Apple said that if the court orders it to pay a rate higher than $1 per device, it would pursue all possible appeals.

"Make no mistake, that is not an outcome Apple desires," it said of the possibility of an appeal and further litigation. "But if the Court were to set, for example, the rate Motorola is seeking, that would amount to billions of dollars per year. That is orders of magnitude more than Apple is paying for even substantially larger standards-essential patent portfolios."

Apple said if it had to pay the Motorola Mobility rate, the total cost over several years would be larger than the $12.5 billion acquisition cost paid by Google, which bought Motorola Mobility in May.

"In such circumstances, Apple may need Motorola to demonstrate that its declared essential patents are in fact essential patents and worth that amount of money, a hurdle Motorola has thus far been unable to clear with what are presumably its best patents," it said.

The IDG News Service