Patent No. 6,918,082
`
`Petition For Covered Business Method Patent Review
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Intralinks, Inc.
`Petitioner
`
`v.
`
`Lone Star Document Management, LLC
`Patent Owner
`
`Patent No. 6,918,082
`Issue Date: July 12, 2005
`Title: ELECTRONIC DOCUMENT PROOFING SYSTEM
`
`Covered Business Method Review No.
`
`DECLARATION OF STEPHEN WINSLOW
`
`IN SUPPORT OF PETITIONER INTRALINKS
`
`Intralinks, Inc. Exhibit 1002 Page 1
`
`

`
`1, Stephen Winslow, make this declaration in connection with the
`
`proceeding identified above.
`
`1.
`
`I am the Vice President, Technology Law at Intralinks, Inc.
`
`(“Intralinks”).
`
`2.
`
`Attached as Appendix A to my declaration is a true and correct copy
`
`of a letter received by Intralinks from Devlin Law Firm LLC (“Devlin”) on behalf
`
`of Lone Star Document Management, LLC (“Lone Star”) dated June 24, 2015.
`
`3.
`
`Attached as Appendix B to my declaration is a true and correct copy
`
`of a letter sent by Intralinks to Devlin on July 24, 2015.
`
`4.
`
`Attached as Appendix C to my declaration is a true and correct copy
`
`of a letter sent by Devlin, on behalf of Lone Star, to Intralinks on August 26,
`
`2015.
`
`5.
`
`Attached as Appendix D to my declaration is a true and correct copy
`
`of a printout from Intralinks’s webpage.
`
`6.
`
`As stated on Intralinks’s website attached as Appendix D, Intralinks’s
`
`software and services are used by more than 75% of the 25 largest U.S. and
`
`European banks and securities firms. Intralinks’s software and services include
`
`the Intralinks VIA platform, with software capabilities such as file
`
`synchronization, file sharing and content collaboration.
`
`Intralinks, Inc. Exhibit 1002 Page 2
`
`

`
`I declare that all statements made herein of my own knowledge are true and
`
`that all statements made on information and belief are believed to be true, and that
`
`these statements were made with knowledge that willful false statements and the
`
`like so made are punishable by fine or imprisonment, or both, under section 1001
`
`of Title 18 of the United States Code.
`
`Dated: October 12, 2015 ¢
`Stephen Winslow
`
`Intralinks, Inc. Exhibit 1002 Page 3
`
`

`
`DEVLIN LAW FIRM LLC
`
`1306 N. Broom Street, 15‘ Floor
`Wilmington, Delaware 19806
`United States of America
`
`Tel.: [302] 449-9010
`Fax: (302) 353-4251
`www.devlinlawfirm.com
`
`June 24, 2015
`
`VIA FEDERAL EXPRESS
`
`Scott Semel, General Counsel
`IntraLinks, Inc.
`150 East 42”‘ Street, 8”‘ Floor
`New York, NY 10017
`
`Re:
`
`Infringement of Lone Star Document Management, LLC’s U.S. Patent
`No. 6,918,082
`
`Dear Mr. Semel:
`
`I am writing on behalf of our client Lone Star Document Management, LLC
`(“Lone Star”). Lone Star is the assignee of all right, title, and interest in U.S. Patent No.
`6,918,082 entitled “Electronic Document Proofing System” (the “’082 patent”).
`The ’082 patent generally relates to proofing electronic documents delivered over a
`network.
`
`Based on our review of publicly available information, Lone Star has learned that
`IntraLinks, Inc. and its affiliates (“IntraLinks”) are infringing one or more claims of
`the ’082 patent through the use, manufacture, sale, and offers for sale of its enterprise
`collaboration system (the “Infringing Products”). The Infringing Products of the ’082
`patent include but are not limited to the IntraLinks Platform products and services.
`
`Based on our investigation, it appears that the provision, use, sale, and/or offer for
`sale of the Infringing Products directly infringes one or more claims of the ’082 patent by
`virtue of a combination of features. For example, claim 10 of the ’082 patent teaches a
`system for proofing portable format electronic documents delivered over a network
`through the use of a computer, software running on said computer, proofer identifiers to
`prevent unauthorized access to content, and the ability to manage and simultaneously
`display electronic documents and comments. The Infringing Products provide
`comprehensive capabilities for managing and processing documents in a way that directly
`infringes claim 10.
`
`Of course, infringement of any patent is determined according to the claims of the
`patent. While our investigation is ongoing, we have enclosed a preliminary infringement
`analysis which we believe demonstrates the infringing nature of IntraLinks’ products and
`services. It is important to note that this analysis is preliminary in nature, based only on
`publicly available information regarding IntraLinks’ products and services. Lone Star
`
`Intralinks, Inc.
`
`Exhibit1002/A Page1
`
`Intralinks, Inc. Exhibit 1002/A Page 1
`
`

`
`DEVLIN LAW FIRM
`June 24, 2015
`Page 2 of 2
`
`reserves all rights to amend or supplement the enclosed analysis, or to assert additional
`patents as our investigation continues.
`
`We also believe that lntraLinks is inducing infringement of the ’O82 patent by
`actively aiding and abetting others to use the Infringing Products. Specifically,
`IntraLinks actively induces these other entities to engage in these actions by advertising,
`offering for sale, and selling the Infringing Products, and by providing user manuals,
`product documentation, and other instructions regarding the use of the claimed features
`of the ’O82 patent in the Infringing Products.
`
`Further, we believe that IntraLinks is contributing to infringement of the ’O82
`patent by providing the Infringing Products to others, including its partners, customers,
`and end users; because the Infringing Products constitute a material part of the invention,
`were especially made or especially adapted for use in an infringement of the patent, and
`have no substantial non-infringing uses.
`
`As a result of IntraLinks’ infringement of the ’O82 patent, Lone Star has suffered
`damages and will continue to suffer damages in the future. Lone Star is nevertheless
`hopeful that the parties can engage in discussions to reach an amicable resolution of this
`matter. Accordingly, please contact me at your earliest convenience to discuss an
`appropriate resolution of your company’s past and ongoing infringement of the ’O82
`patent.
`I can be reached by phone at (302) 449-9010 or by email at
`correspondence@devlinlawfirrn.com.
`
`Thank you in advance for your attention to this important matter.
`
`Very truly yours,
`
`
`
`Timothy Devlin
`
`Devlin Law Firm
`
`1306 N. Broom St., 15‘ Floor
`Wilmington, Delaware 19806
`Tel.: (302) 449-9010
`Fax: (302)353-4251
`wWw.devlinlawfirm.com
`
`Intralinks, Inc.
`
`Exhibit1002/A Page2
`
`Intralinks, Inc. Exhibit 1002/A Page 2
`
`

`
`Preliminary Analysis of Infringement of U.S. Patent N0. 6,918,082 by IntraLinks Holdings, Inc. (“IntraLinks”) by IntraLinks’ Software
`and Services (Based on Public Information Only)
`
`Lone Star Document Management Systems LLC (“Lone Star”) provides this preliminary and exemplary infringement analysis with
`respect to IntraLinks’ infringement of U.S. Patent No. 6,918,082 entitled “Electronic Document Proofing System.” The following chart illustrates
`an exemplary analysis of the document collaboration products and services offered by IntraLinks (the “Infringing Instrumentalities”). The analysis
`is based only upon information gleaned from publically available resources regarding the Infringing Instrumentalities, as IntraLinks has not yet
`provided any non—public information or source code. IntraLinks directly infringes the ’082 Patent in violation of 35 U.S.C. § 27l(a) by selling,
`offering to sell, making, using, and/or importing of the Infringing Instrumentalities which embody the claimed features of the patented systems.
`The following exemplary analysis demonstrate that IntraLinks directly infringes the ’082 Patent.
`
`Unless otherwise noted, Lone Star believes and contends that each element of each claim asserted herein is literally met through
`IntraLinks’ provision of the Infringing Instrumentalities. However, to the extent that IntraLinks attempts to allege that any asserted claim element
`is not literally met, Lone Star believes and contends that such elements are met under the doctrine of equivalents. More specifically, in its
`investigation and analysis of the Infringing Instrumentalities sold, offered for sale, made, used, and/or imported by IntraLinks, Lone Star did not
`identify any substantial differences between the elements of the patent claims and the corresponding features of the Infringing Instrumentalities, as
`set forth herein. In each instance, the identified feature of the Infringing Instrumentalities performs at least substantially the same function in
`substantially the same way to achieve substantially the same result as the corresponding claim element.
`
`Lone Star notes that the present claim chart and analysis are necessarily preliminary for reasons including that there is no pending
`litigation between Lone Star and IntraLinks and therefore Lone Star has not obtained discovery from IntraLinks nor has IntraLinks disclosed any
`detailed analysis for its non—infringement position. Further, because no litigation is currently pending, Lone Star does not have the benefit of claim
`construction or expert discovery. Lone Star hereby specifically reserves the right to supplement and/or amend the positions taken in this
`preliminary and exemplary infringement analysis, including with respect to literal infringement and infringement under the doctrine of equivalents,
`if and when warranted by further information obtained by Lone Star prior to or during the pendency of any subsequent litigation, including
`information adduced through fact discovery, claim construction, expert discovery, and/or further analysis.
`
`Intralinks, Inc.
`
`Exhibit1002/A Page3
`
`Intralinks, Inc. Exhibit 1002/A Page 3
`
`

`
` Evidence
`
`IntraLinks’ VIA platform comprises a system for proofing electronic documents delivered over a network.
`
`Irztralinlz-3. ‘fl.-‘-"4 allmm content «co llaboration tlmmgh the creation ofwnrke1:nacee..enab.I.ing business pm Feaeinnala. to war}: together
`
`on :1 ducumemnt or project. Further. 1tlt1'fil.ifl.h'.’¢. Vii. wlnicla is: a~cc«e~am'1:r.I«e= 12h1'flU1 h a sim ie=1t‘eb-lm-sedueer interface. allvnwe users to
`ac~:«e-ea and share: filfli at air? time fmm the-ir‘ d.e=sL:trJ t 5. to their 1I1t'Il3l'l.vE-d..4!:'7.“I',=l:1‘_‘$. wlnile s~e«curit_1.' and IE1‘-.{ cap a.l:vi.li.1:iea. enmre «t:o11=.=.tant
`control and 111«om7,1:oring m"e1“t1’1e content. Iutmlsinks VIA integmtea. with exirating applia:ati;on5. and &‘j.’§tEfl3t15.. p1'm“i4:li11g an extmsivnn
`offrixuiflar tools and iexperiencee. and the means to rcnvurdmate work acre 5%. people. orgzmizatiana and <::1ve:1riI:es..
`
`IntraLinks Holdings, Inc. Annual Report on Form 10-K For the year ended December 31, 2014 p. 6
`
`IntraLinks’ VLA platform comprise a database of portable format electronic documents.
`
`IntraLinks comprises a database of portable format electronic documents. IntraLinks stores files, including those in
`portable document file format, in a centralized pool known as VIA Drive.
`
`Intralinks, Inc.
`
`Exhibit1002/A Page4
`
`Claim Element
`Claim 10
`
`
`
`A system for
`proofing
`electronic
`documents
`delivered over a
`
`network ,
`
`comprising:
`
`a database of
`
`portable format
`electronic
`documents stored
`
`together with at
`least one proofer
`identifier;
`
`
`
`Intralinks, Inc. Exhibit 1002/A Page 4
`
`

`
`
`
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`
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`
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`
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`
`http://www.lawsitesblog.com/wp—content/umoads/2014/0 8/IntraLinksDriVe .jpg
`
`The term “proofer” as used in the ’O82 Patent refers to a user who is authorized to access and or View a
`document. Similarly, the term “proofer identifier” as used in the ’082 Patent refers to a means to endow the
`authority to access and/or View a document on some users while denying such access to others (one example
`being a password). (See, e. g., ’082 Patent at 3:60-4:14; see also 7:61-64 referring to usernames, passwords, and
`permissions for users of a preferred embodiment of the patented technology.) Intralinks enables the use of
`proofer identifiers to access stored portable format electronic documents.
`
`Intralinks, Inc.
`
`Exhibit 1002/A Page 5
`
`Intralinks, Inc. Exhibit 1002/A Page 5
`
`

`
`-
`
`Intraléinks WA Drive is for secure document storage in the cloud. Eat afiows yoLI
`
`to access your fibres from wherever you warez, whether from your desktop‘
`
`through as web browser or on a rnoiaiie device. The documents you store in
`
`fir?-re are aooessihie only to you, they cmuiot he shared wéth others directly.
`
`{They can he shared through Wort: Streams? as s2l§S»i3L3SiS»8=f3l below}
`
`--
`
`Intrallnka WA Work Streams is a platform for file sharing and ::;oiE.ahoration..
`
`This is where you create projects for sharing with others {called Work
`
`Str«eams), add docunients to nrojects, trar:;i»: doourneirt oormrients and
`
`revaisioiis, and control
`
`
`
`-ermésslons amori ‘ CDllfii3D%FfiiOFS_
`
`
`httgz//www. lawsitesblogcoml20 1 4/08/intralinks-via—emphasizes-securicx-file-sharing-collaboration.html
`
`‘(=Ve1iai“o built :1 highly‘ sophisticateenl au.theutic.ati.on, auflmrization and eincrgptivon saenicve designed to ensure that the cotitmt stored. in our
`ajrsteam is accessibl.e only 113.? authorized users. "1'a'¢'i*=.-z employ a wide range of technical security‘ feaurrea iricludirzg two factor authentication
`using REA A.d.aplZl'u."E Autluenticatiori mid. data em:1"_§.-‘ptioin witli encode-d ma-ssiron identifiers and passwords. ETE1'_'i,' file we transmit from an
`exchange is encrypted. in transit via Transport LEFEI Security, or
`up to V1.1. ‘Ne also use encrypfion technology in on: storage sjssteaais
`and baazkup tapes. We incl: crate so liistirciated infonnation 11' hts management and ennissioiiin —controls that em=JJ'I.e our customers to
`control the role of and access ofgmticigants to infomiatiom. Out platform also pro*rii:le.»s audit trails for c-ompliance and access history’ tmclezing
`for content throughout its lifecjrcle.
`
`IntraLinks Holdings, Inc. Annual Report on Form 10-K For the year ended December 31, 2014 p. 9
`
`Computers or servers running IntraLinks’ VIA platform comprise a computer connectable to the network for receiving a
`plurality of comments, each concerning a particular one of the portable format documents.
`IntraLinks VIA is a software-as-a-service (SaaS) platform. IntraLinks’ software operates on hardware in multiple data
`.
`.
`.
`.
`.
`centers which are in communication over the internet.
`
`a computer
`connectable to the
`network for
`receivin a
`. g
`plurality of
`comments, each
`
`concerning a
`particular one of
`the ortable
`
`
`
`
`
`
`
`Intralinks, Inc.
`
`Exhibit1002/A Page6
`
`Intralinks, Inc. Exhibit 1002/A Page 6
`
`

`
`F f01”fI1at
`documents;
`
`We deliver our solutions thmu h a cloud.-based model. making them availablse on-demand 0’t'E1' the Internet using a multi-tenant
`architecture in which a sin le ins;.tanc~e of our soltvrare serves all ofour CIJ$tO1l1E1"$. ‘We sell our solutions dvirectljr through a fie-lcl sales team
`
`with inclustijr-sp«ecific. expertise and an inside sales, team. and indirectly’ through a customerrefeiral n-etwork and channel partners. In 2014.
`we generated $25 3 .8 mi.ll;i.on in rev-enue., 43.8% ohishich waa derived finm sales .ac1'oss 9*-1 countries outside ofthe U3
`
`IntraLinks Holdings, Inc. Annual Report on Form 10—K For the year ended December 31, 2014 p. 5
`
`
`
`
`
`
`run in primary and
`rovided by Stmflanzl A'rai.la1::ilit}-‘ Sefiicea LP that
`-
`.
`.-.
`s~ -- -.
`'
`u - av
`'.
`‘
`.: nu '
`V
`I: -
`i 2.
`-_=.
`4
`i
`.
`'
`5s&CDIlCla1‘_5;' mode with redundancy and failover capability. Phyeical eecurit}-' at these facilities includes a continually‘ stafied security
`station along with biometric and man trap acceas controls. S}5“.‘sl5E1I15 are pmtected. by firewall; and encryption technology. Each data
`center :fe:atu1'es redundant power‘ on-site backup generators. and envimmnental controls and monitoring. As; part ofour disaster recot'e1*_g~‘
`
`
`
`arrangements, all customer data is re. licated to all sites in near real-time. Our hosting providers. conduct regular security audits of our
`infiastmcture and we alao employ outside tenders for managed security and monitoring 24 houre per clay. 7 clays perweele, 365 days per
`year. The peifonuance ofour application suite in continually monitored using a variety’ ofautomated tools and customer data ie regularly
`backed up and stored in a priinaiy and secondary secure location to minimize the risk ofdata 10so at any facility.
`
`IntraLinks Holdings, Inc. Annual Report on Form 10—K For the year ended December 31, 2014 p. 9
`The IntraLinks platform enables the computer to receive comments pertaining to particular portable format documents.
`
`Revisions to fites are tracked with version numbers and all previous versions are
`retained. Partioigants can add comments to cioc:un1ents_ Others in the Work Stream
`
`are notified of all new activity; including comments and file uploads.
`
`ht_tp://www.lawsitesb1og§_gm/2014/08/intralinks-Via—e_1r1_phasizes—securfiy-file-sharing—collaboration.htm1
`
`Intralinks, Inc.
`
`Exhibit1002/A Page7
`
`Intralinks, Inc. Exhibit 1002/A Page 7
`
`

`
`-
`
`lntralinks VIA Driver is for secure dooorrrerrt storage in the otootl. fit aliows 'r_-you
`
`to access ‘_v,a'CHJ{ files from wherever you are, whettaor from your desk-rtopg
`
`through a web browser or on a rnobite device. The documents you store En
`
`Drive are aooeesielée onty to you, they cannot be ‘shared with others direetty.
`
`(they can oe shared through Work Strearrzac as tli:soLae3er:i betowjl
`
`-
`
`intraléinks VIA Work Streams is a ptatform for file sh.ar'ing and collaboration.
`
`This to where you create projects for eihartrrg with others {called Work
`
`Streams), aocl documents to projects, track oocunieot oornmerite and
`
`rzevisérons, and oontrot permrssiorrs among oollaboratore.
`
`a program
`
`executing on said
`computer for
`associating and
`storing the
`received plurality
`of comments
`
`together with the
`particular
`portable format
`electronic
`
`documents;
`
`l_1ttp_://www. lawsitesblog.com/20 1 4/08/intralinks—via—emphasizes-seeufl-file-sharing-collaboration.htrnl
`
`IntraLinks’ VIA platform comprises a program executing on said computer for associating and storing the received
`plurality of comments together with the particular portable format electronic documents.
`
`IntraLinks VIA SaaS operates on hardware in multiple data centers which are in communication over the internet.
`
`v them rat“ail.abl.e onoernancl. over the Internet train - a multi-tenant
`"We deliver our solutions through a cloud-haaed. model.
`
`architecture in which a single instance of -our aoflwaree serr-:e5 all oifour ‘customers. Wie: sell. our solotione directly: through a field. saler team
`with ,indum3:'-apecific expertise ancl an inside =raJ.e'r tean1.anc1. inriirectlgr through a customer‘ referral network and channel, partners. In 2014,
`we generated. $25-27.3 nnlljon in rrrirenue, 41.35»-6 oftrhich war. deri1'ecl from aales. acro as 94 countries. outaide ofthe U3.
`
`IntraLinks Holdings, Inc. Annual Report on Form 10—K For the year ended December 31, 2014 p. 5
`
`
`. ro‘-ridetl by SnnGarcl Availability Semices LP that are run in primary and
`.
`.
`.
`L
`r
`.,
`-
`li ‘
`.:-r
`.. 2 i..
`r at - 1~
`sec ndarjr mode with redunrla.t1c§; and failover‘ cap abrilitjr. Physical secur.i.t_r_;‘ at these facilitiea includes. a continual,lj.«* staffed security
`station along with biometric and man trap access controls. 3j.’¥l.'E1It15; are protected 1:33: firewalls and encryption technol.ogj;, Each Llata
`center features reclundant power, on-site backup generators, and environmental controls. and monitoring. Ar. part ofour disaster recover}:
`arrangements. all customer data is re1gl,ic.ate~cl to all sites in near real-time. Our‘ hosting providers. conduct regular security audits. of our
`infraa-.truc.tnre and. we also eruplojgr outaide ‘renders for managed security and nronitoring 24 hour-5. per day". 7’ days per week. 365 clays per
`year. The prerfonuance -ofour app lication wire is continually monitored racing a 'cari.etj;* ofau.to1naterl tools and. customer data is regularly;
`backed up and stored. in a priznarj.“ and secondary‘ secure location to
`the rial: ofdata loss at any fzicilitgr.
`
`Intralinks, Inc.
`
`Exhibit1002/A Page8
`
`Intralinks, Inc. Exhibit 1002/A Page 8
`
`

`
`IntraLinks Holdings, Inc. Annual Report on Form 10-K For the year ended December 31, 2014 p. 9
`The computer hardware associates and stores the received plurality of comments together with the particular portable
`format electronic documents. The comments are associated and stored with the portable format electronic document.
`
`Revisions to files are tracked with version numbers and alt previous versions are
`retained. Parrici ants can add comments to documents. Others in the Work Stream
`
`are notified of oil new activity, irivziudirig comments and file uploads.
`
`http;//www.lawsitesblog._coin/20 l 4/08/intralinks-via-emphasizes—securitv—file—sharing£ollaboration.html
`
`Fiirioiioiiaiiy, iriiraiiriirs V5.3. is iiire two separate Eiflfliiflaiifiififi in one piatforni:
`
`-
`
`-
`
`lntraliiiks. ‘elm. Drive is for svahrire doouament storage in the cioud. it aiiows yoii
`to aoiceisa your fiies from wherever ‘grou are; whether from yous“ deskioo,
`through a west» browser or or: 3 rriohiie devise. The dociiiiieiiis }“C3LE store in
`Drive are aizoessihie CJHW to ’y‘fJL!, thee}; QE‘H'H"i£1'it he shared with others; diroiztiy.
`(They sari he shared throi_igh Work Streoriis, as dismissed i:zei:i::ir:.r,fa
`lntraliriks Vlfii Work Streams is so iziiatform for fiie sharirig and Ififllliafiflffiillfifl.
`This is where yogi oi‘-sate projects for sharing with others igrzaiied Work:
`Streams}. add dociirrieiits to projects, ’[§'El{2:i'i doouriieiii cornnieiita arid
`
`revisions, and ilflfliffii periiiissioiis airiorig collaborators,
`
`http://www.lawsitesblog.com/20 1 4/08/intralinks-via—empli_asizes-securfiy-file-sharing—collaboration.html
`IntraLinks’ VIA platform comprises a computer for receiving a request, from a proofer presenting the proofer identifier, to_i
`review a particular portable format electronic document.
`
`said computer for
`receiving a
`request, from a
`
`The computer, as identified in the elements above and running IntraLinks software, receives and authenticates user’s
`credentials (i.e. a proofer identifier) from a user requesting to review a particular portable format electronic document and
`proofer.
`.
`.
`.
`.
`.
`.
`.
`.
`.
`presenting the
`further associates the activities of the individual user with the portable format electronic document requested.
`.
`.
`Lproofer identifier, L_
`
`Intralinks, Inc.
`
`Exhibit 1002/A Page 9
`
`Intralinks, Inc. Exhibit 1002/A Page 9
`
`

`
`articular
`p
`portable format
`61ectrOniC
`(1
`E.
`Ocumen ’
`
`fE}'i"l.tfif’E:3«. imrludirng two factor authentication
`sj.«"s1:em is ztvcrcessiljle 01flI.l'I.~"l.'Jjf‘ authorized users. We employ‘ 11 Wide range of techmizcal seazuritg-'
`.
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`exclnange is encrypted in transit ‘via Transport Layer Security. or
`up to 171.3. 'We also use ‘E1'M21'}«"]3tI'.Di!l technology in our storage systverns
`
`and backulfi tapes. ‘We into crate so histi.m1':/e~:11 infonnatilon rights management and em1issi.»omin2 controls that ema.1:Ile our customers to
`
`
`control. the role: ofand a-r:ce'ss of artici ants to infnnnatiom. Our platfonn also 1J1'>O'4."id.E5 audit trails for compl.i.a;m:e and access histoijr tracking
`for»cou1:-ent tliroughout its Iifecjsclre.
`
`IntraLinks Holdings, Inc. Annual Report on Form 10-K For the year ended December 31, 2014 p. 9
`
`F Lsnctionalily, lnirlalinks Vie. is like two separate appléieatioris in one platform:
`
`-
`
`lntralirrkrs VIA Drive is for secure doeurnent storage in the mood. Est atlows yoL:
`
`to access your files from w:hereve=r you are, whether from your desktop,
`
`through a we hrowsexr or on a mobile device. The el~ocumerri:s you store in
`
`Drive are ascessihée only to you, they oarmot he shared with others directly.
`
`{They can be sshared ‘through ‘Work Streams, as dissusserrl below}
`
`-
`
`Intralinks VIA Work mrearne is E platform for file sharing and soliahoratioxn.
`
`This is where you create orojeclts for sihrasréng with others {called Work
`
`Streams), add etoeumeruts to projects, track. ::1ocum=ent eornrnents and
`
`revisions, and corrlroé ermissiorrs amen r:.ollaho:rators.
`
`
`
`
`http://www.1awsitesblog.com/20 l 4/0 8/intralinks—via-emphasizes-security-fi1e—sha@g-collaborationhtml
`
`IntraLinks’ VIA platform comprises a program for retrieving and formatting the requested document together with the
`associated plurality of comments for simultaneous display to permit review.
`IntraLinks software running on a computer, as identified in the elements above, retrieves and fonnats requested documents
`together with comments and enables simultaneous display of comments and documents. On information and belief,
`documents, including portable format electronic documents can be opened in the native software associated for that file
`type. While simultaneously viewing a requested document in the native software associated for that file type, users of
`IntraLinks can View the plurality of comments associated with said document.
`
`said program for
`retrieving and
`fgriljgfggig the
`d (iument
`t: ether with the
`asfociated
`.
`plurality of
`comments for
`simultaneous
`
`Intralinks, Inc.
`
`Exhibit 1002/A Page 10
`
`Intralinks, Inc. Exhibit 1002/A Page 10
`
`

`
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`
`IntraLinks VIA for the Web Startup Guide p. 7
`
`Additionally, users of IntraLinks can View comments pertaining to particular portable format electronic documents
`simultaneously with the document when using the IntraLinks Viewer.
`
`|_
`
`Intralinks, Inc.
`
`Exhibit 1002/A Page 11
`
`Intralinks, Inc. Exhibit 1002/A Page 11
`
`

`
`tn dizspiéay the document's hnokrnancs. If the PDF -dummenrt includes
`imn
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`
`IntraLinks Platform User Guide for DCM Managers and Publishers p. 107
`
`Intralinks, Inc.
`
`Exhibit 1002/A Page 12
`
`Intralinks, Inc. Exhibit 1002/A Page 12
`
`

`
`
`
`INTR/\
`
`
`LINKS
`
`July 24, 2015
`
`Devlin Law Firm LLC
`
`1306 N. Broom Street, 1st Floor
`Wilmington, DE 19806
`Attn: Robert Kiddie
`
`VIA EMAIL AND OVERNIGHT DELIVERY
`
`RE: Letter re: U.S. Patent No. 6,918,082
`
`Dear Robert:
`
`This is further to our conversation of July 10, 2015, in which we discussed the letter from
`Timothy Devlin of your firm, alleging that Intralinks infringes U.S. Patent 6,918,082.
`
`In our conversation, I emphasized that I wanted to get a sense of the range of your
`licensing fees so that we might avoid further legal expense. You were unable to provide
`me with that information without first receiving confidential financial and technical
`information from Intralinks.
`
`We are therefore responding to your infringement accusation.
`
`One problem with your accusation arises out of the last limitation of claim 10 of the
`patent, which you charted with your letter. That claim requires “simultaneous display” of
`a “requested document together with the associated plurality of comments” to “permit
`review.”
`
`As the screen shot you included from our “Web Startup Guide” illustrates, however,
`Intralinks VIA does not simultaneously display a requested document and the
`commenting functionality that is part of the Intralinks platform.
`
`Your chart included an extract from our “Platform User Guide” that discusses comments
`stored by a document creator within a .pdf document. That suggests you are confusing
`the Intralinks VIA services with those inherent in the Adobe .pdf format, to which the
`extract is referring. Those services are, of course, quite distinct. We don’t think you
`mean to assert that we are infringing on account of Adobe’s document format, and of
`course such a claim would have no merit.
`
`Another fundamental problem with your allegation is that the ’082 patent covers
`unpatentable subject matter. The Supreme Court has recently clarified what a patent can
`cover and what is too abstract to be patented. The courts and the Patent Office have
`consequentially invalidated many previously issued patents.
`
`Intralinks, Inc. Exhibit 1002/B Page 1
`
`

`
`lNTR/\
`
`LlN|<S
`
`The ’082 patent falls squarely within the “too abstract” category. Proofing documents
`and applying comments to them was undertaken long before computers assisted in that
`process. Your patent does no more than apply common computer techniques to that
`abstract idea, and hence does not meet the requirements for patentable subject matter.
`
`For these and other reasons, we see little value in a license to the ’082 patent.
`
`Sincerely,
`
`¢@/pt_%/gay/>v
`
`Stephen Winslow
`Vice President, Technology Law
`
`Intralinks, Inc. Exhibit 1002/B Page 2
`
`

`
`
`Tel.: (302) 449-9010
`Fax: (302) 353-4251
`www.devlinlawfirm.com
`
`1306 N. Broom Street, 1st Floor
`Wilmington, Delaware 19806
`United States of America
`
`
`Stephen Winslow
`Vice President, Technology Law
`Intralinks, Inc.
`150 East 42nd Street, 8th Floor
`New York, NY 10017
`
`August 26, 2015
`
`Re:
`
`Infringement of Lone Star Document Management, LLC’s U.S. Patent No.
`6,918,082
`
`Dear Mr. Winslow:
`
`We are in receipt of your correspondence dated July 24, 2015 in which you
`
`purport to rebut the presence of certain limitations of the ’082 patent in the Intralinks
`platform. You assert that Intralinks VIA “does not simultaneously display a requested
`document and the commenting functionality that is part of the Intralinks platform.” This
`assertion, however, is contradicted by Intralinks’ own literature.
`
`In Intralinks’ most recent 10-K filing with the SEC, Intralinks states that a single
`
`instance of its software delivers all of its SaaS solutions to its clients via the Internet.
`
`
`
`IntraLinks Holdings, Inc. Annual Report on Form 10-K For the year ended
`December 31, 2014 p. 5
`
`Given this language, our understanding is that each of the solutions provided by
`
`Intralinks, including the VIA, are underpinned by a common platform and possess the
`same capabilities including the capabilities pertaining to viewing stored documents. With
`respect to the Intralinks Viewer, Intralinks states, “Intralinks Viewer can be used to view
`PDF documents, Microsoft Excel spreadsheets and Microsoft Word documents. It
`provides an alternative for users who cannot install the tools needed to view documents to
`which printing and download restrictions have been applied. It is an alternative to Adobe
`Reader and similar tools.” See IntraLinks Platform User Guide for DCM Managers and
`Publishers, p. 23. Through the Intralinks Viewer, even users without Adobe or other pdf
`reader software can view pdf documents to which comments have been made. As
`identified in our claim chart, users can view these comments simultaneously with the
`document they are viewing in the Intralinks Viewer. It is the Intralinks platform software
`that is enabling this.
`
`Intralinks, Inc. Exhibit 1002/C Page 1
`
`

`
`Devlin Law Firm
`August 26, 2015
`Page 2 of 3
`
`
`Notwithstanding the above, the Intralinks Viewer is not required to be used to
`view documents.
`
`IntraLinks Platform User Guide for DCM Managers and Publishers, p. 93.
`
`In addition to the above functionality, the Intralinks platform enables users of
`Intralinks to also open documents in their native application.
`
`
`
`
`
`IntraLinks Platform User Guide for DCM Managers and Publishers, p. 93.
`
`Thus, our understanding is that users of the Intralinks platform can open a pdf file in
`whatever software viewer they have assigned to open pdf files, while at the same time,
`maintaining the separate