Case 6:12-cv-00932-JDL Document 1 Filed 12/11/12 Page 1 of 9 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF TEXAS
`
`TYLER DIVISION
`
`LANDMARK TECHNOLOGY, LLC,
`
`CASE NO. 6:12-cv-932
`
`Plaintiff,
`
`v.
`
`BURBERRY LIMITED,
`
`Defendant.
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Landmark Technology, LLC ("Landmark"), for its Complaint against
`
`Burberry Limited ("Defendant"), alleges as follows:
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`JURISDICTION AND VENUE
`
`1.
`
`This is an action for patent infringement in violation of the Patent Act of the
`
`United States, 35 U.S.C. §§ 1 et seq.
`
`2.
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`This Court has original and exclusive subject matter jurisdiction over the patent
`
`infringement claims for relief under 28 U.S.C. §§ 1331 and 1338(a).
`
`3.
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`This Court has personal jurisdiction over Defendant because Defendant has
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`transacted and is transacting business in the Eastern District of Texas that includes, but is not
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`limited to, the use of products and systems that practice the subject matter claimed in the patents
`
`involved in this action.
`
`4.
`
`Venue is proper in this district under 28 U.S.C. §1391(b-c) and 1400(b) because a
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`substantial part of the events or omissions giving rise to the claims occurred in this District
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 1
`
`

`

`Case 6:12-cv-00932-JDL Document 1 Filed 12/11/12 Page 2 of 9 PageID #: 2
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`where Defendant has done business and committed infringing acts and continues to do business
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`and to commit infringing acts.
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`PARTIES
`
`5.
`
`Plaintiff Landmark Technology, LLC ("Plaintiff") is a limited liability company
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`organized under the laws of the State of Delaware with its principal place of business at 719 W.
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`Front Street, Suite 157, Tyler, Texas 75702.
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`6.
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`Plaintiff is informed and believes, and on that basis alleges, that Defendant
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`Burberry Limited ("Burberry"), is a subsidiary of Burberry Group PLC and is a corporation
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`organized under the laws of the State of New York, with its principal place of business at 444
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`Madison Ave. Floor 14, New York, New York, 10022. Plaintiff is further informed and
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`believes, and on that basis alleges, that Burberry is in the business of selling men's and women's
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`apparel and accessories, and derives a significant portion of its revenue from sales and
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`distribution via Internet-based electronic commerce conducted on and using at least, but not
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`limited to, the Internet website located at http://us.burberry.com/store/ (the "Website"). Plaintiff is
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`informed and believes, and on that basis alleges, that, at all times relevant hereto, Burberry has
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`done and continues to do business in this judicial district, including, but not limited to, by selling
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`products to customers located in this judicial district by way of the Burberry Website.
`
`FACTS
`
`7.
`
`On November 19, 1996, United States Patent No. 5,576,951 entitled "Automated
`
`Sales and Services System" was duly and legally issued to Lawrence B. Lockwood
`
`("Lockwood") as inventor. A true and correct copy of United States Patent No. 5,576,951 is
`
`attached hereto as Exhibit "A" and incorporated herein by this reference. Following a
`
`reexamination of Patent No. 5,576,951, the United States Patent and Trademark Office issued an
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`Ex Parte Reexamination Certificate, Number US 5,576,951 C1, on January 29, 2008, confirming
`
`the validity of all ten (10) original claims and allowing twenty-two (22) additional claims. A true
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`and correct copy of Ex Parte Reexamination Certificate, Number US 5,576,951 C1 is attached
`
`hereto as Exhibit "B" and incorporated herein by this reference. (United States Patent No.
`
`- 2 -
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 2
`
`

`

`Case 6:12-cv-00932-JDL Document 1 Filed 12/11/12 Page 3 of 9 PageID #: 3
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`5,576,951, together with the additional claims allowed by Ex Parte Reexamination Certificate,
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`Number US 5,576,951 C1, shall hereinafter be referred to as the "'951 Patent.") On September 1,
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`2008, Lockwood licensed all rights in the '951 Patent to Plaintiff. Plaintiff is the exclusive
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`licensee of the entire right, title and interest in and to the '951 Patent, including all rights to
`
`enforce the '951 Patent and to recover for infringement. The '951 Patent is valid and in force.
`
`8.
`
`On March 7, 2006, United States Patent No. 7,010,508 entitled "Automated
`
`Multimedia Data Processing Network" (the "'508 Patent") was duly and legally issued to
`
`Lawrence B. Lockwood as inventor. A true and correct copy of the '508 Patent is attached hereto
`
`as Exhibit "C" and incorporated herein by this reference. On September 1, 2008, Lockwood
`
`licensed all rights in the '508 Patent to Plaintiff. Plaintiff is the exclusive licensee of the entire
`
`right, title and interest in and to the '508 Patent, including all rights to enforce the '508 Patent and
`
`to recover for infringement. The '508 Patent is valid and in force.
`
`9.
`
`On or about August 28, 2012, Plaintiff sent Defendant a letter informing
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`Defendant of the '951 Patent and the '508 Patent and that Defendant's actions, as more fully
`
`described below, constituted infringement of the '951 Patent and the '508 Patent.
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`10.
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`As more fully laid out below, Defendant has been and is now infringing the '951
`
`Patent and the '508 Patent, in this judicial district and elsewhere, by selling and distributing its
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`products and services using electronic commerce systems, which, individually or in combination,
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`incorporate and/or use subject matter claimed by the '951 Patent and the '508 Patent.
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`FIRST CLAIM FOR RELIEF
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`(Direct Infringement of the '951 Patent, in Violation of 35 U.S.C. § 271(a))
`
`11.
`
`12.
`
`Plaintiff refers to and incorporates herein by reference paragraphs 1-9.
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`The claims of the '951 Patent relate to "a computer search system for retrieving
`
`information" and "a computerized system for selecting and ordering a variety of information,
`
`goods and services," each comprising a variety of features.
`
`- 3 -
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 3
`
`

`

`Case 6:12-cv-00932-JDL Document 1 Filed 12/11/12 Page 4 of 9 PageID #: 4
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`13.
`
`The Burberry Website is a "computer search system[s] for retrieving information"
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`and "computerized system[s] for selecting and ordering a variety of information, goods and
`
`services" practicing the claims of the '951 Patent.
`
`14.
`
`By way of example only, and not limited to it, Defendant's Website infringes
`
`Claim 10 of the '951 Patent in that, for example, the Defendant's Website provides a system that
`
`practices all of the limitations of the claim and on which it's customers search for information
`
`about products and purchase products, including:
`
`a.
`
`The Website is a computerized system for selecting and ordering a
`
`variety of information, goods and services.
`
`b.
`
`The Website includes a plurality of computerized data processing
`
`installations (the web server and its supporting systems) programmed for processing orders for
`
`said information, goods and services.
`
`c.
`
`The Website is operated through at least one computerized station
`
`(the customer's computer).
`
`d.
`
`The web server of the Website and that Defendant's customers'
`
`computers practice all of the remaining limitations of Claim 10 of the '951 Patent.
`
`15.
`
`Defendant, therefore, by the acts complained of herein, is making, using, selling,
`
`or offering for sale in the United States, including in the Eastern District of Texas, products
`
`and/or services embodying the invention, and has in the past and is now continuing to infringe
`
`the '951 Patent, either literally or under the doctrine of equivalents, in violation of 35 U.S.C. §
`
`271(a).
`
`16.
`
`Defendant threatens to continue to engage in the acts complained of herein and,
`
`unless restrained and enjoined, will continue to do so, all to Plaintiff's irreparable injury. It
`
`would be difficult to ascertain the amount of compensation that would afford Plaintiff adequate
`
`relief for such future and continuing acts, and a multiplicity of judicial proceedings would be
`
`required. Plaintiff does not have an adequate remedy at law to compensate it for the injuries
`
`threatened.
`
`- 4 -
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 4
`
`

`

`Case 6:12-cv-00932-JDL Document 1 Filed 12/11/12 Page 5 of 9 PageID #: 5
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`17.
`
`By reason of the acts of Defendant alleged herein, Plaintiff has suffered damage
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`in an amount to be proved at trial.
`
`18.
`
`Plaintiff is informed and believes, and on that basis alleges, that the infringement
`
`by Defendant is willful, wanton, and deliberate, without license and with full knowledge of the
`
`'951 Patent, thereby making this an exceptional case entitling Plaintiff to attorneys' fees and
`
`enhanced damages.
`
`SECOND CLAIM FOR RELIEF
`
`(Inducing Infringement of the '951 Patent, in Violation of 35 U.S.C. § 271(b))
`
`19.
`
`20.
`
`Plaintiff refers to and incorporates herein by reference paragraphs 1-12.
`
`Plaintiff is informed and believes, and on that basis alleges, that Defendant has
`
`actively and knowingly induced infringement of the '951 Patent, in violation of 35 U.S.C. §
`
`271(b) by, among other things, inducing its customers (the endusers of its Website) to utilize
`
`their own computers in combination with its Website, and incorporated and/or related systems, to
`
`search for and order information and products from its Website in such a way as to infringe the
`
`'951 Patent.
`
`21.
`
`By reason of the acts of Defendant alleged herein, Plaintiff has suffered damage
`
`in an amount to be proved at trial.
`
`22.
`
`Defendant threatens to continue to engage in the acts complained of herein and,
`
`unless restrained and enjoined, will continue to do so, all to Plaintiff's irreparable injury.
`
`Plaintiff does not have an adequate remedy at law.
`
`23.
`
`Plaintiff is informed and believes, and on that basis alleges, that the infringement
`
`by Defendant is willful, wanton, and deliberate, without license and with full knowledge of the
`
`'951 Patent, thereby making this an exceptional case entitling Plaintiff to attorneys' fees and
`
`enhanced damages.
`
`THIRD CLAIM FOR RELIEF
`
`(Direct Infringement of the '508 Patent, in Violation of 35 U.S.C. § 271(a))
`
`24.
`
`Plaintiff refers to and incorporates herein by reference paragraphs 1-9.
`
`- 5 -
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 5
`
`

`

`Case 6:12-cv-00932-JDL Document 1 Filed 12/11/12 Page 6 of 9 PageID #: 6
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`25.
`
`The claims of the '508 Patent relate to "an automated multimedia system for data
`
`processing for delivering information on request to at least one user," comprising a variety of
`
`features.
`
`26.
`
`The Burberry Website is "an automated multimedia system for data processing for
`
`delivering information on request to at least one user," practicing the claims of the '508 Patent.
`
`27.
`
`By way of example, only, and not limited to it, Defendant's Website infringes
`
`Claim 8 of the '508 Patent in that, for example, Defendant's Website provides a system that
`
`practices all of the limitations of the claim and on which it's customers search for information
`
`about products, including:
`
`a.
`
`The Website is an automated multimedia system for data
`
`processing for delivering information on request to at least one user. That is, it uses text and
`
`graphics, among other means, to deliver product information and other information to
`
`Defendant's customers.
`
`b.
`
`The Website includes at least one computerized station (the server
`
`and its supporting systems).
`
`c.
`
`The web server(s) of the Website practice all of the remaining
`
`limitations of Claim 8 of the '508 Patent.
`
`28.
`
`Defendant, therefore, by the acts complained of herein, is making, using, selling,
`
`or offering for sale in the United States, including in the Eastern District of Texas, products
`
`and/or services embodying the invention, and has in the past and is now continuing to infringe
`
`the '508 Patent, either literally or under the doctrine of equivalents, in violation of 35 U.S.C. §
`
`271(a).
`
`29.
`
`Defendant threatens to continue to engage in the acts complained of herein and,
`
`unless restrained and enjoined, will continue to do so, all to Plaintiff's irreparable injury. It
`
`would be difficult to ascertain the amount of compensation that would afford Plaintiff adequate
`
`relief for such future and continuing acts, and a multiplicity of judicial proceedings would be
`
`- 6 -
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 6
`
`

`

`Case 6:12-cv-00932-JDL Document 1 Filed 12/11/12 Page 7 of 9 PageID #: 7
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`required. Plaintiff does not have an adequate remedy at law to compensate it for the injuries
`
`threatened.
`
`30.
`
`By reason of the acts of Defendant alleged herein, Plaintiff has suffered damage
`
`in an amount to be proved at trial.
`
`31.
`
`Plaintiff is informed and believes, and on that basis alleges, that the infringement
`
`by Defendant is willful, wanton, and deliberate, without license and with full knowledge of the
`
`'508 Patent, thereby making this an exceptional case entitling Plaintiff to attorneys' fees and
`
`enhanced damages.
`
`FOURTH CLAIM FOR RELIEF
`
`(Inducing Infringement of the '508 Patent, in Violation of 35 U.S.C. § 271(b))
`
`32.
`
`33.
`
`Plaintiff refers to and incorporates herein by reference paragraphs 1-9, 23-25.
`
`Plaintiff is informed and believes, and on that basis alleges, that Defendant has
`
`actively and knowingly induced infringement of the '508 Patent, in violation of 35 U.S.C. §
`
`271(b) by, among other things, inducing its customers (the endusers of its Website) to utilize
`
`their own computers in combination with its Website, and incorporated and/or related systems, to
`
`search for and order information and products from its Website in such a way as to infringe the
`
`'508 Patent.
`
`34.
`
`By reason of the acts of Defendant alleged herein, Plaintiff has suffered damage
`
`in an amount to be proved at trial.
`
`35.
`
`Defendant threatens to continue to engage in the acts complained of herein and,
`
`unless restrained and enjoined, will continue to do so, all to Plaintiff's irreparable damage.
`
`Plaintiff does not have an adequate remedy at law.
`
`36.
`
`Plaintiff is informed and believes, and on that basis alleges, that the infringement
`
`by Defendant is willful, wanton, and deliberate, without license and with full knowledge of the
`
`'508 Patent, thereby making this an exceptional case entitling Plaintiff to attorneys' fees and
`
`enhanced damages.
`
`- 7 -
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 7
`
`

`

`Case 6:12-cv-00932-JDL Document 1 Filed 12/11/12 Page 8 of 9 PageID #: 8
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`JURY DEMAND
`
`Plaintiff demands a jury trial on all issues so triable.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff prays for relief as follows:
`
`A.
`
`B.
`
`C.
`
`For an order finding that the '951 Patent is valid and enforceable;
`
`For an order finding that the '508 Patent is valid and enforceable;
`
`For an order finding that, by the acts complained of herein, Defendant has directly
`
`infringed, and induced others to infringe, the '951 Patent in violation of 35 U.S.C. § 271;
`
`D.
`
`For an order finding that, by the acts complained of herein, Defendant has directly
`
`infringed, and induced others to infringe, the '508 Patent in violation of 35 U.S.C. § 271;
`
`E.
`
`For an order finding that Defendant has willfully infringed the ‘951 Patent and the
`
`‘508 Patent;
`
`F.
`
`For an order temporarily, preliminarily and permanently enjoining Defendant, its
`
`officers, directors, agents, servants, affiliates, employees, subsidiaries, divisions, branches,
`
`parents, attorneys, representatives, and all others acting in concert or privity with any of them,
`
`from infringing the '951 Patent, and from inducing others to infringe the '951 Patent;
`
`G.
`
`For an order temporarily, preliminarily and permanently enjoining Defendant, its
`
`officers, directors, agents, servants, affiliates, employees, subsidiaries, divisions, branches,
`
`parents, attorneys, representatives, and all others acting in concert or privity with any of them,
`
`from infringing the '508 Patent, and from inducing others to infringe the '508 Patent;
`
`H.
`
`For an order directing Defendant to deliver to Plaintiff for destruction or other
`
`disposition all infringing products and systems in its possession;
`
`I.
`
`For an order directing Defendant to file with the Court, and serve upon Plaintiff's
`
`counsel, within thirty (30) days after entry of the order of injunction, a report setting forth the
`
`manner and form in which Defendant has complied with the injunction;
`
`J.
`
`For an order awarding Plaintiff general and/or specific damages, including a
`
`reasonable royalty and/or lost profits, in amounts to be fixed by the Court in accordance with
`
`- 8 -
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 8
`
`

`

`Case 6:12-cv-00932-JDL Document 1 Filed 12/11/12 Page 9 of 9 PageID #: 9
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`proof, including enhanced and/or exemplary damages, as appropriate, as well as all of
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`Defendant's profits or gains of any kind from its acts of patent infringement;
`
`K.
`
`For an order awarding enhanced damages pursuant to 35 U.S.C. § 284 due to the
`
`willful and wanton nature of Defendant's infringement;
`
`L.
`
`For an order awarding Plaintiff all of its costs, including its attorneys' fees,
`
`incurred in prosecuting this action, including, without limitation, pursuant to 35 U.S.C. § 285 and
`
`other applicable law;
`
`M.
`
`N.
`
`For an order awarding Plaintiff pre-judgment and post-judgment interest; and
`
`For an order awarding Plaintiff such other and further relief as the Court may
`
`deem just and proper.
`
`DATED: December 11, 2012
`
`Respectfully Submitted,
`
`OF COUNSEL:
`
`By: /s/ Charles Ainsworth
`
`Jeffer Mangels Butler & Mitchell LLP
`
`Stanley M. Gibson
`(Cal. Bar No. 162329)
`smg@jmbm.com
`
`Gregory S. Cordrey
`(Cal. Bar No. 190144)
`gxc@jmbm.com
`
`1900 Avenue of the Stars, Seventh Floor
`Los Angeles, CA 90067
`Telephone: (310) 203-8080
`Facsimile: (310) 203-0567
`
`Charles Ainsworth
`State Bar No. 00783521
`Robert Christopher Bunt
`State Bar No. 00787165
`PARKER, BUNT & AINSWORTH, P.C.
`100 E. Ferguson, Suite 1114
`Tyler, TX 75702
`903/531-3535
`903/533-9687
`E-mail: charley@pbatyler.com
`E-mail: rcbunt@pbatyler.com
`
`Attorneys for Plaintiff,
`Landmark Technology, LLC
`
`- 9 -
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 9
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 1 of 37 PageID #: 10
`
`EXHIBIT “A”
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 10
`
`

`

`11111 11111111 III 11111111111111111111 11111 1101 11111 11111 111111111111111111
`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 2 of 37 PageID #: 11
`
`US005576951A
`
`United States Patent [19]
`Lockwood
`
`[11] Patent Number:
`
`5,576,951
`
`[45] Date of Patent:
`
`Nov. 19, 1996
`
`[54] AUTOMATED SALES AND SERVICES
`SYSTEM
`
`[76] Inventor: Lawrence B. Lockwood, 5935 Folsom
`Dr., La Jolla, Calif. 92037
`
`[21] Appl. No.: 210,301
`
`[22] Filed:
`
`Mar. 16, 1994
`
`Related U.S. Application Data
`
`[63] Continuation of Ser. No. 116,654, Sep. 3, 1993, Pat. No.
`5,309,355, and Ser. No. 96,610, Jul. 23, 1993, abandoned,
`and a continuation-in-part of Ser. No. 116,654, and Ser. No.
`96,610, which is a continuation of Ser. No. 752,026, Aug.
`29, 1991, abandoned, which is a continuation of Ser. No.
`168,856, Mar. 16, 1988, abandoned, which is a continuation
`of Ser. No. 822,115, Jan. 24, 1986, abandoned, which is a
`continuation-in-part of Ser. No. 613,525, May 24, 1984, Pat.
`No. 4,567,359, said Ser. No. 116,654, is a continuation of
`Ser. No. 396,283, Aug. 21, 1989, abandoned, which is a
`continuation-in-part of Ser. No. 152,973, Feb. 8, 1988,
`abandoned, which is a continuation-in-part of Ser. No.
`822,115.
`[51] Int. CI.6 ............................................... GO6F 19/00
`[52] U.S. Cl. ................................... 395/227; 235/381
`[58] Field of Search ............................. 364/401, 407;
`235/383, 385, 381; 395/600, 650
`
`[56]
`
`References Cited
`
`U.S. PATENT DOCUMENTS
`
`Re. 32,115
`3,718,906
`3,956,615
`4,300,040
`4,359,631
`4,438,326
`4,449,186
`4,567,359
`
`4/1986- Lockwood et al. .................... 235/381
`2/1973 Lightner .
`5/1976 Anderson et al. .
`11/1981 Gould et al. ........................... 235/381
`11/1982 Lockwood et al. .................... 235/381
`3/1984 Uchida ................................... 235/379
`5/1984 Kelly et al. ............................ 364/407
`1/1986 Lockwood ............................. 235/381
`
`4,648,037
`4,650,977
`5,241,671
`5,309,355
`
`3/1987 Valentino ............................... 364/408
`3/1987 Couch .................................... 235/379
`8/1993 Reed et al. ............................. 395/600
`5/1994 Lockwood ............................. 364/401
`
`Primary Examiner—Donald E. McElheny, Jr.
`A ttorney, A gent, or Finn—Henri J. A. Charmasson; John D.
`Buchaca
`
`[57]
`
`ABSTRACT
`
`A system for composing individualized sales presentations
`created from various textual and graphical information data
`sources to match customer profiles. The information search
`and retrieval paths sift through a hierarchy of data sources
`under multiple operating programs. The system provides the
`means for synergistically creating and displaying custom-
`ized presentations in a convenient manner for both the
`customer and salesperson to achieve a more accurate, effi-
`cient and comprehensive marketing presentation. Organiza-
`tional hierarchies of data sources are arranged so that an
`infinite number of sales presentation configurations can be
`created. Multiple micro-programs automatically compose
`the sales presentations initiated by determinants derived
`from customer profile information, sales agent assessment
`data and operator's entries including the retrieval of inter-
`related textual and graphical information from local and
`remote storage sources. A similar system can be used for
`filing applications with an institution from a plurality of
`remote sites, and for automatically processing applications
`in response to each applicant's qualifications. Each multi-
`media terminal comprises a video screen and a video
`memory which holds co-related image-and-sound-generat-
`ing information arranged to simulate the aspect and speech
`of an application loan officer on the video screen. The
`simulated loan officer is used to acquire personal loan data
`from the applicant by guiding him through an interactive
`sequence of inquiries and answers.
`
`10 Claims, 17 Drawing Sheets
`
`4
`
`4
`
`4
`,1
`
`Aldine
`Company
`Computer
`
`Hotel
`Network
`Computer
`
`Quin
`Ur*
`Computer
`
`Car Rental
`
`Computer
`
`Tour
`Company
`Computer
`
`Computerized Reservation System
`
`1
`
`Microprocessor
`
`,
`
`9
`
`14 J
`
`Printer
`
`0 CRT
`
`8
`
`Optical
`Memory
`Card Reader
`
`1 2
`
`ro
`
`—13
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 11
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 3 of 37 PageID #: 12
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 1 of 17
`
`5,576,951
`
`4
`
`Airline
`Company
`Computer
`
`Hotel
`Network
`Computer
`
`Cruise
`Line
`Computer
`
`Car Rental
`-y
`Computer
`
`Tour
`Company
`Computer
`
`4
`
`•
`Computerized Reservation System
`
`Data
`Sources
`
`44--^
`
`\ 9 14 J t
`
`V
`Microprocessor
`
`Printer
`
`CRT•
`
`Optical
`Memory
`Card Reader
`
`12
`
`Keyboard
`
`Figure 1
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 12
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 4 of 37 PageID #: 13
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 2 of 17
`
`5,576,951
`
`•
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 13
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 5 of 37 PageID #: 14
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 3 of 17
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`GSI Commerce Solutions, Inc. Exhibit 1010 Page 14
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 6 of 37 PageID #: 15
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 4 of 17
`
`5,576,951
`
`12
`
`Optical
`Memory
`Card Reader
`
`Opemtor
`(—Entries
`
`13
`
`Destination;
`Dates;
`Type;
`Customer%
`Profile;
`
`Sequencer
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`17
`hi Microprocessor
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`Registers
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`Codes
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`pi CRT
`
`19
`
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`Reservation Information
`
`Figure 4
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 15
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 7 of 37 PageID #: 16
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 5 of 17
`
`5,576,951
`
`Read
`Determinants
`
`Begin Display
`
`Select
`Inquiry
`Data
`(Second Segments)
`
`Select and Display
`First and Third
`Segments
`
`Transmit
`Inquiry To
`Reservation
`System
`
`Store
`Reservation
`System
`Answers
`
`Figure 5
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 16
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 8 of 37 PageID #: 17
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 6 of 17
`
`5,576,951
`
`MEMORY
`CARD
`
`t46
`
`49
`
`51
`
`LOCAL
`
`Client Chapter
`Profile
`25/41
`26A/41
`26N43
`
`5500
`8800
`9700
`
`Client Chapter
`Profile
`25/41
`26N41
`26N43
`
`5500
`8800
`9700
`
`45
`
`START
`
`TRAVEL
`AGENT
`4 47
`
`CRS
`
`448
`
`REMOTE
`
`50
`
`Client Chapter
`Profile
`25/41
`26N41
`26A/43
`
`5500
`8800
`9700
`
`/53
`
`Client
`Profile
`31/43
`
`( 55
`
`Client
`Profile
`31/43
`33N43
`33B/43
`
`52
`
`Client
`Profile
`31/43
`
`Client Chapter
`Profile
`25/41
`5500
`26N41 8800
`26A/43 9700
`
`V 54
`Client -)
`Profile
`31/43
`33N43 4
`33B/43
`
`Figure 6
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 17
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 9 of 37 PageID #: 18
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 7 of 17
`
`5,576,951
`
`CO
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`GSI Commerce Solutions, Inc. Exhibit 1010 Page 18
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 10 of 37 PageID #: 19
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 8 of 17
`
`5,576,951
`
`X 118
`
`VIDEO
`SCREEN
`
`X-119
`
`TOUCH PAD
`
`121
`
`120
`
`X
`
`V
`
`x-113
`
`VOICE
`SYNTHESIZER
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`DATA
`PROCESSOR
`
`-122
`X
`
`STRIP
`READER
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`PRINTER
`
`V
`
`RAM
`MEMORY
`
`117
`
`Figure 8
`
`114
`
`115
`
`116
`
`MODEM
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 19
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 11 of 37 PageID #: 20
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 9 of 17
`
`5,576,951
`
`o> START
`
`24
`
`System
`Activated
`
`V
`Language
`Selection
`
`125
`
`,,126
`
`Y
`
`128
`
`129
`
`Invalid
`
`English
`Presentate
`
`Spanish
`Presentate
`
`130
`
`c431
`
`132
`
`Request
`Processed
`
`,133
`
`134
`
`Instruct
`
`,135 cD,
`
`Figure 9
`
`0
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 20
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 12 of 37 PageID #: 21
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 10 of 17
`
`5,576,951
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 21
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 13 of 37 PageID #: 22
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 11 of 17
`
`5,576,951
`
`CO
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`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 22
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 14 of 37 PageID #: 23
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 12 of 17
`
`5,576,951
`
`Retail Company
`
`Travel Company
`
`Financial Company
`
`Grocery Company
`
`204"'
`
`Retail
`Computer
`
`Travel
`Computer
`
`Financial
`Computer
`
`Grocery
`Computer
`
`209
`
`1
`
`Credit
`Information
`
`Telecom. Network
`Telecom.
`Computer
`
`--205
`
`CENTRAL DATA
`
`201
`PROCESSING CENTER ri
`
`209
`
`221
`
`Voice
`Response
`Synthesizer
`
`Central
`Processor
`
`Audio Visual
`Data Sources
`
`Transitory
`Data Sources
`
`Customer,
`Product,
`Account,
`Files
`
`MEMORY
`
`223+
`
`202
`ri
`Office
`Terminal
`
`Cable
`Television
`Company
`
`210
`
`im
`
`Ho
`e
`Terminal
`
`Terminal
`
`281
`
`202
`
`A
`Home
`Terminal
`
`Figure 12
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 23
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 15 of 37 PageID #: 24
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 13 of 17
`
`5,576,951
`
`Figure 13
`
`-START-
`Dial Remote
`Site
`
`224
`
`Log - On
`
`,, 225
`
`Voice
`Response
`Prompting
`
`226
`
`228
`ri
`Human
`Operator
`
`-›
`
`229
`c-1
`Final
`Greetings
`
`N
`
`->
`
`230
`
`-›
`
`Line
`Disconnect
`
`227
`
`232
`
`Invalid
`Selection
`
`Travel E
`
`Financial
`
`Grocery
`
`=_-
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 24
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 16 of 37 PageID #: 25
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 14 of 17
`
`5,576,951
`
`Figure 14
`
`Final
`Greetings-
`No Order
`
`240
`
`243
`
`244'
`
`245
`
`246
`
`247
`
`Purchase
`
`Select
`Items
`
`Total Items
`$ Amount
`Shipping Ins.
`
`Correct
`
`Payment
`Process
`Explained
`
`Account
`On File
`
`Means of
`Payment
`
`249''
`
`Order Conf.
`Final
`instructions
`
`250 '
`
`251 ' '
`
`Thanks
`1/
`Line
`
`Disconnect f<
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 25
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 17 of 37 PageID #: 26
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 15 of 17
`
`5,576,951
`
`co
`
`U)
`U)
`CV
`
`Nl
`
`0
`
`-->
`
`-›
`
`To g
`E 6
`
`U
`
`rn
`c
`c in
`
`o
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 26
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 18 of 37 PageID #: 27
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 16 of 17
`
`5,576,951
`
`Off-Line
`Processing
`
`E
`4'
`Daily
`Processing
`
`F
`
`Monthly
`Processing
`
`267
`
`G
`
`NI?
`Data
`Request
`Processing
`
`H
`
`270
`
`utility
`Programs
`
`--"•\
`
`272
`
`Sales
`Activity
`
`263
`
`Payment
`Verification
`
`268
`
`Sales
`Analysis
`
`271
`
`Payment
`Verification
`
`264
`
`Audit
`Trail
`4'
`Sales
`Data File
`
`265
`
`266
`
`Retail
`
`Travel
`
`NI/
`
`Financial
`
`NI/
`
`Grocery
`
`273
`
`Product
`Price File
`Maintenance
`Retail
`Travel
`Financial
`Grocery
`
`4,
`
`A
`
`Auto-Dial
`Comm. Net
`
`Auto
`Disconnect
`
`Transfer
`Data
`
`Product + Service
`Customer Activity
`Report Request
`+ Verification
`
`Figure 16
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 27
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 19 of 37 PageID #: 28
`
`U.S. Patent
`
`Nov. 19, 1996
`
`Sheet 17 of 17
`
`5,576,951
`
`Cable T.V. Networtr 281
`
`Telephone Network
`
`x 279
`Information
`Selector
`
`278
`
`Key Code <
`Register
`
`Signal Descrambler
`
`282
`
`280
`
`277
`
`Telephone
`
`275
`
`Figure 17
`
`GSI Commerce Solutions, Inc. Exhibit 1010 Page 28
`
`

`

`Case 6:12-cv-00932-JDL Document 1-1 Filed 12/11/12 Page 20 of 37 PageID #: 29
`
`5,576,951
`
`1
`AUTOMATED SALES AND SERVICES
`SYSTEM
`
`PRIOR APPLICATIONS
`
`This is a continuation-in-part of application Ser. No.
`08/116,654 filed Sep. 3, 1993, now U.S. Pat. No. 5,309,355
`which is a continuation of abandoned application Ser. No.
`07/396,283 filed Aug. 21, 1989, which is a continuation-in-
`part of abandoned application Ser. No. 07/152,973 filed Feb.
`8, 1988, which is a continuation-in-part of abandoned appli-
`cation Ser. No. 822,115 filed Jan. 24, 1986, which is a
`continuation-in-part of application Ser. No. 613,525 filed
`May 24, 1984, now U.S. Pat. No. 4,567,359.
`This is also a continuation-in-part of abandoned applica-
`tion Ser. No. 08/096,610 filed Jul. 23, 1993, which is a
`continuation of abandoned application Ser. No. 07/752,026
`filed Aug. 29, 1991 which is a continuation of abandoned
`application Ser. No. 168,856 filed Mar. 16, 1988, which is a
`continuation of abandoned application Ser. No. 822,115 filed
`Jan. 24, 1986 which is a continuation-in-part of application
`Ser. No. 613,525, filed May 24, 1984, now U.S. Pat. No.
`4,567,359.
`This is also a continuation of the combination of the
`above-cited applications Ser. No. 08/116,654 filed Sep. 3,
`1993 and Ser. No. 08/096,610 filed Jul. 23, 1993.
`
`BACKGROUND OF THE INVENTION
`
`This invention is directed to data processing systems
`designed to facilitate commercial, financial and educational
`transactions between multimedia terminals such as auto-
`mated sales workstations, information dispensing networks
`and self-service banking systems. Specifically this invention
`is directed to a tool for augmentation of sales and marketing
`capabilities of travel agency personnel in conjunction with
`computerized airline reservation systems. This invention
`also relates to financial service application processing, and
`interactive delivery of informative, educational and recre-
`ational audio-visual programs to the home, school or office.
`In the preferred embodiments of the invention, travel
`agents are able to synergistically compose individual cus-
`tomized sales presentations and itineraries for their clients,
`representing thousands of tour destinations and criteria,
`from multiple permutations