Case 1:19-cv-00859-RTH Document 44-1 Filed 03/11/21 Page 1 of 9
`Case 1:19-cv-00859—RTH Document 44-1 Filed 03/11/21 Page 1 of 9
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`EXHIBIT A
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`EXHIBIT A
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`Case 1:19-cv-00859—RTH Document 44-1 Filed 03/11/21 Page 1 of 9
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`EXHIBIT A
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`EXHIBIT A
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`Case 1:19-cv-00859-RTH Document 44-1 Filed 03/11/21 Page 2 of 9
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`Appendix For Claim Chart Of ‘842 Claim 29 By Arelle/EDGARLink Online/EDGAR
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`In response to the Government’s letter of January 29, 2021 and in an effort to be cooperative above and beyond
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`the requirements of the Patent Rules of the Court of Federal Claims, e-Numerate has set forth the below screenshots
`demonstrating infringement of Claim 29 of the ‘842 patent. These contentions are preliminary only and based on e-
`Numerate’s present understanding. Discovery is ongoing and e-Numerate reserves the right to supplement and amend
`these contentions as discovery proceedings.
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`The XBRL standard itself emphasizes the three validation points (datatypes, calculations, and units) specified in
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`claim 29 of the ‘842 patent. That standard is shown below.
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`Figure 1. Validation documentation page for the XBRL standard at https://specifications.xbrl.org/validation.html
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`Case 1:19-cv-00859-RTH Document 44-1 Filed 03/11/21 Page 3 of 9
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`Figure 2. Arelle.org’s Documentation Page
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`The Government has not explicitly stated that the source code found in Arelle is identical to the source code run
`in EDGARLink Online. The Government appears to refer to the validation functionality as the “EDGAR Filer Manual
`(EFM) validation plug-in that implements all validations documents in EDGAR Filer Manual sections 5.2.5. and section 6”
`as referenced the Government’s letter of January 29, 2021 at page 4.
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`The Arelle.org Documentation Page describes the validations that it runs.
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`See https://arelle.org/arelle/documentation/gui-operation/
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`Note that the validation checks that are run include:
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`a) Datatype
`b) Units
`c) Calculation rules
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`Case 1:19-cv-00859-RTH Document 44-1 Filed 03/11/21 Page 4 of 9
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`The presence of the elements in the claims is demonstrated in a non-limiting manner by a sample XBRL filing
`document. In the screenshots below, the document employed is an IBM 10-Q filing for 9/30/2013.
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`Sample XBRL filing document: IBM 10-Q for 9/30/2013
`https://www.sec.gov/Archives/edgar/data/51143/000005114313000007/ibm-20130930.xml
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`The following figures illustrate the IBM 10-Q in different formats.
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`Figure 3. What the IBM 10-Q looks like in the raw XML / XBRL file
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`Case 1:19-cv-00859-RTH Document 44-1 Filed 03/11/21 Page 5 of 9
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`Figure 4. The same IBM 10-Q in the Chrome Browser “Source Code” view
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`The IBM 10-Q is an XML-compliant document that contains tagged numerical values. An example of a tagged
`number is shown in line 8944. This number represents “SalesRevenueGoodsNet” from the us-gaap taxonomy, and the
`highlighted value is 8947000000 with units of “USD”. The tag is illustrated by the beginning and ending angle brackets
`below. The ‘semantic meaning’ of the number is indicated by the attributes within the tag. In this example, the data
`value (8987000000) has four attributes describing its meaning (e.g., unitRef=“USD” is one of the attributes).
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`Case 1:19-cv-00859-RTH Document 44-1 Filed 03/11/21 Page 6 of 9
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`Figure 5. The Same Report, Rendered Into An HTML Report In A Browser
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` IBM report shows a plurality of line items in this figure shown in the left-most column. Each line item has a
`plurality of data values (the quarterly and 9 month numbers to the right of each entry). The document is capable of
`including multiple hierarchical relationships between data values. In a hierarchical revenue sense, Services, Sales and
`Financing are “children” of Total Revenue, and are siblings of each other. Total Revenue is also a calculated sum of the
`three. Other hierarchical relationships exist between the other numerical values as well.
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`Note the Sales item that was 8987000000 in the raw XBRL file, is now formatted with a comma, and reduced by
`1 million to be displayed “Dollars in Millions”:
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`Case 1:19-cv-00859-RTH Document 44-1 Filed 03/11/21 Page 7 of 9
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`Figure 6. Parsing
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`Upon information and belief, Figure 6 shows the parsing functionality of Arelle. Arelle is a collection of modules
`in Python, Javascript, and plug-in modules. Upon information and belief, one place that parsing is done for XBRL
`instance documentation is in Arelle’s Python module called “FormulaConsisAsser.py”:
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`https://github.com/Arelle/Arelle/blob/master/arelle/FormulaConsisAsser.py
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`The individual data values (“facts” in XBRL) are separated into list structure that is looped through so that each
`fact is parsed to be validated in turn. Note also that there is a check to make sure that the calculated fact (this is a
`calculation validation module) is a number and the units are checked.
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`Case 1:19-cv-00859-RTH Document 44-1 Filed 03/11/21 Page 8 of 9
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`Figure 8. Screen Shots of Validation in EdgarLink Online. From Edgar Filing Manual vII.
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`Figure 8 shows that EDGARLink displays a result of a validation of the at least one computer-readable XML-
`compliant data document. This screenshot is taken from EDGAR Filer Manual Volume II December 2020 in section 7.4.2.
`The number of errors is shown in the “Errors” field of the “Documents” tab.
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`Case 1:19-cv-00859-RTH Document 44-1 Filed 03/11/21 Page 9 of 9
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`Figure 9. Screen Shots Of A Validation Report in EDGARLink Online.
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`Upon information and belief, EDGARLink Online also develops a report of the validation. The number of error
`messages in the filing can be clicked on and EDGARLink generates, by way of non-limiting example, a report shown
`below.
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`Output of error message. (Report of number of errors [1] is both in the view window, and in the original screen.)
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