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`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 1 of 34
`Case 1:19—cv-00859—RTH Document 53-8 Filed 04/27/21 Page 1 of 34
`
`EXHIBIT H
`EXHIBIT H
`
`

`

`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 2 of 34
`
`
`
`
`
`Claim Chart For U.S. Patent 8,185,816
`
`The SEC’s infringement of the ‘816 patent is demonstrated by the Office of Structured Disclosure (OSD) within the SEC as well as by Mr. Michael Willis’ comments in the
`article entitled “The SEC’s Increasingly Sophisticated Use of XBRL-Tagged Data.”
`
`
`“OSD works closely with other SEC Divisions and Offices to design data structuring approaches for required disclosures, and supports the SEC’s data collections and data usage by
`designing taxonomies, validation rules, data quality assessments, and tools for conducting data analyses. OSD also works with investors, regulated entities, and the public to support
`the submission and use of structured data.”
`https://www.sec.gov/structureddata
`
`
`https://www.sec.gov/page/osdhistoryandrulemaking
`
`
`
`
`
`
`
`1
`
`

`

`
`
`Claim Chart For U.S. Patent 8,185,816
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 3 of 34
`
`
`
`https://www.sec.gov/page/osd_edgarvalandrender
`
`
`
`Mr. Willis described an unidentified SEC analysis program as follows:
`
` How is the SEC using XBRL data internally?
`
` Q
`
`
`
`A: While the word on the street may be that the SEC is not using XBRL, that is simply not true.
`
`
`One way the SEC uses XBRL data is for economic analysis. When an analysis is looking across all SEC companies – and I repeat that: all companies, from the largest
`to the smallest– that is when the XBRL data is very useful. Some data aggregators may focus on the largest filers. When we need an answer that covers all
`companies, XBRL data is the only game in town for assessing information from the entire set of corporate filers.
` (emphasis added)
`
`As set forth below, Mr. Willis’ comments demonstrate infringement of at least claims 1, 10, 17, 26 and 27 of the ‘816 patent.
`
`
`
`
`
`
`
`2
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`

`

`
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`
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 4 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`Claim 1
`1. A method in a data
`processing system,
`comprising the 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 method that uses a set of interrelated eXtensible
`Markup Language (XML)-formatted files containing tagged numerical data in a data processing system 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 with 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,
`
`3
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`

`

`
`
`
`
`
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`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 5 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`Claim 1
`
`
`
`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 a “A method in a data processing system.”
`
`Therefore, any SEC analysis program analyzing multiple Financial Reports that comply with the XBRL Financial
`Reporting standard by the SEC would entail use of such “A method in a data processing system” to perform the
`actions specified in the XBRL Instance Document and the associated linkbases. Mr. Willis describes the SEC
`performing a method in a data processing system using an unidentified SEC analysis program.
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’s analyzing multiple XBRL-
`compliant Financial Reports would require “A method in a data processing system, comprising the steps of:
`receiving a first markup document and a second markup document, both the first markup document and the
`second markup document including numerical values and tags reflecting characteristics of the numerical values,
`wherein the characteristics indicate that the numerical values of the first markup document differ in format from
`the numerical values of the second markup document;” in order to perform adjustments to the scale factor (e.g.,
`thousands ($1,000) vs. millions ($1,000,000)) as specified for the numeric data value for the XBRL-compliant
`Financial Report Instance Document.
`
`Mr. Willis describes the SEC’s ability to analyze filings of multiple filers (i.e., at least first and second markup
`documents). The documents contain numerical data (the reported numbers) and tags reflecting characteristics of
`the numerical numbers (the XBRL tags where the semantics are in the attributes within the tags). Mr. Willis
`
`4
`
`receiving a first markup
`document and a second
`markup document, both
`the first markup
`document and the
`second markup
`document including
`numerical values and tags
`reflecting characteristics
`of the numerical values,
`wherein the
`
`

`

`
`
`
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 6 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`describes a situation where the SEC compares all filers in a given industry. This encompasses both the largest
`filer(s) with, e.g., sales in billions and the smallest filer(s) with, e.g., sales in millions or hundreds of thousands.
`These sales numbers are in different formats.
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric data values to
`be included in the Financial Report. Based on the tags associated with each numeric data value to be displayed, its
`
`5
`
`

`

`
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 7 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`Claim 1
`characteristics indicate
`that the numerical values
`of the first markup
`document differ in
`format from the
`numerical values of the
`second markup
`document;
`
`automatically
`transforming the
`numerical values of at
`least one of the first
`markup document and
`the second markup
`document, so that the
`numerical values of the
`first markup document
`and the second markup
`document have a
`common format;
`
`
`
`
`
`
`
`Infringement Analysis
`label and scale factor are obtained from the referenced linkbase files and are used to generate the display with the
`specified scale factor.
`
`Therefore, any analysis of Financial Reports that comply with the XBRL Financial Reporting standard by the SEC
`would require “A method in a data processing system, comprising the steps of: receiving a first markup
`document and a second markup document, both the first markup document and the second markup document
`including numerical values and tags reflecting characteristics of the numerical values, wherein the
`characteristics indicate that the numerical values of the first markup document differ in format from the
`numerical values of the second markup 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, the SEC’s analyzing multiple XBRL-
`compliant Financial Reports would require “A method in a data processing system, comprising the steps of: …
`automatically transforming the numerical values of at least one of the first markup document and the second
`markup document, so that the numerical values of the first markup document and the second markup document
`have a common format” in order to perform adjustments to the scale factor (e.g., thousands ($1,000) vs. millions
`($1,000,000)) as specified for the numeric data value for the XBRL-compliant Financial Report Instance Document.
`
`Mr. Willis describes the analysis system(s) at the SEC permitting comparing all of these filers at once (i.e., the sales
`figures have to be put in a common format).
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric data values to
`be included in the Financial Report. Based on the tags associated with each numeric data value to be displayed, its
`label and scale factor are obtained from the referenced linkbase files and are used to generate the display with the
`specified scale factor.
`
`Therefore, any SEC analysis of multiple Financial Reports that comply with the XBRL Financial Reporting standard
`by the SEC would require “A method in a data processing system, comprising the steps of: … automatically
`transforming the numerical values of at least one of the first markup document and the second markup
`document, so that the numerical values of the first markup document and the second markup document have a
`common format” ” to perform the actions specified in the XBRL Instance Document and the associated linkbases.
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’sanalyzing multiple
`XBRL-compliant Financial Reports would require “A method in a data processing system,
`comprising the steps of:… combining the first markup document and the second markup document into a single
`
`combining the first
`markup document and
`the second markup
`
`6
`
`

`

`
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 8 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`Claim 1
`document into a single
`data set;
`
`Infringement Analysis
`data set” in order to perform the adjustments to the scale factor (e.g., thousands ($1,000) vs. millions
`($1,000,000)) as specified for the numeric data value for the XBRL-compliant Financial Report Instance Document.
`
`and displaying the single
`data set.
`
`
`
`
`
`
`
`
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric data values to
`be included in the Financial Report. Based on the tags associated with each numeric data value to be displayed, its
`label and associated display format are obtained from the referenced linkbase files and are used to generate the
`single data set as specified in the Instance Document. Where calculated composite numeric data values that
`summarize individual numeric data values with differing scale factors are needed, the Calculation Rules are used to
`generate the combined numeric data values in accordance with the Taxonomy’s specified scale factor.
`
`Mr. Willis describes looking at the filers at the same time (i.e., the sales numbers have been combined into a
`single data set).
`
`Therefore, any analysis of Financial Reports that comply with the XBRL Financial Reporting standard by the SEC
`would require “A method in a data processing system, comprising the steps of… combining the first markup
`document and the second markup document into a single data set” to perform the actions specified in the XBRL
`Instance Document and the associated linkbases.
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’s analysis of multiple
`XBRL-compliant Financial Reports would require “A method in a data processing system, comprising the steps
`of:… displaying the single data set.
`
`Mr. Willis is presumably looking at the results on a display (e.g., computer monitor).
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric data values to
`be included in the Financial Report. Based on the tags associated with each numeric data value to be displayed, its
`label and associated display format are obtained from the referenced linkbase files and are used to display the
`single data set as specified in the Instance Document. Where calculated composite numeric data values that
`summarize individual numeric data values with differing scale factors are needed, the Calculation Rules are used to
`display the combined numeric data values in accordance with the Taxonomy’s specified scale factor.
`
`Therefore, any analysis of Financial Reports that comply with the XBRL Financial Reporting standard by the SEC
`would require A method in a data processing system, comprising the steps of :… displaying the single data set”
`to the results as specified in the XBRL Instance Document and the associated linkbases.
`
`7
`
`

`

`
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 9 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`Claim 10
`10. 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 data processing system that uses a set of
`interrelated eXtensible Markup Language (XML)-formatted files containing tagged numerical data that specify:
`
`
`
`
`
`
`
`
`
`
`
`(1) how tagged numerical data items to be formatted in an XBRL Financial Report are identified as a Fact (a tagged
`numerical data value that will be reported) related to a Concept (a particular Financial semantic meaning for the
`tagged numerical data value) in the context of the Taxonomy (a list of concepts to be included in the Financial
`Report, and a collection of XML-compliant documents (linkbases) that provide additional information that forms
`part of the concept definitions) for inclusion in a given XBRL Financial Report Instance Document (see XBRL
`“Essentials https://specifications.xbrl.org/xbrl-essentials.html),
`
`(2) how the numerical data items are tagged in the XML-compliant Instance Document file (with a name ending in
`“.xml”), which indicates the content of the Financial Report, to facilitate association the related linkbases:
`(a) XML-compliant Schema Definition file (with a name ending in “.xsd”) which contains formatting and
`semantic meaning information,
`(b) XML-compliant Label file (with a name ending in “_lab.xml”) which indicates the label of the numeric
`data value,
`(c) XML-compliant Calculation file (with a name ending in “_cal.xml”) which contains rules that determine
`how to combine information and to determine that the set of XML-compliant documents are valid,
`(d) XML-compliant Definition file (with a name ending in “_def.xml”) relates concepts with other concepts,
`(e) XML-compliant Presentation file (with a name ending in “_pre.xml”) This linkbase associates concepts
`with other concepts so that the resulting relations can guide the creation of a user interface, rendering,
`or visualization.
`
`(3) how each tagged numerical data item is identified and categorized from the information 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,
`
`8
`
`

`

`
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 10 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`Claim 10
`
`
`
`Infringement Analysis
`(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 SEC analysis program analyzingmultiple Financial Reports that comply with the XBRL Financial
`Reporting standard by the SEC would entail use of such “A data processing system” to perform the actions
`specified in the XBRL Instance Document and the associated linkbases. . Mr. Willis describes the SEC using a data
`processing system containing an unidentified SEC analysis program.
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’s analyzing multiple XBRL-
`compliant Financial Reports would require “A data processing system comprising: a non- volatile storage device
`storing a first markup document and a second markup document, both the first markup document and the
`second markup document containing numerical values and tags reflecting characteristics of the numerical
`values, wherein the characteristics indicate that the numerical values of the first markup document differ in
`format from the numerical values of the second markup document;” in order to perform adjustments to the scale
`factor (e.g., thousands ($1,000) vs. millions ($1,000,000)) as specified for the numeric data value for the XBRL-
`compliant Financial Report Instance Document.
`
`The SEC system is computer-based and contains the XBRL filings being analyzed. Mr. Willis describes the SEC’s
`ability to analyze filings of multiple filers (i.e., at least first and second markup documents). The documents
`contain numerical data (the reported numbers) and tags reflecting characteristics of the numerical numbers (the
`XBRL tags where the semantics are in the attributes within the tags). Mr. Willis describes a situation where the
`SEC compares all filers in a given industry. This encompasses both the largest filer(s) with, e.g., sales in billions and
`the smallest filer(s) with, e.g., sales in millions or hundreds of thousands. These sales numbers are in different
`
`9
`
`a non-volatile storage
`device storing a first
`markup document and a
`second markup
`document, both the first
`markup document and
`the second markup
`document containing
`numerical values and tags
`reflecting characteristics
`of the numerical values,
`wherein the
`characteristics indicate
`that the numerical values
`
`

`

`
`
`
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 11 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`formats.
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric data values to
`be included in the Financial Report. Based on the tags associated with each numeric data value to be displayed, its
`label and scale factor are obtained from the referenced linkbase files and are used to generate the display with the
`specified scale factor.
`
`10
`
`

`

`
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 12 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`Claim 10
`of the first markup
`document differ in
`format from the
`numerical values of the
`second markup
`document;
`
`a memory storing a
`program that receives the
`first markup document
`and the second markup
`document, that
`automatically transforms
`the numerical values of at
`least one of the first
`markup document and
`the second markup
`document so that the
`numerical values of the
`first markup document
`and the second markup
`document have a
`common format, and that
`combines the first
`markup document and
`the second markup
`document into a single
`data set;
`
`
`
`
`
`Infringement Analysis
`Therefore, any analysis of Financial Reports that comply with the XBRL Financial Reporting standard by the SEC
`would require “A data processing system comprising: a non-volatile storage device storing a first markup
`document and a second markup document, both the first markup document and the second markup document
`containing numerical values and tags reflecting characteristics of the numerical values, wherein the
`characteristics indicate that the numerical values of the first markup document differ in
`format from the numerical values of the second markup 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, the SEC’sanalyzing multiple XBRL-
`compliant Financial Report would require “A data processing system comprising:… a memory storing a program
`that receives the first markup document and the second markup document, that automatically transforms the
`numerical values of at least one of the first markup document and the second markup document so that the
`numerical values of the first markup document and the second markup document have a common format, and
`that combines the first markup document and the second markup document into a single data set;” in order to
`perform adjustments to the scale factor (e.g., thousands ($1,000) vs. millions ($1,000,000)) as specified for the
`numeric data value for the XBRL-compliant Financial Report Instance Document.
`
`The SEC system is computer-based and runs an analysis program. Mr. Willis describes the analysis system(s) at the
`SEC permitting comparing all of these filers at once (i.e., the sales figures have to be put in a common unit of
`measure). Mr. Willis describes looking at the filers at the same time (i.e., the sales numbers have combined into a
`single data set which would be in a single markup document).
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric data values to
`be included in the Financial Report. Based on the tags associated with each numeric data value to be displayed, its
`label and scale factor are obtained from the referenced linkbase files and are used to generate the display with the
`specified scale factor.
`
`Therefore, any SEC analysis of multiple Financial Reports that comply with the XBRL Financial Reporting standard
`by the SEC would require “A data processing system comprising:… a memory storing a program that receives the
`first markup document and the second markup document, that automatically transforms the numerical values
`of at least one of the first markup document and the second markup document so that the numerical values of
`the first markup document and the second markup document have a common format, and that combines the
`first markup document and the second markup document into a single data set” to perform the actions specified
`in the XBRL Instance Document and the associated linkbases.
`
`11
`
`

`

`
`
`
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 13 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`and a processor that runs
`the program.
`
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’sanalyzing multiple XBRL-
`compliant Financial Reports would require “A data processing system comprising:… a processor that runs the
`program in order to perform adjustments to the scale factor (e.g., thousands ($1,000) vs. millions ($1,000,000))
`as specified for the numeric data value for the XBRL-compliant Financial Report Instance
`Document. The SEC system is computer-based and contains a processor that runs the analysis program described
`by Mr. Willis.
`
`12
`
`

`

`
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 14 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`Claim 10
`
`
`
`Infringement Analysis
`
`
`
`
`
`The Taxonomy contained in the XBRL-compliant Instance Document specifies the specific numeric data values to
`be included in the Financial Report. Based on the tags associated with each numeric data value to be displayed, its
`label and associated display format are obtained from the referenced linkbase files and are used to display the
`single data set as specified in the Instance Document. Where calculated composite numeric data values that
`summarize individual numeric data values with differing scale factors are needed, the Calculation Rules are used to
`display the combined numeric data values in accordance with the Taxonomy’s specified display format), adjusting
`the calculation to accommodate the differing scale factors.
`
`Therefore, any analysis of Financial Reports that comply with the XBRL Financial Reporting standard by the SEC
`would require “A data processing system comprising:…and a processor that runs the program” to perform the
`actions specified in the XBRL Instance Document and the associated linkbases.
`
`13
`
`

`

`
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 15 of 34
`
`Claim Chart For U.S. Patent 8,185,816
`
`Claim 17
`17. A non-transitory
`computer-readable
`medium containing
`instructions for
`controlling a data
`processing system to
`perform a 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 process using “A non-transitory computer-readable
`medium containing instructions for controlling a data processing system to perform a method” that uses a set of
`interrelated eXtensible Markup Language (XML)-formatted files containing tagged numerical data 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),
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`(2) how the numerical data items are tagged in the XML-compliant Instance Document file (with a name ending in
`“.xml”), which indicates the content of the Financial Report, to facilitate association the related linkbases:
`(a) XML-compliant Schema Definition file (with a name ending in “.xsd”) which contains formatting and
`semantic meaning information,
`(b) XML-compliant Label file (with a name ending in “_lab.xml”) which indicates the label of the numeric
`data value,
`(c) XML-compliant Calculation file (with a name ending in “_cal.xml”) which contains rules that determine
`how to combine information and to determine that the set of XML-compliant documents are valid,
`(d) XML-compliant Definition file (with a name ending in “_def.xml”) relates concepts with other concepts,
`(e) XML-compliant Presentation file (with a name ending in “_pre.xml”) This linkbase associates concepts
`with other concepts so that the resulting relations can guide the creation of a user interface, rendering,
`or visualization.
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`(3) how each tagged numerical data item is identified and categorized from the information contained in the
`referenced linkbases using the tags,
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`(4) how each tagged numerical data item is formatted for display,
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`(5) how each tagged numerical data item is displayed hierarchically in relation to other tagged numerical data
`items,
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`Case 1:19-cv-00859-RTH Document 53-8 Filed 04/27/21 Page 16 of 34
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`Claim Chart For U.S. Patent 8,185,816
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`(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
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`(7) how the set of interrelated XBRL files are validated to ensure consistency and completeness of the information
`contained therein.
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`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 non-transitory computer-readable medium containing instructions
`for controlling a data processing system to perform a method”
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`Therefore, any SEC analysis program analyzing multiple Financial Reports that comply with the XBRL Financial
`Reporting standard by the SEC would entail use of such “A non-transitory computer-readable medium
`containing instructions for controlling a data processing system to perform a method” to perform the actions
`specified in the XBRL Instance Document and the associated linkbases. The SEC system described by Mr. Willis
`is run on a computer where the analysis program is stored in a memory.
`In accordance with the XBRL Financial Reporting standard as described above, the SEC’s analyzing multiple XBRL-
`compliant Financial Reports would require “A non-transitory computer-readable medium containing instructions
`for controlling