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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 1 of 20
`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 1 of 20
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`EXHIBIT
`EXHIBIT
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 2 of 20
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`Claim Chart for U.S. Patent 9,262,383
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`The following claim charts are preliminary in nature. The details of the SEC’s systems are being sought in discovery. By its own admission, the Government has refused to
`product core technical documents for the SEC system accused of infringing the ‘816 and the ‘383 patents.
`
`e-Numerate reserves the right to amend and supplement these charts as discovery proceeds. The Government is referred to the included Appendix that sets forth the
`Government’s infringement in additional detail. The SEC’s infringement of the ‘816 patent is demonstrated by the Office of Structured Disclosure (OSD) within the SEC
`as well as by Mr. Michael Willis’ comments in the article entitled “The SEC’s Increasingly Sophisticated Use of XBRL-Tagged Data.” See Second Amended Complaint (D.I.
`53) at Ex. G. A YouTube video where Mike Willis makes similar admissions is here: https://www.youtube.com/watch?v=x31UDWhFYjw&t=3s.
`
`It is believed that the SEC uses data provided by the filers and transforms the data into common units of measure as specified in the ‘383 patent. These include
`calculating standard financial ratios used as metrics in evaluating corporate filings. Mr. Willis is believed to be describing the SEC comparing these ratios
`between companies as well as on a sector-wide and industry-wide basis. Certain of these ratios are believed to have SEC-specified tag-attributes.
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`
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`“OSD works closely with other SEC Divisions and Offices to design data structuring approaches for required disclosures, and supports the SEC’s data collections and data usage by
`designing taxonomies, validation rules, data quality assessments, and tools for conducting data analyses. OSD also works with investors, regulated entities, and the public to support the
`submission and use of structured data.”
`https://www.sec.gov/structureddata
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`https://www.sec.gov/page/osdhistoryandrulemaking
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 3 of 20
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`Claim Chart for U.S. Patent 9,262,383
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`https://www.sec.gov/page/osd_edgarvalandrender
`
`Mr. Willis described an unidentified SEC analysis program as follows:
`
`Q How is the SEC using XBRL data internally?
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`
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`A: While the word on the street may be that the SEC is not using XBRL, that is simply not true.
`
`One way the SEC uses XBRL data is for economic analysis. When an analysis is looking across all SEC companies – and I repeat that: all companies, from the largest to
`the smallest– that is when the XBRL data is very useful. Some data aggregators may focus on the largest filers. When we need an answer that covers all companies,
`XBRL data is the only game in town for assessing information from the entire set of corporate filers.
`(emphasis added)
`
`As set forth below, Mr. Willis’ comments demonstrate infringement of at least claims 1, 17 and 18 of the ‘383 patent.
`
`Claim 1
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`Infringement Analysis
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`2
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 4 of 20
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`Claim Chart for U.S. Patent 9,262,383
`1. A computer program product
`embodied on a non-transitory
`computer-readable medium comprising:
`
`
`
`
`
`Non-limiting preamble. By way of background, the eXtensible Business Reporting Language (XBRL)
`Financial Reporting standard (see http://www.xbrl.org/Specification/xbrl-recommendation-2003-
`12-31+corrected-errata-2012-01-25.htm) specifies a Financial Report generation and formatting
`facility that can be implemented as a “Computer Program Product …“ that can be “ …embodied on
`a non-transitory computer readable medium …” comprised of a set of interrelated computer-
`implemented eXtensible Markup Language (XML)-formatted files that specify:
`
`(1) how tagged numerical data items to be formatted in an XBRL Financial Report are identified as
`a Fact (a tagged numerical data value that will be reported) related to a Concept (a particular
`Financial semantic meaning for the tagged numerical data value) in the context of the Taxonomy (a
`list of concepts to be included in the Financial Report, and a collection of XML-compliant documents
`(linkbases) that provide additional information that forms part of the concept definitions) for
`inclusion in a given XBRL Financial Report Instance Document (see XBRL
`“Essentials https://specifications.xbrl.org/xbrl-essentials.html),
`
`(2) how the numerical data items are tagged in the XML-compliant Instance Document file (with a
`name ending in “.xml”), which indicates the content of the Financial Report, to facilitate association
`the related linkbases:
`(a) XML-compliant Schema Definition file (with a name ending in “.xsd”) which contains
`formatting and semantic meaning information,
`(b) XML-compliant Label file (with a name ending in “_lab.xml”) which indicates the label of
`the numeric data value,
`(c) XML-compliant Calculation file (with a name ending in “_cal.xml”) which contains rules
`that determine how to combine information and to determine that the set of XML-
`compliant documents are valid,
`(d) XML-compliant Definition file (with a name ending in “_def.xml”) relates concepts with
`other concepts,
`(e) XML-compliant Presentation file (with a name ending in “_pre.xml”) This linkbase
`associates concepts with other concepts so that the resulting relations can guide the
`creation of a user interface, rendering, or visualization.
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`3
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 5 of 20
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`Claim Chart for U.S. Patent 9,262,383
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`Claim 1
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`Infringement Analysis
`(3) how each tagged numerical data item is identified and categorized from the information
`contained in the referenced linkbases using the tags,
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`(4) how each tagged numerical data item is formatted for display,
`
`(5) how each tagged numerical data item is displayed hierarchically in relation to other tagged
`numerical data items,
`
`(6) how an individual tagged numerical data item is combined with other tagged numerical data
`items to yield a “summary” tagged numerical data item based on specified formulas relating to the
`semantic meaning associated with the numerical data item’s tag in accordance with information
`contained in the XBRL Taxonomy file and the associated XBRL Calculation linkbase file, and
`
`(7) how the set of interrelated XBRL files are validated to ensure consistency and completeness of
`the information contained therein.
`
`The XBRL Reporting Standard specifies that each of the interrelated files comprising the XBRL
`Financial Report are encoded using the eXtensible Markup Language (XML) syntax such that they
`may be interpreted, manipulated and displayed using standard computer program products such as
`a World Wide Web “browser” (e.g., Microsoft Internet Explorer, Apple Safari, Google Chrome,
`Mozilla Firefox, etc.) that is capable of interpreting the set of interrelated XML-compliant
`documents containing tagged numerical data items and implementing the formatting, computation
`formulas and rules required to validate and present the XBRL encoded Financial Report in human
`readable form through the use of a “computer program product embodied on a non-transitory
`computer-readable medium”.
`
`Therefore, any SEC analysis program analyzing multiple Financial Reports that comply with the
`XBRL Financial Reporting Standard would entail use of such a “computer program
`product embodied on a non-transitory computer-readable medium”. Here, Mr. Willis is
`describing an SEC system that runs on a computer that has a memory (i.e., a non-transitory
`compute readable medium).
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 6 of 20
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`Claim Chart for U.S. Patent 9,262,383
`code for identifying a first markup
`document including first numerical
`values and first tags reflecting first
`characteristics of the first numerical
`
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’s
`analyzing multiple XBRL-compliant Financial Reports would require “A computerprogram
`product embodied on a non-transitory computer-readable medium ….” that executes
`“code for identifying a first markup document including first numerical values and first tags
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 7 of 20
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`Claim Chart for U.S. Patent 9,262,383
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`Claim 1
`values associated with a first unit of
`measure, and a second markup
`document including second numerical
`values and second tags reflecting second
`characteristics of the second numerical
`values associated with a second unit of
`measure, wherein the first tags and the
`second tags each include computer-
`readable semantic tags that describe a
`semantic meaning of a corresponding
`one of at least one of the first numerical
`values or the second numerical values,
`via a computer-readable tagging
`association therebetween, where the
`first characteristics of the first numerical
`values associated with the first unit of
`measure are different from the second
`characteristics of the second numerical
`values associated with the second unit
`of measure;
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`Therefore, any analysis of Financial Reports that comply with the XBRL Reporting Standard by the
`SEC would require “A computer program product embodiedon a non-transitory computer-
`readable medium … “ that executes “code for identifying a first markup document including first
`numerical values and first tags reflecting first characteristics of the first numerical values
`
`6
`
`Infringement Analysis
`reflecting first characteristics of the first numerical values associated with a first unit of measure,
`and a second markup document including second numerical values and second tags reflecting
`second characteristics of the second numerical values associated with a second unit of measure,
`wherein the first tags and the second tags each include computer-readable semantic tags that
`describe a semantic meaning of a corresponding one of at least one of the first numerical values
`or the second numerical values, via a computer-readable tagging association therebetween,
`where the first characteristics of the first numerical values associated with the first unit of
`measure are different from the second characteristics of the second numerical values associated
`with the second unit of measure” in order to perform adjustments to the numeric data value to
`match the display format for the unit of measure selected for display of the numeric data value in
`the Financial Report, and any adjustments needed to display “summary” numeric data values in a
`consistent form based on the display format associated with the “summary” numeric data item.
`
`
`Mr. Willis describes the SEC’s ability to analyze filings of multiple filers (i.e., at least first and second
`markup documents). The XBRL filings are markup language documents that contain numerical data
`(the reported numbers). The numerical values are tagged using computer-readable semantic tags (the
`XBRL tags where the semantics are in the attributes within the tags). Mr. Willis describes a situation
`where the SEC compares all filers in a given industry. This encompasses both the largest filer(s) with,
`e.g., sales in billions and the smallest filer(s) with, e.g., sales in millions or hundreds of thousands.
`These sales figures are in different units of measure.
`
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric
`data values, their tags, and their hierarchical position in relation to other numeric data values to be
`included in the XBRL Financial Report to be generated. Based on the tags associated with each
`numeric data value included in the XBRL Instance Document, the label to be displayed and the
`numeric data value display format associated with the display format for the numeric data value
`selected for display in the XBRL Financial Report are obtained from the referenced linkbase files:
`this referenced information is used to identify numeric data values that require transformation of
`the display format, display label and displayed value of the numeric data values in accordance with
`the unit of measure transformation specifications contained in the referenced linkbase files.
`
`
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 8 of 20
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`Claim Chart for U.S. Patent 9,262,383
`
`
`
`associated with a first unit of measure, and a second markup documentincluding second
`numerical values and second tags reflecting second characteristics of the secondnumerical values
`associated with a second unit of measure, wherein the first tags and the second tags each include
`computer-readable semantic tags that describe a semantic meaning of a corresponding one of at
`least one of the first numerical values or the second numerical values, via
`a computer-readable tagging association therebetween, where the first characteristics of the first
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 9 of 20
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`Claim Chart for U.S. Patent 9,262,383
`
`Claim 1
`
`
`
`code for causing automatic
`transformation of at least a portion of
`the first or second numerical values of at
`least one of the first markup document
`or the second markup document, so that
`at least some of the first numerical
`values of the first markup document and
`at least some of the second numerical
`values of the second markup document
`have a common unit of measure;
`
`Infringement Analysis
`numerical values associated with the first unit of measure are different from the second
`characteristics of the second numerical values associated with the second unit of measure” in
`order to perform the actions specified in the XBRL Instance Document and the associated linkbases.
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’s analyzing
`multiple XBRL-compliant Financial Reports would require “A computer program product embodied
`on a non-transitory computer-readable medium ….” that executes “code for causing automatic
`transformation of at least a portion of the first or second numerical values of at least one of the
`first markup document or the second markup document, so that at least some of the first
`numerical values of the first markup document and at least some of the second numerical values
`of the second markup document have a common unit of measure” in order to perform
`adjustments to the numeric data value to match the display format for the unit of measure selected
`for display of the numeric data value in the Financial Report, and any adjustmentsneeded to display
`“summary” numeric data values in a consistent form based on the display format associated with
`the “summary” numeric data item.
`
`Mr. Willis describes the analysis system(s) at the SEC permitting comparing all of these filers at once
`(i.e., the sales figures have to be put in a common unit of measure).
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric
`data values, their tags, and their hierarchical position in relation to other numeric data values to be
`included in the XBRL Financial Report to be generated. Based on the tags associated with each
`numeric data value included in the XBRL Instance Document, the label to be displayed and the
`numeric data value display format associated with the display format for the numeric data value
`selected for display in the XBRL Financial Report are obtained from the referenced linkbase files:
`this referenced information is used to transform numeric data values display format, display label
`and displayed value of the numeric data values in accordance with the unit of measure
`transformation specifications contained in the referenced linkbase files.
`
`Therefore, any SEC analysis of multiple Financial Reports that comply with the XBRL Reporting
`Standard by the SEC would require “A computer program product embodiedon a non-transitory
`computer-readable medium …” that executes “code for causing automatic transformation of at
`least a portion of the first or second numerical values of at least one of the first markup
`document or the second markup document, so that at least some of the first numerical values of
`the first markup document and at least some of the second numerical values of the second
`markup document have a common unit of measure” in order to perform the actions
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 10 of 20
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`Claim Chart for U.S. Patent 9,262,383
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`
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`specified in the XBRL Instance Document and the associated linkbases.
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 11 of 20
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`Claim Chart for U.S. Patent 9,262,383
`
`Claim 1
`code for processing at least a part of the
`first markup document and at least a
`part of the second markup document,
`resulting in a single markup document;
`
`
`
`Infringement Analysis
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’s analyzing
`multiple XBRL-compliant Financial Reports would require “A computer program product embodied
`on a non-transitory computer-readable medium ….” that executes “code for processing at least a
`part of the first markup document and at least a part of the secondmarkup document, resulting in
`a single markup document”.
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric
`data values to be included in the XBRL Financial Report. Based on the tags associated with each
`numeric data value to be displayed, its label and associated Calculation Rules are obtained from the
`referenced “Schema Definition” & “Calculation” linkbase files. Where calculated composite numeric
`data values that summarize individual numeric data values are specified in the XBRL Instance
`Document, the “Calculation Rules” from the “Calculation” linkbase file are used to generate and
`display the calculated composite numeric data in accordance with the Taxonomy specifications
`contained in the Instance Document.
`
`
`Mr. Willis describes looking at the filers at the same time (i.e., the sales numbers have combined into
`a single data set which would be in a single markup document).
`
`
`Therefore, any analysis of Financial Reports that comply with the XBRL Reporting Standard by the
`SEC would require “A computer program product embodiedon a non-transitory computer-
`readable medium ….” that executes “code for processing at least a part of the first markup
`document and at least a part of the second markup document, resulting in a single markup
`document” in order to perform the actions specified in the XBRL Instance
`Document and the associated linkbases.
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 12 of 20
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`Claim Chart for U.S. Patent 9,262,383
`and code for causing a display of at least
`a portion of the single markup
`document.
`
`
`
`
`
`
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’s analysis
`of XBRL-compliant Financial Reports would require “A computerprogram product embodied on
`a non-transitory computer-readable medium ….” that executes “code for causing a display of
`at least a portion of the single markup document.”
`
`Mr. Willis is presumably looking at the results on a display (e.g., a computer monitor).
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric
`data values to be included in the Financial Report. Based on the tags associated with each numeric
`data value to be displayed, its label, geographic location are obtained from the referenced linkbase
`files. Where calculated composite numeric data values that summarize individual numeric data
`values from differing locations are needed, the Calculation Rules are used to derive the combined
`numeric data values which are displayed in accordance with the Taxonomy’s specified format.
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 13 of 20
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`Claim Chart for U.S. Patent 9,262,383
`
`Claim 1
`
`
`
`Infringement Analysis
`Therefore, any analysis of Financial Reports that comply with the XBRL Reporting Standard by the
`SEC would entail “A computer program product embodied on a non-transitory computer-readable
`medium ….” that executes “code for causing a display of at
`least a portion of the single markup document” in order to perform the actions specified in the
`XBRL Instance Document and the associated linkbases.
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`12
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 14 of 20
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`Claim Chart for U.S. Patent 9,262,383
`
`Claim 17
`17. A method comprising:
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`Infringement Analysis
`Non-limiting preamble. By way of background, the eXtensible Business Reporting Language (XBRL)
`Financial Reporting standard (see http://www.xbrl.org/Specification/xbrl-recommendation-2003-
`12-31+corrected-errata-2012-01-25.htm) specifies a method for Report generation through the use
`of a set of interrelated computer-implemented eXtensible Markup Language (XML)-formatted files
`that specify:
`
`(1) how tagged numerical data items to be formatted in an XBRL Financial Report are identified as
`a Fact (a tagged numerical data value that will be reported) related to a Concept (a particular
`Financial semantic meaning for the tagged numerical data value) in the context of the Taxonomy (a
`list of concepts to be included in the Financial Report, and a collection of XML-compliant documents
`(linkbases) that provide additional information that forms part of the concept definitions) for
`inclusion in a given XBRL Financial Report Instance Document (see XBRL
`“Essentials https://specifications.xbrl.org/xbrl-essentials.html),
`
`(2) how the numerical data items are tagged in the XML-compliant Instance Document file (with a
`name ending in “.xml”), which indicates the content of the Financial Report, to facilitate association
`the related linkbases:
`(a) XML-compliant Schema Definition file (with a name ending in “.xsd”) which contains
`formatting and semantic meaning information,
`(b) XML-compliant Label file (with a name ending in “_lab.xml”) which indicates the label of
`the numeric data value,
`(c) XML-compliant Calculation file (with a name ending in “_cal.xml”) which contains rules
`that determine how to combine information and to determine that the set of XML-
`compliant documents are valid,
`(d) XML-compliant Definition file (with a name ending in “_def.xml”) relates concepts with
`other concepts,
`(e) XML-compliant Presentation file (with a name ending in “_pre.xml”) This linkbase
`associates concepts with other concepts so that the resulting relations can guide the
`creation of a user interface, rendering, or visualization.
`
`(3) how each tagged numerical data item is identified and categorized from the information
`
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`
`
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 15 of 20
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`Claim Chart for U.S. Patent 9,262,383
`
`Claim 17
`
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`Infringement Analysis
`contained in the referenced linkbases using the tags,
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`(4) how each tagged numerical data item is formatted for display,
`
`(5) how each tagged numerical data item is displayed hierarchically in relation to other tagged
`numerical data items,
`
`(6) how an individual tagged numerical data item is combined with other tagged numerical data
`items to yield a “summary” tagged numerical data item based on specified formulas relating to the
`semantic meaning associated with the numerical data item’s tag in accordance with information
`contained in the XBRL Taxonomy file and the associated XBRL Calculation linkbase file, and
`
`(7) how the set of interrelated XBRL files are validated to ensure consistency and completeness of
`the information contained therein.
`
`The XBRL Reporting Standard specifies that each of the interrelated files comprising the XBRL
`Financial Report are encoded using the eXtensible Markup Language (XML) syntax such that they
`may be interpreted, manipulated and displayed using standard computer program products such as
`a World Wide Web “browser” (e.g., Microsoft Internet Explorer, Apple Safari, Google Chrome,
`Mozilla Firefox, etc.) that is capable of interpreting the set of interrelated XML-compliant
`documents containing tagged numerical data items and implementing the formatting, computation
`formulas and rules required to validate and present the XBRL encoded Financial Report in human
`readable form through the use of this method.
`
`Therefore, any SEC analysis program analyzing multiple Financial Reports that complies with the
`XBRL Reporting Standard by the SEC would entail use of such a method to perform the actions
`specified in the XBRL Instance Document and the associated linkbases. Mr. Willis describes the SEC
`performing a method using an unidentified SEC analysis program.
`
`identifying a first markup document
`including first numerical values and first
`tags reflecting first characteristics of the
`first numerical values associated with a
`first unit of measure, and a second
`markup document including second
`
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’s analyzing
`multiple XBRL-compliant Financial Reports would use a method for “identifying a first markup
`document including first numerical values and first tags reflecting firstcharacteristics of the first
`numerical values associated with a first unit of measure, and a second markup document
`including second numerical values and second tags reflecting second
`characteristics of the second numerical values associated with a second unit of measure, wherein
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 16 of 20
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`Claim Chart for U.S. Patent 9,262,383
`
`Claim 17
`numerical values and second tags
`reflecting second characteristics of the
`second numerical values associated with
`a second unit of measure, wherein the
`first tags and the second tags each
`include computer-readable semantic
`tags that describe a semantic meaning of
`a corresponding one of at least one of
`the first numerical values or the second
`numerical values, via a computer-
`readable tagging association
`therebetween, where the first
`characteristics of the first numerical
`values associated with the first unit of
`measure are different from the second
`characteristics of the second numerical
`values associated with the second unit
`of measure;
`
`Infringement Analysis
`the first tags and the second tags each include computer-readable semantic tags that describe a
`semantic meaning of a corresponding one of at least one of the first numerical values or the
`second numerical values, via a computer-readable tagging association therebetween, where the
`first characteristics of the first numerical values associated with the first unit of measure are
`different from the second characteristics of the second numerical values associated with the
`second unit of measure” in order to perform adjustments to the numeric data value to match the
`display format for the unit of measure selected for display of the numeric data value in the Financial
`Report, and any adjustments needed to display “summary” numeric data values in a consistent form
`based on the display format associated with the “summary” numeric data item.
`
`Mr. Willis describes the SEC’s ability to analyze filings of multiple filers (i.e., at least first and second
`markup documents). The XBRL filings are markup language documents that contain numerical data
`(the reported numbers). The numerical values are tagged using computer-readable semantic tags
`(the XBRL tags where the semantics are in the attributes within the tags).
`
`Mr. Willis describes a situation where the SEC compares all filers in a given industry. This
`encompasses both the largest filer(s) with, e.g., sales in billions and the smallest filer(s) with, e.g.,
`sales in millions or hundreds of thousands. These sales figures are in different units of measure.
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric
`data values, their tags, and their hierarchical position in relation to other numeric data values to be
`included in the XBRL Financial Report to be generated. Based on the tags associated with each
`numeric data value included in the XBRL Instance Document, the label to be displayed and the
`numeric data value display format associated with the display format for the numeric data value
`selected for display in the XBRL Financial Report are obtained from the referenced linkbase files:
`this referenced information is used to identify numeric data values that require transformation of
`the display format, display label and displayed value of the numeric data values in accordance with
`the unit of measure transformation specifications contained in the referenced linkbase files.
`
`Therefore, any analysis of Financial Reports that comply with the XBRL Reporting Standard by the
`SEC would require the use of this method … “ identifying a first markup document including first
`numerical values and first tags reflecting first characteristicsof the first numerical values
`associated with a first unit of measure, and a second markup document including second
`numerical values and second tags reflecting second characteristics of the second numerical values
`associated with a second unit of measure, wherein the first tags and the second tags each include
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`15
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 17 of 20
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`Claim Chart for U.S. Patent 9,262,383
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`computer-readable semantic tags that describe a semantic meaning of a corresponding one of at
`least one of the first numerical values or the second numerical values, via a computer-readable
`tagging association therebetween, where the first characteristicsof the first numerical values
`associated with the first unit of measure are different from the second characteristics of the
`second numerical values associated with the second unit of measure”in order to perform the
`actions specified in the XBRL Instance Document and the associated
`linkbases.
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`16
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`Case 1:19-cv-00859-RTH Document 122-13 Filed 08/12/24 Page 18 of 20
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`Claim Chart for U.S. Patent 9,262,383
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`Claim 17
`automatically transforming at least a
`portion of the first or second numerical
`values of at least one of the first markup
`document or the second markup
`document, so that at least some of the
`first numerical values of the first markup
`document and at least some of the
`second numerical values of the second
`markup document have a common unit
`of measure;
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`Infringement Analysis
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’s analyzing
`multiple XBRL-compliant Financial Reports would require the use of a method for “automatically
`transforming at least a portion of the first or second numerical values of at least one of the first
`markup document or the second markup document, so that at least some of the first numerical
`values of the first markup document and at least some of the second numerical values of the
`second markup document have a common unit of measure” in order to perform adjustments to
`the numeric data value to match the display format for the unit of measureselected for display of
`the numeric data value in the Financial Report, and any adjustments needed to display “summary”
`numeric data values in a consistent form based on the display format associated with the
`“summary” numeric data item.
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`Mr. Willis describes the analysis system(s) at the SEC permitting comparing all of these filers at
`once (i.e., the sales figures have to be put in a common unit of measure).
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`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric
`data values, their tags, and their hierarchical position in relation to other numeric data values to be
`included in the XBRL Financial Report to be generated. Based on the tags associated with each
`numeric data value included in the XBRL Instance Document, the label to be displayed and the
`numeric data value display format associated with the display format for the numeric data value
`selected for display in the XBRL Financial Report are obtained from the referenced linkbase files:
`this r