Case 1:19-cv-00859-RTH Document 53-27 Filed 04/27/21 Page 1 of 10
`Case 1:19—cv-00859—RTH Document 53-27 Filed 04/27/21 Page 1 of 10
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` EXHIBIT AA
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`EXHIBIT AA
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`

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`Case 1:19-cv-00859-RTH Document 53-27 Filed 04/27/21 Page 2 of 10
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`Claim Chart for U.S. Patent 10,223,337
`
`Claim 1
`A computer program product
`embodied on a non-transitory
`computer readable medium and
`configured to be executed by a
`system including at least one
`hardware processor, the
`computer program product
`comprising instructions for:
`
`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 and configured to
`be executed by a system including at least one hardware processor 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 53-27 Filed 04/27/21 Page 3 of 10
`
`Claim Chart for U.S. Patent 10,223,337
`
`Claim 1
`
`
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`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;
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`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 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 “computer program
`product embodied on a non-transitory computer readable medium and configured to be executed by a
`system including at least one hardware processor.”
`
`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 “computer program product
`embodied on a non-transitory computer readable medium and configured to be executed by a system
`including at least one hardware processor.”
`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:… 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”.
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`Case 1:19-cv-00859-RTH Document 53-27 Filed 04/27/21 Page 4 of 10
`
`Claim Chart for U.S. Patent 10,223,337
`
`Claim 1
`
`
`
`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
`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 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 “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”.
`
`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:… 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: …. 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
`by “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
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`Case 1:19-cv-00859-RTH Document 53-27 Filed 04/27/21 Page 5 of 10
`
`Claim Chart for U.S. Patent 10,223,337
`
`Claim 1
`
`
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`receiving a user selection of one
`or more computer-readable
`semantic tags;
`
`receiving a user selection of one
`or more of the original values;
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`Infringement Analysis
`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
`a non-transitory computer readable medium, comprising: …. 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: …. 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:… 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:… receiving a user selection of
`one or more of the original values”.
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`Case 1:19-cv-00859-RTH Document 53-27 Filed 04/27/21 Page 6 of 10
`
`Claim Chart for U.S. Patent 10,223,337
`
`Claim 1
`
`
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`mapping the one or more of the
`computer-readable semantic tags
`to the one or more of the original
`values;
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`Infringement Analysis
`
`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 receiving a user selection of one or
`more of the original values for input into the XBRL-compliant Instance Document. Once selected, the
`corresponding tag is associated with the 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:… receiving a user selection of one or more of
`the original values” 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:… mapping the one or more of
`the computer-readable semantic tags to the one or more of the original values”.
`
`The XBRL Financial Reporting standard uses an XML-compliant Instance Document to describe the contents
`of the Financial Report, and associated linkbases to describe semantic, formatting, calculation and
`validation information. During Mattress Firm’s creation and editing of an XBRL-compliant Financial Report,
`a computer program product embodied on a non-transitory computer readable medium to allow
`mapping the one or more of the computer-readable semantic tags to the one or more of the original
`values from those available in the XBRL-compliant linkbases must be provided. Once selected, the
`corresponding tag is associated with the 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:… mapping the one or more of the computer-
`readable semantic tags to the one or more of the original values” in order to create and/or edit the XBRL
`Instance Document and the associated linkbases.
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`Case 1:19-cv-00859-RTH Document 53-27 Filed 04/27/21 Page 7 of 10
`
`Claim Chart for U.S. Patent 10,223,337
`
`Claim 1
`outputting a presentation that is
`based on at least a portion of the
`at least one object, the
`presentation capable of including
`at least a portion of the original
`values including the at least one
`original value, where the system
`is configured to execute the
`instructions such that, based on
`the at least one reference of the
`at least one object to the at least
`one original value of the at least
`one original document, a change
`to the at least one original value
`of the at least one original
`document results in a
`corresponding change in a
`subsequent instance of the
`presentation;
`
`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 Presentation would require “a computer program
`product embodied on a non-transitory computer readable medium, comprising:… outputting a
`presentation that is based on at least a portion of the at least one object, the presentation capable of
`including at least a portion of the original values including the at least one original value, where the
`system is configured to execute the instructions such that, based on the at least one reference of the at
`least one object to the at least one original value of the at least one original document, a change to the
`at least one original value of the at least one original document results in a corresponding change in a
`subsequent instance of the presentation”.
`
`The XBRL Financial Reporting standard uses an Instance Document to describe the contents of the Financial
`Report, and associated linkbases to describe semantic, formatting, calculation and validation information.
`During Mattress Firm’s editing of an XBRL-compliant Financial Presentation, a computer program product
`embodied on a non-transitory computer readable medium must exist to allow change to the at least one
`original value of the at least one original Instance Document data value. Once the change to the at least
`one original value of the at least one Instance Document data value has been input by the user, the
`computer program product embodied on a non-transitory computer readable medium for “outputting a
`presentation that is based on at least a portion of the at least one object, the presentation capable of
`including at least a portion of the original values including the at least one original value, such that,
`based on the at least one reference of the at least one object to the at least one original value of the at
`least one original document, a change to the at least one original value of the at least one original
`document results in a corresponding change in an instance of the presentation” would be executed to
`generate the XBRL-compliant presentation.
`
`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:… outputting a presentation that is based on at
`least a portion of the at least one object, the presentation capable of including at least a portion of the
`original values including the at least one original value, where the system is configured to execute the
`instructions such that, based on the at least one reference of the at least one object to the at least one
`original value of the at least one original document, a change to the at least one original value of the at
`least one original document results in a corresponding change in a subsequent instance of the
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`Case 1:19-cv-00859-RTH Document 53-27 Filed 04/27/21 Page 8 of 10
`
`Claim Chart for U.S. Patent 10,223,337
`
`Claim 1
`
`
`
`outputting a report that is based
`on at least a portion of the at
`least one object, the report
`capable of including at least a
`portion of the original values
`including the at least one original
`value, where the system is
`configured to execute the
`instructions such that, based on
`the at least one reference of the
`at least one object to the at least
`one original value of the at least
`one original document, a change
`to the at least one original value
`of the at least one original
`document results in a
`corresponding change in a
`subsequent instance of the
`report; and
`
`Infringement Analysis
`presentation” in order to edit and then present the contents of 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:…. outputting a report that is
`based on at least a portion of the at least one object, the report capable of including at least a portion of
`the original values including the at least one original value, where the system is configured to execute
`the instructions such that, based on the at least one reference of the at least one object to the at least
`one original value of the at least one original document, a change to the at least one original value of
`the at least one original document results in a corresponding change in a subsequent instance of the
`report”.
`
`The XBRL Financial Reporting standard uses an XML-compliant Instance Document to describe the contents
`of the Financial Report, and associated linkbases to describe semantic, formatting, calculation and
`validation information. During Mattress Firm’s editing of an XBRL-compliant Financial Report, a computer
`program product embodied on a non-transitory computer readable medium must exist to allow change
`to the at least one original value of the at least one original Instance Document. Once the change to the
`at least one original value of the at least one original Instance Document has been input by the user,
`validated and stored in as a revised version of the XBRL-compliant Instance Document, a computer
`program product embodied on a non-transitory computer readable medium “for outputting a report that
`is based on at least a portion of the at least one object, the report capable of including at least a portion
`of the original values including the at least one original value, where the system is configured to execute
`the instructions such that, based on the at least one reference of the at least one object to the at least
`one original value of the at least one original document, a change to the at least one original value of
`the at least one original document results in a corresponding change in a subsequent instance of the
`report” would be executed to generate the XBRL-compliant 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
`a non-transitory computer readable medium, comprising:… outputting a report that is based on at least
`a portion of the at least one object, the report capable of including at least a portion of the original
`values including the at least one original value, where the system is configured to execute the
`instructions such that, based on the at least one reference of the at least one object to the at least one
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`Case 1:19-cv-00859-RTH Document 53-27 Filed 04/27/21 Page 9 of 10
`
`Claim Chart for U.S. Patent 10,223,337
`
`Claim 1
`
`
`
`Infringement Analysis
`original value of the at least one original document, a change to the at least one original value of the at
`least one original document results in a corresponding change in a subsequent instance of the report” to
`edit and then report the contents of the XBRL Instance Document and the associated linkbases.
`
`outputting at least one computer-
`readable Extensible Markup
`Language (XML)-compliant data
`document that is produced using
`a markup language that extends
`XML for reporting and that is not
`XML, Hypertext Markup Language
`(HTML), Extensible Style
`Language (XSL), nor Standard
`Generalized Markup Language
`(SGML) and that is based on at
`least a portion of the at least one
`object and at least a portion of
`the mapping, the at least one
`computer-readable XML-
`compliant data document
`capable of including a plurality of
`line items with at least a portion
`of the original values including
`the at least one original value and
`at least some of the computer-
`readable semantic tags, where
`the system is configured to
`execute the instructions such
`that, based on the at least one
`reference of the at least one
`object to the at least one original
`value of the at least one original
`document, a change to the at
`
`
`
`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:… outputting at least one
`computer-readable Extensible Markup Language (XML)-compliant data document that is produced using
`a markup language that extends XML for reporting and that is not XML, Hypertext Markup Language
`(HTML), Extensible Style Language (XSL), nor Standard Generalized Markup Language (SGML) and that is
`based on at least a portion of the at least one object and at least a portion of the mapping, the at least
`one computer-readable XML-compliant data document capable of including a plurality of line items with
`at least a portion of the original values including the at least one original value and at least some of the
`computer-readable semantic tags, where the system is configured to execute the instructions such that,
`based on the at least one reference of the at least one object to the at least one original value of the at
`least one original document, a change to the at least one original value of the at least one original
`document results in a corresponding change in a subsequent instance of the at least one computer-
`readable XML-compliant data document”.
`
`The XBRL Financial Reporting standard specifies an XML-compliant Instance Document to describe the
`contents of the Financial Report, and associated linkbases to describe semantic, formatting, calculation and
`validation information. For Mattress Firm to “output at least one computer-readable Extensible Markup
`Language (XML)-compliant data document” such as an XBRL-compliant Financial Instance Document and
`its associated linkbases, a computer program product embodied on a non-transitory computer readable
`medium must exist to allow change to the at least one original value of the at least one original Instance
`Document. Once the change to the at least one original value of the at least one original Instance
`Document data value has been input, validated and stored in as a revised version of the XBRL-compliant
`Instance, the “computer program product embodied on a non-transitory computer readable medium,
`comprising:…. outputting at least one computer-readable Extensible Markup Language (XML)-compliant
`data document that is produced using a markup language that extends XML for reporting and that is not
`XML, Hypertext Markup Language (HTML), Extensible Style Language (XSL), nor Standard Generalized
`Markup Language (SGML) and that is based on at least a portion of the at least one object and at least a
`portion of the mapping, the at least one computer-readable XML-compliant data document capable of
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`Case 1:19-cv-00859-RTH Document 53-27 Filed 04/27/21 Page 10 of 10
`
`Claim Chart for U.S. Patent 10,223,337
`
`Claim 1
`least one original value of the at
`least one original document
`results in a corresponding change
`in a subsequent instance of the at
`least one computer-readable
`XML-compliant data document.
`
`
`
`Infringement Analysis
`including a plurality of line items with at least a portion of the original values including the at least one
`original value and at least some of the computer-readable semantic tags, where the system is configured
`to execute the instructions such that, based on the at least one reference of the at least one object to the
`at least one original value of the at least one original document, a change to the at least one original
`value of the at least one original document results in a corresponding change in a subsequent instance of
`the at least one computer-readable XML-compliant data document” would be executed to generate the
`XBRL-compliant Instance Document and associated linkbase Documents in XML-compatible format.
`
`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:… outputting at least one computer-readable
`Extensible Markup Language (XML)-compliant data document that is produced using a markup language
`that extends XML for reporting and that is not XML, Hypertext Markup Language (HTML), Extensible
`Style Language (XSL), nor Standard Generalized Markup Language (SGML) and that is based on at least a
`portion of the at least one object and at least a portion of the mapping, the at least one computer-
`readable XML-compliant data document capable of including a plurality of line items with at least a
`portion of the original values including the at least one original value and at least some of the computer-
`readable semantic tags, where the system is configured to execute the instructions such that, based on
`the at least one reference of the at least one object to the at least one original value of the at least one
`original document, a change to the at least one original value of the at least one original document
`results in a corresponding change in a subsequent instance of the at least one computer-readable XML-
`compliant data document” to edit and then output the contents of the XBRL Instance Document and the
`associated linkbases as computer-readable XML-compliant data documents.
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