Case 5:18-md-02834-BLF Document 96-3 Filed 09/13/18 Page 1 of 19
`Case 5:18—md-02834-BLF Document 96-3 Filed 09/13/18 Page 1 of 19
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`APPENDIX C
`APPENDIX C
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`

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`Case 5:18-md-02834-BLF Document 96-3 Filed 09/13/18 Page 2 of 19
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`Appendix C
`
`The first set of tables in this appendix compares PersonalWeb's infringement allegations asserted in PersonalWeb's current counter(cid:173)
`claims against Amazon (Amazon.com Inc. v. Persona/Web Techs., LLC, No. 5:18-cv-00767-BLF, Dkt. No. 62) with PersonalWeb's
`infringement allegations in one of its latest-filed complaints that Personal Web does not intend to amend. (Persona/Web Techs., LLC v.
`Strava, Inc., No. 5:18-cv-04627-BLF, Dkt. No. 1).
`
`The second set of tables compares Personal Web's infringement allegations in its proposed amended counterclaims against Amazon in
`the DJ Action (No. 5: 18-cv-00767-BLF) with its infringement allegations from a sample second amended complaint that Personal Web
`proposes filing in many of the website defendant cases.
`
`I.
`
`Comparison of Infringement Allegations in Filed Counterclaims against Amazon and Filed Complaints
`
`Filed Counterclaims Against Amazon1
`
`Filed Complaint PersonalWeb Does Not Intend to Amend2
`
`Alleged "INFRINGEMENT OF U.S. PATENT NO. 6,928,442"
`
`Amazon has infringed at least claims 10 and 11 of the '442 pa-
`Defendant has infringed at least claims 10 and 11 of the '442 pa-
`tent by its manufacture, use, sale, importation, and/or offer for
`tent by its manufacture, use, sale, importation, and/or offer for
`sale of products or services, and/or controlling the distribution of sale of products or services, and/or controlling the distribution of
`its webpage content in the manner described herein. Amazon's
`its webpage content in the manner described herein. Defendant's
`infringement is literal and/or under the doctrine of equivalents
`infringement is literal and/or under the doctrine of equivalents
`and Amazon is liable for its infringement of the '442 patent pur-
`and Defendant is liable for its infringement of the '442 patent
`suant to 35 U.S.C. § 271.
`pursuant to 35 U.S.C. § 271.
`
`For example, claim 10 covers "a method, in a system in which a
`plurality of files are distributed across a plurality of computers."
`On information and belief, Amazon has used a system of notifi-
`cations and authorizations to distribute a plurality of files, e.g,
`
`For example, claim 10 covers "a method, in a system in which a
`plurality of files are distributed across a plurality of computers."
`On information and belief, Defendant has used a system of noti-
`fications and authorizations to distribute a plurality of files, e.g.,
`
`1 Amazon.com Inc. v. Persona/Web Techs., LLC, No. 5: 18-cv-00767-BLF, Dkt. No . 62 ,r,r 46-50.
`2 Persona/Web Techs. , LLC v. Strava, Inc., No. 5: 18-cv-04627-BLF, Dkt. No. 1 ,r,r 52-56.
`Joint Case Management Statement
`Appendix C
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`the web server customers' files containing content necessary to
`render the web server customers' webpages, across a plurality of
`computers such as S3 web host servers, intermediate cache serv(cid:173)
`ers, and endpoint caches used by browsers rendering the web
`server customers' webpages.
`
`Claim 10 then recites the act of "obtaining a name for a data file,
`the name being based at least in part on a given function of the
`data, wherein the data used by the function comprises the con(cid:173)
`tents of the particular file." As set forth above, on information
`and belief, Amazon generated ETags for the index and asset files
`used to render web server customers' webpages using a hash
`function, wherein the ETag were based on the contents of the
`particular file. Moreover, Amazon caused the intermediate
`caches servers and endpoint caches to obtain the ETags and
`URis in HTTP 200 messages sent from the S3 web host servers.
`On information and belief, Amazon caused intermediate cache
`servers to obtain ETags and URis in conditional GET messages
`from endpoint and intermediate caches, as described supra.
`
`Defendant's files containing content necessary to render its
`webpages, across a plurality of computers such as production
`servers, origin servers, intermediate cache servers and endpoint
`caches used by browsers rendering Defendant's webpages.
`
`Claim 10 then recites the act of "obtaining a name for a data file,
`the name being based at least in part on a given function of the
`data, wherein the data used by the function comprises the con(cid:173)
`tents of the particular file." As set forth above, on information
`and belief, Defendant generated or otherwise obtained ETags for
`its webpage and asset files used to render its webpages using a
`hash function, wherein the ETags were based on the contents of
`the particular files. Moreover, Defendant caused the intermedi(cid:173)
`ate caches servers and endpoint caches to obtain the ETags in
`HTTP 200 responses sent from Defendant's origin servers. On
`information and belief, Defendant caused intermediate cache
`servers and its origin servers to obtain ETags in conditional GET
`messages from endpoint and intermediate caches, as described
`supra.
`
`Claim 10 then recites the act of "determining, using at least the
`name, whether a copy of the data file is present on at least one of
`said computers." On information and belief, as set forth above,
`S3 web host servers have, and Amazon has caused the interme(cid:173)
`diate cache servers between an endpoint cache and one of the S3
`web host servers to, in response to receiving a conditional GET
`request with an If-None-Match header, determine whether it has
`a file present that matches the URI in the conditional GET and to
`compare the ETag in the conditional GET to the Etag for that
`URI and determine whether a copy of the content having that
`ETag is present.
`
`Claim 10 then recites the act of "determining, using at least the
`name, whether a copy of the data file is present on at least one of
`said computers." On information and belief, as set forth above,
`Defendant has caused its origin severs and the intermediate
`cache servers between and endpoint cache and one of its origin
`servers to, in response to receiving a conditional GET request
`with an If-None-Match header, determine whether it has a file
`present that matches the URI in the conditional GET and to com(cid:173)
`pare the ETag in the conditional GET to the ETag for that URI
`and determine whether a copy of the content having that ETag is
`present.
`
`Claim 10 then recites the act of "determining whether a copy of
`the data file that is present on a at least one of said computers is
`
`Claim 10 then recites the act of "determining whether a copy of
`the data file that is present on a at least one of said computers is
`
`Joint Case Management Statement
`Appendix C
`
`2
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`an unauthorized copy or an unlicensed copy of the data file." On
`information and belief, as set forth above, if there was a match,
`and it was determined that the max-age value was unexpired
`and/or after any further reauthorization check required by other
`directives set by the web server customer via "cache-control"
`headers, the origin or intermediate cache server determined that
`the copy of the file present at the downstream intermediate cache
`server and/or the endpoint cache was an authorized or licensed
`copy of the data file. Conversely, if there was no match, it deter(cid:173)
`mined that the copy of the file present at the downstream inter(cid:173)
`mediate cache server and/or the endpoint cache was an unauthor(cid:173)
`ized or unlicensed copy of the data file. Likewise, if the browser
`determined that it had a file with a matching URI, and its max(cid:173)
`age value was unexpired and/or after any further reauthorization
`check required by the web server customer via other directives
`in "cache-control" headers, the browser determined that it was
`still authorized to use that file.
`
`an unauthorized copy or an unlicensed copy of the data file." On
`information and belief, as set forth above, if there was a match,
`the origin or intermediate cache server determined that the copy
`of the file present at the downstream intermediate cache server
`and/or the endpoint cache was an authorized or licensed copy of
`the data file. Conversely, if there was no match, it determined
`that the copy of the file present at the downstream intermediate
`cache server and/or the endpoint cache was an unauthorized
`copy of the data file. Likewise, if the browser determined that it
`had a file with a matching URI, the browser determined that it
`was still authorized to use that file.
`
`Counterclaims Against Amazon3
`
`Filed Complaint PersonalWeb Does Not Intend to Amend4
`
`Alleged "INFRINGEMENT OF U.S. PATENT NO. 7,945,544"
`
`Amazon has infringed at least claims 46, 48, 52, and 55 of the
`'544 patent by its manufacture, use, sale, importation, and/or of-
`fer for sale of products or services, and/or controlling the distri-
`bution of its webpage content in the manner described herein.
`Amazon's infringement is literal and/or under the doctrine of
`
`Defendant has infringed at least claims 46, 48, 52, and 55 of the
`'544 patent by its manufacture, use, sale, importation, and/or of-
`fer for sale of products or services, and/or controlling the distri-
`bution of its webpage content in the manner described herein.
`Defendant's infringement is literal and/or under the doctrine of
`
`3 Amazon.com Inc. v. Persona/Web Techs., LLC, No. 5:18-cv-00767-BLF, Dkt. No. 62 ,-r,-r 61-68.
`4 Persona/Web Techs., LLC v. Strava, Inc., No. 5:18-cv-04627-BLF, Dkt. No. 1 ,-r,-r 70-77.
`
`Joint Case Management Statement
`Appendix C
`
`,.,
`
`.)
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`equivalents and Amazon is liable for its infringement of the '544
`patent pursuant to 35 U.S.C. § 271.
`
`equivalents and Defendant is liable for its infringement of the
`'544 patent pursuant to 35 U.S.C. § 271.
`
`For example, claim 46 covers a claimed "computer-implemented
`method." On information and belief, Amazon uses the claimed
`computer implemented method by using a system of notifica(cid:173)
`tions and authorizations to locate and control the distribution of
`data items, such as various index and asset files, necessary to
`render its web server customers' webpages.
`
`For example, claim 46 covers a claimed "computer-implemented
`method." On information and belief, Defendant uses the claimed
`computer implemented method by using a system of notifica(cid:173)
`tions and authorizations to locate and control the distribution of
`data items, such as various webpage and asset files, necessary to
`render its webpages.
`
`Claim 46 then recites the act of "(A) for each particular file of a
`plurality of files: ( a2) determining a particular digital key for the
`particular file, wherein the particular file comprises a first one or
`more parts." On information and belief, for some of Amazon's
`web server customers ("URI fingerprint customers"), each of the
`URI fingerprint customers' webpages comprises one or more as(cid:173)
`set files and has an associated index file. The index file con(cid:173)
`tained URis having fingerprints of a plurality of asset files com(cid:173)
`prising that webpage. On information and belief, once the index
`and asset files are compiled and complete and the files have been
`uploaded to the S3 host system by the URI fingerprint custom(cid:173)
`ers, the index file's associated ETag value is generated by apply(cid:173)
`ing a hash algorithm to the index file's contents, wherein any
`two index files comprising the identical content will have identi(cid:173)
`cal associated ETag values. On information and belief, whenever
`a new index file is uploaded to an S3 server or the index file's
`content changes, Amazon determines and associates an ETag for
`the index file at the time of upload.
`
`Claim 46 then recites the act of "(A) for each particular file of a
`plurality of files: ( a2) determining a particular digital key for the
`particular file, wherein the particular file comprises a first one or
`more parts." On information and belief, each of Defendant's
`webpages comprises one or more asset files and has an associ(cid:173)
`ated webpage file, the webpage file containing the URis having
`fingerprints of a plurality of asset files comprising the webpage,
`and once the webpage and asset files are compiled and complete,
`Defendant stores them on a host system. On information and be(cid:173)
`lief, the webpage file's associated ETag value is generated by
`applying a hash algorithm to the webpage file's contents. On in(cid:173)
`formation and belief, whenever a new webpage file is generated
`or the webpage file's content changes, Defendant caused an
`ETag to be determined and associated to the webpage file.
`
`Claim 46 then recites "each part of said first one or more parts
`having a corresponding part value, the part value of each specific
`part of said first one or more parts being based on a first function
`of the contents of the specific part, wherein two identical parts
`will have the same part value as determined by the first function,
`
`Claim 46 then recites "each part of said first one or more parts
`having a corresponding part value, the part value of each specific
`part of said first one or more parts being based on a first function
`of the contents of the specific part, wherein two identical parts
`will have the same _l)_art value as determined by the first function,
`
`Joint Case Management Statement
`Appendix C
`
`4
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`and wherein the particular digital key for the particular file is de(cid:173)
`termined using a second function of the one or more of part val(cid:173)
`ues of said first one or more parts." On information and belief,
`prior to an asset file being uploaded to the S3 host system, a fin(cid:173)
`gerprint is generated for that asset file by applying a hash func(cid:173)
`tion to its contents. On information and belief, the fingerprint is
`inserted into the URI for that asset file. On information and be(cid:173)
`lief, the webpage's ETag value is generated by applying a sec(cid:173)
`ond hash function to its index file's contents, which consist of
`the URis of one or more of the asset files which comprise the
`webpage's contents. On information and belief, because the re(cid:173)
`spective asset file's URis include the fingerprints of their con(cid:173)
`tent, the webpage's ETag value will change and a new associ(cid:173)
`ated ETag value is generated to represent the webpage's content,
`when the content changes and two identical webpages having the
`identical content represented by their index file will have the
`same ETag value.
`
`and wherein the particular digital key for the particular file is de(cid:173)
`termined using a second function of the one or more of part val(cid:173)
`ues of said first one or more parts." On information and belief,
`prior to various asset files being stored on a host system, a fin(cid:173)
`gerprint is generated for each of these asset files by applying a
`hash function to the asset file's contents and the fingerprints are
`inserted into the URis for the respective asset files. On infor(cid:173)
`mation and belief, the webpage's ETag value is generated by ap(cid:173)
`plying a second hash function to the webpage file's contents,
`which include the URis of one or more of the asset files which
`comprise the webpage's contents. On information and belief, be(cid:173)
`cause the respective asset files' URis include the fingerprints of
`their content, the webpage's ETag value will change and a new
`associated ETag value is generated to represent the webpage's
`content, when the content changes and two identical webpages
`having the identical content represented by their webpage file
`will have the same ETag value.
`
`Claim 46 then recites the act of "(a2) adding the particular digi(cid:173)
`tal key of the particular file to a database, the database including
`a mapping from digital keys of files to information about the
`corresponding files." On information and belief, the S3 host sys(cid:173)
`tem, intermediate caches, and browser caches are caused to
`maintain database/tables which map the ETag of each webpage's
`index file to its URI, and information about the corresponding
`webpage, such as, for example, cache control information for the
`webpage.
`
`Claim 46 then recites the act of "(a2) adding the particular digi(cid:173)
`tal key of the particular file to a database, the database including
`a mapping from digital keys of files to information about the
`corresponding files." On information and belief, Defendant
`caused the origin server, intermediate caches and browser caches
`to maintain databases/tables which mapped the ETag of each
`webpage's webpage file to its URI, and information about the
`corresponding webpage, such as, for example, information from
`cache-control headers for the webpage.
`
`Claim 46 then recites "(B) determining a search key based on
`search criteria, wherein the search criteria comprise a second one
`or more parts, each of said second one or more parts of said
`search criteria having a corresponding part value, the part value
`of each specific part of said second one or more parts being
`based on the first function of the contents of the specific part,
`
`Claim 46 then recites "(B) determining a search key based on
`search criteria, wherein the search criteria comprise a second one
`or more parts, each of said second one or more parts of said
`search criteria having a corresponding part value, the part value
`of each specific part of said second one or more parts being
`based on the first function of the contents of the s2_ecific part,
`
`Joint Case Management Statement
`Appendix C
`
`5
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`and wherein the search key is determined using the second func(cid:173)
`tion of the one or more of part values of said se~ond one or more
`parts." On information and belief, when a downstream interme(cid:173)
`diate cache server or a browser again requests a webpage of a
`URI fingerprint customer, it sends a conditional GET request
`with an If-None-Match header with the webpage's associated
`ETag value. On information and belief, the received ETag value
`was determined using the second hash function of the webpage's
`index file, which includes URis including fingerprints for one or
`more of the asset files which comprise the webpage's contents.
`
`Claim 46 then recites "(C) attempting to match the search key
`with a digital key in the database." On information and belief,
`when the responding server receives the webpage's ETag value
`in a conditional GET request with an If-None-Match header, it
`compares the received ETag with the ETags it has maintained in
`a database/table corresponding to the URI of the webpage's in(cid:173)
`dex file to determine if there is matching value for that webpage.
`
`and wherein the search key is determined using the second func(cid:173)
`tion of the one or more of part values of said second one or more
`parts." On information and belief, when a downstream interme(cid:173)
`diate cache server or a browser again requested a webpage of
`Defendant, Defendant caused it to send a conditional GET re(cid:173)
`quest with an If-None-Match header with the webpage's associ(cid:173)
`ated ETag value. On information and belief, the received ETag
`value was determined using the second hash function of the
`webpage's webpage file, which included URis including finger(cid:173)
`prints for one or more of the asset files which comprised the
`webpage's contents.
`
`Claim 46 then recites "(C) attempting to match the search key
`with a digital key in the database." On information and belief,
`when the responding server received the webpage's ETag value
`in a conditional GET request with an If-None-Match header, it
`compared the received ETag with the ETag it has maintained in
`a database/table corresponding to the URI of the webpage's
`webpage file to determine if there is matching value for that
`webpage.
`
`Claim 46 then recites "(D) if the search key matches a particular
`digital key in the database, providing information about the file
`corresponding to the particular digital key." On information and
`belief, if the responding server has a matching ETag value for
`the webpage's index file, the responding server sends an HTTP
`304 message, which includes information about the correspond(cid:173)
`ing webpage, such as, for example, cache control information for
`the webpage
`
`Claim 46 then recites "(D) if the search key matches a particular
`digital key in the database, providing information about the file
`corresponding to the particular digital key." On information and
`belief, if the responding server had a matching ETag value for
`the webpage's webpage file, the responding server sent an HTTP
`304 response, which included information about the correspond(cid:173)
`ing webpage, such as, for example, information from cache-con(cid:173)
`trol headers for the webpage.
`
`Joint Case Management Statement
`Appendix C
`
`6
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`Counterclaims Against Amazon5
`
`Filed Complaint PersonalWeb Does Not Intend to Amend 6
`
`Alleged "INFRINGEMENT OF U.S. PATENT No. 8,099,420"
`
`Amazon has infringed claims 25, 26, 27, 29, 30, 32, 34-36, and
`166 of the '420 patent by its manufacture, use, sale, importation,
`and/or offer for sale of products or services, and/or controlling
`the distribution of its webpage content in the manner recited
`herein. Amazon's infringement is literal and/or under the doc-
`trine of equivalents and Amazon is liable for its infringement of
`the '420 patent pursuant to 35 U.S.C. § 271.
`
`Defendant has infringed claims 25, 26, 27, 29, 30, 32, 34-36,
`and 166 of the '420 patent by its manufacture, use, sale, importa-
`tion, and/or offer for sale of products or services, and/or control-
`ling the distribution of its webpage content in the manner recited
`herein. Defendant's infringement is literal and/or under the doc-
`trine of equivalents and Defendant is liable for its infringement
`of the '420 patent pursuant to 35 U.S.C. § 271.
`
`For example, claim 166 covers a "system comprising hard ware,
`including at least a processor, and software, in combination with
`said hardware." On information and belief, Amazon's system
`has comprised hardware including a processor, such as its S3
`web host servers and the associated Amazon S3 software system
`which has been used in combination with its hardware.
`
`For example, claim 166 covers a "system comprising hardware,
`including at least a processor, and software, in combination with
`said hardware." On information and belief, Defendant has con-
`trolled the distribution of its website content across a system that
`included hardware including a processor, such as its production
`servers as well as origin servers, intermediate cache servers, and
`endpoint caches; and software, in combination with such hard-
`ware, such as a web development framework, software utilized
`in implementing the HTTP web protocol, and the software used
`on host servers that Defendant used to serve its webpages.
`
`Claim 166 then recites "(A) for a particular data item in a set of Claim 166 then recites "(A) for a particular data item in a set of
`data items, said particular data item comprising a corresponding
`data items, said particular data item comprising a corresponding
`particular sequence of bits." On information and belief, Arna-
`particular sequence of bits." On information and belief, Defend-
`ant's system has controlled the distribution of asset files and
`zon' s system has been used to control the distribution of asset
`files and index files necessary to render the web host customers' webpage files necessary to render its webpages which represent
`webpages which represent particular data items, and each of
`particular data items, and each of these files comprise a corre-
`these files comprise a corresponding sequence of bits.
`sponding sequence of bits.
`
`Claim 166 then recites that for the particular data item to "(al)
`determine one or more content-dependent digital identifiers for
`
`Claim 166 then recites that for the particular data item to "( a 1)
`determine one or more content-dependent digital identifiers for
`
`5 Amazon.com Inc. v. Persona/Web Techs., LLC, No. 5:18-cv-00767-BLF, Dkt. No. 62 ~~ 72-77.
`6 Persona/Web Techs., LLC v. Strava, Inc., No. 5:l 8-cv-04627-BLF, Dkt. No. 1 ~~ 81-86.
`
`Joint Case Management Statement
`Appendix C
`
`7
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`said particular data item, each said content-dependent digital
`identifier being based at least in part on a given function of at
`least some of the bits in the particular sequence of bits of the
`particular data item, wherein two identical data items will have
`the same digital identifiers as determined using said given func(cid:173)
`tion." On information and belief, Amazon's system has, for par(cid:173)
`ticular files of the web server customers' webpage files, applied
`a hash function to all of the bits of each of the files' content to
`determine an ETag for the file's content; whereby two identical
`files have the same ETag. On information and belief, the ETag
`value was associated with the file's URI.
`· '
`
`said particular data item, each said content-dependent digital
`identifier being based at least in part on a given function of at
`least some of the bits in the particular sequence of bits of the
`particular data item, wherein two identical data items will have
`the same digital identifiers as determined using said given func(cid:173)
`tion." On information and belief, Defendant's system has ap(cid:173)
`plied hash functions to each of various Defendant's webpage
`files to all of the bits of the file's content to determine a finger(cid:173)
`print, an ETag, or both for the file's content; whereby two identi(cid:173)
`cal data items have the same ETag values and the same finger(cid:173)
`print values. On information and belief, fingerprints were in(cid:173)
`cluded in files' URI and ETag values were associated with files'
`URis.
`
`Claim 166 then recites that for the particular data item "(a2) se(cid:173)
`lectively permits the particular data item to be made available
`for access and to be provided to or accessed by or from at least
`some of the computers in a network of computers, wherein the
`data item is not to be made available for access or provided
`without authorization, as resolved based, at least in part, on
`whether or not at least one of said one or more content-depend(cid:173)
`ent digital identifiers for said particular data item corresponds to
`an entry in one or more databases, each of said one or more data(cid:173)
`bases comprising a plurality of identifiers, each of said identifi(cid:173)
`ers in each said database corresponding to at least one data item
`of a plurality of data items, and each of said identifiers in each
`said database being based, at least in part, on at least some of the
`data in a corresponding data item."
`On information and belief, Amazon's S3 web host servers in(cid:173)
`cluded databases containing ETag values associated with the
`various URis for asset and manifest/index files necessary to ren(cid:173)
`der web host customers' webpages; moreover, Amazon's system
`has used a system of conditional GET requests with If-None-
`
`Claim 166 then recites that for the particular data item "(a2) se(cid:173)
`lectively permits the particular data item to be made available
`for access and to be provided to or accessed by or from at least
`some of the computers in a network of computers, wherein the
`data item is not to be made available for access or provided
`without authorization, as resolved based, at least in part, on
`whether or not at least one of said one or more content-depend(cid:173)
`ent digital identifiers for said particular data item corresponds to
`an entry in one or more databases, each of said one or more data(cid:173)
`bases comprising a plurality of identifiers, each of said identifi(cid:173)
`ers in each said database corresponding to at least one data item
`of a plurality of data items, and each of said identifiers in each
`said database being based, at least in part, on at least some of the
`data in a corresponding data item."
`On information and belief, Defendant's system has included one
`or more web servers with databases containing ETag values as(cid:173)
`sociated with the URis for various of the asset and webpage files
`necessary to render its webpages; moreover, Defendant's system
`has used a system of conditional GET requests with If-None-
`
`Joint Case Management Statement
`Appendix C
`
`8
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`Case 5:18-md-02834-BLF Document 96-3 Filed 09/13/18 Page 10 of 19
`
`Match headers and HTTP 304 and HTTP 200 messages contain(cid:173)
`ing the ETags, as described more particularly supra, to ensure
`that downstream caches only access authorized file content to ei(cid:173)
`ther serve that file content further downstream or to use it to ren(cid:173)
`der the web server customers' webpages. On information and
`belief, in particular, as more fully described supra, the system
`compared the ETag received in a given conditional GET request
`with the ETags contained in the database to selectively deter(cid:173)
`mine whether the requesting computer could access the file con(cid:173)
`tent it already had or must access newly received authorized
`content.
`
`Match headers and HTTP 304 and HTTP 200 responses contain(cid:173)
`ing the ETags, as described more particularly supra, to ensure
`that downstream caches only access authorized file content to ei(cid:173)
`ther serve that file content further downstream or to use it to ren(cid:173)
`der Defendant' s webpages. On information and belief, in partic(cid:173)
`ular, as more fully described supra, the system compared the
`ETag received in a given conditional GET request with the
`ETags contained in the database to selectively determine
`whether the requesting computer could access the file content it
`already had or must access newly received authorized content.
`
`Counterclaims Against Amazon 7
`
`Filed Complaint PersonalWeb Does Not Intend to Amend 8
`
`Alleged "INFRINGEMENT OF U.S. PATENT NO. 7,802,310"
`
`Amazon has infringed at least claim 20 of the '310 patent by its
`manufacture, use, sale, importation, and/or offer for sale of prod-
`ucts or services, and/or controlling the distribution of its
`webpage content in the manner described herein. Amazon's in-
`fringement is literal and/or under the doctrine of equivalents and
`Amazon is liable for its infringement of the '310 patent pursuant
`to 35 U.S.C. § 271.
`
`Defendant has infringed at least claims 20 and 69 of the ' 310 pa-
`tent by its manufacture, use, sale, importation, and/or offer for
`sale of products or services, and/or controlling the distribution of
`its webpage content in the manner described herein. Defendant's
`infringement is literal and/or under the doctrine of equivalents
`and Defendant is liable for its infringement of the '310 patent
`pursuant to 35 U.S.C. § 271.
`
`For example, claim 20 covers a "computer-implemented method For example, claim 20 covers a "computer-implemented method
`operable in a system which includes a plurality of computers."
`operable in a system which includes a plurality of computers."
`On information and belief, Amazon used the claimed computer
`On information and belief, Defendant used the claimed computer
`implemented method by using a system of notifications and au-
`implemented method by using a system of notifications and au-
`thorizations to control the distribution of data items, such as var-
`thorizations to control the distribution of data items, such as var-
`ious index and asset files, necessary to render the web host cus-
`ious webpage and asset files, necessary to render its webpages,
`tamers' webpages, across a plurality of computers such as S3
`
`7 Amazon.com Inc. v. Persona/Web Techs., LLC, No. 5:18-cv-00767-BLF, Dkt. No. 62 ,-i,-i 54-57.
`8 Persona/Web Techs., LLC v. Strava, Inc. , No. 5:18-cv-04627-BLF, Dkt. No. 1 ,-i,-i 60-63.
`
`Joint Case Management Statement
`Appendix C
`
`9
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`Case 5:18-md-02834-BLF Document 96-3 Filed 09/13/18 Page 11 of 19
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`web host servers, intermediate cache servers, and endpoint
`caches.
`
`across a plurality of computers such as production servers, origin
`servers, intermediate cache servers, and endpoint caches.
`
`Claim 20 then recites "controlli