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`Case 1:19-cv-00859-RTH Document 53-15 Filed 04/27/21 Page 1 of 34
`Case 1:19—cv-00859—RTH Document 53-15 Filed 04/27/21 Page 1 of 34
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`EXHIBIT O
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`EXHIBIT 0
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`

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`Case 1:19-cv-00859-RTH Document 53-15 Filed 04/27/21 Page 2 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 1
`1. An apparatus, comprising:
`
`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 Report generation and formatting facility that uses an
`apparatus to process a set of interrelated 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 of 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 contained in
`the referenced linkbases using the tags,
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`Case 1:19-cv-00859-RTH Document 53-15 Filed 04/27/21 Page 3 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 1
`
`
`
`a device;
`
`and an application including a
`network browser on the device
`for accessing a system configured
`for: identification of at least one
`computer-readable Extensible
`Markup Language (XML)-
`compliant data document
`
`
`
`
`
`
`
`
`
`
`
`Infringement Analysis
`(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 Financial 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 a standard apparatus 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 “an apparatus”.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Reporting Standard by Mattress Firm would entail use of such “an apparatus”.
`The apparatus used by Mattress Firm to prepare, edit and submit a Financial Report that complies with
`the XBRL Financial Reporting Standard would entail use of an information processing device capable of
`supporting a network browser operating on the apparatus.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “An apparatus, comprising:
`…an application including a network browser on the device for accessing a system configured for:
`identification of at least one computer-readable Extensible Markup Language (XML)-compliant data
`document including: a plurality of line items with a plurality of data values, and a plurality of computer-
`readable semantic tags that describe a semantic meaning of the data values and are each computer-
`readably coupled to at least one of the data values, where the at least one computer-readable XML-
`
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`Case 1:19-cv-00859-RTH Document 53-15 Filed 04/27/21 Page 4 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 1
`including: a plurality of line items
`with a plurality of data values,
`and a plurality of computer-
`readable semantic tags that
`describe a semantic meaning of
`the data values and are each
`computer-readably coupled to at
`least one of the data values,
`where the at least one computer-
`readable XML-compliant data
`document is capable of including
`multiple hierarchical relationships
`between two line items;
`
`
`
`
`
`
`
`
`
`Infringement Analysis
`compliant data document is capable of including multiple hierarchical relationships between two line
`items”.
`
`The XBRL Financial Reporting standard specifies the generation and display of standard Financial Reports
`using “a network browser on the device for accessing a system configured for identification of at least
`one computer-readable Extensible Markup Language (XML)-compliant data document”. Mattress Firm’s
`creation of a XBRL-compliant Instance Document and associated linkbase documents in XML-compliant
`format would require the use of such an apparatus and device.
`
`As required by the XBRL Financial Reporting specifications, Mattress Firm’s creation, editing and
`generation of an XBRL-compliant Instance Document, and its associated linkbases in XML-compliant
`format, consists of “a plurality of line items with a plurality of data values, and a plurality of computer-
`readable semantic tags”. Each of the data value tags in the XBRL-compliant Instance Document are used
`to reference associated entries in the associated linkbases “that describe a semantic meaning of the data
`values and are each [thereby] computer-readably coupled to at least one of the data values”.
`
`The XBRL Financial Reporting standard includes “multiple hierarchical relationships between two line
`items”. The XBRL Taxonomy provides the semantic information needed to identify, format and interpret
`the semantic meaning of data values, while the Rule Set(s) specify multiple hierarchical relationships
`between two of the plurality of line items, facilitating the formatting, display and validation of the
`elements of the Financial Report.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Reporting Standard by Mattress Firm would require “An apparatus, comprising: … an application
`including a network browser on the device for accessing a system configured for: identification of at least
`one computer-readable Extensible Markup Language (XML)-compliant data document including: a
`plurality of line items with a plurality of data values, and a plurality of computer-readable semantic tags
`that describe a semantic meaning of the data values and are each computer-readably coupled to at least
`one of the data values, where the at least one computer-readable XML-compliant data document is
`capable of including multiple hierarchical relationships between two line items” in order to perform the
`actions specified in the XBRL Instance Document and the associated linkbases.
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`3
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`Case 1:19-cv-00859-RTH Document 53-15 Filed 04/27/21 Page 5 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 1
`parsing of the at least one
`computer-readable XML-
`compliant data document;
`
`accessing a plurality of computer-
`readable rules including: a
`computer-readable datatype rule
`for validation of a type of data
`values, a computer-readable
`calculation rule for validation of a
`calculation involving data values,
`and a computer-readable unit
`rule for validation of a unit of
`data values;
`
`Infringement Analysis
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “An apparatus, comprising: …
`parsing of the at least one computer-readable XML-compliant data document”. Since the XBRL-
`compliant Instance Document, and the linkbases it references, are all computer-readable XML-compliant
`data documents, the device would have to be able to parse the computer-readable XML-compliant data
`documents to obtain the data values and tags to identify, format, apply calculation and/or formatting
`rules and then to display the results.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Reporting Standard by Mattress Firm would require “An apparatus, comprising: … parsing of the at least
`one computer-readable XML-compliant data document” 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, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “An apparatus, comprising:
`…accessing a plurality of computer-readable rules including: a computer-readable datatype rule for
`validation of a type of data values, a computer-readable calculation rule for validation of a calculation
`involving data values, and a computer-readable unit rule for validation of a unit of data values;
`
`The XBRL Financial Reporting standard uses an XML-compliant computer-readable Instance Document to
`describe the contents of the Financial Report, and associated linkbases to describe semantic, formatting,
`calculation and validation information. The XML-compliant Calculation (.cal) linkbase, referenced using the
`tag associated with each individual data value contained in the instance Document, contain a “plurality of
`computer-readable rules including: a computer-readable datatype rule for validation of a type of data
`values, a computer-readable calculation rule for validation of a calculation involving data values, and a
`computer-readable unit rule for validation of a unit of data values”.
`
`The XBRL Taxonomy contained in the Instance Document provides the hierarchical data value display
`sequence and identification of calculated heading/summary data values, while the information needed to
`identify, format and interpret the semantic meaning of data values is extracted from the linkbases
`referenced via the data value’s tag.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Reporting Standard by Mattress Firm would require “An apparatus, comprising: … accessing a plurality of
`
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`

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`Case 1:19-cv-00859-RTH Document 53-15 Filed 04/27/21 Page 6 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 1
`
`
`
`validation of the at least one
`computer-readable XML-
`compliant data document by:
`identifying at least a subset of the
`computer-readable rules
`including at least one of: the
`computer-readable datatype rule
`for validation of the type of data
`values, the computer-readable
`calculation rule for validation of
`the calculation involving data
`values, or the computer-readable
`unit rule for validation of the unit
`of data values;
`
`Infringement Analysis
`computer-readable rules including: a computer-readable datatype rule for validation of a type of data
`values, a computer-readable calculation rule for validation of a calculation involving data values, and a
`computer-readable unit rule for validation of a unit of data values” 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, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “An apparatus, comprising: …
`validation of the at least one computer-readable XML-compliant data document by: identifying at least a
`subset of the computer-readable rules including at least one of: the computer-readable datatype rule for
`validation of the type of data values, the computer-readable calculation rule for validation of the
`calculation involving data values, or the computer-readable unit rule for validation of the unit of data
`values.”
`
`The XBRL Taxonomy contained in the computer-readable XML compliant data document, the
`XBRL Instance Document, provides the hierarchical numeric data value display sequence and identification
`of heading/summary data values to be calculated, while the information needed to identify, format,
`interpret the semantic meaning, perform calculation of selected numeric data values, and validate the
`XBRL Instance Document’s numeric data values is extracted from the XBRL linkbases referenced via the
`XBRL Instance Document’s data value’s tag. Where the XBRL Instance Document’s data value’s “tag”
`references a rule within the computer-readable XML compliant Calculation linkbase that contains “at least
`one datatype rule for validation of the type of data values, the computer-readable calculation rule for
`validation of the calculation involving data values, or the computer-readable unit rule for validation of
`the unit of data values” the validation and or calculation rules are applied to the value generated in the
`XBRL Financial Report data value displayed.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would require “An apparatus, comprising: …validation of
`the at least one computer-readable XML-compliant data document by: identifying at least a subset of
`the computer-readable rules including at least one of: the computer-readable datatype rule for
`validation of the type of data values, the computer-readable calculation rule for validation of the
`calculation involving data values, or the computer-readable unit rule for validation of the unit of data
`values” 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 53-15 Filed 04/27/21 Page 7 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 1
`processing at least a portion of
`the data values of at least a
`portion of the line items of the at
`least one computer-readable
`XML-compliant data document,
`utilizing the at least subset of the
`computer-readable rules and at
`least a portion of the computer-
`readable sematic tags of the at
`least one computer-readable
`XML-compliant data document;
`
`
`
`
`
`
`
`
`
`Infringement Analysis
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “An apparatus, comprising: …
`processing at least a portion of the data values of at least a portion of the line items of the at least one
`computer-readable XML-compliant data document, utilizing the at least subset of the computer-readable
`rules and at least a portion of the computer-readable sematic tags of the at least one computer-readable
`XML-compliant data document.”
`
`The XBRL Taxonomy contained in the computer-readable XML compliant data document, the
`XBRL Instance Document, provides the hierarchical data value display sequence and identification of
`heading/summary data values to be calculated, while the information needed to identify, format, interpret
`the semantic meaning, perform calculation of selected data values, and validate the XBRL Instance
`Document’s data values is extracted from the XBRL linkbases referenced via the XBRL Instance Document’s
`data value’s tag.
`
`Where the XBRL Instance Document’s data value’s “tag” references a rule within the computer-readable
`XML compliant Calculation (.cal) linkbase that contains “the at least subset of the computer-readable
`rules … of the at least one computer-readable XML-compliant data document” the validation and or
`calculation rules are applied to generate the numeric data value to be displayed in the XBRL Financial
`Report.
`
`Where the XBRL Instance Document’s data value’s “tag” references a formatting and/or semantic entry
`within the computer-readable XML compliant Schema Definition (.xsd) linkbase that contains “at least a
`portion of the computer-readable sematic tags of the at least one computer-readable XML-compliant
`data document” the semantic information is used to identify, format, and if applicable invoke a rule
`related to the numeric data value.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would require “An apparatus, comprising: … processing at
`least a portion of the data values of at least a portion of the line items of the at least one computer-
`readable XML-compliant data document, utilizing the at least subset of the computer-readable rules and
`at least a portion of the computer-readable sematic tags of the at least one computer-readable XML-
`compliant data 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 53-15 Filed 04/27/21 Page 8 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 1
`said apparatus configured for:
`accessing at least a portion of the
`at least one computer-readable
`XML-compliant data document
`utilizing the application including
`the network browser.
`
`Infringement Analysis
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “An apparatus, …said
`apparatus configured for: accessing at least a portion of the at least one computer-readable XML-
`compliant data document utilizing the application including the network browser.
`
`The apparatus used by Mattress Firm to prepare, edit and submit a Financial Report that complies with
`the XBRL Financial Reporting standard by would entail use of an information processing device capable of
`supporting a network browser operating on the apparatus accessing at least a portion of the at least one
`computer-readable XML-compliant data document: The XBRL Taxonomy contained in the computer-
`readable XML compliant data document, the XBRL Instance Document, provides the hierarchical data
`value display sequence and identification of heading/summary data values to be calculated, while the
`information needed to identify, format, interpret the semantic meaning, perform calculation of selected
`data values, and validate the XBRL Instance Document’s data values is extracted from the computer-
`readable XML-compliant XBRL linkbases referenced via the XBRL Instance Document’s data value’s tag.
`
`The XBRL Financial Reporting standard specifies the generation and display of a standard Financial Report
`using “a network browser” on the device for accessing a system configured for identification of at least
`one computer-readable Extensible Markup Language (XML)-compliant data document. Mattress Firm’s
`creation of a XBRL-compliant Instance Document and associated linkbase documents in XML-compliant
`format would require the use of such an apparatus and device.
`
`
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`

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`Case 1:19-cv-00859-RTH Document 53-15 Filed 04/27/21 Page 9 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 11
`11. A computer program product
`embodied on a non-transitory
`computer readable medium,
`comprising:
`
`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 Report generation and formatting facility that uses a
`computer program product embodied on a non-transitory computer readable medium to process a set of
`interrelated 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 of 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 contained in
`the referenced linkbases using the tags,
`
`(4) how each tagged numerical data item is formatted for display,
`
`
`
`
`
`
`
`
`
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`

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`Case 1:19-cv-00859-RTH Document 53-15 Filed 04/27/21 Page 10 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 11
`
`
`
`code for storing a plurality of
`original documents including a
`plurality of original values,
`including a first document
`including first values and a
`second document including
`second values;
`
`
`
`
`
`
`
`
`
`
`
`
`
`Infringement Analysis
`
`(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 Financial 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 “an apparatus: a device;”
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would entail use of such “a computer program product
`embodied on a non-transitory computer readable medium.”
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “A computer program product
`embodied on a non-transitory computer readable medium, comprising:… code for storing a plurality of
`original documents including a plurality of original values, including a first document including first
`values and a second document including second values”.
`
`The XBRL Financial Reporting standard uses an XML-compliant computer-readable Instance Document
`embodied on a non-transitory computer readable medium to describe the contents of the Financial
`Report, and associated linkbases embodied on a non-transitory computer readable medium to describe
`semantic, formatting, calculation and validation information. Together, the XML-compliant computer-
`
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`Case 1:19-cv-00859-RTH Document 53-15 Filed 04/27/21 Page 11 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 11
`
`
`
`code for processing at least a part
`of the first document and at least
`a part of the second document,
`resulting in at least one object
`including at least one reference
`to at least one of the plurality of
`original values of at least one of
`the plurality of original
`documents;
`
`Infringement Analysis
`readable Instance Document embodied on a non-transitory computer readable medium and the
`computer-readable linkbase embodied on a non-transitory computer readable medium, referenced using
`the tag associated with each individual data value contained in the instance Document, contain “a
`plurality of original documents including a plurality of original values, including a first document
`including first values and a second document including second value”.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would require “A computer program product embodied on
`a non-transitory computer readable medium, comprising:… code for storing a plurality of original
`documents including a plurality of original values, including a first document including first values and a
`second document including second values” in order to store the XBRL Instance Document and the
`associated linkbases.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “A computer program product
`embodied on a non-transitory computer readable medium, comprising:… code for processing at least a
`part of the first document and at least a part of the second document, resulting in at least one object
`including at least one reference to at least one of the plurality of original values of at least one of the
`plurality of original documents”.
`
`The XBRL Financial Reporting Standard uses an XML-compliant computer-readable Instance Document
`embodied on a non-transitory computer readable medium to describe the contents of the Financial
`Report, and associated linkbases embodied on a non-transitory computer readable medium to describe
`semantic, formatting, calculation and validation information. Together, the XML-compliant computer-
`readable Instance Document embodied on a non-transitory computer readable medium and the
`computer-readable linkbases embodied on a non-transitory computer readable medium, referenced using
`the tag associated with each individual data value contained in the instance Document, must be processed
`using “code for processing at least a part of the first document and at least a part of the second
`document, resulting in at least one object including at least one reference to at least one of the plurality
`of original values of at least one of the plurality of original documents” in order to generate the required
`XBRL-compliant Financial Report.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would require “A computer program product embodied on
`
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`

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`Case 1:19-cv-00859-RTH Document 53-15 Filed 04/27/21 Page 12 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 11
`
`
`
`code for receiving a user
`selection of one or more
`computer-readable semantic
`tags;
`
`code for receiving a user
`selection of one or more of the
`original values;
`
`Infringement Analysis
`a non-transitory computer readable medium, comprising:… code for processing at least a part of the first
`document and at least a part of the second document, resulting in at least one object including at least
`one reference to at least one of the plurality of original values of at least one of the plurality of original
`documents. 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, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “A computer program product
`embodied on a non-transitory computer readable medium, comprising code:… for receiving a user
`selection of one or more computer-readable semantic tags”.
`
`The XBRL Financial Reporting Standard uses an XML-compliant computer-readable Instance Document
`embodied on a non-transitory computer readable medium to describe the contents of the Financial
`Report, and associated linkbases embodied on a non-transitory computer readable medium to describe
`semantic, formatting, calculation and validation information. During Mattress Firm’s creation and editing
`of an XBRL-compliant Financial Report, code must exist to allow for user selection of one or more
`computer-readable semantic tags from those available in the XBRL-compliant linkbases. Once selected,
`the tag corresponding to the user’s selection is associated with the numeric data value in the XBRL-
`compliant Instance Document.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would require “A computer program product embodied on
`a non-transitory computer readable medium, comprising:… code for receiving a user selection of one or
`more computer-readable semantic tags” in order to create and/or edit the XBRL Instance Document and
`the associated linkbases.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “A computer program product
`embodied on a non-transitory computer readable medium, comprising:… code for receiving a user
`selection of one or more of the original values”.
`
`The XBRL Financial Reporting standard uses an XML-compliant computer-readable Instance Document
`embodied on a non-transitory computer readable medium to describe the contents of the Financial
`Report, and associated linkbases embodied on a non-transitory computer readable medium to describe
`semantic, formatting, calculation and validation information. During Mattress Firm’s creation and editing
`
`
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`11
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`Case 1:19-cv-00859-RTH Document 53-15 Filed 04/27/21 Page 13 of 34
`
`Claim Chart For U.S. Patent 9,268,748
`
`Claim 11
`
`
`
`code for mapping the one or
`more of the