Case 2:07-cv-00271-CE Document 235 Filed 09/13/10 Page 1 of 6
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`Civil Action No. 2:07-CV-271-CE
`
`JURY DEMAND
`
`§§§§§§§§§§
`
`
`
`
`
`DEFENDANTS’ CLAIM CONSTRUCTION BRIEF ON
`“TRANSMITTING…TO A WEB PAGE”
`
`
`Plaintiff,
`
`AMERANTH, INC.,
`
`
`
`v.
`
`MENUSOFT SYSTEMS CORP., ET AL.,
`
`
`
`Defendants.
`
`

`

`Case 2:07-cv-00271-CE Document 235 Filed 09/13/10 Page 2 of 6
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`I.
`
`SUMMARY OF ARGUMENT
`
`The ordinary and customary meaning of a “web page” is “[a] document on the World
`
`Wide Web.” Ex. A, MICROSOFT® PRESS COMPUTER DICTIONARY 479 (4th ed. 1999). The
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`intrinsic record, including both the prosecution history and the patent specifications, confirms the
`
`ordinary use of the term. Because Plaintiff (1) did not set forth a clear definition of a novel
`
`meaning of “web page,” and (2) propose a construction contrary to the intrinsic record, the
`
`ordinary and customary meaning controls. Thus, Plaintiff’s notion that a “web page” means a
`
`“web client,” or “browser” or some combination thereof is incorrect.
`
`II.
`
`THE CLAIM TERM “TRANSMITTING…TO A WEB PAGE” MEANS
`“TRANSMITTING…TO A DOCUMENT ON THE WORLD WIDE WEB.”
`
`Claims are generally given their ordinary and customary meaning. Phillips v. AWH
`
`Corporation, 415 F.3d 1303, 1312 (Fed. Cir. 2005) (en banc). The ordinary and customary
`
`meaning of a “web page” at the time of the effective filing date of the applications of the Patents-
`
`in-Suit was “[a] document on the World Wide Web.” MICROSOFT® PRESS COMPUTER
`
`DICTIONARY 479 (4th ed. 1999) (Exhibit A).1 Likewise, the ordinary and customary meaning of
`
`“World Wide Web” indicates documents on the World Wide Web are called “web pages.” Id. at
`
`486.
`
`The intrinsic evidence establishes that the Patents-in-Suit have used the term “web page”
`
`as “a document on the worldwide web.” For example, in response to an office action, Plaintiff
`
`argued that a prior art reference “describes the dynamic creation of menu web pages that are
`
`customized to a customer’s request.” Ex. B, 2/26/2001 Patent ‘850 Amendment at 6-7 (emphasis
`
`added). Under Plaintiff’s proposed construction, one of ordinary skill reading this response
`
`would be forced to reach the unreasonable conclusion that there is a “dynamic creation of menu
`
`1 Defendants seek the same construction of “web page” as requested in their summary judgment
`reply of Dkt. 165.
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`Case 2:07-cv-00271-CE Document 235 Filed 09/13/10 Page 3 of 6
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`[devices that can receive and render a web page visible, e.g. a browser,] that are customized to a
`
`customer’s request.”
`
`Similarly, in the patent specification, Plaintiff defined the phrase “web” in accord with its
`
`ordinary meaning – the “world wide web.” (‘850 Patent at 2:8-19.) Thus, the phrase “world
`
`wide web” is an adjective that modifies the word page, which is simply a document. Thus, what
`
`must be transmitted to are documents on the “world wide web.” Furthermore, the patentee did
`
`not otherwise act as a lexicographer and “clearly set forth a definition” of “web page” in the
`
`specification. See CCS Fitness, Inc. v. Brunswick Corp., 288 F.3d 1359, 1366 (Fed. Cir. 2002).
`
`
`
`Finally, with respect to the claims themselves, the ordinary and customary meaning of
`
`“web page” is consistent with the “information entered on at least one web page” recited in claim
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`14 of the ‘850 Patent. (Id. at 16:32-36.) Thus, the ordinary and customary meaning of a “web
`
`page” controls. See Kegel Co., Inc. v. AMF Bowling, Inc., 127 F.3d 1420, 1427 (Fed. Cir. 1997)
`
`(“Without an express intent to impart a novel meaning to a claim term, the term takes on its
`
`ordinary meaning.”).
`
`III. UNLIKE A “WEB CLIENT” OR BROWSER, A “WEB PAGE” IS A DOCUMENT
`LOCATED AT THE SERVER END IN A TRADITIONAL CLIENT/SERVER
`ARCHITECTURE.
`
`Further demonstrating the Patents-in-Suit’s intention of an ordinary meaning for a “web
`
`page” is a description of the traditional client/server architecture2 including “client computers”3
`
`on the client end and “Web server computers” on the server4 end. (Id. at 12:21-29.) The
`
`Patents-in-Suit explain that the “software running on the user’s computer that enables the user to
`
`2 See Ex. A, MICROSOFT® PRESS COMPUTER DICTIONARY, at 88 (defining “client/server
`architecture”).
`3 The separate use of “client computer” and “web page” in the specification demonstrates the two
`phrases are not synonymous. (See 850 Patent at 12:21-33.)
`4 See Ex. A, MICROSOFT® PRESS COMPUTER DICTIONARY, at 403-04 (defining “server”).
`
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`Case 2:07-cv-00271-CE Document 235 Filed 09/13/10 Page 4 of 6
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`view the HTML documents” is called a “browser.” (Id. at 12:29-33.) The Asserted Patents use
`
`of “client” and “browser” belies its argument that the Patents-in-Suit somehow defined a “web
`
`page” as a client, browser, or combination thereof.5 That the Patents-in-Suit fail to enable the
`
`transmission of linked levels of information to a document on the world wide web does not
`
`suggest that the Court should adopt another meaning that preserves validity.
`
`IV.
`
`EVEN THOUGH THE ASSERTED PATENTS USE THE TERM “CLIENT AND
`“BROWSER,” PLAINTIFF ATTEMPTS TO IMPERMISSIBLY REWRITE THE
`CLAIM TERM “WEB PAGE” AS A “CLIENT/BROWSER” COMBINATION.
`
`Plaintiff attempts to rewrite the “transmitting…to a Web page” claim language to mean
`
`transmitting “to a device that can receive and render a web page visible.” See Exhibit C, Shamos
`
`Expert Report at ¶97 (“Under the Court’s construction, element 1g requires software having the
`
`capability to transmit to both handheld devices and Web pages. I understand this phrasing to
`
`mean that the software must be able to send to a wireless handheld device and to a device that
`
`can receive and render a Web page visible, e.g. a browser.”). But, Plaintiff’s attempted rewrite is
`
`contrary to the Patents-in-Suit’s teaching that the client/browser combination receives “menus”
`
`from a web server – not application software. (‘850 Patent at 12:21-33.) This attempt to now
`
`rewrite the claims – “transmitting . . . to a web page” – would require application software that
`
`transmits to a web server, which then transmits HTML code to a client device that uses a browser
`
`to render a menu visible. This is because the only teaching of transmitting to a client/web
`
`browser combination is through a web server. (‘850 Patent at 12:21-51.) The Patents-in-Suit do
`
`not support this interpretation for the claimed “application software.”
`
`
`5 The term “web server” is not synonymous with “web page” as both terms are recited in claim
`12 of the ‘850 Patent and claims 11-13 of the ‘325 Patent. (‘850 Patent at 16:1-22.)
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`Case 2:07-cv-00271-CE Document 235 Filed 09/13/10 Page 5 of 6
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`V.
`
`CONCLUSION
`
`For the above reasons, Defendants Menusoft Systems Corporation and Cash Register
`
`Sales & Service of Houston, Inc. respectfully request that this Court construe “transmitting…to a
`
`Web Page” to mean “transmitting…to a document on the World Wide Web.”
`
`Dated: September 13, 2010
`
`Respectfully submitted,
`
`/s/ Marc L. Delflache
`Marc L. Delflache
`Texas Bar No. 05725650
`FULBRIGHT & JAWORSKI L.L.P.
`2200 Ross Avenue, Suite 2800
`Dallas, TX 75201-2784
`Telephone: (214) 855-8000
`Facsimile: (214) 855-8200
`Email: mdelflache@fulbright.com
`
`Richard S. Zembek
`Texas Bar No. 00797726
`FULBRIGHT & JAWORSKI L.L.P.
`Fulbright Tower
`1301 McKinney, Suite 5100
`Houston, TX 77010
`Telephone: (713) 651-5151
`Facsimile: (713) 541-5246
`Email: rzembek@fulbright.com
`
`Counsel for Defendants
`MENUSOFT SYSTEMS CORP. and
`CASH REGISTER SALES & SERVICE OF
`HOUSTON, INC.
`
`
`OF COUNSEL:
`
`Otis W. Carroll
`Texas Bar. No. 03895700
`IRELAND, CARROLL & KELLEY, PC
`6101 S. Broadway, Suite 500
`Tyler, TX 75703
`Telephone: (903) 561-1600
`Facsimile: (903) 581-1071
`Email: otiscarroll@icklaw.com
`
`
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`Case 2:07-cv-00271-CE Document 235 Filed 09/13/10 Page 6 of 6
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`
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`CERTIFICATE OF SERVICE
`
`I certify that this document was filed electronically pursuant to Local Rule CV-5(a) on
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`September 13, 2010. Pursuant to Local Rule CV-5(a)(3)(A), this electronic filing acts to
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`electronically serve all counsel who have consented to electronic service via the Court’s
`
`CM/ECF system.
`
`
`
`/s/ Marc L. Delflache
`Marc. L. Delflache
`
`
`
`
`
`
`
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`Case 2:07-cv-00271-CE Document 235-1 Filed 09/13/10 Page 1 of 8
`Case 2:07-cv-00271-CE Document 235-1
`Filed 09/13/10 Page1 of 8
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`EXHIBIT A
`
`EXHIBIT A
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`

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`Case 2:07-cv-00271-CE Document 235-1 Filed 09/13/10 Page 2 of 8
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`MicI'osott·Press
`
`M"crosoft
`
`OCT 1 7 zooo
`RECEIVED
`
`

`

`Case 2:07-cv-00271-CE Document 235-1 Filed 09/13/10 Page 3 of 8
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`PUBUSHEDBY
`Microsofl Press
`A Division of Microsoft Corporation
`One Microsoft Way
`Redmond, Washington 98052-6399
`
`Copyright Cl 1999 by Microsoft Corporation
`
`All rights reserved. No paI1 of the contents of lh.is book may be reproduced or lraDsmilled in any form
`or by any means without the written permission of the publisher.
`
`Library of Congress Cataloging-in-Publication Data
`Microsoft Computer Dictionary. - 4d1 ed
`p. em.
`Previous eds. pUblished under title: Microsoft Press computer
`dictionary
`ISBN 0-7356-0615-3
`I. Computers Dictionaries.
`2. Microcomputers Dictionaries.
`I. Microsoft Press computer dictionary.
`QA76.15.M538
`1999
`(l()4'.03---dc21
`
`99-20168
`elF
`
`Printed and bound in the United States of America.
`
`123456789 MLML 432109
`
`Distributed in Canada by ITP Nelson, a division of Thomson Canada Limited.
`
`A CIP catalogue record for this book is available from die British Library.
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`Microsoft Press books are available through booksellers and distributors worldwide. For further information
`about international editions, contael. your local Microsoft Corporation office or contact Microsoft Press
`International directly aI fax (425) 936-7329. Visit our Web site aI mspress,mjcrosoft com.
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`Macintosh, Power Macintosh, QuickTune. and TrueType fonts are registered lrademarks of Apple Computer.
`Inc. Kodak is a registered ttademark of the Eastman Kodak Company. Intel is a registered lrademark and Indeo
`is a trademark of lnlel Corporation. Active Desktop, Active Directory, ActiveMovie, Active Platform, ActiveX,
`Authenticode, BackOftke, DirectInput, DireclX, Microsoft, Microsofl Press, MS-DOS. MSN, NelMeeting,
`NetShow, Visual Basic. Visual C++, Visual J++, WebTV, WebTV Network, Win32. Win32s, Windows,
`Windows NT, and XENIX are either registered trademarks or trademarks of Microsofl Corporation in die
`United States and/or other countries. PANTONE is a registered trademark of Pantone, Inc. Other product and
`company names mentioned berein may be die trademarks of their respective owners.
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`1be example companies. organizations. products. people. and events depieted herein are fictitious. No associa(cid:173)
`tion with any real oompany. organization.. product, person. or event is intended or should be inferred.
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`Acquisitions Editor: Christey Bahn
`Project Editor: Kim Fryer
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`

`

`Case 2:07-cv-00271-CE Document 235-1 Filed 09/13/10 Page 4 of 8
`clickable maps
`
`cllp a
`
`fonned to select or deselect an item or to activate a
`program or program feature. See also right click.
`Compare double-click, drag.
`clickable maps n. See image map.
`click rate n. See click-through rate.
`click speed n. The maximum interval between the
`frrst and second lime a user presses a button on a
`mouse or other pointing device that will still identify
`these actions as a double-click to the computer as
`opposed to two single-clicks. See also double-click,
`mouse, pointing device.
`clickstream n. 'The path a user takes while browsing a
`Web site. Each distinct selection made on a Web
`page adds one click to the stream. The further down
`the clickstream the user goes without finding the
`sought item, the more likely he or she is to depart to
`another Web site. Analysis of usage patterns helps
`Web site designers create user-friendly site struc(cid:173)
`tures, links, and search facilities. See also Web site.
`click-through n. The number of times that visitors to a
`Web -site click on an advertising banner within a speci(cid:173)
`fied period of time. Click-through is one of the ele(cid:173)
`ments that Web site producers use to decide how much
`to charge advertisers. See also click-through rate.
`click-through rate n. The proportion of visitors to a
`Web site who click on a banner advertisement there,
`expressed as a percentage of total visitors to the Web
`site. Also called click rate. See also click-through.
`client n. 1. In object-oriented prograrruning, a mem(cid:173)
`ber of a class (group) that uses the services of an(cid:173)
`other class to which it is not related. See also
`inheriWlcc (definition 1). 2, A process, such as a
`program or task, that requests a service provided by
`another program-for example, a word processor
`that calls on a sort routine buill into another program.
`The client process uses the requested service without
`having to "know" any working details about the other
`program or the service itself. Compare child (defini(cid:173)
`tion I), descendant (definition 2). 3. On a local area
`network or the Internet, a computer that accesses
`shared network resOUI'Ces provided by another com(cid:173)
`puter (called a server). See also client/server archi(cid:173)
`tecture, server.
`client error n. A problem reported by the Hypertext
`Transfer Protocol (HTIP) client module as the result
`of diffic'ully in interpreting a command or the inabil(cid:173)
`ity to connect properly to a remote host.
`
`client/server architecture n. An arrangement used
`on LANs (local area networks) that makes use of
`distributed intelligence to treat both the server and
`the individual workstations as intelligent, program_
`mable devices, thus exploiting the full computing
`power of each. This is done by splitting the process_
`ing of an application between two distinct compo..
`nents: a "front-end" client and a "back-end" server.
`The client component is a complete, stand-alone
`personal computer (not a "dumb" tenninal), and it
`offers the user its full range of power and features
`for running applications. The server component can
`be a personal computer, a minicomputer, or a main(cid:173)
`frame that provides the traditional strengths offered
`by minicompUlers and mainframes in a time-sharing
`environment: data management, information sharing
`between clients, and sophisticated network adminis(cid:173)
`tration and security features. The client and server
`machines work together to accomplish the process(cid:173)
`ing of the application being used. Not only does this
`increase the processing power available o'(er older
`architectures but it also uses that power more effi(cid:173)
`ciently. The client portion of the application is typi(cid:173)
`cally optimized for user interaction, whereas the
`server portion provides the cenlralized, multiuser
`functionality. See also distributed intelligence.
`Compare peer-to-peer network.
`client/server network n. See client/server architecture.
`client-side image maps n. An image map thilt per(cid:173)
`fonns the processing completely within the client
`program (i.e., Web browser) itself. Early Web imple(cid:173)
`mentations of image maps (circa 1993) lransmitted
`user mouse click coordinates to the Web server for
`processing. Generally client-side image maps im(cid:173)
`prove the speed of response to the user. See also im(cid:173)
`age map.
`clip vb. 1. To cut off the portion of a displayed image
`that lies beyond a certain boundary, such as the edge
`of a window. Certain graphics programs also support
`clipping as a means of masking everything but a cer(cid:173)
`tain object so that painting tools, for example, can be
`applied to the object alone. 2. To cut a photograph,
`drawing, or other illustrations from a clip art collec(cid:173)
`tion--either in a book or on a disk. See also clip art.
`3. To cut off the peaks of a sign3J. in an electronic
`circuit.
`clip art n. A collection--either in a book or on a
`disk-of proprietary or public-domain photographs,
`
`88
`
`

`

`Case 2:07-cv-00271-CE Document 235-1 Filed 09/13/10 Page 5 of 8
`
`uential laile e1emen
`
`sequential logic element n. A logic circuit element
`that has at least one input and one output and in
`which the output signal depends on the present and
`past states of the input signal or signals.
`sequential processing n. 1. The processing of items
`of infonnation in the order in which they are stored
`or inpuL 2. The execution of one instruction, routine.
`or task followed by the execution of the next in line.
`Compare multiprocessing, parallel processing,
`pipelining (definition 1).
`sequential search n. See linear search.
`luial tulj. One by one. For example, in serial trans(cid:173)
`mission, information is transferred one bit at a time;
`a serial computer has only one: arithmetic logic unit.
`which must execute the whole program one step at a
`time. Compor~ parallel (definition 3).
`serial access n. Su sequential access.
`serial adder n. A circuit that adds two numbers one
`bit position (one digit place) at a time.
`
`serial communication n. The exchange of informa(cid:173)
`tion between computers or between computers and
`peripheral devices ooe bit at a time over a single
`channel. Serial communications can be synchronous
`or asynchronous. Both sender and receiver must use
`the same baud rate, parity, and control infonnation.
`Su also baud rate, parity, start bit, stop bit.
`Serial Infrared n. A system developed by Hewlett(cid:173)
`Packard for transmitting data between two devices up
`to I meter apart using an infrared light beam. Infra(cid:173)
`red pons on the receiving and the sending devices
`must be aligned. Geoerally, $eriallnfram:l. is used
`with laptops and many notebook: computers. as well
`as with peripherals such as printers. Acronym: SIR.
`Set also infrared pori.
`serial interface n. A data transmission scheme in
`Which data and control bits are sent sequentially over
`a single channel. In reference to a serial input/output
`CDnnection. the teon usually implies the use of an RS(cid:173)
`232 or RS-422 interface. See also RS-232.c standard,
`RS-42214231449. Compare panJlel interface.
`strializc lib. To change from parallel transmission
`(bYte by byte) to serial transmission (bit by bit).
`Compare deserialize.
`
`SerialKeys n. A feature of Windows 9x and Windows
`NT that, in conjunction with a communications aid
`interface device. allows keystrokes and mouse con(cid:173)
`trDls to be accepted through a computer's serial port.
`
`Serial Line Internet Protocol n. Se~ SLIP.
`serial mouse n. A pointing device that attaches to the
`computer through a standard serial port. See also
`mouse. CompoT~ bus mouse.
`serial port n. An inputloutputlocatioo (channel) that
`sends and receives data to and from a computer's
`central processing unit or' a communications device
`one bit at a time. Serial ports are used for serial data
`communication and as interfaces with some periph(cid:173)
`eral devices, such as mice and primers.
`serial port adapter n. An interface card or device that
`either provides a serial port or converts a serial port
`to another use. See also adapter, serial port.
`serial printer n. A printer connected to the computer
`Via a serial interface (commonly RS·232.c or com(cid:173)
`patible). Connectors for this type of printer vary
`widely, which is one reason they are less popular
`than parallel printers among those who use IBM and
`IBM-compatible Pes. Serial printers are standard for
`Apple computers. See also DB connector, serial, se(cid:173)
`rial transmission. Compare parallel printer.
`serial processing n. Se~ sequential processing (defmi(cid:173)
`tion 2).
`Serial Storage ArclUtecture n. Su SSA.
`serial transmission n. The transfer of discrete signals
`one after another. In communications and data trans(cid:173)
`fer, serial transmission involves sending infomlation
`over a single line one bit at a time, as in modem-to(cid:173)
`modem connections. Compore parallel transmission.
`series clttult n. A circuit in which two Of more com·
`ponents are link:ed in series. All the current passes
`through each component in a series circuit. but the
`voltage is divided among the components. See the
`illustration. Compar~ parallel circuit.
`
`S~ries circuiL
`serif' adj. Marked by the use of serifs. For example.
`Goudy is a serif typeface, whereas Helvetica is a sans
`serif typeface. See the illustration. See also scriP.
`Compore sans serif.
`serif l n. Any of the short lines or ornaments at the
`ends of the strokes that form a typeface character.
`server n. 1. On a local area network (LAN), a com(cid:173)
`puter running administrative software that contrOls
`access to the network and its resources, such as
`printen and disk drives, and provides resources to
`
`403
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`

`Case 2:07-cv-00271-CE Document 235-1 Filed 09/13/10 Page 6 of 8
`
`rver-based application
`
`s
`
`let
`
`ABCV
`ABC
`
`serifs
`
`Sui/. A. suift]fWf~~ (top) lUUl II StlIU s~rif~fWfac~
`(bott(}m).
`computcn functioning as workstations on the netwtrl.
`2.. On the Intc:met or other netWork, a computer or
`program that responds to commands from a client. For"
`Q.ample. a file server may contain an archive of data
`or program files; when a client submits a request for a
`file. the server transfers a copy of the file to the client.
`Su also client/server architeeture. Compare client
`(definition 3).
`server-based application n. A program that is shared
`over a network. The program is stored on the nel(cid:173)
`work server and can be used at more than one client
`machine at a time.
`server cluster n. A group of independent compulers
`that work together as a single system. A server cluster
`presents the appearance of a single server 10 a client.
`server eIT'Or n. A failure to complete a request for in-
`formation through HITP that results from an error at
`the server rather than an error by the clieDt or the Uscf.
`Server errors are indicated by HTI'P status codes be(cid:173)
`ginning with 5. See also HTI'P, HTTP status codes.
`serverlet n. See servLet.
`server push-puU n. A combination of Web client!
`server techniques individually caUed "server push"
`and "client pull." In server push, the server loads data
`to the client, but the data connection stays open. This
`allows the server to continue sending data to the
`browser as necessary. In client pull, the server loads
`data 10 the client. but the data connection does. not
`stay open. The server sends an HTML directive to
`the browser telling it to reopen the connection after a
`certain interval to get more data or possibly 10 open a
`new URL. Sec the illustration. See also HTML,
`server (definition 2), URL.
`servcr-side include n. A mechanism for including
`dynamic text in World Wide Web documents. Server(cid:173)
`side includes are special command codes that are
`recognized and interpreted by the server; their output
`
`is placed in thc document body before the docuIPCnt
`is sent to the browser. Server-side includes can be
`used. for Q.ample. to include the dateJtime stamp in
`the text of the file. Acronym: SSt. S~c alsa server
`(definition 2).
`servia n. 1. A customer-based or user-orienled func(cid:173)
`tion. such as lechnical support or network provisioo.
`2.. In reference to programming and software, a pr0(cid:173)
`gram or routine that provides support to otheT pr0(cid:173)
`grams, particularly at a low (close to the hardware)
`level. 3. In networking. specialized. software-based
`functionality provided by network servers-for ex(cid:173)
`ample. directory services that provide the network
`equivalent of "phone books" ocedcd for locating us(cid:173)
`ers and resources. Su also utility.
`Service Advertising Protocol n. A method used by a
`service-providing node in a netWork (such as a file
`server or application server) to notify other nodes 00
`the pctwork that it is available for access. When a
`server boots, it uses the protocol to advertise its SCf(cid:173)
`vice:; when the same server goes offline. it uses tbc
`protocol to announce that it is no longer available.
`Acronym: SAP. See also server (definition I).
`service bureau n. 1. A company thaI provides vari-
`ous services related to publishing. such as prepress
`production, desklop publishing, typesetting. image(cid:173)
`setting, and optical scanning or graphics. 2. An or(cid:173)
`ganization that provides data processing services
`and access to software packages for a fcc.
`
`service provider n. See ISP.
`servlet or servelet n. A small Java program that runs
`on a server. The lenn is a companion to applel, a lava
`program that usually runs on the clienl. Serviets pcr(cid:173)
`fann lightweight Web services. such as redirecting a
`Web user from an outdated address to the correct
`page.tasks traditionally handled by eGi (Common
`Gateway Interface) applications. Because servlets are
`automatically threaded and highly responsive. they
`execute quiekly. thereby reducing system overhead.
`Also called serverlel. Sec also applet. Cal.
`
`Server push
`
`Client pull
`
`SerwT push-puLL
`
`404
`
`

`

`Case 2:07-cv-00271-CE Document 235-1 Filed 09/13/10 Page 7 of 8
`
`we
`
`Web site
`
`wristwatch but which, unlike those items, is interac(cid:173)
`tive, responds to commands, and carries out instruc(cid:173)
`tions. A wearable compuler may be used like a
`conventional computer for data collection, storage,
`and retrieval, but without lying the user 10 a station(cid:173)
`ary location while operating the computer. The earli(cid:173)
`est wearable computers were clandestine devices
`used in the mid-1960s to predict the performance of
`roulette wheels. Today, wearable computers are used
`for such applications as inventory and express pack(cid:173)
`age tracking.
`web n. A set of interlinked documents in a hypertext
`system. The user enters the web through a home
`page. See also World Wide Web.
`
`Web n. See World Wide Web.
`Web address n. See URL.
`Web author n. A person who creates content for the
`World Wide Web. A Web author might be a writer
`who produces texl for a designer to include in a Web
`page, or such an author might be a Web designer who
`writes the tel't and also adds graphic elements and
`prepares the HTML code.
`Web-Based Enterprise Management n. See WBEM.
`Web browser n. Software that lets a user view HTML
`documents and access files and software related to
`those documents. Originally developed to allow users
`to view or "browse" documents on the World Wide
`Web, Web browsers can blur the distinction between
`local and remote resources for the user by also pro(cid:173)
`viding access to documents on a network, an intranet,
`or the local hard drive. Web browser software is built
`on the concept of hyperlinks, which allow users to
`point and click with a mouse in order to jump from
`document to documcnt in whatever order they desire.
`Most Web browsers are also capable of downloading
`and transferring files, providing access to news(cid:173)
`groups, displaying graphics embedded in the docu(cid:173)
`ment, playing audio and video files associated with
`the document, and executing small programs, such as
`Iava applets or ActiveX controls included by pro(cid:173)
`grammers in the documents. Helper applications or
`plug-ins are required by some Web browsers 10 ac(cid:173)
`complish one or more of these tasks. Also called
`browser. See also ActiveX control, helper applica(cid:173)
`tion, hyperlink, Internet Explorer, Java applet, Lynx,
`Mosaic, Netscape Navigator, plug-in.
`webcastiog n. Popular term for b~oadcasting informa(cid:173)
`tion via the World Wide Web, using push and pull
`
`technologies to move selected information from a
`server to a client. An emergent technology in 1997,
`webcasting was developed to provide users with cus(cid:173)
`tomized content-for example, spons, news, stocks,
`and weather-that can be updated both regularly and
`automatically. Webcasting gives users the ability to
`specify the type of content they want to see, and it
`gives content providers a means of delivering such
`information directly to the user's desktop. See also
`pull, push (definition 2).
`
`WebCrawler n. A World Wide Web search engine
`operated by America Online. See also search engine.
`Web development n. The design and coding of World
`Wide Web pages.
`Web directory n. A list of Web sites, giving the URL
`and a description of each. See also URL.
`Web index n. A Web site intended to enable a user to
`locate other resources on the Web. The Web index
`may include a search facility or may merely contain
`individual hyperlinks to the resoUl'Ces indexed.
`Webmaster or webmaster n. A person responsible
`for creating and maintaining a World Wide Web site.
`A Webmaster is often responsible for responding to
`e-mail, ensuring the site is operating properly, creat(cid:173)
`ing and updating Web pages, and maintaining the
`overall structure and design of the site. Also called
`webmistress, webweaver.
`webmistress n. See webmaster.
`Web page n. A document on the World Wide Web. A
`Web page consists of an HTML file, with associated
`files for graphics and scripts, in a particular directory
`on a panicular machine (and thus identifiable by a
`URL). Usually a Web page contains links to other
`Web pages. See also URL.
`Web phone n. See Internet telephone.
`
`Web rage n. 1. Anger or frustration related to the use
`or operation of the Internet. 2. An intemperate, rude,
`or angry posting on the Internet; a flame. 3. The lat(cid:173)
`est fad to gain popularity among Web users.
`Web server n. See HTIP server.
`Web site II. A group of related HTML documents and
`associated files, scripts, and databases that is served
`up by an HTIP server on the World Wide Web. The
`HTML documents in a Web site generally cover one
`or more related topics and are interconnected through
`hyperlinks. Most Web sites have a home page as their
`starting point, which frequently functions as a table
`
`479
`
`

`

`Case 2:07-cv-00271-CE Document 235-1 Filed 09/13/10 Page 8 of 8
`r:W;;O;;'"k';;h;;e;;e"I----==::'-':=::====::=::~'::_::~-----"":'--"';w~riiS,,,tSUPPOrt
`
`II,
`
`worksheet II. In a spreadsheet program. a page orga(cid:173)
`nized inlo rows and columns appearing 00 screeD and
`used for constructing a single lable.
`workstation II. 1. A combination of input. output. and
`computing hardware that can be used (Of wort by an
`individual. 2. A povo·crful stand-alonc compUler of
`the son used in computer-aided design and other ap(cid:173)
`plications requiring a high-end. usually expensive,
`machine with considerable calculating or graphics
`capability. 3. A microcomputer or terminal conneded
`to a nelwork.
`Wodd Wide Web II. The lotal sct of interlinked
`hypertext documents residing on H1TP servers all
`around the world. Documents on the World Wide
`Web, called pages or Web pages, are written in
`HTML (Hypertext Markup Language), identified by
`URLs (Uniform Resource Locators) lhat specify the
`particular machine and pathname by which a file can
`be accessed, and transmitted from server 10 end user
`under HTrP (Hypertext Transfer Protocol). Codes,
`called tags, embedded in an HTML document associ(cid:173)
`ate particular words and images in the document with
`URLs so that a user- can access another file, whi(:h
`may be halfway around the world, at the press of a
`key or the (:li(:k of a mouse. These fLics may oontain
`text (in a variety of fonts and styles), graphics im(cid:173)
`ages, movie files. and sounds as well as Java applets,
`AaiveX oontroLs. Of other- small embedded software
`programs that execule when the user activates them
`by eliciting on a link.. A user visiting a Web page: also
`may be able to download files from an FTP site and
`send messages to other users via e-mail by using
`links on the Web page. The World Wide Web was
`developed by Timothy Bemers-Lee in 1989 for the
`European Laboratory for Paniele Physics (CERN).
`Acronym: WWW. Also called WI, W3, Web. See also
`ActiveX controls, HTML, HTTP, HTIP server (defi(cid:173)
`nition 2), Java applet, URL.
`World Wide Web Con.'lOrtium n. See W3C.
`worm n. A program that propagates itself across com(cid:173)
`puters, usually by (:feating copies of itself in each
`computer's memory. A worm might duplicate itself
`in one oomputcr so often lhat it causes the computer
`to crasb. Sometimes written in separate segments, a
`worm is introduced suneptitiously into a host system
`either as a prank or with the intent of damaging or
`destroying information. See also bacterium, lnteme:1
`Worm, Trojan horse, virus.
`
`WORM \w~rm\ n. Acronym for write once, read
`many. A type of optical disc that can be read and
`reread but cannot be altered after it has been reo
`corded. WORMs are high-capacily storage devices.
`Because