IPod sixth generation, it has been applied here retroactively to all generic iPods for clarity. In 2005, Apple faced two lawsuits claiming patent infringement by the iPod line and its associated technologies: Advanced Audio Devices claimed the iPod line breached its patent on a "music jukebox", while a Hong Kong-based IP portfolio company called Pat-rights filed a suit claiming that Apple's FairPlay technology breached a patent issued to inventor Ho Keung Tse. The latter case also includes the online music stores of Sony, RealNetworks, Napster, and Musicmatch as defendants. Apple's application to the United States Patent and Trademark Office for a
IPhone 3GS more favorable reviews mainly because it comes pre-installed with iOS 4. Jason Snell of Macworld praised the iPhone 3GS, saying that "the device's internal changes shines in the iOS 4 update, making the iPhone 3GS a worthwhile upgrade compared to its predecessor although a little too late compared to the iPhone 4." TIPB stated that "aside from hardware specific features like FaceTime, Retina Display, and gyroscope support, the bottom line is iPhone 3GS users are getting the same software that makes the iPhone 4 great." Shortly after the release of the iPhone 3GS, some users reported overheating of the device