Case 1:13-cv-00919-LPS Document 307-5 Filed 03/10/21 Page 1 of 10 PageID #: 26783
`Case 1:13-cv-00919—LPS Document 307-5 Filed 03/10/21 Page 1 of 10 PageID #: 26783
`
`EXHIBIT 25
`
`EXHIBIT 25
`
`

`

`Case 1:13-cv-00919-LPS Document 307-5 Filed 03/10/21 Page 2 of 10 PageID #: 26784
`
`Exhibit B-14
`
`Claim Chart Applying U.S. Patent No. 6,377,965 (“Hachamovitch”) Against the ’854 Patent
`
`U.S. Patent No. 6,377,965 to Hachamovitch et al. (“Hachamovitch”) was filed on November 7, 1997. It
`therefore constitutes prior art under pre-AIA 35 U.S.C. § 102(e). As shown below, Hachamovitch anticipates
`and/or renders obvious claims 19, 25, 34, 43, 57, 60, 63, 64, 72 and 73 of the ’854 patent. If the Judge or Jury
`finds that Hachamovitch does not anticipate a particular claim, then Hachamovitch still renders the claim
`obvious for the reasons discussed in Exhibit F.
`
`
`Disclosure
`
`To the extent this preamble is found to be limiting, Hachamovitch
`discloses this preamble.
`
`For example, Hachamovitch states:
`
`“A word completion system that can automatically predict unrestricted
`word completions for data entries in an unstructured portion of a data
`file. The word completion system applies prediction criteria to avoid
`annoying the user by displaying an excessive number of wrong
`suggestions. Suggested word completions which may change as the user
`types a partial data entry are displayed in a non-disruptive manner and
`selected using traditional acceptance keystrokes, such as the “tab” key or
`the “enter” key.” Abstract.
`
`“The present invention is a word completion system that can
`automatically predict unrestricted word completions for data entries in an
`unstructured portion of a data file, such as the body of a word processing
`document or email message. The word completion system applies
`prediction criteria to avoid annoying the user by displaying an excessive
`number of wrong suggestions. Suggested word completions, which
`may change as the user types a partial data entry, are displayed in a
`non-disruptive manner and selected using traditional acceptance
`keystrokes, such as the “tab” key or the “enter” key.” 4:10-21.
`
`Hachamovitch discloses this element.
`
`For example, Hachamovitch states:
`
`“The present invention is a word completion system that can
`automatically predict unrestricted word completions for data entries in an
`unstructured portion of a data file, such as the body of a word processing
`document or email message.” 4:10-14.
`
`“FIG. 2A illustrates a graphical user interface 200 for a data file
`including a word completion suggestion in which the completion entry of
`a name-completion pair is tied to a dynamic system parameter. The
`graphical user interface 200 includes an unstructured area 202 into which
`
`’854 Patent Claims
`Claim 19
`A method for information handling
`within a document created by a first
`application program comprising the
`steps of:
`
`entering a first information in the
`first application program;
`
`
`
`1
`
`

`

`Case 1:13-cv-00919-LPS Document 307-5 Filed 03/10/21 Page 3 of 10 PageID #: 26785
`
`’854 Patent Claims
`
`marking without user intervention
`the first information to alert the user
`that the first information can be
`utilized in a second application
`program; and
`
`responding to a user selection by
`performing an operation related to a
`second information, the second
`information associated with the first
`information from the second
`application program.
`
`Exhibit B-14
`
`
`Disclosure
`the user may enter free text using the keyboard 40 or another suitable
`text entry device.” 10:18-24.
`
`See also Figs. 2A-2C.
`
`Hachamovitch discloses this element.
`
`For example, Hachamovitch states:
`
`“The host application program causes the partial data entry to be
`displayed in the usual manner, and the Auto-Complete utility 100 causes
`a completion suggestion 206 to be displayed in association with the
`partial data entry in a non-disruptive word completion field, such as a
`pop-up word completion frame 208 that appears directly above the
`partial data entry.” 10:31-37.
`
`“The word completion utility selects a suggestion list including a
`plurality of associated name-completion pairs, each name completion
`pair including a name entry and a completion entry. The word
`completion utility identifies a particular one of the name entries in the
`suggestion list that corresponds to the partial data entry. The word
`completion utility then applies prediction criteria to the particular name
`entry, the particular completion entry, and the partial data entry. If the
`prediction criteria are met, the word completion utility displays the
`associated completion entry as a word completion suggestion for the
`partial data entry. Advantageously, the suggestion list, as well as
`name-completion pairs within the suggestion list, may be specified by
`the user.” 4:60-5:6.
`
`“Alternatively, the word completion system may be deployed within an
`operating system or as a stand-alone utility that may operate on an
`application-independent basis. Application independence is the ability of
`the same word completion system to work with several different
`application programs, such as a word processing program, an e-mail
`program, a spreadsheet program, a personal calendar program, and so
`forth.” 7:65-8:5.
`
`See also Figs. 2A-2C; 7:18-61; 11:30-65.
`
`Hachamovitch discloses this element.
`
`For example, Hachamovitch states:
`
`“Suggested word completions, which may change as the user types a
`partial data entry, are displayed in a non-disruptive manner. Specifically,
`a word suggestion field appears in a word completion frame above the
`
`
`
`2
`
`

`

`Case 1:13-cv-00919-LPS Document 307-5 Filed 03/10/21 Page 4 of 10 PageID #: 26786
`
`’854 Patent Claims
`
`Claim 25
`A computer readable medium,
`including program instructions
`related to information handling
`within a document created by a first
`application program and for
`performing the steps of:
`
`entering a first information in the
`first application program;
`marking without user intervention
`the first information to alert the user
`
`
`
`Exhibit B-14
`
`
`Disclosure
`partial data entry such that the suggestion and the partial data entry are
`vertically aligned. This makes it easy for the user to compare the
`suggestion to the partial data entry. If the suggestion is too long to
`display directly above the partial data entry, it is truncated with ellipses
`(i.e., . . . ) so that the suggestion and the partial data entry are still
`displayed in vertical alignment. The user accepts a suggestion using
`traditional acceptance keystrokes, such as the “tab” key or the “enter”
`key.” 6:61-7:5.
`
`“The word completion utility may then receive a command indicating
`acceptance of the completion entry. In response, the word completion
`utility replaces the partial data entry with the completion entry in the data
`file.” 5:7-10.
`
`“FIG. 3 is a diagram illustrating a word completion suggestion list 300
`with context-based and capitalization-based suggestion limitations. Each
`item in the suggestion list 300 includes a name entry 302 that is
`associated with a completion entry 304, thus forming a name-completion
`pair. The name entry 302 is compared against a partial data entry, which
`may have been entered by a user into a structured field or into an
`unstructured area of a data file. As noted previously, if the name entry
`302 corresponds to the partial data entry within certain prediction
`criteria, the completion entry 304 associated with the name entry 302 is
`displayed as a completion suggestion for the partial data entry within the
`data file. The user may then accept the completion suggestion by
`entering a familiar data acceptance keystroke, such as the “tab” key or
`the “enter” key.” 11:36-50.
`
`See also Figs. 2A-2C, 3.
`
`
`To the extent this preamble is found to be limiting, Hachamovitch
`discloses this preamble.
`
`For example, Hachamovitch states:
`
`“Generally stated, the invention is a computer-readable medium having
`computer-executable instructions for running a word completion utility
`on a computer system.” 4:53-55.
`
`See also claim 19.
`
`See claim 19.
`
`See claim 19.
`
`3
`
`

`

`Case 1:13-cv-00919-LPS Document 307-5 Filed 03/10/21 Page 5 of 10 PageID #: 26787
`
`’854 Patent Claims
`that the first information can be
`utilized in a second application
`program; and
`responding to a user selection by
`performing an operation related to a
`second information, the second
`information associated with the first
`information from the second
`application program.
`Claim 36
`A method for information handling
`within a document operated on by a
`first application program, the
`document containing first
`information that can be utilized in a
`second application program, the
`method comprising the steps of:
`
`identifying without user
`intervention or designation the first
`information; and
`
`Exhibit B-14
`
`
`Disclosure
`
`See claim 19.
`
`
`To the extent this preamble is found to be limiting, Hachamovitch
`discloses this preamble.
`
`For example, Hachamovitch states:
`
`“A word completion system that can automatically predict unrestricted
`word completions for data entries in an unstructured portion of a data
`file. The word completion system applies prediction criteria to avoid
`annoying the user by displaying an excessive number of wrong
`suggestions. Suggested word completions which may change as the user
`types a partial data entry are displayed in a non-disruptive manner and
`selected using traditional acceptance keystrokes, such as the “tab” key or
`the “enter” key.” Abstract.
`
`“The present invention is a word completion system that can
`automatically predict unrestricted word completions for data entries in an
`unstructured portion of a data file, such as the body of a word processing
`document or email message. The word completion system applies
`prediction criteria to avoid annoying the user by displaying an excessive
`number of wrong suggestions. Suggested word completions, which
`may change as the user types a partial data entry, are displayed in a
`non-disruptive manner and selected using traditional acceptance
`keystrokes, such as the “tab” key or the “enter” key.” 4:10-21.
`
`“Alternatively, the word completion system may be deployed within an
`operating system or as a stand-alone utility that may operate on an
`application-independent basis. Application independence is the ability of
`the same word completion system to work with several different
`application programs, such as a word processing program, an e-mail
`program, a spreadsheet program, a personal calendar program, and so
`forth.” 7:65-8:5.
`
`Hachamovitch discloses this element.
`
`For example, Hachamovitch states:
`
`
`
`
`4
`
`

`

`Case 1:13-cv-00919-LPS Document 307-5 Filed 03/10/21 Page 6 of 10 PageID #: 26788
`
`’854 Patent Claims
`
`responding to a user selection by
`inserting a second information into
`the document, the second
`information associated with the first
`information from a second
`application program.
`
`Exhibit B-14
`
`
`Disclosure
`“The host application program causes the partial data entry to be
`displayed in the usual manner, and the Auto-Complete utility 100 causes
`a completion suggestion 206 to be displayed in association with the
`partial data entry in a non-disruptive word completion field, such as a
`pop-up word completion frame 208 that appears directly above the
`partial data entry.” 10:31-37.
`
`“The word completion utility selects a suggestion list including a
`plurality of associated name-completion pairs, each name completion
`pair including a name entry and a completion entry. The word
`completion utility identifies a particular one of the name entries in the
`suggestion list that corresponds to the partial data entry. The word
`completion utility then applies prediction criteria to the particular name
`entry, the particular completion entry, and the partial data entry. If the
`prediction criteria are met, the word completion utility displays the
`associated completion entry as a word completion suggestion for the
`partial data entry. Advantageously, the suggestion list, as well as
`name-completion pairs within the suggestion list, may be specified by
`the user.” 4:60-5:6.
`
`“Alternatively, the word completion system may be deployed within an
`operating system or as a stand-alone utility that may operate on an
`application-independent basis. Application independence is the ability of
`the same word completion system to work with several different
`application programs, such as a word processing program, an e-mail
`program, a spreadsheet program, a personal calendar program, and so
`forth.” 7:65-8:5.
`
`See also Figs. 2A-2C; 7:18-61; 11:30-65.
`
`Hachamovitch discloses this element.
`
`For example, Hachamovitch states:
`
`“Suggested word completions, which may change as the user types a
`partial data entry, are displayed in a non-disruptive manner. Specifically,
`a word suggestion field appears in a word completion frame above the
`partial data entry such that the suggestion and the partial data entry are
`vertically aligned. This makes it easy for the user to compare the
`suggestion to the partial data entry. If the suggestion is too long to
`display directly above the partial data entry, it is truncated with ellipses
`(i.e., . . . ) so that the suggestion and the partial data entry are still
`displayed in vertical alignment. The user accepts a suggestion using
`traditional acceptance keystrokes, such as the “tab” key or the “enter”
`key.” 6:61-7:5.
`
`
`
`
`5
`
`

`

`Case 1:13-cv-00919-LPS Document 307-5 Filed 03/10/21 Page 7 of 10 PageID #: 26789
`
`’854 Patent Claims
`
`Claim 43
`A computer readable medium,
`including program instructions
`related to information handling
`within a document operated on by a
`first application program, the
`document containing first
`information that can be utilized in a
`second application program, and for
`performing the steps of:
`
`identifying without user
`intervention or designation the first
`information; and
`responding to a user selection by
`inserting a second information into
`the document, the second
`information associated with the first
`information from a second
`application program.
`Claim 57
`A method for information handling
`within a document operated on by a
`
`Exhibit B-14
`
`
`Disclosure
`“The word completion utility may then receive a command indicating
`acceptance of the completion entry. In response, the word completion
`utility replaces the partial data entry with the completion entry in the data
`file.” 5:7-10.
`
`“FIG. 3 is a diagram illustrating a word completion suggestion list 300
`with context-based and capitalization-based suggestion limitations. Each
`item in the suggestion list 300 includes a name entry 302 that is
`associated with a completion entry 304, thus forming a name-completion
`pair. The name entry 302 is compared against a partial data entry, which
`may have been entered by a user into a structured field or into an
`unstructured area of a data file. As noted previously, if the name entry
`302 corresponds to the partial data entry within certain prediction
`criteria, the completion entry 304 associated with the name entry 302 is
`displayed as a completion suggestion for the partial data entry within the
`data file. The user may then accept the completion suggestion by
`entering a familiar data acceptance keystroke, such as the “tab” key or
`the “enter” key.” 11:36-50.
`
`See also Figs. 2A-2C, 3.
`
`
`To the extent this preamble is found to be limiting, Hachamovitch
`discloses this preamble.
`
`For example, Hachamovitch states:
`
`“Generally stated, the invention is a computer-readable medium having
`computer-executable instructions for running a word completion utility
`on a computer system.” 4:53-55.
`
`See also claim 36.
`
`See claim 36.
`
`See claim 36.
`
`
`See claim 36.
`
`
`
`6
`
`

`

`Case 1:13-cv-00919-LPS Document 307-5 Filed 03/10/21 Page 8 of 10 PageID #: 26790
`
`’854 Patent Claims
`first application program, the
`document containing first
`information that can be utilized in a
`second application program the
`method comprising the steps of:
`identifying without user
`intervention or designation the first
`information; and
`responding to a user selection by
`performing an operation related to a
`second information, the second
`information associated with the first
`information from the second
`application program.
`Claim 60
`The method of claim 57, wherein
`the operation performed is entering
`additional data into a database.
`
`Claim 63
`The method of claim 57 wherein
`the user selection comprises an
`activation of a menu.
`
`Claim 64
`The method of claim 63, wherein
`the step of performing the operation
`further comprises the steps of:
`
`initializing the second application
`program;
`
`searching, using the second
`application program, for the second
`information associated with the first
`information; and
`
`Exhibit B-14
`
`
`Disclosure
`
`See claim 36.
`
`See claim 19.
`
`
`If the Judge or Jury finds that Miller does not disclose this element, the
`element and the claim are still rendered obvious for the reasons stated in
`Exhibit F, Table 6.
`
`
`
`If the Judge or Jury finds that Miller does not disclose this element, the
`element and the claim are still rendered obvious for the reasons stated in
`Exhibit F, Table 7.
`
`
`Hachamovitch discloses the method of claim 63. See claim 63 above.
`
`Hachamovitch further discloses the additional steps of claim 64, as
`detailed below.
`
`Hachamovitch discloses this element.
`
`For example, the auto-complete program must necessarily be
`initialized in order to run.
`
`Hachamovitch discloses this element.
`
`For example, Hachamovitch states:
`
`“As discussed in more detail with reference to FIG. 3 below, the word
`completion suggestion 206 is identified by comparing the partial data
`entry 204 to the name entries in a suggestion list that includes a group of
`name-completion pairs. If the partial data entry 204 corresponds to the
`name entry of a name-completion pair within certain prediction criteria,
`
`
`
`7
`
`

`

`Case 1:13-cv-00919-LPS Document 307-5 Filed 03/10/21 Page 9 of 10 PageID #: 26791
`
`Exhibit B-14
`
`
`’854 Patent Claims
`
`Disclosure
`the completion entry of the name-completion pair is displayed as the
`completion suggestion 206 in the word completion frame 208.”
`10:38-46.
`
`“The word completion utility selects a suggestion list including a
`plurality of associated name-completion pairs, each name completion
`pair including a name entry and a completion entry. The word
`completion utility identifies a particular one of the name entries in the
`suggestion list that corresponds to the partial data entry. The word
`completion utility then applies prediction criteria to the particular name
`entry, the particular completion entry, and the partial data entry. If the
`prediction criteria are met, the word completion utility displays the
`associated completion entry as a word completion suggestion for the
`partial data entry. Advantageously, the suggestion list, as well as
`name-completion pairs within the suggestion list, may be specified by
`the user.” 4:60-5:6
`
`See also Figs. 2A-2C; 7:18-61; 11:30-65.
`
`retrieving the second information. Hachamovitch discloses this element.
`
`For example, Hachamovitch states:
`
`“As discussed in more detail with reference to FIG. 3 below, the word
`completion suggestion 206 is identified by comparing the partial data
`entry 204 to the name entries in a suggestion list that includes a group of
`name-completion pairs. If the partial data entry 204 corresponds to the
`name entry of a name-completion pair within certain prediction criteria,
`the completion entry of the name-completion pair is displayed as the
`completion suggestion 206 in the word completion frame 208.”
`10:38-46.
`
`“The word completion utility selects a suggestion list including a
`plurality of associated name-completion pairs, each name completion
`pair including a name entry and a completion entry. The word
`completion utility identifies a particular one of the name entries in the
`suggestion list that corresponds to the partial data entry. The word
`completion utility then applies prediction criteria to the particular name
`entry, the particular completion entry, and the partial data entry. If the
`prediction criteria are met, the word completion utility displays the
`associated completion entry as a word completion suggestion for the
`partial data entry. Advantageously, the suggestion list, as well as
`name-completion pairs within the suggestion list, may be specified by
`the user.” 4:60-5:6
`
`See also Figs. 2A-2C; 7:18-61; 11:30-65.
`
`
`
`8
`
`

`

`Case 1:13-cv-00919-LPS Document 307-5 Filed 03/10/21 Page 10 of 10 PageID #: 26792
`
`Exhibit B-14
`
`
`Disclosure
`
`
`If the Judge or Jury finds that Miller does not disclose this element, the
`element and the claim are still rendered obvious for the reasons stated in
`Exhibit F, Table 8.
`
`
`See claim 43.
`
`See claim 36.
`
`See claim 19.
`
`’854 Patent Claims
`
`Claim 72
`The method of claim 57, wherein
`the second information is associated
`with only part of the identified first
`information.
`Claim 73
`A computer readable medium,
`including program instructions
`related to information handling
`within a document operated on by a
`first application program, the
`document containing first
`information that can be utilized in a
`second application program, and for
`performing the steps of:
`identifying without user
`intervention or designation the first
`information; and
`responding to a user selection by
`performing an operation related to a
`second information, the second
`information associated with the first
`information from the second
`application program.
`
`
`
`
`
`9
`
`