`Patent Owner’s Patent Owner’s
`
`DemonstrativesDemonstratives
`
`
`IBG, LLC et al. IBG, LLC et al.
`
`v.v.
`
`Trading TechnologiesTrading Technologies
`
`
`Case CBM2016‐00054Case CBM2016‐00054
`
`U.S. Patent No. 7,693,768U.S. Patent No. 7,693,768
`
`TRADING TECH EXHIBIT 2359
` IBG ET AL. v. TRADING TECH
`CBM2016-00054
`
`1
`
`Page 1 of 32
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`
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`
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`Problem Caused by Prior Art GUIProblem Caused by Prior Art GUI
`
`Ex. 1001 at Fig. 2.
`
`E.g., POR at 6.
`
`2
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`Page 2 of 32
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`
`
`
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`Problem Solved by the InventionProblem Solved by the Invention
`
`POR at 7.
`
`Ex. 2214.
`
`3
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`Page 3 of 32
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`
`
`
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`Problem Solved by the InventionProblem Solved by the Invention
`
`POR at 13.
`
`Ex. 1001 at Fig. 3.
`
`4
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`Page 4 of 32
`
`
`
`
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`Problem Solved by the InventionProblem Solved by the Invention
`
`E.g., POR at 13.
`
`Ex. 1001 at Fig. 4.
`
`5
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`Page 5 of 32
`
`
`
`
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`TSE – No Order Entry RegionTSE – No Order Entry Region
`
`Pet. at 34.
`
`TSE at 0137.
`
`6
`
`Page 6 of 32
`
`
`
`
`
`Problem Solved by the InventionProblem Solved by the Invention
`
`Ex. 1001 at 11:46‐67.
`
`POR at 13, 81.
`
`Ex. 1001 at 12:1‐36.
`
`Ex. 1001 at Fig. 4.
`
`7
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`Page 7 of 32
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`
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`
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`Problem Solved by the InventionProblem Solved by the Invention
`
`Ex. 1001 at 11:65‐67.
`
`Ex. 1001 at 12:32‐36.
`
`POR at 13, 81.
`
`Ex. 1001 at Fig. 4.
`
`8
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`Page 8 of 32
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`
`
`
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`The Combination Would Not Have Resulted in the ClaimsThe Combination Would Not Have Resulted in the Claims
`
`TSE at 0107, 0137.
`
`Pet. at 34; 36.
`
`Belden at Fig. 2b.
`
`9
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`Page 9 of 32
`
`
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`"'..+._1-'I".-."~'_-1-n—r--—H-'~—' fl_~J
`
`TSE at 0107, 0137.
`
`Pet. at 34.
`
`10
`
`1810
`3
`I32
`
`__
`
`,._.-,____
`
`I. -...|
`_ _. ..
`
`I
`
`Page 10 of 32
`
`
`
`
`
`Claims 6 and 7Claims 6 and 7
`
`Ex. 1001 at 12:56‐60.
`
`Ex. 1001 at 12:61‐65.
`
`E.g., POR at 13, 32‐34, 81.
`
`Ex. 1001 at Fig. 4.
`11
`
`Page 11 of 32
`
`
`
`
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`Invention Caused Initial SkepticismInvention Caused Initial Skepticism
`
`* * *
`
`POR at 53.
`
`Ex. 2170 at ¶ 14.
`
`12
`
`Page 12 of 32
`
`
`
`
`
`Invention Caused Initial SkepticismInvention Caused Initial Skepticism
`
`* * *
`
`POR at 52.
`
`13
`
`Ex. 2171 at ¶39.
`
`Page 13 of 32
`
`
`
`
`
`Invention was PraisedInvention was Praised
`
`* * *
`
`* * *
`
`Ex. 2534 at ¶4.
`
`Ex. 2534 at ¶¶6‐7.
`
`POR at 51, 70.
`
`14
`
`Page 14 of 32
`
`
`
`
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`Invention was PraisedInvention was Praised
`
`* * *
`
`POR at 69‐70.
`
`15
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`Page 15 of 32
`
`
`
`
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`Invention was PraisedInvention was Praised
`
`* * *
`
`POR at 70.
`
`Ex. 2223 at 17 (Feltes).
`
`16
`
`Page 16 of 32
`
`
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`
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`Invention was PraisedInvention was Praised
`
`* * *
`
`* * *
`
`Ex. 2223 at 47 (Monieson).
`
`POR at 70.
`
`17
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`Page 17 of 32
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`
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`Invention was PraisedInvention was Praised
`
`* * *
`
`* * *
`
`POR at 70.
`
`Ex. 2223 at 54‐55 (Oryhon).
`
`18
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`Page 18 of 32
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`
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`
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`Invention was Commercially SuccessfulInvention was Commercially Successful
`
`* * *
`
`Ex. 2173 at ¶22 (McDonnell).
`
`Ex. 2173 at ¶¶20‐22 (McDonnell).
`
`POR at 71.
`
`19
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`Page 19 of 32
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`
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`Invention was Commercially SuccessfulInvention was Commercially Successful
`
`* * *
`
`Ex. 2173 at ¶22 (McDonnell).
`
`Ex. 2173 at ¶12 (McDonnell).
`
`POR at 71.
`
`20
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`Page 20 of 32
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`
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`
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`Invention was Commercially SuccessfulInvention was Commercially Successful
`
`* * *
`
`* * *
`
`Ex. 2171 at ¶45 (Geannopulos).
`
`POR at 57, 59.
`
`Ex. 2171 at ¶43 (Geannopulos).
`
`21
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`Page 21 of 32
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`
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`Invention was Commercially SuccessfulInvention was Commercially Successful
`
`* * *
`
`* * *
`
`Ex. 2171 at ¶37 (Geannopulos).
`
`POR at 53.
`
`22
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`Page 22 of 32
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`
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`Invention was Commercially SuccessfulInvention was Commercially Successful
`
`* * *
`
`Ex. 2171 at ¶38 (Geannopulos).
`
`POR at 53.
`
`23
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`Page 23 of 32
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`Invention was Commercially SuccessfulInvention was Commercially Successful
`
`* * *
`
`* * *
`
`POR at 49‐50.
`
`Ex. 2227 at ¶¶3‐5 (Johnston)
`
`24
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`Page 24 of 32
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`
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`PROTECTIVE ORDER MATERIAL
`
`25
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`Page 25 of 32
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`
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`Invention was Copied by PetitionersInvention was Copied by Petitioners
`
`Ex. 2144; Ex. 2169 at ¶124.
`
`http://web.archive.org/web/20030416082330/http://www.tradingtechnologies.com/products/xtradertour/test3.html
`
`Ex. 2405/2234; Ex. 2169 at ¶124.
`
`POR at 42, 67.
`
`26
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`Page 26 of 32
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`
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`Invention was CopiedInvention was Copied
`
`POR at 65.
`
`27
`
`Ex. 2169 at ¶135.
`
`Page 27 of 32
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`
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`Invention was CopiedInvention was Copied
`
`Ex. 2277.
`
`POR at 66.
`
`Ex. 2169, ¶140.
`
`28
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`Page 28 of 32
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`
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`Invention was CopiedInvention was Copied
`
`POR at 69, 72.
`
`Ex. 2169 ¶114.
`
`29
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`Page 29 of 32
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`
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`
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`TSE – Not Prior ArtTSE – Not Prior Art
`
`“A reference will be considered publicly accessible
`if it was disseminated or otherwise made
`available to the extent that persons interested and
`ordinarily skilled in the subject matter or art
`exercising reasonable diligence, can locate it.”
`
`Blue Calypso LLC v. Groupon, Inc.,
`815 F.3d 1331, 1348 (Fed. Cir. 2016)
`(emphasis added).
`
`POR at 14.
`
`30
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`Page 30 of 32
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`
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`TSE – Not Prior ArtTSE – Not Prior Art
`
`Ex. 1065 (Thomas Dep. Tr.) at 136:17 – 138:1.
`
`Reply at 13.
`
`31
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`Page 31 of 32
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`
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`TSE – Not Prior ArtTSE – Not Prior Art
`
`Ex. 2169 at ¶ 42.
`
`Reply at 13.
`
`32
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`Page 32 of 32
`
`
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