IBG LLC, INTERACTIVE BROKERS LLC, TRADESTATION
`GROUP INC., TRADESTATION SECURITIES, INC.,
`v.
`
`TRADING TECHNOLOGIES INTERNATIONAL, INC.
`
`Case CBM2016-00054
`Patent No. 7,693,768
`
`PETITIONERS’ DEMONSTRATIVES
`
`Sterne, Kessler, Goldstein & Fox P.L.L.C.
`
`Hearing: June 23, 2017
`
`1
`
`IBG 1088
`IBG v. TT
`CBM2016-00054
`
`

`

`The ’768 Claims are Ineligible
`Under 35 U.S.C. § 101
`
`2
`
`

`

`Alice Corp. Pty. Ltd. v. CLS Bank Int’l
`
`(Petition, 16)
`
`3
`
`

`

`(Petition, 17; 768 Patent, claim 1)
`
`4
`
`

`

`Fundamental Economic Practices Long Prevalent in
`Our System of Commerce
`
`Jan. 27, 2017 Thomas Deposition
`
`(Ex. 1066, 51:18-52:1)
`
`(Reply, 5)
`
`5
`
`

`

`Fundamental Economic Practices Long Prevalent in
`Our System of Commerce
`
`Jan. 27, 2017 Thomas Deposition
`
`(Reply, 5)
`
`(Ex. 1066, 55:1-10)
`
`6
`
`

`

`Fundamental Economic Practices Long Prevalent in
`Our System of Commerce
`
`Handwritten
`Specialist’s Book
`
`NYSE (1983)
`Electronic Display Book
`
`INTEX (1984)
`Electronic Trading
`
`(Ex. 1020 (Weiss), 45)
`
`(Ex. 1077, 9)
`
`(Ex. 1073, 1)
`
`(Reply, 5, 27)
`
`7
`
`

`

`’768 Patent
`
`(768 Patent, 4:4-8)
`
`(768 Patent, 4:64-68)
`
`(Petition, 20-21)
`
`8
`
`

`

`CBM2015-00182 (’132 patent) Thomas Declaration
`
`(Ex. 1071, ¶ 99)
`
`(Reply, 21)
`
`9
`
`

`

`TSE is a Prior Art Printed
`Publication
`
`10
`
`

`

`TSE is a Prior Art Printed Publication
`
`TSE
`
`2005 Kawashima Deposition
`
`. . .
`
`. . .
`
`(Ex. 1019, 11:1-13:5)
`
`(Ex. 1017, 0005)
`
`(Petition, 11-12; Reply, 12-14)
`
`11
`
`

`

`The Attachments to Ex. 2163 (Exs.1048-1059)
`Corroborate Kawashima’s Testimony
`
`(Reply, 14)
`
`12
`
`(Ex. 1052, 1)
`
`

`

`TSE is Not Ambiguous Regarding Updating the
`Display While in Scroll Screen
`
`TSE
`
`(Reply, 16)
`
`13
`
`(Ex. 1017, 0091)
`
`

`

`Ryan Confirmed that Speed is Important in
`both Open-Outcry and Electronic Trading
`
`Apr. 5, 2017 Ryan Deposition
`
`(Reply, 17)
`
`14
`
`(Ex. 1070, 68:16-69:2)
`
`

`

`TT’s Alleged Secondary
`Considerations Fail
`
`15
`
`

`

`United States Court of Appeals for the Federal Circuit
`
`EBB-13?!)
`
`LINE ROTHMAN and GLAMOURMOM LLC.
`
`Plaintiffs-«Appellants.
`
`U.
`
`TARGET CORR.
`KOHL'S DEPARTMENT STORES. INC.. J.C. PENNEY COMPANY. INC.,
`REDCATS USA, L.P. (
`
`TT’s evidence doesn’t overcome the Petition’s strong primcfccie
`obviousness showing.
`
`Fisher-Price Inc.. 485 F.3d 115?. 1162 (Fed. Cir. 200?] {"The district court explicitly
`
`Indeed. a strong prima facie obviousness showing may stand even in the face of
`
`considerable evidence of secondary:r considerations. Si Leagfrog Enters,
`
`Inc. v.
`
`(Reply, 19)
`
`16
`
`

`

`TT Failed to Establish Nexus
`
`17
`
`

`

`TT Failed to Establish Nexus
`
`1. “The citations to Exhibits 2223 … amount
`to improper incorporation by reference.”
`(Paper 38, 4.)
`
`2. TT’s “alleged secondary considerations
`‘result from something other than what is
`both claimed and novel in the claim.’”
`
`3. “TT reuses evidence it offered to support
`different patents without tying the
`evidence to the ’768 claims.”
`
`(Reply, 20-21)
`
`18
`
`

`

`No Nexus: “alleged secondary considerations result from something
`other than what is both claimed and novel in the claim”
`
`Apr. 5, 2017 Ryan Deposition
`
`(Ex. 1070, 64:13-15)
`
`(Ex. 1070, 65:2-5)
`
`19
`
`(Reply, 20-21)
`
`

`

`No Nexus: “alleged secondary considerations result from something
`other than what is both claimed and novel in the claim”
`
`McElveen
`
`(Reply, 21)
`
`(Ex. 2223, 40)
`
`20
`
`

`

`TT’s Evidence Does Not Support
`Secondary Considerations
`
`21
`
`

`

`TT’s Evidence Does Not Support Secondary
`Considerations
`
`INTEX 1984
`
`Gutterman 1990
`
`Weiss 1993
`
`TSE 1998
`
`(Reply, 27)
`
`22
`
`

`

`TT’s Evidence Does Not Support Secondary
`Considerations
`
`Patsystems 1998
`
`(Reply, 27)
`
`(Ex. 2285, 9)
`
`23
`
`

`

`TT’s Evidence Does Not Support
`Secondary Considerations
`
`(Reply, 22-24)
`
`24
`
`(Ex. 2231, 1)
`
`

`

`TT’s Evidence Does Not Support
`Secondary Considerations
`
`(Reply, 24)
`
`(Ex. 1072, 36)
`
`25
`
`

`

`Claim 6, ’768 Patent
`
`Claim 6, ’768 Patent
`
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`
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`
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`
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`.43mm
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`level aleng the p
`indicator
`represents an order
`
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`
`26
`
`i 1
`
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`
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`
`mg
`
`at
`
`the electre
`
`nie
`
`

`

`Claims 7-9, ’768 Patent
`
`Claims 7-9, ’768 Patent
`
`7. The method of claim 6, further comprising sending a
`message to the electronic exchange to delete the order repre-
`sented by the entered order indicator in response to a single
`action of the user input device with a pointer of the user input
`device positioned over the entered order indicator.
`8. The method of claim 7, wherein the single action of the
`user input device that results in sending the message to the
`electronic exchange to delete the order consists of a single
`click of the user input device with the pointer ofthe user input
`device positioned over the entered order indicator.
`
`device positioned over the entered order indicator.
`
`9. The method of claim 8, wherein the single action of the
`user input device that results in sending the message to the
`electronic exchange to delete the order consists of a double
`click of the user input device with the pointer ofthe user input
`
`27
`
`

`

`Claim 11, ’768 Patent
`
`Claim 11, ’768 Patent
`
`11. The method of claim 1, wherein the bid and ask display
`regions are displayed in a windowj the method fin‘ther com-
`prising centering the display ofthe first and second indicators
`
`in the window upon receipt of a centering instruction.
`
`28
`
`

`

`Claim 23, ’768 Patent
`
`Claim 23, ’768 Patent
`
`user input device.
`
`(a) at least one first fixed location corresponding to a first
`price level along the price axis associated with the high-
`est bid price currently available in the market, wherein
`upon receipt ofnew data representing an updated highest
`bid price currently available for the conunodity, the at
`least one first fixed location continues to correspond to
`the first price level even ifthe first price level is no longer
`associated with the highest bid price currently available
`in the market; and
`(b) at least one second fixed location corresponding to a
`second price level along the price axis associated with
`the lowest ask price currently available in the market,
`wherein upon receipt of new data representing an
`updated lowest ask price currently available for the corn-
`ntodity, the at least one second fixed location continues
`to correspond to the second price level even ifthe second
`price level is no longer associated with the lowest ask
`price currently available in the market;
`updating the display of the first indicator such that the first
`indicator is moved relative to the price axis to a different
`area in the bid display region corresponding with a dif-
`ferent price level along the price axis in response to
`receipt of new data representing an updated highest bid
`price currently available for the commodity;
`updating the display of the second indicator such that the
`second indicator is moved relative to the price axis to a
`different area in the ask display region corresponding
`with a different price level along the price axis in
`response to receipt of new data representing an updated
`lowest ask price currently available for the commodity;
`and
`
`23. A computer readable medium having program code
`recorded thereon for execution on a computer for displaying
`market information relating to and facilitating trading of a
`commodity being traded in an electronic exchange on a
`graphical user interface, the program code causing a machine
`to perform the following method steps:
`receiving data relating to the commodity from the elec-
`tronic exchange, the data comprising an inside market
`with a highest bid price and a lowest ask price currently
`available for the commodity;
`dynamically displaying a first indicator in one of a plurality
`of areas in a bid display region, each area in the bid
`display region corresponding to a price level along a
`price axis, the first indicator representing a quantity
`associated with at least one order to buy the commodity
`at the highest bid price;
`dynamically displaying a second indicator in one of a plu-
`rality of areas in an ask display region, each area in the
`ask display region corresponding to a price level along
`the price axis, the second indicator representing a quan-
`tity associated with at least one order to sell the com-
`modity at the lowest ask price;
`displaying an order entry region comprising a plurality of
`locations for receiving single action commands to send
`trade orders, the plurality of locations including:
`
`setting a plurality ofparameters for a trade order relating to
`the commodity and sending the trade order to the elec-
`
`29
`
`