Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 1 of 16 PageID #: 27224
`Case 1:13-cv-00919—LPS Document 308-2 Filed 03/10/21 Page 1 of 16 PageID #: 27224
`
`EXHIBIT 31
`
`EXHIBIT 31
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 2 of 16 PageID #: 27225
`
`Exhibit C-32
`
`Claim Chart Applying Newton 2.0 Programmer's Guide Against the '843 Patent
`
`The "Newton Programmer's Guide: For Newton 2.0" ("Newton Guide") was published by Apple Press in
`1996. It therefore constitutes prior art under pre-AlA 35 U.S.C. § 102(b). As shown below, Newton Guide
`If the Judge or Jury
`anticipates and/or renders obvious claims 1, 8, 13, 15, 17-19,23 and 30 of the '843 patent.
`finds that Newton Guide does not anticipate a particular claim, then Newton Guide still renders the claim
`obvious for the reasons discussed in Exhibit F.
`
`, 843 Patent Claims
`Claim 1
`A computer-implemented method
`for finding data related to the
`contents of a document using a first
`computer program running on a
`computer, the method comprising:
`
`Disclosure
`
`To the extent this preamble is found to be limiting, Newton Guide
`discloses this preamble. For example, Newton Guide states:
`
`"About the Notes Application
`
`Notes is a simple application based on NewtApp that allows the user to
`create new stationery, scroll up and down, route and file notes, and scan
`an overview."
`
`p.19-31.
`
`"Notes
`
`This section describes the Notes API. The Notes application uses three
`regular notes, checklists, and outlines. Figure
`types of stationery:
`19-6 shows a note and a checklist; an outline (not shown) is like the
`checklist without the checkboxes."
`
`p. 19-30.
`
`1
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 3 of 16 PageID #: 27226
`
`'843 Patent Claims
`
`Disclosure
`Built-in Applications and System Data
`
`Exhibit C-32
`
`Figure 19-6
`
`Notes note and Checklist views
`
`"mI~!I""""".~p;er;so;n:a~I~~i·IEHmdf~Ulfll""""~~;;~
`
`p.19-31.
`
`"A key part of the Newton information architecture is the Intelligent
`Assistant. The Intelligent Assistant is a system service that attempts to
`complete actions for the user according to deductions it makes about the
`task that the user is currently performing. The Assistant is always
`instantly available to the user through the Assist button, yet remains
`nonintrusive.
`
`The Assistant knows how to complete several built-in tasks; they are
`Scheduling (adding meetings), Finding, Reminding (adding To Do
`items), Mailing, Faxing, Printing, Calling, and getting time information
`from the Time Zones map. Each of these tasks has several synonyms;
`for example, the user can write 'call,' 'phone,' 'ring,' or 'dial' to make a
`phone call."
`
`p. 1-8.
`
`displaying the document
`electronically using the first
`computer program;
`
`Newton Guide discloses this element. For example, Newton Guide
`states:
`
`"About the Notes Application
`
`Notes is a simple application based on NewtApp that allows the user to
`create new stationery, scroll up and down, route and file notes, and scan
`an overview."
`
`2
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 4 of 16 PageID #: 27227
`
`'843 Patent Claims
`
`Disclosure
`
`Exhibit C-32
`
`p.19-31.
`
`"Notes
`
`This section describes the Notes API. The Notes application uses three
`types of stationery:
`regular notes, checklists, and outlines. Figure
`19-6 shows a note and a checklist; an outline (not shown) is like the
`checklist without the checkboxes."
`
`p. 19-30.
`
`Built-in Applications and System Data
`
`Figure 19-6
`
`Notes note and Checklist views
`
`p.19-31.
`
`"When a user writes a line of text on the Newton screen, the Newton
`system software performs a series of operations, as follows:
`• The raw data for the input is captured as ink, which is also known
`as sketch ink or raw ink.
`• Raw ink is stored as a sequence of strokes or stroke data.
`If the view in which the ink was drawn is configured for ink text,
`•
`the recognition system groups the stroke data into a series of ink
`words, based on the timing and spacing of the user's
`handwriting. A user can insert, delete, and move ink words in
`Ink words can be scaled to
`the same way as recognized text.
`various sizes for display and printing. They can also be
`
`3
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 5 of 16 PageID #: 27228
`
`'843 Patent Claims
`
`while the document is being
`displayed, analyzing, in a computer
`process, first information from the
`document to determine if the first
`information is at least one of a
`plurality of types of information
`that can be searched for in order to
`find second information related to
`the first information;
`
`Exhibit C-32
`
`Disclosure
`recognized at a later time, by a process known as deferred
`recognition.
`If the view in which the ink was drawn supports or is configured
`for text recognition, the ink words are processed by the
`recognition system into recognized text and displayed in a
`typeface."
`
`•
`
`p.8-2.
`
`Newton Guide discloses this element. For example, Newton Guide
`states:
`
`"A key part of the Newton information architecture is the Intelligent
`Assistant. The Intelligent Assistant is a system service that attempts to
`complete actions for the user according to deductions it makes about the
`task that the user is currently performing. The Assistant is always
`instantly available to the user through the Assist button, yet remains
`nonintrusive.
`
`The Assistant knows how to complete several built-in tasks; they are
`Scheduling (adding meetings), Finding, Reminding (adding To Do
`items), Mailing, Faxing, Printing, Calling, and getting time information
`from the Time Zones map. Each of these tasks has several synonyms;
`for example, the user can write 'call,' 'phone,' 'ring,' or 'dial' to make a
`phone call."
`
`p. 1-8.
`
`"When the user invokes the Assistant, the system passes the current text
`If no text is selected, the system passes to the Assistant
`selection to it.
`the contents of a buffer that holds the most recent text input.
`
`The Assistant then attempts to match words in the input string with
`templates and dictionaries that classify the words as actions, targets, or
`unknown entities."
`
`p. 18-1.
`
`"When an action is specified but required information is still missing, the
`Assistant tries to supply as much of the required information as possible.
`F or example, if the input string is 'fax bob', the Assistant can query the
`Names soup for information such as Bob's name and fax number.
`However, the user may still need to correct the input if the Assistant
`chooses the wrong Bob from the Names soup, cannot find Bob in the
`Names soup, or cannot find Bob's fax number in this soup.
`
`The user can resolve ambiguities or provide additional information from
`
`4
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 6 of 16 PageID #: 27229
`
`Exhibit C-32
`
`'843 Patent Claims
`
`Disclosure
`within a task slip that the Assistant displays for this purpose."
`
`p. 18-4.
`
`"To permit more natural interaction, the Assistant ignores words that do
`not appear in any registered template's lexicon. Rather than limiting the
`user to terse commands, the Assistant extracts meaningful words from
`phrases such as "Make a call to Bob at work" and ignores the others. For
`example, the words "call", "Bob" and "work" are meaningful to the
`Assistant because they appear in the lexicons of registered templates. (In
`this case, the templates are supplied and registered by the system.) On
`the other hand, because the words "a", "to", and "at" do not appear in the
`lexicons of any registered templates, they are not matched and are
`therefore ignored."
`
`p. 18-9.
`
`retrieving the first information;
`
`Newton Guide discloses this element. For example, Newton Guide
`states:
`
`"When the user invokes the Assistant, the system passes the current text
`If no text is selected, the system passes to the Assistant
`selection to it.
`the contents of a buffer that holds the most recent text input.
`
`The Assistant then attempts to match words in the input string with
`templates and dictionaries that classify the words as actions, targets, or
`unknown entities."
`
`p. 18-1.
`
`"When an action is specified but required information is still missing, the
`Assistant tries to supply as much of the required information as possible.
`F or example, if the input string is 'fax bob', the Assistant can query the
`Names soup for information such as Bob's name and fax number.
`However, the user may still need to correct the input if the Assistant
`chooses the wrong Bob from the Names soup, cannot find Bob in the
`Names soup, or cannot find Bob's fax number in this soup.
`
`The user can resolve ambiguities or provide additional information from
`within a task slip that the Assistant displays for this purpose."
`
`p. 18-4.
`
`providing an input device,
`configured by the first computer
`program, that allows a user to enter
`
`Newton Guide discloses this element. For example, Newton Guide
`states:
`
`5
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 7 of 16 PageID #: 27230
`
`'843 Patent Claims
`a user command to initiate an
`operation, the operation comprising
`(i) performing a search using at
`least part of the first information as
`a search term in order to find the
`second information, of a specific
`type or types, associated with the
`search term in an information
`source external to the document,
`wherein the specific type or types
`of second information is dependent
`at least in part on the type or types
`of the first information, and (ii)
`performing an action using at least
`part of the second information;
`
`Exhibit C-32
`
`Disclosure
`"When a user writes a line of text on the Newton screen, the Newton
`system software performs a series of operations, as follows:
`
`• The raw data for the input is captured as ink, which is also known
`as sketch ink or raw ink.
`• Raw ink is stored as a sequence of strokes or stroke data.
`If the view in which the ink was drawn is configured for ink text,
`•
`the recognition system groups the stroke data into a series of ink
`words, based on the timing and spacing of the user's
`handwriting. A user can insert, delete, and move ink words in
`the same way as recognized text.
`Ink words can be scaled to
`various sizes for display and printing. They can also be
`recognized at a later time, by a process known as deferred
`recognition.
`If the view in which the ink was drawn supports or is configured
`for text recognition, the ink words are processed by the
`recognition system into recognized text and displayed in a
`typeface."
`
`•
`
`p.8-2.
`
`"When the user invokes the Assistant, the system passes the current text
`If no text is selected, the system passes to the Assistant
`selection to it.
`the contents of a buffer that holds the most recent text input.
`
`The Assistant then attempts to match words in the input string with
`templates and dictionaries that classify the words as actions, targets, or
`unknown entities."
`
`p. 18-1.
`
`"When an action is specified but required information is still missing, the
`Assistant tries to supply as much of the required information as possible.
`F or example, if the input string is 'fax bob', the Assistant can query the
`Names soup for information such as Bob's name and fax number.
`However, the user may still need to correct the input if the Assistant
`chooses the wrong Bob from the Names soup, cannot find Bob in the
`Names soup, or cannot find Bob's fax number in this soup.
`
`The user can resolve ambiguities or provide additional information from
`within a task slip that the Assistant displays for this purpose."
`
`p. 18-4.
`
`6
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 8 of 16 PageID #: 27231
`
`'843 Patent Claims
`
`Exhibit C-32
`
`Disclosure
`"You define the PostParse method in your task template. Your PostParse
`method must perform any actions required to complete the primary task.
`The PostParse method usually acts as a dispatching method that executes
`the subtasks comprising the primary action. In doing so, the PostParse
`method may validate data and retrieve information that the Assistant was
`unable to find on its own."
`
`p. 18-8.
`
`"Words representing elements of the signature array do not necessarily
`need to appear in the input string in order to be matched to a template;
`for example, your PostParse method might supply Bob's fax number by
`finding it in the Names soup."
`
`p. 18-10.
`
`"Continuing with the example based on the previous code fragment,
`when the Assistant parses the input phrase "fax Bob", it matches the
`word "fax" to the fax_action template in the first element of the signature
`array and creates an action frame from this template. The Assistant
`places this action frame in an action slot (named for the symbol in the
`first element of the preConditions array) that it creates in the task frame.
`Similarly, the Assistant creates a target frame when the word "Bob" is
`matched to the who _ obj template in the third element of the signature
`array. The Assistant places this target frame in a recipient slot (named for
`the symbol in the third element of the preConditions array) that it creates
`in the task frame.
`
`Words representing elements of the signature array do not necessarily
`need to appear in the input string in order to be matched to a template;
`for example, your PostParse method might supply Bob's fax number by
`finding it in the Names soup."
`
`p. 18-10.
`
`in consequence of receipt by the
`first computer program of the user
`command from the input device,
`causing a search for the search term
`in the information source, using a
`second computer program, in order
`to find second information related
`to the search term; and
`
`Newton Guide discloses this element. For example, Newton Guide
`states:
`
`"When the user invokes the Assistant, the system passes the current text
`If no text is selected, the system passes to the Assistant
`selection to it.
`the contents of a buffer that holds the most recent text input.
`
`The Assistant then attempts to match words in the input string with
`templates and dictionaries that classify the words as actions, targets, or
`unknown entities."
`
`7
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 9 of 16 PageID #: 27232
`
`'843 Patent Claims
`
`Disclosure
`p. 18-1.
`
`Exhibit C-32
`
`"When an action is specified but required information is still missing, the
`Assistant tries to supply as much of the required information as possible.
`F or example, if the input string is 'fax bob', the Assistant can query the
`Names soup for information such as Bob's name and fax number.
`However, the user may still need to correct the input if the Assistant
`chooses the wrong Bob from the Names soup, cannot find Bob in the
`Names soup, or cannot find Bob's fax number in this soup.
`
`The user can resolve ambiguities or provide additional information from
`within a task slip that the Assistant displays for this purpose."
`
`p. 18-4.
`
`"You define the PostParse method in your task template. Your PostParse
`method must perform any actions required to complete the primary task.
`The PostParse method usually acts as a dispatching method that executes
`the subtasks comprising the primary action. In doing so, the PostParse
`method may validate data and retrieve information that the Assistant was
`unable to find on its own."
`
`p. 18-8.
`
`"Words representing elements of the signature array do not necessarily
`need to appear in the input string in order to be matched to a template;
`for example, your PostParse method might supply Bob's fax number by
`finding it in the Names soup."
`
`p. 18-10.
`
`"Continuing with the example based on the previous code fragment,
`when the Assistant parses the input phrase "fax Bob", it matches the
`word "fax" to the fax_action template in the first element of the signature
`array and creates an action frame from this template. The Assistant
`places this action frame in an action slot (named for the symbol in the
`first element of the preConditions array) that it creates in the task frame.
`Similarly, the Assistant creates a target frame when the word "Bob" is
`matched to the who _ obj template in the third element of the signature
`array. The Assistant places this target frame in a recipient slot (named for
`the symbol in the third element of the preConditions array) that it creates
`in the task frame.
`
`Words representing elements of the signature array do not necessarily
`need to appear in the input string in order to be matched to a template;
`for example, your PostParse method might supply Bob's fax number by
`
`8
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 10 of 16 PageID #: 27233
`
`'843 Patent Claims
`
`Disclosure
`finding it in the Names soup."
`
`Exhibit C-32
`
`p. 18-10.
`
`"Names
`
`This section describes the application program interface (API) to the
`Names application. The Names application manages a database of
`people and places.
`It presents information either as a business card, or
`as a list of all available information. These two views are shown in
`Figure 19-1."
`
`p. 19-2.
`
`"The Names application stores its data in the ROM _ CardFileSoupName
`("Names") soup. Entries in this soup are frames for either a person, an
`owner, a group, a company, or a worksite card."
`
`p.19-7.
`
`Figure 19-1
`
`Names application Card and All Info views
`
`In Box
`
`Oul Box
`
`~
`EJ
`Nol.,
`
`.AII Names~
`I
`I
`~ &
`'@Cd)!fl9ii)])"j(i'DOj))Yln)U9v~Yili
`I
`IaNewton Cafe
`i· 24 1 cappuccino Court
`,
`g
`I Newton, MA 02 163
`i
`~~~!~~~~~~~~ i . 1r 6 17555- 1000
`I
`G
`,. 1r 6 17 555-3123 F
`i
`r-.;;;..&;;.;..a..;;;.. ........ -'-"'-.......... -;.:;;.&..':""O';;'....&;.......L...;;.~ I · Card Style: 1-=;,;]
`i
`i
`--
`1
`, . -Around the corner from Allce's
`I
`• Newton Car e. • • • • •
`restaurant..
`1
`241 Cappuccino COUl't
`NeVlon. MA 02168
`
`1
`
`I
`
`1r 617555-1000
`1r 617 555-8123 [
`
`I 1 __ _ ----1 Card L_
`
`l~vAllltlfoemg ,
`
`p. 19-3.
`
`if searching finds any second
`information related to the search
`term, performing the action using at
`least part of the second information,
`wherein the action is of a type
`depending at least in part on the
`type or types of the first
`
`Newton Guide discloses this element. For example, Newton Guide
`states:
`
`"When an action is specified but required information is still missing, the
`Assistant tries to supply as much of the required information as possible.
`F or example, if the input string is 'fax bob', the Assistant can query the
`Names soup for information such as Bob's name and fax number.
`
`9
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 11 of 16 PageID #: 27234
`
`'843 Patent Claims
`information.
`
`Exhibit C-32
`
`Disclosure
`However, the user may still need to correct the input if the Assistant
`chooses the wrong Bob from the Names soup, cannot find Bob in the
`Names soup, or cannot find Bob's fax number in this soup.
`
`The user can resolve ambiguities or provide additional information from
`within a task slip that the Assistant displays for this purpose."
`
`p. 18-4.
`
`Figure 18-3
`
`Calling task slip
`
`•
`
`ame Boh Ande"on (Home)
`, 3 1
`
`• Using Speaker
`
`00 LO(j
`[tAs is )§[)(8)
`
`p. 18-4.
`
`"The built-in tasks that the Assistant can complete include calling,
`faxing, finding, mailing, printing, remembering (adding To Do items),
`scheduling (adding meetings), getting time information from the built-in
`Time Zones application and displaying online help. Note that the top
`portion of this menu displays only one word for each action the Assistant
`can perform. For example, the word "call" appears here but the
`synonyms "ring" and "phone" do not. Recently used synonyms may
`appear in the bottom half of the slip, however."
`
`p. 18-3.
`
`"When routing an item from the Assistant-for example, when filing,
`faxing, printing, or mailing the item-the Assistant sends a
`GetTargetInfo message to your application"
`
`p. 18-20.
`
`"I I Action template for sending electronic mail
`
`10
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 12 of 16 PageID #: 27235
`
`'843 Patent Claims
`
`Exhibit C-32
`
`Disclosure
`mail_act := {
`,
`,
`,
`lexicon' ["mail" "send" "email"]
`.
`... }"
`
`p. 18-24.
`
`"Newton can serve as a phone dialer by dialing phone numbers through
`the speaker. The dialing tones are built into the system ROM, along with
`several other sounds that can be used in applications."
`
`p. 1-9.
`
`If the Judge or Jury finds that Newton Guide does not disclose this
`element, the element and the claim are still rendered obvious for the
`reasons stated in Exhibit F, Table 9.
`
`Claim 8
`A method according to claim 1,
`further comprising, providing a
`prompt for updating the information
`source to include the first
`information.
`Claim 13
`A method according to claim 1,
`wherein the user command is the
`only command from a user
`Newton Guide further discloses this element. For example, Newton
`necessary to initiate performing the Guide states:
`operation.
`
`Newton Guide discloses the method of claim 1. See claim 1 above.
`
`"When the user invokes the Assistant, the system passes the current text
`If no text is selected, the system passes to the Assistant
`selection to it.
`the contents of a buffer that holds the most recent text input.
`
`The Assistant then attempts to match words in the input string with
`templates and dictionaries that classify the words as actions, targets, or
`unknown entities."
`
`p. 18-1.
`
`"When an action is specified but required information is still missing, the
`Assistant tries to supply as much of the required information as possible.
`F or example, if the input string is 'fax bob', the Assistant can query the
`Names soup for information such as Bob's name and fax number.
`However, the user may still need to correct the input if the Assistant
`chooses the wrong Bob from the Names soup, cannot find Bob in the
`Names soup, or cannot find Bob's fax number in this soup.
`
`The user can resolve ambiguities or provide additional information from
`within a task slip that the Assistant displays for this purpose."
`
`p. 18-4.
`
`11
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 13 of 16 PageID #: 27236
`
`'843 Patent Claims
`
`Disclosure
`
`Exhibit C-32
`
`Claim 15
`A method according to claim 1,
`further comprising, if searching
`results in a plurality of distinct
`instances of second information,
`displaying such instances to enable
`user selection of one of them for
`use in performing the action.
`
`Newton Guide discloses the method of claim 1. See claim 1 above.
`
`Newton Guide further discloses this element. For example, Newton
`Guide states:
`
`"When an action is specified but required information is still missing, the
`Assistant tries to supply as much of the required information as possible.
`F or example, if the input string is 'fax bob', the Assistant can query the
`Names soup for information such as Bob's name and fax number.
`However, the user may still need to correct the input if the Assistant
`chooses the wrong Bob from the Names soup, cannot find Bob in the
`Names soup, or cannot find Bob's fax number in this soup.
`
`The user can resolve ambiguities or provide additional information from
`within a task slip that the Assistant displays for this purpose."
`
`p. 18-4.
`
`If the Judge or Jury finds that Newton Guide does not disclose this
`element, the element and the claim are still rendered obvious for the
`reasons stated in Exhibit F, Table 18.
`
`Claim 17
`A method according to claim 1,
`wherein the information source is
`Newton Guide further discloses this element. For example, Newton
`associated with the second
`computer program and is available Guide states:
`through the computer.
`
`Newton Guide discloses the method of claim 1. See claim 1 above.
`
`"Names
`
`This section describes the application program interface (API) to the
`Names application. The Names application manages a database of
`people and places.
`It presents information either as a business card, or
`as a list of all available information. These two views are shown in
`Figure 19-1."
`
`p. 19-2.
`
`"The Names application stores its data in the ROM _ CardFileSoupName
`("Names") soup. Entries in this soup are frames for either a person, an
`owner, a group, a company, or a worksite card."
`
`p.19-7.
`
`12
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 14 of 16 PageID #: 27237
`
`Exhibit C-32
`
`'843 Patent Claims
`
`Disclosure
`Figure 19-1
`------=--
`
`Names application Card and All Info views
`
`In Box
`
`Out Box
`
`n
`I::J
`
`Not ..
`
`'%1
`IL2I
`
`~ & I[@I
`IiiiI
`~:::~;::~~~~ i 0 1:' 6 17555- 1000
`
`.AIINames~
`I
`I
`!@Cii)-ef)9ii)])"id'DOP)Ylrt)uvy,~Yili
`I
`IaNewton Cafe
`i
`i 0 24 1 cappuccino Cour t
`'I Newton, MA 02 163
`
`'I
`
`i
`
`I
`i
`
`' 0 1:' 6 17555-3 123 F
`,0 Card Style: 10m;,]
`I 0
`-Around the corner from Allce's
`• Newton Cafe • • • • • •
`I restaurant"·
`241 Cappuccino Court
`I
`Nevton. MA 02168
`I
`I I ___ ----l Card L_
`I~ vAIII.lfo BIl25J,
`
`1:' 617555- 1000
`1:' 617555-8123F
`
`p. 19-3.
`
`Claim 18
`A method according to claim 1,
`wherein performing the action
`includes causing insertion of at
`least part of the second information
`into the document.
`Claim 19
`A method according to claim 1,
`wherein performing the action
`includes causing insertion of at
`least part of the second information
`into the document by the first
`computer program.
`Claim 23
`At least one non-transitory
`computer readable medium
`encoded with instructions which,
`when loaded on a computer,
`establish processes for finding data
`related to the contents of a
`document using a first computer
`program running on a computer, the
`processes compnsmg:
`
`Newton Guide discloses the method of claim 1. See claim 1 above.
`
`If the Judge or Jury finds that Newton Guide does not disclose this
`element, the element and the claim are still rendered obvious for the
`reasons stated in Exhibit F, Table 5.
`
`Newton Guide discloses the method of claim 1. See claim 1 above.
`
`If the Judge or Jury finds that Newton Guide does not disclose this
`element, the element and the claim are still rendered obvious for the
`reasons stated in Exhibit F, Table 5.
`
`To the extent this preamble is found to be limiting, Newton Guide
`discloses this preamble. For example, Newton Guide states:
`
`"U sing System Software
`
`Most of the routines and application components that comprise the
`Newton system software reside in ROM, provided in special chips
`contained in every Newton device. When you application calls a
`system routine, the operating system executes the appropriate code
`contained in ROM."
`
`p. 1-17.
`
`13
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 15 of 16 PageID #: 27238
`
`'843 Patent Claims
`
`Disclosure
`"Memory
`
`Exhibit C-32
`
`It is helpful to understand the user of random access memory (RAM) in
`the system, since this resource is shared by the operating system and all
`applications. Newton RAM is divided into separate domains, or
`sections, that have controlled access. Each domain has its own heap
`and stack ... "
`
`displaying the document
`electronically using the first
`computer program;
`while the document is being
`displayed, analyzing, in a computer
`process, first information from the
`document to determine if the first
`information is at least one of a
`plurality of types of information
`that can be searched for in order to
`find second information related to
`the first information;
`retrieving the first information;
`
`providing an input device,
`configured by the first computer
`program, that allows a user to enter
`a user command to initiate an
`operation, the operation comprising
`(i) performing a search using at
`least part of the first information as
`a search term in order to find the
`second information, of a specific
`type or types, associated with the
`search term in an information
`source external to the document,
`wherein the specific type or types
`of second information is dependent
`at least in part on the type or types
`of the first information, and (ii)
`performing an action using at least
`part of the second information;
`in consequence of receipt by the
`first computer program of the user
`command from the input device,
`
`p. 1-3.
`
`See also claim 1.
`See claim 1.
`
`See claim 1.
`
`See claim 1.
`
`See claim 1.
`
`See claim 1.
`
`14
`
`

`

`Case 1:13-cv-00919-LPS Document 308-2 Filed 03/10/21 Page 16 of 16 PageID #: 27239
`
`Exhibit C-32
`
`Disclosure
`
`See claim 1.
`
`'843 Patent Claims
`causing a search for the search term
`in the information source, using a
`second computer program, in order
`to find second information related
`to the search term; and
`if searching finds any second
`information related to the search
`term, performing the action using at
`least part of the second information,
`wherein the action is of a type
`depending at least in part on the
`type or types of the first
`information.
`Claim 30
`At least one non-transitory
`computer readable medium
`according to claim 23, the
`instructions establishing processes
`..
`compnsmg:
`providing a prompt for updating the See claim 8.
`information source to include the
`first information.
`
`See claim 23.
`
`15
`
`