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`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 1 of 42
`Case 1:19—cv-00859—RTH Document 53-4 Filed 04/27/21 Page 1 of 42
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`EXHIBIT D
`
`EXHIBIT D
`
`

`

`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 2 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 1
`1. A computer-
`implemented method of
`processing tagged
`numerical data, the
`method 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 method that uses
`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 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.
`
`1
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`

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`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 3 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 1
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Infringement Analysis
`
`(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,
`
`(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 a “A computer-implemented method of processing tagged numerical data, the
`method …:”
`
`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-implemented
`method of processing tagged numerical data, the method …:”
`
`2
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`

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`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 4 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 1
`receiving a series of
`numerical values having
`tags indicating
`characteristics of the
`numerical values;
`
`generating at least one
`first title corresponding to
`the series of numerical
`values;
`
`receiving a macro defined
`to perform an operation on
`the series of numerical
`values;
`
`
`
`
`
`Infringement Analysis
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s
`method of creating, editing and generating an XBRL-compliant Financial Report requires “a computer-
`implemented method of processing tagged numerical data...” that includes “receiving a series of
`numerical values having tags indicating characteristics of the numerical values.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting standard by Mattress Firm would entail “receiving a series of numerical values
`having tags indicating characteristics of the numerical values.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation method requires “a computer-implemented method of processing
`tagged numerical data...” and “generating at least one first title corresponding to the series of
`numerical values” by reading and processing an XBRL-compliant Instance Document which contains
`the Facts, Concepts, Taxonomy and references to associated sematic meaning, formatting schema
`definition, calculation rule and validation rule linkbases: “generating at least one first title
`corresponding to the series of numerical values” is specified by the XBRL Taxonomy which identifies
`the first title of the section of the XBRL Financial Report displaying “the series of numerical values”
`contained in that section of the XBRL Financial Report.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting standard by Mattress Firm would entail “generating at least one first title
`corresponding to the series of numerical values”.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation method requires “a computer-implemented method of processing
`tagged numerical data...” and “receiving a macro defined to perform an operation on the series of
`numerical values” by reading and processing an XBRL-compliant Instance Document which contains
`the Facts, Concepts, Taxonomy and references to associated sematic meaning, formatting schema
`definition, calculation rule and validation rule linkbases. The XBRL Financial Reporting standard uses
`the term “Rule” in lieu of the term “Macro”, however, both terms are synonymous with describing a
`method that comprises a series of manipulations which (a) transform tagged numerical data format,
`and/or (b) combining tagged numerical data values, and/or (c) validating tagged numerical data
`
`3
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`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 5 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 1
`
`
`
`performing an operation
`defined by the macro on
`the series of numerical
`values to transform the
`series of numerical values
`into a new representation
`of the series of numerical
`values based on the tags;
`
`generating at least one
`second title corresponding
`to results of the operation;
`
`
`
`
`
`Infringement Analysis
`values, as specified by the XBRL Taxonomy contained in the XBRL Instance Document used to
`generate the XBRL-compliant Financial Report.
`
`Therefore, Mattress Firm’s method of generating an XBRL-compliant Financial Report the involves
`“receiving a macro (i.e., rule) defined to perform an operation on the series of numerical values” as
`specified by the Taxonomy contained in the XBRL Instance Document which identifies the rule(s) to
`be applied to “the series of numerical values” contained in that section of the XBRL-compliant
`Financial Report.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation method requires “a computer-implemented method of processing
`tagged numerical data...” and “performing an operation defined by the macro on the series of
`numerical values to transform the series of numerical values into a new representation of the series
`of numerical values based on the tags” by reading and processing an XBRL-compliant Instance
`Document which contains the Facts, Concepts, Taxonomy and references to associated sematic
`meaning, formatting schema definition, calculation rule and validation rule linkbases. The XBRL
`Financial Reporting Standard uses the term “Rule” in lieu of the term “Macro”, however, both terms
`are synonymous with describing a method that consists of a series of manipulations which (a)
`transform tagged numerical data format, and/or (b) combining tagged numerical data values,
`and/or (c) validating tagged numerical data values, as specified by the XBRL Taxonomy contained in
`the XBRL Instance Document used to generate the XBRL-compliant Financial Report.
`
`Therefore, Mattress Firm’s method of generating an XBRL-compliant Financial Report involves
`“performing an operation defined by the macro (i.e., rule) on the series of numerical values to
`transform the series of numerical values into a new representation of the series of numerical values
`based on the tags” as specified by the Taxonomy contained in the XBRL Instance Document which
`identifies the rule(s) to be applied to “the series of numerical values” contained in that section of the
`XBRL-compliant Financial Report.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation method requires “a computer-implemented method of processing
`tagged numerical data...” and “generating at least one second title corresponding to results of the
`
`4
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`

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`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 6 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 1
`
`
`
`and displaying the results
`of the operation and the at
`least one second title,
`wherein:
`
`the macro makes a copy of
`the series of numerical
`values before the
`operation is performed,
`the macro comprises at
`least one arithmetic
`statement, the at least one
`
`
`
`
`
`Infringement Analysis
`operation” by reading and processing an XBRL-compliant Instance Document which contains the
`Facts, Concepts, Taxonomy and references to associated sematic meaning, formatting schema
`definition, calculation rule and validation rule linkbases: “generating at least one second title
`corresponding to results of the operation” is specified by the XBRL Taxonomy which identifies the
`second title of the section of the XBRL Financial Report corresponding to “results of the operation”
`generated in that section of the XBRL Financial Report.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting standard by Mattress Firm would entail “generating at least one second title
`corresponding to results of the operation.”
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation method requires “a computer-implemented method of processing
`tagged numerical data... and displaying the results of the operation and the at least one second
`title …” by reading and processing an XBRL-compliant Instance Document which contains the Facts,
`Concepts, Taxonomy and references to associated sematic meaning, formatting schema definition,
`calculation rule and validation rule linkbases: “ … displaying the results of the operation and the at
`least one second title …” is specified by the XBRL Taxonomy which identifies the second title of the
`section of the XBRL Financial Report and displaying the “results of the operation” generated in that
`section of the XBRL Financial Report.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting standard by Mattress Firm would entail “displaying the results of the operation
`and the at least one second title …”
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation method requires “a computer-implemented method of processing
`tagged numerical data... and displaying the results of the operation and the at least one second
`title, wherein: the macro makes a copy of the series of numerical values before the operation is
`performed, the macro comprises at least one arithmetic statement, the at least one arithmetic
`statement comprises a variable, the variable is referenced in a local or remote document other than
`a document that contains the macro, and the step of receiving the macro comprises receiving the
`
`5
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`

`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 7 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 1
`arithmetic statement
`comprises a variable, the
`variable is referenced in a
`local or remote document
`other than a document
`that contains the macro,
`and the step of receiving
`the macro comprises
`receiving the macro
`including interpreted code,
`meta-data, and error
`handling instructions.
`
`
`
`
`
`Infringement Analysis
`macro including interpreted code, meta-data, and error handling instructions ” by reading and
`processing an XBRL-compliant Instance Document which contains the Facts, Concepts, Taxonomy and
`references to associated sematic meaning, formatting schema definition, calculation rule and
`validation rule linkbases: “ … the XBRL-compliant “Rule” (i.e., macro):
`
`1) In order to perform the required computation, the XBRL-compliant Calculation Rule (i.e.
`macro) method “ … makes a copy of the series of numerical values before the operation is
`performed” as specified by the Calculation Rule for the referenced tags contained in the
`associated XBRL-compliant Calculation Rule linkbase,
`2) the XBRL-compliant Calculation Rule (i.e., “macro) comprises at least one arithmetic
`statement” as specified in the XBRL-compliant Calculation Rule linkbase,
`3) the XBRL-compliant Calculation Rule (i.e., macro) specifies that “the at least one arithmetic
`statement comprises a variable”, that is used to record the result of the specified Calculation
`Rule (i.e., operation),
`4) the XBRL-compliant Calculation Rule (i.e., macro) is contained in the linkbase entry referenced
`by the tag contained in the XBRL-compliant Instance Document: the “variable is referenced in
`a local or remote document …”, in this case the XBRL-compliant Instance Document “ other
`than a document that contains the macro,”
`5) the XBRL-compliant Calculation Rule (i.e., macro) method performs “ … the step of receiving
`the macro comprises receiving the macro including interpreted code, meta-data, and error
`handling instructions. …” as specified by the XBRL Taxonomy.
`
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation method requires “the macro makes a copy of the series of numerical
`values before the operation is performed, the macro comprises at least one arithmetic statement,
`the at least one arithmetic statement comprises a variable, the variable is referenced in a local or
`remote document other than a document that contains the macro, and the step of receiving the
`macro comprises receiving the macro including interpreted code, meta-data, and error handling
`instructions.”
`
`6
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`
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`
`
`
`
`

`

`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 8 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 27
`27. A data processing
`system 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 system
`implemented using “A data processing system … “ that uses 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 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.
`
`7
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`
`

`

`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 9 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 27
`
`
`
`a memory including a
`numerical analysis
`
`
`
`
`
`
`
`
`
`
`
`
`
`Infringement Analysis
`(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,
`
`(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 a “A data processing system …:”
`
`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 “A data processing system
`…:”
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation data processing system requires “a memory including a numerical
`
`8
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`
`
`
`
`
`

`

`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 10 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 27
`program having a macro
`defined to perform an
`operation on a series of
`numerical values, the
`series of numerical values
`having tags indicating
`characteristics of the
`numerical values;
`
`a generator for generating
`at least one first title
`corresponding to the series
`
`Infringement Analysis
`analysis program having a macro defined to perform an operation on a series of numerical values,
`the series of numerical values having tags indicating characteristics of the numerical values” by
`reading and processing an XBRL-compliant Instance Document which contains the Facts, Concepts,
`Taxonomy and references to associated sematic meaning, formatting schema definition, calculation
`rule and validation rule linkbases. The XBRL Financial Reporting Standard uses the term “Rule” in lieu
`of the term “Macro”, however, both terms are synonymous with describing a method that comprises
`a series of manipulations which (a) transform tagged numerical data format, and/or (b) combining
`tagged numerical data values, and/or (c) validating tagged numerical data values, as specified by
`the XBRL Taxonomy contained in the XBRL Instance Document used to generate the XBRL-compliant
`Financial Report.
`
`“ … The data processing system:”
`
`1) includes “a memory including a numerical analysis program having a macro defined within
`the Calculation Rule specified in the Calculation Rule linkbase referenced from the XBRL
`Taxonomy within the XBRL-compliant Instance Document that specifies the selected XBRL-
`compliant Reporting Format.
`2) The XBRL-compliant Calculation Rule is “used to perform an operation on a series of
`numerical values, the series of numerical values having tags indicating characteristics of the
`numerical values;”
`
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation data processing system would require “a memory including a
`numerical analysis program having a macro defined to perform an operation on a series of
`numerical values, the series of numerical values having tags indicating characteristics of the
`numerical values”.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation data processing system would require “a generator for generating at
`least one first title corresponding to the series of numerical values”. The XBRL-compliant data
`
`
`
`
`
`
`
`
`9
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`

`

`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 11 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 27
`of numerical values;
`
`a processor for running the
`program such that the
`program performs an
`operation defined by the
`macro on the series of
`numerical values using the
`indicated characteristics of
`the tags to transform the
`series of numerical values
`into a new representation
`of the series of numerical
`values;
`
`Infringement Analysis
`processing system would create an XBRL-compliant Instance Document which contains the Facts,
`Concepts, Taxonomy and references to associated sematic meaning, formatting schema definition,
`calculation rule and validation rule linkbases: the “generator for generating at least one first title
`corresponding to the series of numerical values” would specify the XBRL Taxonomy which identifies
`the first title of the section of the XBRL Financial Report displaying “the series of numerical values”
`contained in that section of the XBRL 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 “data processing system” that
`includes “a generator for generating at least one first title corresponding to the series of numerical
`values”.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation data processing system requires “a processor for running the
`program such that the program performs an operation defined by the macro on the series of
`numerical values using the indicated characteristics of the tags to transform the series of numerical
`values into a new representation of the series of numerical values” by reading and processing an
`XBRL-compliant Instance Document which contains the Facts, Concepts, Taxonomy and references to
`associated sematic meaning, formatting schema definition, calculation rule and validation rule
`linkbases.
`
`Therefore, Mattress Firm’s data processing system would have to be capable of generating an XBRL-
`compliant Financial Report using “a processor for running the program such that the program
`performs an operation defined by the macro on the series of numerical values using the indicated
`characteristics of the tags to transform the series of numerical values into a new representation of
`the series of numerical values” as specified by the Taxonomy contained in the XBRL Instance
`Document which identifies the rule(s) to be applied to “the series of numerical values” contained in
`that section of the XBRL-compliant Financial Report.
`
`
`
`
`
`10
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`

`

`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 12 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 27
`the generator generates at
`least one second title
`corresponding to results of
`the operation;
`
`and a display for displaying
`the at least second title
`and the results of the
`operation, wherein:
`
`the macro makes a copy of
`the series of numerical
`values before the
`operation is performed,
`
`Infringement Analysis
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation data processing system must include “the generator generates at
`least one second title corresponding to results of the operation;” by reading and processing an XBRL-
`compliant Instance Document which contains the Facts, Concepts, Taxonomy and references to
`associated sematic meaning, formatting schema definition, calculation rule and validation rule
`linkbases: “the generator generates at least one second title corresponding to results of the
`operation” as specified by the XBRL Taxonomy which identifies the second title of the section of the
`XBRL Financial Report corresponding to “results of the operation” generated in that section of the
`XBRL 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 data processing system that includes
`“the generator generates at least one second title corresponding to results of the operation”.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation data processing system would require the ability to “display for
`displaying the at least second title and the results of the operation, wherein:” by reading and
`processing an XBRL-compliant Instance Document which contains the Facts, Concepts, Taxonomy and
`references to associated sematic meaning, formatting schema definition, calculation rule and
`validation rule linkbases: “ … displaying the results of the operation and the at least one second title
`…” is specified by the XBRL Taxonomy which identifies the second title of the section of the XBRL
`Financial Report and displaying the “results of the operation” generated in that section of the XBRL
`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 data processing system that includes
`“a display for displaying the at least second title and the results of the operation …”.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation data processing system must support the execution of “the macro
`(e.g., Rule) makes a copy of the series of numerical values before the operation is performed, …the
`macro comprises at least one arithmetic statement, the at least one arithmetic statement
`
`
`
`
`
`11
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`

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`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 13 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 27
`the macro comprises
`interpreted code, meta-
`data, error handling
`instructions, and at least
`one arithmetic statement,
`the at least one arithmetic
`statement comprises a
`variable, and the variable is
`referenced in a local or
`remote document other
`than a document that
`contains the macro.
`
`Infringement Analysis
`comprises a variable, the variable is referenced in a local or remote document other than a
`document that contains the macro, …and macro comprises interpreted code, meta-data, and error
`handling instructions. ” by reading and processing an XBRL-compliant Instance Document which
`contains the Facts, Concepts, Taxonomy and references to associated sematic meaning, formatting
`schema definition, calculation rule and validation rule linkbases: “ … the XBRL-compliant “Rule” (i.e.,
`macro)
`
`1) In order to perform the required computation, the XBRL-compliant Calculation Rule (i.e.
`macro) method “ … makes a copy of the series of numerical values before the operation is
`performed” as specified by the Calculation Rule for the referenced tags contained in the
`associated XBRL-compliant Calculation Rule linkbase,
`2) the XBRL-compliant Calculation Rule (i.e., “macro) comprises at least one arithmetic
`statement” as specified in the XBRL-compliant Calculation Rule linkbase
`3) the XBRL-compliant Calculation Rule (i.e., macro) specifies that “the at least one arithmetic
`statement comprises a variable”, that is used to record the result of the specified Calculation
`Rule (i.e., operation)
`4) the XBRL-compliant Calculation Rule (i.e., macro) is contained in the linkbase entry referenced
`by the tag contained in the XBRL-compliant Instance Document: the “variable is referenced in
`a local or remote document …”, in this case the XBRL-compliant Instance Document “ other
`than a document that contains the macro,”
`5) the XBRL-compliant Calculation Rule (i.e., macro) method performs “ … the step of receiving
`the macro comprises receiving the macro including interpreted code, meta-data, and error
`handling instructions. …” as specified by the XBRL Taxonomy.
`
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s XBRL
`Financial Reporting generation method requires “ the macro comprises interpreted code, meta-data,
`error handling instructions, and at least one arithmetic statement, the at least one arithmetic
`statement comprises a variable, and the variable is referenced in a local or remote document other
`than a document that contains the macro ”.
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`Case 1:19-cv-00859-RTH Document 53-4 Filed 04/27/21 Page 14 of 42
`
`Claim Chart For U.S. Patent 7,650,355
`
`Claim 28
`28. A computer-readable
`memory storing
`instructions that are
`executed by a computer
`for performing steps of:
`
`
`
`
`
`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 system
`implemented using “A computer-readable memory storing instructions that are executed by a
`computer for performing steps of … “ that uses a set of interrelated eXtensible Markup Language
`(XML)-formatted files that specify:
`
`(1) how tagged numerical data items to