TS0022413-TS0022426
`
`Confidential
`
`Evidence of the existence of an inventive concept;
`
`101 ANALYSIS
`
`shows importance of products; shows products viewed
`by TS as technological in nature, rebuts position that
`
`trading screens are only aesthetics
`
`TS0024612-TS0024677
`
`Confidential
`
`Evidence of the existence of an inventive concept;
`
`shows importance of products; shows products viewed
`
`by TS as technological in nature, rebuts position that
`
`trading screens are only aesthetics
`
`TS0025391-TS0025423
`
`Confidential
`
`Forms/tickets/documents that show like-forms exist for
`
`TS0027984-TS0028053
`
`Confidential
`
`TS0028765-TS0028808
`
`Confidential
`
`Matrix, but were not produced
`
`Evidence of importance of products;
`forms/tickets/documents that show like-forms exist for
`
`Matrix, but were not produced
`Forms/tickets/documents that show like-forms exist for
`
`Matrix, but were not produced
`
`TS0033540-TS0033547
`
`Confidential
`
`Evidence of the existence of an inventive concept;
`
`TS0041856-TS0041886
`
`Confidential
`
`shows importance of products; shows products viewed
`
`by TS as technological in nature; rebuts position that
`
`trading screens are only aesthetics
`
`Evidence of importance of products;
`forms/tickets/documents that show like-forms exist for
`
`Matrix, but were not produced
`
`TS0083543-TS0083596
`
`Confidential
`
`Forms/tickets/documents that show like-forms exist for
`
`TS1234993-TS1234994
`
`HC-AEO
`
`Evidence of the existence of an inventive concept;
`
`Matrix, but were not produced
`
`TS1270483-TS1270504
`
`TS1533871-TS1533873
`
`shows importance of products; shows products viewed
`
`by TS as technological in nature; rebuts position that
`
`trading screens are only aesthetics
`
`Evidence of the existence of an inventive concept;
`
`shows importance of products; shows products viewed
`
`by TS as technological in nature; rebuts position that
`trading screens are only aesthetics
`
`Evidence of the existence of an inventive concept;
`
`shows importance of products; shows products viewed
`
`by TS as technological in nature; rebuts position that
`
`trading screens are only aesthetics
`
`|BG_00026004
`
`HC-AEO
`
`Shows benefits of claimed features; Trader interaction
`
`|BG_00014726
`
`HC-AEO
`
`Trader interaction with interface is the key, layout of
`
`with claimed features is key
`
` with claimed features is key
`Confidential
`Shows benefits ofclaimed features; Trader interaction
` windowsissecondary; rebutspositionthattrading
` productsviewed by IB astechnological in nature; rebuts
`
`|BG_00040515
`
`HC-AEO
`
`screens are only aesthetics
`
`Evidence of the existence of an inventive concept;
`
`Page 1 of 9
`
`TRADING TECH EXHIBIT 2155
`TRADESTATION v TRADING TECH
`
`CBM2015-00161
`
`

`
`position that trading screens are only aesthetics
`
`TSO005733-TSOOOS738
`
`Confidential
`
`Patent features are innovative/non-obvious: shows
`
`NON-OBVIOUSNESS ANALYSIS
`
`TSO107044-TS0107049
`
`TSO107054-TS0107075
`
`TS0107076-TS0107078
`
`development of claimed features well after Tl"s invention
`
`dates; Patent features are innovative/non-obvious: shows
`TS had conventional screens well after the patents issued
`
`Patent features are innovative/non-obvious: shows
`
`customer request/complaint originated from the claimed
`
`features (following MDTrader/TT), as opposed to GUI
`designers
`
`Evidence of mindset at time of development; Praises
`claimed features (unprecedented market feel, innovative,
`
`very different from traditional order entry windows);
`
`Describes advantages of Matrix window; direct evidence of
`
`copying 1T's MD Trader window
`
`Patent features are innovative/non-obvious: shows
`
`customer request/complaint originated the claimed
`
`features (following MDTrader/Tl’), as opposed to GUI
`designers
`
`mindset of conventional GUI tools
`
`TS1270483-TS1270504
`
`HC-AEO
`
` TradeStation development history ofconventional screens
`
`Patent features are innovative/non-obvious: Shows
`
`TS1525746-TS1525755
`
`HC-AEO
`
`Patent features are innovative/non-obvious: shows
`
`TS1526733-TS1526734
`
`development of claimed features well after Tl"s invention
`
`dates; Patent features are innovative/non-obvious: shows
`TS had conventional screens well after the patents issued;
`
`direct evidence of copying competitor products
`
`Patent features are innovative/non-obvious: praises
`claimed features with superlatives such as state-of-the-art
`
`order entry tool
`Commercial Success Demonstrates Non—0bviousness of the Invention
`
`TS1244558-TS1244561
`
`TS1261405-TS1261409
`
`TS1268720-TS1268720
`
`Page 2 of 9
`
`Commercial success: shows popularity of Matrix tool
`
`among TradeStation customers; shows significance of use
`
`of different trading GU|s (Matrix GU|'s importance/claimed
`feature's importance to TS)
`
`Commercial success: shows Matrix responsible for
`
`significant amount of TradeStation revenue; shows
`
`significance of use of different trading GU|s (Matrix GU|'s
`
`importance/claimed feature's importance to TS)
`
`Commercial success: shows popularity of Matrix tool
`
`among TradeStation customers; shows significance of use
`
`of different trading GU|s (Matrix GU|'s importance/claimed
`feature's importance to TS)
`
`

`
`TS1274603-TS1274625
`
`HC-AEO
`
`TS1533975-TS1533976
`
`TS1533977-TS1533980
`
`Commercial success: shows popularity of Matrix tool
`among TradeStation customers; shows significance of use
`
`of different trading GU|s (Matrix GU|'s importance/claimed
`feature's importance to TS)
`
`Commercial success: shows popularity of Matrix tool
`
`among TradeStation customers; shows significance of use
`
`of different trading GUls (Matrix GUl's importance/claimed
`feature's importance to TS)
`
`Commercial success: shows popularity of Matrix tool
`among TradeStation customers; shows significance of use
`
`of different trading GUls (Matrix GUl's importance/claimed
`feature's importance to TS)
`
`|BG_00017206
`
`HC-AEO
`
`Commercial Success: shows popularity of BookTrader as
`
`Widespread Copying Demonstrates Non-Obviousness
`
`top commission generating tool
`
`TS0005733-TS0005738
`
`Confidential
`
`Patent features are innovative/non-obvious: shows
`
`TS0047283-TS0047288
`
`Confidential
`
`Patent features are innovative/non-obvious: shows
`
`development of claimed features well after T1"s invention
`
`dates; Patent features are innovative/non-obvious: shows
`TS had conventional screens well after the patents issued
`
`TSO107054-TS0107075
`
`development of claimed features well after TT's invention
`dates
`
`Evidence of mindset at time of development; Praises
`
`claimed features (unprecedented market feel, innovative,
`
`very different from traditional order entry windows);
`
`Describes advantages of Matrix window; direct evidence of
`
`copying TT's MD Trader window
`
`TS1234823-TS1234823
`
`TS1263381-TS1263382
`
`HC-AEO
`
`HC-AEO
`
`Shows regular monitoring of news relating to Tl’
`
`Shows copying or regular monitoring of competitors w/
`
`claimed features, including Tl"
`
`TS1525666-TS1525666
`
`HC-AEO
`
`Patent features are innovative/non-obvious: Praise for
`
`Matrix; shows customer requests to implement claimed
`
`features or expand offerings with claimed features and
`
`customer feedback regarding claimed features
`
`Patent features are innovative/non-obvious: Praise for
`
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`
`customer feedback regarding claimed features
`
`Patent features are innovative/non-obvious: Praise for
`
`Matrix; shows customer requests to implement claimed
`
`features or expand offerings with claimed features and
`
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`
`Matrix; shows customer requests to implement claimed
`
`features or expand offerings with claimed features and
`
`customer feedback regarding claimed features
`
`TS1525667-TS1525667
`
`TS1525668-TS1525668
`
`TS1525669-TS1525669
`
`Page 3 of 9
`
`

`
`TS1525670-TS1525670
`
`HC-AEO
`
`TS1525671-TS1525671
`
`HC-AEO
`
`TS1525672-TS1525672
`
`HC-AEO
`
`TS1525673-TS1525673
`
`HC-AEO
`
`TS1525746-TS1525755
`
`HC-AEO
`
`TS1528344-TS1528346
`
`HC-AEO
`
`TS1528395-TS1528395
`
`HC-AEO
`
`TS1528404-TS1528404
`
`HC-AEO
`
`TS1528462-TS1528463
`
`HC-AEO
`
`TS1528489-TS1528490
`
`HC-AEO
`
`TS1528491-TS1528494
`
`HC-AEO
`
`TS1528565-TS1528567
`
`HC-AEO
`
`TS1528568-TS1528570
`
`HC-AEO
`
`TS1528571-TS1528573
`
`HC-AEO
`
`TS1528578-TS1528578
`
`HC-AEO
`
`TS1528799-TS1528802
`
`HC-AEO
`
`TS1529252-TS1529253
`
`HC-AEO
`
`TS1529254-TS1529254
`
`HC-AEO
`
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: shows
`development of claimed features well after TT's invention
`dates; Patent features are innovative/non-obvious: shows
`TS had conventional screens well after the patents issued;
`direct evidence of copying competitor products
`Shows copying and development history of the claimed
`features
`Shows regular monitoring of TT's product with claimed
`features and news relating to TT
`shows copying or regular monitoring of competitors w/
`claimed features
`shows copying or regular monitoring of competitors w/
`claimed features
`shows copying or regular monitoring of competitors w/
`claimed features, including TT
`shows copying or regular monitoring of competitors w/
`claimed features, including TT
`Shows copying or regular monitoring of competitors w/
`claimed features
`Shows copying or regular monitoring of competitors w/
`claimed features
`Shows copying or regular monitoring of competitors w/
`claimed features
`Shows copying or regular monitoring of competitors w/
`claimed features, including TT
`Shows copying or regular monitoring of competitors w/
`claimed features
`shows copying or regular monitoring of competitors w/
`claimed features, monitoring news relating to TT
`shows copying or regular monitoring of competitors w/
`claimed features, monitoring news relating to TT
`
`Page 4 of 9
`
`

`
`TS1529945-TS1529945
`
`HC-AEO
`
`Shows regular monitoring of '|'|"s product with claimed
`features and news relating to TT
`
`TS1531463-TS1531463
`
`HC-AEO
`
`Shows regular monitoring of T|"s product with claimed
`
`features and news relating to 1T
`
`TS1532722-TS1532729
`
`HC-AEO
`
`Patent features are innovative/non-obvious: Praise for
`
`TS1533574-TS1533576
`
`HC-AEO
`
`Matrix; shows customer requests to implement claimed
`
`features or expand offerings with claimed features and
`
`customer feedback regarding claimed features
`
`Shows copying or regular monitoring of competitors w/
`claimed features, including Tl"
`
`TS1538703-TS1538703
`
`HC-AEO
`
`Shows regular monitoring of TT's product with claimed
`
`features and news relating to ‘IT
`
`TS1547001-TS1547003
`
`HC-AEO
`
`Shows copying or regular monitoring of competitors w/
`claimed features
`
`‘lT1529064-TS1529064
`
`HC-AEO
`
`Shows regular monitoring of T|"s product with claimed
`
`|BG_00026004
`
`HC-AEO
`
`features and news relating to TT
`
`Shows copying of claimed features; describes praise for
`BookTrader and claimed features.
`
`TSO029696-TSO029729
`
`Confidential
`
`Shows customer requests to implement claimed features
`
`Praise by Others Demonstrates Non-Olwiousness
`
`TS0107054-TS0107075
`
`or expand offerings with claimed features; describes
`benefits of claimed features
`
`Evidence of mindset at time of development; Praises
`
`claimed features (unprecedented market feel, innovative,
`very different from traditional order entry windows);
`
`Describes advantages of Matrix window; direct evidence of
`
`copying '|T's MD Trader window
`
`TS0018219-TSOO18221
`
`Confidential
`
`Patent features are innovative/non-obvious: praises
`
`claimed features with superlatives such as innovative
`
`TS0023504-TS0023507
`
`Confidential
`
`Patent features are innovative/non-obvious: praises
`
`claimed features with superlatives such as innovative
`
`TS0107035-TS0107035
`
`HC-AEO
`
`Patent features are innovative/non-obvious: shows
`
`customer request/complaint originated the claimed
`
`features (following MDTrader/'lT), as opposed to GUI
`designers
`Patent features are innovative/non-obvious: shows
`
`customer request/complaint originated the claimed
`
`features (following MDTrader/'lT), as opposed to GUI
`designers
`
`Evidence of mindset at time of development; Praises
`
`claimed features (unprecedented market feel, innovative,
`
`very different from traditional order entry windows);
`
`Describes advantages of Matrix window; direct evidence of
`copying '|T's MD Trader window
`
`TS0107050-TS0107053
`
`TS0107054-TS0107075
`
`Page 5 of 9
`
`

`
`TS0107079-TS0107084
`
`HC-AEO
`
`TS1244458-TS1244460
`
`HC-AEO
`
`TS1245173-TS1245173
`
`HC-AEO
`
`TS1246012-TS1246012
`
`HC-AEO
`
`TS1246642-TS1246642
`
`HC-AEO
`
`TS1247248-TS1247248
`
`HC-AEO
`
`TS1252581-TS1252581
`
`HC-AEO
`
`TS1253247-TS1253247
`
`HC-AEO
`
`TS1253260-TS1253260
`
`HC-AEO
`
`TS1256138-TS1256138
`
`HC-AEO
`
`TS1256406-TS1256406
`
`HC-AEO
`
`TS1257809-TS1257809
`
`HC-AEO
`
`TS1257878-TS1257878
`
`HC-AEO
`
`TS1258091-TS1258091
`
`HC-AEO
`
`Patent features are innovative/non-obvious: shows
`customer request/complaint originated the claimed
`features (following MDTrader/TT), as opposed to GUI
`designers
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows suggestion by TS to use claimed features and
`request by customer expand offerings with claimed
`features and customer feedback regarding claimed
`features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`
`Page 6 of 9
`
`

`
`TS1262147-TS1262147
`
`HC-AEO
`
`TS1264269-TS1264269
`
`HC-AEO
`
`TS1269846-TS1269846
`
`HC-AEO
`
`TS1269897-TS1269897
`
`HC-AEO
`
`TS1269993-TS1269993
`
`HC-AEO
`
`TS1270054-TS1270054
`
`HC-AEO
`
`TS1272177-TS1272177
`
`HC-AEO
`
`TS1296799-TS1296820
`TS1452693-TS1452694
`
`HC-AEO
`HC-AEO
`
`TS1482217-TS1482220
`
`HC-AEO
`
`TS1525666-TS1525666
`
`HC-AEO
`
`TS1525667-TS1525667
`
`HC-AEO
`
`TS1525668-TS1525668
`
`HC-AEO
`
`TS1525669-TS1525669
`
`HC-AEO
`
`TS1525670-TS1525670
`
`HC-AEO
`
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer request to implement claimed
`features or expand offerings with claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer request to implement claimed
`features or expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Patent features are innovative/non-obvious: Shows
`customer request to implement claimed features or
`expand offerings with claimed features
`Evidence of customer feedback regarding claimed features
`Praises claimed features, stating that Matrix is critical (in
`2014)
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer request to implement claimed
`features or expand offerings with claimed features and
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`
`Page 7 of 9
`
`

`
`customer feedback regarding claimed features
`
`TS1525671-TS1525671
`
`Patent features are innovative/non-obvious: Praise for
`
`TS1525672-TS1525672
`
`TS1525673-TS1525673
`
`TS1525674-TS1525674
`
`TS1526338-TS1526343
`
`TS1526733-TS1526734
`
`TS1526836-TS1526836
`
`Matrix; shows customer requests to implement claimed
`
`features or expand offerings with claimed features and
`
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`
`Matrix; shows customer requests to implement claimed
`
`features or expand offerings with claimed features and
`
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`
`Matrix; shows customer requests to implement claimed
`
`features or expand offerings with claimed features and
`
`customer feedback regarding claimed features
`Patent features are innovative/non-obvious: Praise for
`
`Matrix; shows customer requests to implement claimed
`
`features or expand offerings with claimed features and
`
`customer feedback regarding claimed features
`
`Patent features are innovative/non-obvious: Praise for
`
`Matrix; shows customer requests to implement claimed
`features or expand offerings with claimed features and
`
`customer feedback regarding claimed features
`
`Patent features are innovative/non-obvious: praises
`claimed features with superlatives such as state-of-the-art
`
`order entry tool
`Patent features are innovative/non-obvious: Shows
`
`customer request to implement claimed features or
`
`expand offerings with claimed features
`
`TS1527002-TS1527009
`
`HC-AEO
`
`Patent features are innovative/non-obvious: praises
`
`TS1527617-TS1527622
`
`HC-AEO
`
`TS1528137-TS1528137
`
`claimed features with superlatives such as state-of-the-art
`
`Patent features are innovative/non-obvious: praises
`claimed features with superlatives such as state-of-the-art
`
`order entry tool
`
`Patent features are innovative/non-obvious: Praise for
`
`Matrix; shows customer requests to implement claimed
`
`features or expand offerings with claimed features and
`customer feedback regarding claimed features, specifically
`
`with respect to the Beta Forum
`RELEVANT DOCUMENTS WITHHELD
`
`Evidence of customer feedback, requests, and praise for
`claimed features
`
`Evidence of defects, version releases, and bug tracking
`based on feedback from customers
`
`Evidence of early use of TradeStation's Matrix window,
`
`including feedback from customers regarding the claimed
`
`features; praise for claimed features
`
`Database
`
`TradeStation - Jira/TFS
`Database
`
`TradeStation - Beta Forum
`
`Page 8 of 9
`
`

`
`Interactive Brokers -
`"Jeet" database
`
`
`HC-AEO
`
`Includes transaction information which would indicate
`number of trades through BookTrader
`
`Page 9 of 9