications running on a mobile device 100. For 

example, when the mobile device 100 includes a multimedia streaming application, the application server 106 

employs a Real-Time Transfer Protocol (RTP) to stream the requested content to the multimedia streaming 

application launched on the mobile device 100. In this embodiment, the application server 106 is part of a 

core network 108, which is an IP Multimedia Services (IMS) network responsible for session control and 

Quality of Service (QoS) management of ongoing application sessions. Alternately, the application server 

106 is located outside of the core network 108, whereby the core network 108 connects to the application 

server 106 via the Internet 110. In embodiments where the IMS core network 108 is not implemented, the 

application server 106 may be part of one of the access networks 102, 104, for example, or it may connect to 

the access networks 102, 104 via the Internet 110.

[0014] As illustrated in FIG. 1, the access networks 102, 104 interface with the mobile device 100 in 

accordance with a network interface specification 112. Preferably, the network interface specification 112 

complies with one or more wireless access standards, each having corresponding data handling capabilities, 

such as average and maximum uplink/downlink throughput speeds. In embodiments, the wireless network 

standards include CDMA 2000 1X, 1xEV-DO, 1xEV-DV, EDGE, and HSPDA network technologies, or 

combinations thereof In order to launch the application 106, the mobile device 100 typically accesses its 

home network 102. However, when the access network 102 is not available, such as when the mobile device 

100 travels outside of its home coverage area, the mobile device 100 is capable of launching the application 

106 via a roaming network 104.

[0015] Turning to FIG. 2, embodiments of the mobile device 200 and networks 214, 220 are provided in 

accordance with an embodiment of the present invention, wherein the mobile device 200 controls access to 

one or more applications 202-206 based on access conditions associated with the access networks 214, 220. 

The mobile device 200 is capable of launching one or more applications 202-206 from its memory. The 

applications 202-206 include multimedia, voice, email, instant messaging, text messaging, firmware update, 

or any other applications or services requiring access to the home network 214 or roaming network 220 to 

establish an application session. In the illustrated embodiment, the memory of the mobile device 200 includes 

a Firmware Update Over the Air (FOTA) application 202, a Voice over IP (VoIP) application 204, and a 

video streaming application 206.

[0016] To prevent one or more applications or services 202-206 from running when the access conditions are 

not suitable, the memory of the mobile device 200 includes a policy or application access database 212, 

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

which is used to store a list of access conditions that are inappropriate for launching the applications 202-206. 

Specifically, the access conditions are based on the type of the current access network used by the mobile 

device 200 for launching or maintaining the requested application session 202-206. For example, the access 

conditions may indicate whether the mobile device is currently accessing its home network 214 or roaming 

on the network 220. Similarly, the access conditions may indicate the type of network access interface or 

standard used by the current network 214, 220 to provide data connection necessary to run the application 

202-206. The following table illustrates an example of the policy database 212 having a list of applications 

and corresponding access conditions, which in this embodiment are designated as inappropriate for allowing 

access to the listed applications or services.

[0017] Alternatively, the database 212 may contain a list of application/access condition pairs under which 

access to the requested applications or services is allowed. In embodiments, the policy database 212 includes 

application types, such as “video streaming” and/or associated application names, such as “Windows Media 

Player,” for example. As illustrated above, the policy database 212 correlates predetermined actions with 

current status of access conditions associated with a given application session. When the mobile device 200 

registers with an access network having a network access technology specification 222 with insufficient data 

handling capabilities for the requested application, the mobile device 200 is instructed to deny access to a 

data-intensive application or service specified in the database or lookup table 212. For example, the mobile 

device 200 is instructed to deny access to a video streaming or VoIP application session when the access 

conditions indicate that the mobile device 200 is currently using a CDMA 2000 1x network access 

technology. This avoids unnecessary use of network resources which, under current access conditions, are 

incapable of providing a satisfying user experience for the desired application. On the other hand, if the 

current access conditions do not match those in the policy database 212, such as when the mobile device 200 

is registered with an EVDO access network, a user is granted full access to the desired video streaming or 

VoIP applications. Similarly, to avoid unwanted roaming charges, the policy database 212 includes 

instructions to suspend any scheduled firmware updates via a FOTA application until the mobile device 200 

returns to the home network 214.

[0018] Preferably, the policy database 212 is populated by a network provider using conventional Over the 

Air Device Management (OTA DM) technology to provide the network operator with full control over the 

contents of the database 212. In an embodiment, the policy database 212 is centrally populated, distributed, 

and updated over the air for each mobile device 200 via a management console 218 connected to a device 

management server 216. The network provider may choose to distribute the policy database 212 according to 

different classes of mobile devices 200, wherein each device class designates the types of access networks 

accessible to the device 200, as well as the types of applications installed in its memory. The management 

console 218, as well as the device management server 216, are located within the home access network 214 

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or may be collocated with the network administration equipment at a network operations center (NOC) or at a 

mobile switching center (MSC), for example.

[0019] As further illustrated in FIG. 2, to gain access to the network resources, the application 202-206 

registers with an application manager 210. Specifically, when a user attempts to launch an application 202-

206, the application 202-206 supplies its name and/or type information to the application manager 210, 

which, in turn, receives an input of the monitored access conditions from the access network monitor 208. 

The application manager 210 queries the policy database 212 for the corresponding application/access 

condition entry and denies access to the application if a match is found. Otherwise, the mobile device 200 

initiates the application session over the current access network 214, 220. In a further embodiment, the access 

network monitor 208 continues to report the changes in current access conditions during the application 

session to allow the application manager 210 to terminate the application when a change in the access 

conditions matches an entry in the policy database 212.

[0020] In this embodiment, the application manager 210 and the access network monitor 208 are 

implemented as Binary Runtime Environment for Wireless (BREW) software modules exposing standard 

interfaces for interaction with other software components of the mobile device 200 via an application 

programming interface (API). Other embodiments of the application manager 210 and access network 

monitor 208 include using a Java-based implementation capable of running on a plurality of mobile phone 

operating systems, such as Symbian, Windows Mobile Edition, or Palm, for example.

[0021] Turning to FIG. 3, an embodiment of a method for controlling access to applications from a mobile

device 200 is illustrated with reference to an exemplary message flow scenario. In step 300, the device 

management server 216 updates the policy database 212 when new applications or services are introduced by 

the network operator or pursuant to setting up a new customer account. In step 302, when the user requests to 

launch a video streaming application 206, the application 206 registers with the application manager 210 by 

providing it with its name and/or type information, such as “Windows Media Player”/“video streaming,” for 

example. This prompts the application manager 2 10 to request and receive the current access condition 

information from the access network monitor 208, steps 304-306. In this embodiment, the access condition 

information includes information regarding the current access network, such as roaming status and 

compatible network access technology. In steps 308-310, based on the received application information, the 

application manager 210 requests and receives one or more entries from the policy database 212 indicating 

which access conditions preclude the establishment of an application session for the application 206. In step 

312, the application manager allows the user to launch the requested application if the current access 

conditions do not match any of the entries returned by the policy database 212 that require denial or 

suspension of access to the application. In this embodiment, upon establishment of the application session, 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 23 of 77 PageID #:

4598
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

the access network monitor 208 continuously monitors any changes in the current access conditions. 

Therefore, when, in step 314, the access network monitor 208 detects a change in the access conditions, for 

example when the mobile device 200 migrates from an EVDO to a CDMA 2000 1X access network overlay, 

it notifies the application manager 210 accordingly. Since this change in the access conditions matches an 

entry received from the policy database 212 requiring denial of access to the application, the application 

manager 210, in step 316, sends an event to the application 206 ending the current application session by 

forcing it to quit.

See Figs. 1, 2 & 3. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

2. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the first software component 

comprises at least a portion of an 

application component or at least a 

portion of an operating system 

component, and wherein the one or more 

prospective or successful communications 

over the wireless network comprise an 

update to the first software component.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

3. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the one or more prospective or 

successful communications over the 

wireless network comprise a 

communication associated with a network 

access, background signaling, a cloud 

synchronization service, an information 

feed, a download, an e-mail, a chat client, 

a security update, a peer-to-peer 

networking application update, a report of 

a behavior associated with the wireless 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 24 of 77 PageID #:

4599
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

end-user device, or a combination of 

these.

4. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the one or more prospective or 

successful communications over the 

wireless network comprise a 

communication associated with a content 

update or a content download.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

5. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the one or more prospective or 

successful communications over the 

wireless network comprise a 

communication associated with an image, 

music, a video, an electronic book, an email attachment, a content or media 

subscription, a news feed, a text message, 

a video chat, or a combination of these.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

6. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the one or more prospective or 

successful communications over the 

wireless network comprise a 

communication associated with a device 

application or widget, a device operating 

system function, a file download, 

streaming media, a software update, a 

firmware update, a website, a connection 

to a server, a web browser, or a 

synchronization service.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

7. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein identify a service usage activity 

of the wireless end-user device comprises 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 25 of 77 PageID #:

4600
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

identify an intention to launch or start the 

first software component.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

8. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein identify a service usage activity 

of the wireless end-user device comprises 

identify: an application identifier 

associated with the service usage activity 

or the first software component, an 

operating system function identifier 

associated with the service usage activity 

or the first software component, an 

aggregate service activity identifier, a 

component service activity identifier, or a 

combination of these.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

9. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the service usage activity results 

from cooperation between the first 

software component and at least one other 

software component, application, process, 

function, activity, or service, and wherein 

identify a service usage activity of the 

wireless end-user device comprises:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) identify a data flow to or from the at 

least one other software component, 

application, process, function, activity, or 

service; and

Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) associate the data flow with the first 

software component.

Abichandani discloses this element. See supra claim 1.

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 26 of 77 PageID #:

4601
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

10. The non-transitory computer-readable 

storage medium recited in claim 9, 

wherein the first software component 

comprises at least a portion of an 

application, and wherein the at least one 

other software component, application, 

process, function, activity, or service 

performs a proxy function.

Abichandani anticipates and/or renders obvious claim 9. See supra claims 1, 9. 

In addition, Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

11. The non-transitory computer-readable 

storage medium recited in claim 9, 

wherein the at least one other software 

component, application, process, function, 

activity, or service performs a proxy 

function.

Abichandani anticipates and/or renders obvious claim 9. See supra claims 1, 9. 

In addition, Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

12. The non-transitory computer-readable 

storage medium recited in claim 9, 

wherein the at least one other software 

component, application, process, function, 

activity, or service comprises a media 

service manager, an e-mail service 

manager, a domain name service (DNS) 

function, a software download service 

manager, a media download manager, a 

data download service manager, a media 

library function, a simple mail transfer 

protocol (SMTP) proxy, an Internet 

message access protocol (IMAP) proxy, a 

post office protocol (POP) proxy, a 

hypertext transfer protocol (HTTP) proxy, 

Abichandani anticipates and/or renders obvious claim 9. See supra claims 1, 9. 

In addition, Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 27 of 77 PageID #:

4602
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

an instant messaging (IM) proxy, a virtual 

private network (VPN) service manager, 

or a secure socket layer (SSL) proxy.

13. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein identify a service usage activity 

of the wireless end-user device comprises:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) monitor an application proxy service 

flow; and

Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) classify the application proxy service 

flow as being initiated by or belonging to 

the first software component.

Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

14. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein identify a service usage activity 

of the wireless end-user device comprises:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) associate an identifier identifying the 

first software component with a request to 

a proxy service;

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 28 of 77 PageID #:

4603
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) associate the request to the proxy 

service with a traffic flow, the traffic flow 

comprising the service usage activity; and

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(c) associate the traffic flow with the 

identifier.

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

15. The non-transitory computer-readable 

storage medium recited in claim 14, 

wherein the identifier comprises a name, a 

fingerprint, an identification tag, a process 

number, or a credential.

Abichandani anticipates and/or renders obvious claim 14. See supra claims 1, 14. 

In addition, Abichandani discloses this claim. See supra claims 1, 14.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

16. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the service usage activity results 

from cooperation between the first 

software component and a proxy function, 

and wherein identify a service usage 

activity of the wireless end-user device 

comprises:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claims 1, 14.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) identify a data flow to or from the 

proxy function; and

Abichandani discloses this element. See supra claims 1, 14.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 29 of 77 PageID #:

4604
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) associate the data flow with the first 

software component.

Abichandani discloses this element. See supra claims 1, 14.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

17. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein identify a service usage activity 

of the wireless end-user device comprises 

identify the service usage activity based 

on a stream, a flow, a destination, a port, a 

packet inspection, or a combination of 

these.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

18. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein identify a service usage activity 

of the wireless end-user device comprises 

determine an identifier associated with the 

first software component, a number 

associated with the first software 

component, a name associated with the 

first software component, or a signature 

associated with the first software 

component.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

19. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the first software component 

comprises at least a portion of an 

application on the wireless end-user 

device.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 30 of 77 PageID #:

4605
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

20. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the first software component 

comprises an operating system 

component, function, or service.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these

Invalidity Contentions or identified in the cover document to which this chart is attached.

21. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the first software component 

comprises a software function, utility, 

process, or tool.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

22. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the first software component 

comprises a plurality of applications, 

processes, functions, activities, or 

services.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

23. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the first software component 

comprises a Java archive (JAR) file, an 

application that uses an operating system 

(OS) function, an application that uses a 

proxy service function, or an OS process 

function that supports an application or 

OS function.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

24. The non-transitory computer-readable 

storage medium recited in claim 1, 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 31 of 77 PageID #:

4606
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

wherein the network element is 

communicatively coupled to the wireless 

end-user device over the wireless 

network.

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

25. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy is based on an amount 

of time, a time of day, a day of a week, a 

schedule, a network busy state, a network 

performance state, a network quality-ofservice state, a priority of the service 

usage activity, or a combination of these.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

26. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy is based on a 

background service class, a background 

service state, or a combination of these.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

27. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy is based on at least an 

aspect of a service plan.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

28. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy is based on a behavior 

of the first software component, a 

behavior of the service usage activity, a 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

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4607
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

messaging layer behavior, a random backoff, a power state of the wireless end-user 

device, a usage state of the wireless enduser device, or a combination of these.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

29. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy is based on a user 

interaction with the first software 

component, a user interaction with the 

service usage activity, a user interaction 

with the wireless end-user device, a user 

interface priority of the service usage 

activity, or a combination of these.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

30. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the wireless end-user device is 

part of a device group, and wherein the 

policy is associated with the device group.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

31. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy is based on a type of 

the wireless network.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

32. The non-transitory computer-readable 

storage medium recited in claim 31, 

wherein the type of the wireless network 

is cellular, 2G, 3G, 4G, home, roaming, 

wireless fidelity (WiFi), or a combination 

of these.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 33 of 77 PageID #:

4608
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

33. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy is based on a roaming 

condition of the wireless end-user device, 

a cost associated with communicating 

over the wireless network, or a 

combination of these.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

34. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein controlling the service usage 

activity comprises preventing the first 

software component from launching, 

executing, or running.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

35. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the at least an aspect of the policy 

is based on the user input obtained 

through the user interface of the wireless 

end-user device, and wherein the user 

input identifies the first software 

component or the service usage activity.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

36. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the at least an aspect of the policy 

is based on the user input obtained 

through the user interface of the wireless 

end-user device, and wherein the user 

input identifies a network parameter or a 

network type.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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4609
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

37. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy is based on a usage 

limit or a threshold.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

38. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy is based on a limit, 

wherein the limit is based on the user 

input obtained through the user interface 

of the wireless end-user device, a user 

preference, an indication of a threshold, a 

total traffic, a type of traffic, a destination, 

a port, a frequency of access, an access 

behavior, or a combination of these.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

39. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy is based on a type of 

the service usage activity, a priority of the 

service usage activity, a duration of the 

service usage activity, a characteristic of 

the wireless network, a quality-of-service 

(QoS) rule associated with the service 

usage activity, or a combination of these.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

40. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy comprises one or more 

filters, wherein the one or more filters 

provide filtering based on: a characteristic 

of the wireless network, a service plan 

applicable to the wireless end-user device, 

a characteristic of the first software 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 35 of 77 PageID #:

4610
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

component, a time of day, a network busy 

state, or a combination of these.

41. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the wireless network is a first 

wireless network, and wherein the service 

usage activity is a first service usage 

activity, and wherein the policy assists the 

one or more processors to control the first 

service usage activity when the wireless 

end-user device is connected to the first 

wireless network and refrain from 

controlling a second service usage activity 

when the wireless end-user device is 

connected to a second wireless network, 

the second service usage activity being 

associated with the first software 

component.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

42. The non-transitory computer-readable 

storage medium recited in claim 41, 

wherein control the first service usage 

activity comprises prevent, restrict, or 

block the first service usage activity.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

43. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the second wireless network is a 

wireless fidelity (WiFi) network or a 

home network.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claims 1, 32.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

44. The non-transitory computer-readable 

storage medium recited in claim 1, 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 36 of 77 PageID #:

4611
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

wherein determine whether the service 

usage activity comprises a background 

activity comprises determine whether a 

user is interacting with or has interacted 

with the first software component.

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

45. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

activity comprises determine whether the 

first software component is in a user 

interface foreground.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

46. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

activity comprises determine whether the 

service usage activity is a software 

update.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

47. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

activity comprises determine whether the 

first software component is or has been 

classified as being in a background state 

or the service usage activity is or has been 

classified as a background service.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

48. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

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4612
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

activity comprises determine whether the 

service usage activity is identified by a 

list specifying one or more background 

activities.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

49. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

activity comprises determine whether the 

service usage activity is a foreground 

activity.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

50. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

activity comprises determine whether the 

first software component is a foreground 

component.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

51. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

activity comprises:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) determine a classification of the 

service usage activity, and

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 38 of 77 PageID #:

4613
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) based on the classification of the 

service usage activity, determine whether 

the service usage activity comprises the 

background activity.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

52. The non-transitory computer-readable 

storage medium recited in claim 51, 

wherein the classification of the service 

usage activity is based on: whether the 

first software component requires access 

to the wireless network, whether the one 

or more prospective or successful 

communications over the wireless 

network comprise an update to the first 

software component, whether the first 

software component requires information 

about the wireless network, whether the 

first software component requires location 

information, whether the one or more 

prospective or successful communications 

over the wireless network comprise an 

operating system software update, 

whether the one or more prospective or 

successful communications over the 

wireless network comprise a security 

software update, whether the one or more 

prospective or successful communications 

over the wireless network comprise a 

communication associated with a 

network-based back-up, whether the one 

Abichandani anticipates and/or renders obvious claim 51. See supra claims 1, 51. 

In addition, Abichandani discloses this claim. See supra claims 1, 51.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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4614
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

or more prospective or successful 

communications over the wireless 

network comprise a communication 

associated with an e-mail download, 

whether the one or more prospective or 

successful communications over the 

wireless network comprise 

communications associated with a cloud 

synchronization service, or a combination 

of these.

53. The non-transitory computer-readable 

storage medium recited in claim 51, 

wherein the user input obtained through 

the user interface of the wireless end-user 

device is a first user input, and wherein 

determine a classification of the service 

usage activity is based on a characteristic 

of the first software component, a content 

type associated with the service usage 

activity, a characteristic of the wireless 

network, a service plan, a user preference, 

the first user input, a second user input, 

the information from the network 

element, or a combination of these.

Abichandani anticipates and/or renders obvious claim 51. See supra claims 1, 51. 

In addition, Abichandani discloses this claim. See supra claims 1, 51.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

54. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

activity is based on a user interaction with 

the wireless end-user device.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

55. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

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4615
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

activity comprises determine whether a 

value comprising a measure of the service 

usage activity satisfies a condition relative 

to a threshold.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

56. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

activity comprises determine whether the 

first software component is a foreground 

component or an unclassified component.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

57. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

activity comprises determine whether the 

first software component is in a 

foreground of user interaction or 

determine whether the first software 

component is in a background of user 

interaction.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

58. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

activity comprises determine whether 

content associated with the service usage 

activity is in a foreground of a user 

interface of the wireless end-user device.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

59. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein determine whether the service 

usage activity comprises a background 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 41 of 77 PageID #:

4616
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

activity comprises determine whether the 

first software component is active.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

60. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises at 

least assist in allowing, restricting, 

delaying, throttling, or preventing the 

service usage activity.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

61. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises at 

least assist in: blocking access to the 

wireless network, restricting access to the 

wireless network, delaying access to the 

wireless network, or aggregating and 

holding the service usage activity.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

62. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises at 

least assist in queuing, time-windowing, 

suspending, quarantining, killing, or 

removing the service usage activity.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

63. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises at 

least assist in preventing an update 

associated with the first software 

component.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 42 of 77 PageID #:

4617
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

64. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the one or more prospective or 

successful communications over the 

wireless network comprise one or more 

Internet protocol (IP) address requests, 

and wherein apply the policy comprises at 

least assist in withholding, delaying, timewindowing, reducing in frequency, or 

aggregating at least a portion of the 

service usage activity.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

65. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the information from the network 

element is first information, and wherein 

apply the policy comprises provide 

second information to the first software 

component.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

66. The non-transitory computer-readable 

storage medium recited in claim 65, 

wherein provide second information to 

the first software component comprises 

provide the second information through 

an application programming interface.

Abichandani anticipates and/or renders obvious claim 65. See supra claims 1, 65. 

In addition, Abichandani discloses this claim. See supra claims 1, 65. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

67. The non-transitory computer-readable 

storage medium recited in claim 65, 

wherein, when executed by the one or 

more processors of the wireless end-user 

device, the machine-executable 

Abichandani anticipates and/or renders obvious claim 65. See supra claims 1, 65. 

In addition, Abichandani discloses this element. See supra claims 1, 65. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 43 of 77 PageID #:

4618
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

instructions further cause the one or more 

processors to:

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) provide third information to a second 

software component on the wireless enduser device, the third information being 

different from the second information.

Abichandani discloses this element. See supra claims 1, 65. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

68. The non-transitory computer-readable 

storage medium recited in claim 67, 

wherein provide third information to a 

second software component on the 

wireless end-user device comprises 

provide the third information through an 

application programming interface.

Abichandani anticipates and/or renders obvious claim 67. See supra claims 1, 67. 

In addition, Abichandani discloses this claim. See supra claims 1, 67. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

69. The non-transitory computer-readable 

storage medium recited in claim 67, 

wherein the third information enables the 

second software component to 

communicate over the wireless network.

Abichandani anticipates and/or renders obvious claim 67. See supra claims 1, 67. 

In addition, Abichandani discloses this claim. See supra claims 1, 67. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

70. The non-transitory computer-readable 

storage medium recited in claim 65, 

wherein the wireless network is a first 

wireless network, and wherein the second 

information comprises a network access 

condition of the first wireless network, a 

network busy state associated with the 

first wireless network, a network 

availability state associated with the first 

wireless network, a network busy state 

associated with a second wireless 

Abichandani anticipates and/or renders obvious claim 65. See supra claims 1, 65. 

In addition, Abichandani discloses this claim. See supra claims 1, 65. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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4619
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

network, a network availability state 

associated with the second wireless 

network, or information about the policy.

71. The non-transitory computer-readable 

storage medium recited in claim 65, 

wherein the second information comprises 

a setting for assisting the first software 

component in restricting, allowing, 

blocking, throttling, deferring, timescheduling, or queuing the service usage 

activity.

Abichandani anticipates and/or renders obvious claim 65. See supra claims 1, 65. 

In addition, Abichandani discloses this claim. See supra claims 1, 65. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

72. The non-transitory computer-readable 

storage medium recited in claim 71, 

wherein the setting is based on a 

characteristic of the wireless network, a 

network busy state associated with the 

wireless network, a time, a service plan 

associated with the wireless end-user 

device, a classification of the service 

usage activity, or a combination of these.

Abichandani anticipates and/or renders obvious claim 71. See supra claims 1, 71. 

In addition, Abichandani discloses this claim. See supra claims 1, 71. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

73. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises 

inform the first software component 

whether the first software component is 

allowed to access the wireless network.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

74. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises 

inform the first software component 

whether the wireless network is available.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 45 of 77 PageID #:

4620
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

75. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises 

inform the first software component of a 

traffic control to be implemented or 

applied by the first software component.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

76. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the information from the network 

element is first information, and wherein 

apply the policy comprises obtain second 

information from the first software 

component.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

77. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises at 

least assist in intercepting, controlling, 

blocking, modifying, removing, or 

replacing a notification associated with 

the first software component or the 

service usage activity, the notification for 

presentation through a user interface of 

the wireless end-user device.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

78. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises at 

least assist in intercepting, controlling, 

blocking, modifying, removing, or 

replacing a notification for presentation 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 46 of 77 PageID #:

4621
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

through a user interface of the wireless 

end-user device.

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

79. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises at 

least assist in intercepting a stack 

application programming interface (API) 

level or application messaging layer 

request.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

80. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises at 

least assist in killing or suspending the 

service usage activity or the first software 

component.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

81. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises at 

least assist in changing or setting a 

priority of the service usage activity.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

82. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises at 

least assist in emulating a network 

application programming interface (API) 

message.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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4622
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

83. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises at 

least assist in intercepting, modifying, 

blocking, removing, injecting, swapping, 

or replacing an application interface 

message.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

84. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) at least assist in preventing initiation 

of the service usage activity by the first 

software component; and

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) send a message to the first software 

component.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

85. The non-transitory computer-readable 

storage medium recited in claim 84, 

wherein initiation of the service usage 

activity by the first software component 

comprises opening of a connection, 

opening of a socket, initiating 

Abichandani anticipates and/or renders obvious claim 84. See supra claims 1, 84. 

In addition, Abichandani discloses this claim. See supra claims 1, 84. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 48 of 77 PageID #:

4623
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

transmission, initiating a data flow, or 

initiating a data stream.

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

86. The non-transitory computer-readable 

storage medium recited in claim 84, 

wherein the message comprises a reset 

message, an indication that the service 

usage activity is not allowed, or an 

indication that the wireless network is not 

available.

Abichandani anticipates and/or renders obvious claim 84. See supra claims 1, 84. 

In addition, Abichandani discloses this claim. See supra claims 1, 84. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

87. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) identify a socket to be opened for the 

service usage activity; and

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) based on a condition, block the service 

usage activity or terminate the socket.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

88. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein controlling the service usage 

activity comprises: blocking a network 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

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4624
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

access event or attempt associated with 

the first software component, modulating 

a number of access events or attempts 

associated with the first software 

component, aggregating a plurality of 

access events or attempts associated with 

the first software component, or timewindowing the number of access events 

or attempts associated with the first 

software component.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

89. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein, when executed by the one or 

more processors of the wireless end-user 

device, the machine-executable 

instructions further cause the one or more 

processors to:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) if it is determined that the service 

usage activity is not the background 

activity, refrain from applying the policy.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

90. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein the policy is a first policy, and 

wherein, when executed by the one or 

more processors of the wireless end-user 

device, the machine-executable 

instructions further cause the one or more 

processors to:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) if it is determined that the service 

usage activity is not the background 

activity, apply a second policy.

Abichandani discloses this element. See supra claim 1. 

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4625
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

91. The non-transitory computer-readable 

storage medium recited in claim 1, 

wherein apply the policy comprises cause 

a notification to be presented through a 

user interface of the wireless end-user 

device.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

92. The non-transitory computer-readable 

storage medium recited in claim 91, 

wherein the notification provides 

information about the policy.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

93. The non-transitory computer-readable 

storage medium recited in claim 91, 

wherein the notification provides 

information about an option to set, 

control, override, or modify the at least an 

aspect of the policy or a second aspect of 

the policy.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

94. The non-transitory computer-readable 

storage medium recited in claim 91, 

wherein, when executed by the one or 

more processors of the wireless end-user 

device, the machine-executable 

instructions further cause the one or more 

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 51 of 77 PageID #:

4626
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

processors to obtain an indication of a 

user response to the notification.

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

95. The non-transitory computer-readable 

storage medium recited in claim 91, 

wherein the notification provides a 

warning or an alert.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

96. The non-transitory computer-readable 

storage medium recited in claim 91, 

wherein the notification provides 

information about a service plan limit.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

97. The non-transitory computer-readable 

storage medium recited in claim 91, 

wherein the first software component is at 

least a portion of an application, and 

wherein the one or more prospective or 

successful communications over the 

wireless network comprise an attempt to 

launch, run, or execute the application, 

and wherein the notification comprises 

information about the attempt to launch, 

run, or execute the application.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

98. The non-transitory computer-readable 

storage medium recited in claim 91,

wherein the one or more prospective or 

successful communications over the 

wireless network comprise an attempted 

or successful launch or execution of the 

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

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4627
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

first software component, and wherein the 

notification comprises information about 

the attempted or successful launch or 

execution of the first software component.

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

99. The non-transitory computer-readable 

storage medium recited in claim 91, 

wherein the policy is based on a limit, and 

wherein, when executed by the one or 

more processors of the wireless end-user 

device, the machine-executable 

instructions further cause the one or more 

processors to determine that a data usage 

associated with the service usage activity 

is not less than the limit, and wherein 

cause a notification to be presented 

through a user interface of the wireless 

end-user device comprises trigger 

presentation of the notification based on 

the determination that the data usage 

associated with the service usage activity 

is not less than the limit.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

100. The non-transitory computerreadable storage medium recited in claim 

91, wherein the one or more prospective 

or successful communications over the 

wireless network comprise an attempt to 

download or load an application, and 

wherein the notification comprises 

information about the attempted 

download or load of the application.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

101. The non-transitory computerreadable storage medium recited in claim 

91, wherein the one or more prospective 

or successful communications over the 

wireless network comprise an attempt to 

initiate usage of a cloud-based service or 

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 53 of 77 PageID #:

4628
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

application, and wherein the notification 

comprises information about the 

attempted initiation of usage of the cloudbased service or application.

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

102. The non-transitory computerreadable storage medium recited in claim 

91, wherein the notification indicates that 

one or more service usage activities are 

subject to the policy.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

103. The non-transitory computerreadable storage medium recited in claim 

91, wherein the notification provides 

information about a second network.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

104. The non-transitory computerreadable storage medium recited in claim 

91, wherein the notification comprises an 

offer for a service plan upgrade or 

downgrade.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

105. The non-transitory computerreadable storage medium recited in claim 

91, wherein apply the policy further 

comprises obtain an indication of a user 

preference in response to the notification.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

Case 2:23-cv-00379-JRG-RSP Document 76-15 Filed 08/21/24 Page 54 of 77 PageID #:

4629
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

106. The non-transitory computerreadable storage medium recited in claim 

105, wherein the indication of the user 

preference comprises a user directive to 

associate the policy with a second 

software component.

Abichandani anticipates and/or renders obvious claim 105. See supra claims 1, 105. 

In addition, Abichandani discloses this claim. See supra claims 1, 105. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

107. The non-transitory computerreadable storage medium recited in claim 

105, wherein the indication of the user 

preference comprises a user directive to 

allow or block the service usage activity.

Abichandani anticipates and/or renders obvious claim 105. See supra claims 1, 105. 

In addition, Abichandani discloses this claim. See supra claims 1, 105. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

108. The non-transitory computerreadable storage medium recited in claim 

105, wherein the indication of the user 

preference identifies a traffic control 

setting associated with the policy.

Abichandani anticipates and/or renders obvious claim 105. See supra claims 1, 105. 

In addition, Abichandani discloses this claim. See supra claims 1, 105. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

109. The non-transitory computerreadable storage medium recited in claim 

105, wherein the indication of the user 

preference comprises a user directive to 

allow the service usage activity under a 

specified condition.

Abichandani anticipates and/or renders obvious claim 105. See supra claims 1, 105. 

In addition, Abichandani discloses this claim. See supra claims 1, 105. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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4630
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

110. The non-transitory computerreadable storage medium recited in claim 

105, wherein the indication of the user 

preference comprises a user directive to 

override or modify the policy.

Abichandani anticipates and/or renders obvious claim 105. See supra claims 1, 105. 

In addition, Abichandani discloses this claim. See supra claims 1, 105. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

111. The non-transitory computerreadable storage medium recited in claim 

91, wherein cause a notification to be 

presented through a user interface of the 

wireless end-user device comprises cause 

the notification to be presented based on 

occurrence of a trigger.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

112. The non-transitory computerreadable storage medium recited in claim 

111, wherein the trigger is: a measure of 

the service usage activity satisfies a first 

condition relative to a threshold, an aspect 

of the service usage activity satisfies a 

second condition, a change to the policy, 

or a message from the network element.

Abichandani anticipates and/or renders obvious claim 111. See supra claims 1, 111. 

In addition, Abichandani discloses this claim. See supra claims 1, 111. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

113. The non-transitory computerreadable storage medium recited in claim 

91, wherein the notification enables a user 

associated with the wireless end-user 

device to obtain information about at least 

an aspect of the service usage activity or a 

service plan associated with the wireless 

end-user device.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

114. The non-transitory computerreadable storage medium recited in claim 

91, wherein the notification presents a list 

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

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4631
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

of service usage activities or software 

components, the list of service usage 

activities or software components 

including the service usage activity or the 

first software component.

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

115. The non-transitory computerreadable storage medium recited in claim 

91, wherein the notification presents an 

option to modify the policy.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

116. The non-transitory computerreadable storage medium recited in claim 

91, wherein the notification presents an 

indication of a measure of usage of the 

wireless network associated with the 

service usage activity.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

117. The non-transitory computerreadable storage medium recited in claim 

91, wherein the notification is provided 

through an e-mail, a text message, a 

window, a setting, or a voice message.

Abichandani anticipates and/or renders obvious claim 91. See supra claims 1, 91. 

In addition, Abichandani discloses this claim. See supra claims 1, 91. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

118. The non-transitory computerreadable storage medium recited in claim 

1, wherein, when executed by the one or 

more processors of the wireless end-user 

device, the machine-executable 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

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4632
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

instructions further cause the one or more 

processors to:

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) cause a notification to be presented 

through a user interface of the wireless 

end-user device.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

119. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification provides 

information about the policy.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

120. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification provides 

information about an option to set, 

control, override, or modify the at least an 

aspect of the policy or a second aspect of 

the policy.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

121. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification indicates 

that the service usage activity is the 

background activity.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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4633
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

122. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification provides 

information about a second network.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

123. The non-transitory computerreadable storage medium recited in claim 

118, wherein, when executed by the one 

or more processors of the wireless enduser device, the machine-executable 

instructions further cause the one or more 

processors to obtain an indication of a 

user preference in response to the 

notification.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

124. The non-transitory computerreadable storage medium recited in claim 

123, wherein the indication of the user 

preference comprises a user directive to 

associate the policy with the first software 

component.

Abichandani anticipates and/or renders obvious claim 123. See supra claims 1, 123. 

In addition, Abichandani discloses this claim. See supra claims 1, 123. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

125. The non-transitory computerreadable storage medium recited in claim 

123, wherein the indication of the user 

preference comprises a user directive to 

restrict, allow, or block the service usage 

activity.

Abichandani anticipates and/or renders obvious claim 123. See supra claims 1, 123. 

In addition, Abichandani discloses this claim. See supra claims 1, 123. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

126. The non-transitory computerreadable storage medium recited in claim 

Abichandani anticipates and/or renders obvious claim 123. See supra claims 1, 123. 

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4634
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

123, wherein the indication of the user

preference identifies a traffic control 

setting associated with the policy.

In addition, Abichandani discloses this claim. See supra claims 1, 123. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

127. The non-transitory computerreadable storage medium recited in claim 

123, wherein the indication of the user 

preference comprises a user directive to 

override or modify the policy.

Abichandani anticipates and/or renders obvious claim 123. See supra claims 1, 123. 

In addition, Abichandani discloses this claim. See supra claims 1, 123. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

128. The non-transitory computerreadable storage medium recited in claim 

123, wherein the indication of the user 

preference comprises a user 

acknowledgment of the notification.

Abichandani anticipates and/or renders obvious claim 123. See supra claims 1, 123. 

In addition, Abichandani discloses this claim. See supra claims 1, 123. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

129. The non-transitory computerreadable storage medium recited in claim 

123, wherein the indication of the user 

preference indicates one or more network 

types.

Abichandani anticipates and/or renders obvious claim 123. See supra claims 1, 123. 

In addition, Abichandani discloses this claim. See supra claims 1, 123. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

130. The non-transitory computerreadable storage medium recited in claim 

129, wherein the one or more network 

types comprise WiFi, 4G, 3G, wireless, 

wired, or a combination of these.

Abichandani anticipates and/or renders obvious claim 129. See supra claims 1, 129. 

In addition, Abichandani discloses this claim. See supra claims 1, 32, 129. 

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4635
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

131. The non-transitory computerreadable storage medium recited in claim 

118, wherein cause a notification to be 

presented through a user interface of the 

wireless end-user device comprises cause 

the notification to be presented based on 

occurrence of a trigger.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

132. The non-transitory computerreadable storage medium recited in claim 

131, wherein the trigger is: a measure of 

the service usage activity satisfies a first 

condition relative to a threshold, an aspect 

of the service usage activity satisfies a 

second condition, a change to the policy, 

or a message from the network element.

Abichandani anticipates and/or renders obvious claim 131. See supra claims 1, 131. 

In addition, Abichandani discloses this claim. See supra claims 1, 131. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

133. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification enables a 

user associated with the wireless end-user 

device to obtain information about at least 

an aspect of the service usage activity or a 

service plan associated with the wireless 

end-user device.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

134. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification presents a 

list of service usage activities or software 

components, the list of service usage 

activities or software components 

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

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4636
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

including the service usage activity or the 

first software component.

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

135. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification presents 

information about a setting associated 

with the policy.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

136. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification presents 

information about the wireless network.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

137. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification presents an 

indication of a measure of usage of the 

wireless network associated with the 

service usage activity.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

138. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification presents 

information about a network busy state or 

a network availability state.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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4637
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

139. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification presents an 

indication of a measure of usage of the 

wireless network associated with the first 

software component.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

140. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification presents 

information about a statistic associated 

with the service usage activity.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

141. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification comprises a 

gauge providing service usage 

information associated with the service 

usage activity.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

142. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification comprises a 

gauge providing service usage 

information associated with one or more 

networks, the one or more networks 

including the wireless network.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

143. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification comprises a 

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

gauge providing information associated 

with a service plan.

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

144. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification is provided 

through an e-mail, a text message, a 

window, a setting, or a voice message.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

145. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification comprises a 

warning or an alert.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

146. The non-transitory computerreadable storage medium recited in claim 

118, wherein the information from the 

network element is first information, and 

wherein the notification is based on 

second information from the network 

element.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

147. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification comprises 

information about a cost or a charge 

associated with the service usage activity.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

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4639
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

148. The non-transitory computerreadable storage medium recited in claim 

118, wherein the notification comprises 

information about a service sponsor.

Abichandani anticipates and/or renders obvious claim 118. See supra claims 1, 118. 

In addition, Abichandani discloses this claim. See supra claims 1, 118. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

149. The non-transitory computerreadable storage medium recited in claim 

1, wherein, when executed by the one or 

more processors of the wireless end-user 

device, the machine-executable 

instructions further cause the one or more 

processors to:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) detect an attempted use of the first 

software component; and

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) based on the detected attempted use of 

the first software component, cause a 

notification to be presented through a user 

interface of the wireless end-user device.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

150. The non-transitory computerreadable storage medium recited in claim 

Abichandani anticipates and/or renders obvious claim 149. See supra claims 1, 149. 

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

149, wherein the notification provides 

information to enable a user associated 

with the wireless end-user device to 

override the policy.

In addition, Abichandani discloses this claim. See supra claims 1, 149. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

151. The non-transitory computerreadable storage medium recited in claim 

149, wherein the notification provides 

information about a cost or a charge 

associated with the service usage activity.

Abichandani anticipates and/or renders obvious claim 149. See supra claims 1, 149. 

In addition, Abichandani discloses this claim. See supra claims 1, 149. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

152. The non-transitory computerreadable storage medium recited in claim 

149, wherein the notification provides 

information to enable a user associated 

with the wireless end-user device to 

change or upgrade a service plan 

associated with the wireless end-user 

device.

Abichandani anticipates and/or renders obvious claim 149. See supra claims 1, 149. 

In addition, Abichandani discloses this claim. See supra claims 1, 149. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

153. The non-transitory computerreadable storage medium recited in claim 

1, wherein the at least an aspect of a 

policy is based on the user input obtained 

through the user interface of the wireless 

end-user device, and wherein the user 

input specifies a user preference 

associated with one or more network 

types.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

154. The non-transitory computerreadable storage medium recited in claim 

153, wherein the one or more network 

types comprise wireless fidelity (WiFi), 

Abichandani anticipates and/or renders obvious claim 153. See supra claims 1, 153. 

In addition, Abichandani discloses this claim. See supra claims 1, 32, 153. 

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

home, roaming, 4G, 3G, wireless, wired, 

or a combination of these.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

155. The non-transitory computerreadable storage medium recited in claim 

1, wherein the user input obtained through 

the user interface of the wireless end-user 

device is a first user input, and wherein 

the policy is a first policy, and wherein 

the first user input or a second user input 

comprises a directive to apply a second 

policy to a second software component of 

the plurality of software components on 

the wireless end-user device.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

156. The non-transitory computerreadable storage medium recited in claim 

1, wherein the user input obtained through 

the user interface of the wireless end-user 

device is a first user input, and wherein 

the first user input or a second user input 

comprises a directive to refrain from 

applying the policy to a second software 

component of the plurality of software 

components on the wireless end-user 

device.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

157. The non-transitory computerreadable storage medium recited in claim 

1, wherein the user input obtained through 

the user interface of the wireless end-user 

device comprises a directive to apply the 

policy to a second software component of 

the plurality of software components on 

the wireless end-user device.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

158. The non-transitory computerreadable storage medium recited in claim 

1, wherein the user input obtained through 

the user interface of the wireless end-user 

device specifies a user preference 

associated with the service usage activity 

or the first software component.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

159. The non-transitory computerreadable storage medium recited in claim 

158, wherein the user preference 

comprises a preference to restrict, allow, 

block, delay, or throttle the service usage 

activity.

Abichandani anticipates and/or renders obvious claim 158. See supra claims 1, 158.

In addition, Abichandani discloses this claim. See supra claims 1, 158. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

160. The non-transitory computerreadable storage medium recited in claim 

1, wherein the service usage activity is a 

first service usage activity, and wherein 

the wireless network is a first wireless 

network, and wherein, when executed by 

the one or more processors of the wireless 

end-user device, the machine-executable 

instructions further cause the one or more 

processors to:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) identify a second service usage 

activity of the wireless end-user device, 

the second service usage activity being 

associated with the first software 

component or with a second software 

component of the plurality of software 

components on the wireless end-user 

device, the second service usage activity 

comprising one or more prospective or 

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

successful communications over a second 

wireless network; and

(b) refrain from applying the policy to the 

second service usage activity.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

161. The non-transitory computerreadable storage medium recited in claim 

1, wherein the service usage activity is a 

first service usage activity, and wherein 

the background activity is a first 

background activity, and wherein the 

wireless network is a first wireless 

network, and wherein the policy is a first 

policy, and wherein, when executed by 

the one or more processors of the wireless 

end-user device, the machine-executable 

instructions further cause the one or more 

processors to:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) identify a second service usage 

activity of the wireless end-user device, 

the second service usage activity being 

associated with the first software 

component or with a second software 

component of the plurality of software 

components on the wireless end-user 

device, the second service usage activity 

comprising one or more prospective or 

successful communications over a second 

wireless network; and

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) determine whether the second service 

usage activity is a second background 

activity;

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

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4644
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(c) if it is determined that the second 

service usage activity is the second 

background activity, apply a second 

policy to the second service usage 

activity.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

162. The non-transitory computerreadable storage medium recited in claim 

161, wherein the first policy restricts or 

prevents the first background activity, and 

wherein the second policy allows the 

second background activity.

Abichandani anticipates and/or renders obvious claim 161. See supra claims 1, 161. 

In addition, Abichandani discloses this claim. See supra claims 1, 161. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

163. The non-transitory computerreadable storage medium recited in claim 

1, wherein the service usage activity is a 

first service usage activity, and wherein 

the wireless network is a first wireless 

network, and wherein the policy is a first 

policy, and wherein, when executed by 

the one or more processors of the wireless 

end-user device, the machine-executable 

instructions further cause the one or more 

processors to:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) identify a second service usage 

activity of the wireless end-user device, 

the second service usage activity being 

associated with the first software 

component or with a second software 

component of the plurality of software 

components on the wireless end-user 

device, the second service usage activity 

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

comprising one or more prospective or 

successful communications over a second 

wireless network; and

(b) apply a second policy to the second 

service usage activity.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

164. The non-transitory computerreadable storage medium recited in claim 

163, wherein the second policy comprises 

a control policy, a notification policy, or 

an accounting policy associated with the 

first software component or the second 

software component.

Abichandani anticipates and/or renders obvious claim 163. See supra claims 1, 163. 

In addition, Abichandani discloses this claim. See supra claims 1, 163. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

165. The non-transitory computerreadable storage medium recited in claim 

1, wherein the service usage activity is a 

first service usage activity, and wherein 

the one or more prospective or successful 

communications over the wireless 

network are first one or more prospective 

or successful communications over the 

first wireless network, and wherein the 

background activity is a first background 

activity, and wherein the user input 

obtained through the user interface of the 

wireless end-user device is a first user 

input, and wherein, when executed by the 

one or more processors of the wireless 

end-user device, the machine-executable 

instructions further cause the one or more 

processors to:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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4646
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

(a) identify a second service usage 

activity of the wireless end-user device, 

the second service usage activity being 

associated with a second software 

component of the plurality of software 

components on the wireless end-user 

device, the second service usage activity 

comprising second one or more 

prospective or successful communications 

over the wireless network;

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) determine whether the second service 

usage activity is a second background 

activity; and

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(c) if it is determined that the second 

service usage activity is the second 

background activity, apply at least a 

portion of the policy, wherein the at least 

a portion of the policy is based on a 

second user input.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

166. The non-transitory computerreadable storage medium recited in claim 

1, wherein the service usage activity is a 

first service usage activity, and wherein 

the one or more prospective or successful 

communications over the wireless 

network are first one or more prospective 

or successful communications over the 

wireless network, and wherein, when 

executed by the one or more processors of 

the wireless end-user device, the machineexecutable instructions further cause the 

one or more processors to:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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4647
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

(a) identify a second service usage 

activity of the wireless end-user device, 

the second service usage activity being 

associated with a second software 

component of the plurality of software 

components on the wireless end-user 

device, the second service usage activity 

comprising second one or more 

prospective or successful communications 

over the wireless network;

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) determine whether the second service 

usage activity is the background activity; 

and

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(c) if it is determined that the second 

service usage activity is the background 

activity, refrain from applying at least a 

portion of the policy.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

167. The non-transitory computerreadable storage medium recited in claim 

1, wherein the background activity is a 

first background activity, and wherein the 

service usage activity is a first service 

usage activity, and wherein the one or 

more prospective or successful 

communications over the wireless 

network are first one or more prospective 

or successful communications over the 

wireless network, and wherein the policy 

is a first policy, and wherein, when 

executed by the one or more processors of 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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4648
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

the wireless end-user device, the machineexecutable instructions further cause the 

one or more processors to:

(a) identify a second service usage 

activity of the wireless end-user device, 

the second service usage activity being 

associated with a second software 

component of the plurality of software 

components on the wireless end-user 

device, the second service usage activity 

comprising second one or more 

prospective or successful communications 

over the wireless network;

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) determine whether the second service 

usage activity is a second background 

activity;

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(c) obtain a second policy, the second 

policy to be applied when the second 

service usage activity is the second 

background activity, the second policy for 

controlling the second service usage 

activity; and

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(d) if it is determined that the second 

service usage activity is the second 

background activity, apply the second 

policy.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

168. The non-transitory computerreadable storage medium recited in claim 

167, wherein the first policy, the second 

policy, or both are based on a network 

Abichandani anticipates and/or renders obvious claim 167. See supra claims 1, 167. 

In addition, Abichandani discloses this claim. See supra claims 1, 167. 

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4649
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

busy state, a network availability state, or 

a cost associated with the wireless 

network.

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

169. The non-transitory computerreadable storage medium recited in claim 

1, wherein the service usage activity is a 

first service usage activity, and wherein 

the one or more prospective or successful 

communications over the wireless 

network are first one or more prospective 

or successful communications over the 

wireless network, and wherein, when 

executed by the one or more processors of 

the wireless end-user device, the machineexecutable instructions further cause the 

one or more processors to:

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(a) identify a second service usage 

activity of the wireless end-user device, 

the second service usage activity being 

associated with the first software 

component, the second service usage 

activity comprising second one or more 

prospective or successful communications 

over the wireless network;

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(b) determine whether the second service 

usage activity is the background activity; 

and

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

(c) if it is determined that the second 

service usage activity is the background 

activity, apply at least a portion of the 

policy.

Abichandani discloses this element. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

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4650
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

170. The non-transitory computerreadable storage medium recited in claim 

1, wherein, when executed by the one or 

more processors of the wireless end-user 

device, the machine-executable 

instructions further cause the one or more 

processors to monitor the service usage 

activity, account for the service usage 

activity, report information about the 

service usage activity, or a combination of 

these.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

171. The wireless end-user device 

embodying the non-transitory computerreadable storage medium recited in claim 

1.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

172. The non-transitory computerreadable storage medium recited in claim 

1, wherein the network element comprises 

a service controller, a server, a cloud 

element, or a billing element.

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

173. The non-transitory computerreadable storage medium recited in claim 

1, wherein, when executed by the one or 

more processors of the wireless end-user 

device, the machine-executable 

instructions further cause the one or more 

Abichandani anticipates and/or renders obvious claim 1. See supra claim 1. 

In addition, Abichandani discloses this claim. See supra claim 1. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

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4651
Exhibit A-1 – Invalidity of U.S. Patent No. 8,589,541 in view of Abichandani

processors to provide information about 

the service usage activity to the network 

element.

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

174. The non-transitory computerreadable storage medium recited in claim 

173, wherein the information about the 

service usage activity comprises a count 

of data traffic associated with the service 

usage activity, a transaction count, a 

message count, a connection time, a 

connection duration, a classification of 

traffic, an indication that a measure of the 

service usage activity satisfies a condition 

relative to a threshold, a parameter 

associated with the service usage activity, 

an indication that the background activity 

is restricted, or a combination of these.

Abichandani anticipates and/or renders obvious claim 173. See supra claims 1, 173. 

In addition, Abichandani discloses this claim. See supra claims 1, 173. 

To the extent Abichandani does not explicitly and/or inherently disclose this element, it would have been 

obvious in view of the knowledge of a person of ordinary skill in the art in light of Abichandani alone or it 

would have been obvious to combine Abichandani with one or more prior art references charted in these 

Invalidity Contentions or identified in the cover document to which this chart is attached.

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4652