Kyocera Corp. & Motorola Mobility LLC,
`Petitioners,
`v.
`SoftViewLLC,
`Patent Owner.
`
`IPR2013‐00004 / IPR2013‐00257
`IPR2013‐00007 / IPR2013‐00256
`
`SoftView’s Demonstrative Exhibits
`
`SoftView Ex. 2063 (IPR2013‐00004)
`SoftView Ex. 2084 (IPR2013‐00007)
`
`
`Petitioners,
`v.
`SoftViewLLC,
`Patent Owner.
`
`IPR2013‐00004 / IPR2013‐00257
`IPR2013‐00007 / IPR2013‐00256
`
`SoftView’s Demonstrative Exhibits
`
`SoftView Ex. 2063 (IPR2013‐00004)
`SoftView Ex. 2084 (IPR2013‐00007)
`
`
`
`Overview
`
`• The Invention
`• Claim Groups
`• Claim Construction
`• Patentability
`– Prior Art Combinations
`– Objective Evidence of Non‐Obviousness
`• Motion to Exclude
`
`DX1
`
`
`
`Overview
`
`• The Invention
`• Claim Groups
`• Claim Construction
`• Patentability
`– Prior Art Combinations
`– Objective Evidence of Non‐Obviousness
`• Motion to Exclude
`
`DX2
`
`
`
`Gary Rohrabaugh, Inventor
`
`• B.S., Purdue University
`• Worked At Texas Instruments
`(1979‐1982)
`• Started SoftSource In 1982
`‐ CAD Software
`Late 1990s: Mobile Browser
`‐
`• Started SoftView In 2004
`‐
`Successor to SoftSource
`
`Ex. 1025_ 5‐6 (Softview Tutorial)
`
`DX3
`
`
`
`Web Pages Are Designed
`for Desktop Computers
`
`“Much of the Internet
`content has been designed
`for display on [a] desktop
`computer with a single
`target resolution.”
`
`Ex. 1001 (‘353 Patent), Col. 2:4‐5
`
`DX4
`
`
`
`Web Pages Have a Specific
`Look and Feel
`“[M]ajor Internet content providers have
`chosen to create their Web pages using
`fixed resolution structures, such as tables.
`This gives them the ability to control the
`look and feel of their Web sites. . . .
`[F]ixed resolution layout of Web pages
`has become the most common method
`to brand or uniquely identify Web sites.”
`
`Ex. 1001 (‘353 Patent), Col. 2:7‐13 (emphasis added)
`
`DX5
`
`
`
`Mobile Device Screen Size and Resolution
`Are Much Smaller than Desktops
`
`Ex. 1025_17‐18 (SoftView Tutorial)
`
`Ex. 1025_17‐18 (SoftView Tutorial)
`
`DX6
`
`
`
`Desktop Web Pages Could Not Be Properly
`Displayed on Small Screens
`
`• “While this fixed resolution approach is good
`for site branding and product differentiation it
`does present a daunting technical problem for
`display of Internet content (designed for
`desktop computers) on small screen, low
`resolution, or different aspect ratio devices,
`such as cell phones and hand held
`computers.”
`
`Ex. 1001 (‘353 Patent), Col. 2:13‐19 (emphasis added)
`
`DX7
`
`
`
`Failed Approaches To Mobile Browsing
`
`Prior Art Mobile Browsers Did Not Preserve Look
`And Feel Of Web Pages:
`
`• Browsers that Stripped Content of Web Page
`
`• Wireless Application Protocol (“WAP”):
`– Distorted, pared‐down pages for mobile devices
`– The “Baby Web”
`
`Ex. 2003‐39‐41 (Reinman Decl. ¶¶ 122‐123, 129‐131)
`
`DX8
`
`
`
`The SoftView Solution:
`The Real Web For Mobile Devices
`• Browses web pages
`as designed for
`desktop computers
`• Not dumbed‐
`down web pages
`• Context‐based
`zooming for mobile
`devices
`
`Ex. 1002_221, 223 (‘353 File History)
`
`DX9
`
`
`
`The SoftView Solution:
`The Real Web For Mobile Devices
`
`“It is noted that the princip[al]
`developers of the SoftViewTM
`browsers were . . . the inventors
`of the claimed inventions in the
`present application, and the
`SoftViewTM browsers employ
`the . . . techniques disclosed in
`this application.”
`
`Ex. 1002_212 (‘353 File History), Fig. 1A
`
`DX10
`
`
`
`Key to SoftView Patents is Maintaining
`Look and Feel of Desktop Browsing
`
`BRIEF SUMMARY OF THE INVENTION
`“The methods and software enable users of various
`devices, from handheld devices with small screens,
`to desktop PC's and laptops, to very large screen
`devices, to view and interact with Web pages in a
`manner independent of the screen resolution of
`such device's built‐in or associated display, while
`maintaining the look and feel of browsing such
`pages with a conventional desktop browser. Thus,
`users of various devices having different screen
`resolutions are enabled to browse Web pages from
`among literally billions of Web pages while
`providing a full Web browsing experience.”
`
`Ex. 1001 (‘353 Patent), Col. 2:20, 49‐59 (emphasis added)
`
`DX11
`
`
`
`Preserving Layout of Original Web Page
`Makes Mobile Browsing Easier
`
`BRIEF SUMMARY OF THE INVENTION
`“The mobile devices employ novel processing of
`original Web content, including HTML‐based
`content, XML, cascade style sheets, etc. to generate
`scalable content. The scalable content and/or data
`derived therefrom are then employed to enable the
`Web content to be rapidly rendered, zoomed, and
`panned. Moreover, the rendered displays provide
`substantially the same or identical layout as the
`original Web page, enabling users to easily navigate
`to selected content and features on familiar Web
`pages.
`
`Ex. 1001 (‘353 Patent), Col. 2:20‐34 (emphasis added)
`
`DX12
`
`
`
`Preserving Layout of Original Web Page is
`Central to the SoftView Patents
`
`Ex. 1002_221, 223 (‘353 File History)
`
`DX13
`
`
`
`Preserving Layout of Original Web Page
`Is Central to the SoftView Patents
`
`BRIEF SUMMARY OF THE INVENTION
`“Moreover, the rendered displays provide
`substantially the same or identical layout as the
`original Web page, enabling users to easily
`navigate to selected content and features on
`familiar Web pages.”
`
`Ex. 1001 (‘353 Patent), Col. 2:31‐34 (emphasis added)
`
`DX14
`
`
`
`Claims Require Preservation
`
`36. A mobile hand‐held device, comprising:
`
`…r
`
`endering a browser interface via which a user is enabled to request access to a
`Web page comprising HTML‐based Web content defining an original
`page layout, functionality, and design of content on the Web page;
`
`…e
`
`mploying at least one of the scalable content or data derived therefrom to,
`render the Web page on the display; and
`re‐render the display in response to associated user inputs to enable the
`Web page to be browsed at various zoom levels and panned views
`while preserving the original page layout, functionality, and design
`of the Web page content at each zoom level and panned view.
`
`Ex. 1001 (‘353 Patent), Col. 25:31‐57 (emphasis added)
`
`DX15
`
`
`
`SoftView Patents Enable
`Context‐Based Column Zooming
`
`“In addition to directly scaling and
`offsetting content, the client user‐
`interface software for PDA’s
`provides additional functionality.
`For instance, a user may select to
`view a column . . . by tapping that
`column with a stylus, [as] shown in
`FIG. 7A.
`
`Ex. 1001 (‘353 Patent) , Col. 20:56‐60 (emphasis added)
`
`DX16
`
`
`
`SoftView Patents Enable
`Context‐Based Column Zooming
`
`Stylus tapping on column
`
`Column Zoom
`
`Ex. 1001 (‘353 Patent), Figs. 7A and 7B
`
`DX17
`
`
`
`SoftView Patents Enable
`Context‐Based Image Zooming
`
`“[T]he user may select to zoom in
`on an image by tapping the image
`with the stylus, as shown in FIGS.
`8A and 8B.”
`
`Ex. 1001 (‘353 Patent), Col. 20:60‐62 (emphasis added)
`
`DX18
`
`
`
`SoftView Patents Enable
`Context‐Based Image Zooming
`
`Stylus tapping on image
`
`Image Zoom
`
`Ex. 1001 (‘353 Patent), Figs. 8A and 8B
`
`DX19
`
`
`
`SoftView Patents Use
`Scalable Data (Vectors)
`BRIEF SUMMARY OF THE INVENTION
`“The mobile devices employ novel processing of
`original Web content, including HTML‐based
`content, cascade style sheets, etc. to generate
`scalable content. The scalable content and/or
`data derived therefrom are then employed to
`enable the Web content to be rapidly rendered,
`zoomed, and panned. Moreover, the rendered
`displays provide substantially the same or
`identical layout as the original Web page,
`enabling users to easily navigate to selected
`content and features on familiar Web pages.
`
`Ex. 1001 (‘353 Patent), Col. 2:20‐34 (emphasis added)
`
`DX20
`
`
`
`Original HTML‐Based Web Pages
`Have Multiple Objects
`
`Ex. 1001 (‘353 Patent), col. 12:21‐15:31
`
`HTML web pages include objects such as:
`• Frames (212, 214)
`• Table (236A)
`• Forms (255A, 256A)
`
`Ex. 1001 (‘353 Patent), Fig. 4A
`
`DX21
`
`
`
`Original HTML‐Based Web Pages
`Have Multiple Objects
`
`Ex. 1001 (‘353 Patent), Col. 12:21‐15:31
`
`HTML web pages include objects such as:
`• Frames (212, 214)
`• Table (236A)
`• Forms (255A, 256A)
`• Formatted text
`
`Ex. 1001 (‘353 Patent), Fig. 4A
`
`DX22
`
`
`
`SoftView Translates Objects Into
`Scalable Vector Representations
`
`• “Once the page’s
`datum point and an
`object’s datum point
`are known, a vector
`between these two
`points is generated for
`each object in a block.”
`
`Ex. 1001 (‘353 Patent), Col. 17:65‐67
`
`Ex. 1001 (‘353 Patent), Fig. 4D
`
`DX23
`
`
`
`Vector Representations are Used to
`Render Preserved Original Page Layout
`
`Ex. 1002_221, 223 (‘353 File History)
`
`DX24
`
`
`
`Overview
`
`• The Invention
`• Claim Groups
`• Claim Construction
`• Patentability
`– Prior Art Combinations
`– Objective Evidence of Non‐Obviousness
`• Motion to Exclude
`
`DX25
`
`
`
`Claim Group #1 – “Preserving” Claims
`
`• “Preserving Layout, Functionality, and Design”:
`• ‘353 Patent: Claims 1, 33, 36, 43, 48, 51, 52, 58,
`59, 66, 118, 138, 139, 149, 183, 252 and 283
`• ‘926 Patent: Claims 30, 31, 40, 41, 43, 52, 55, 59,
`72, and 75
`
`DX26
`
`
`
`Claim Group #2 – Context Zooming Claims
`
`• Claims Requiring Context‐Based Tap‐to‐Zoom:
`• ‘353 Patent: Claims 48, 51, 52, and 317
`• ‘926 Patent: Claims 31, 40, 41, and 55
`
`DX27
`
`
`
`‘353 Claim 1
`
`1. A wireless device, comprising:
`processing means;
`wireless communications means, to facilitate wireless communication with a network that
`supports access to the Internet;
`a display;
`memory; and
`storage means, in which a plurality of instructions are stored that when executed by the
`processing means enable the wireless device to perform operations including,
`rendering a browser interface via which a user is enabled to request access to an original
`Web page, the Web page comprising HTML‐based Web content having an original
`format defining an original width and height of the Web page and an original page
`layout, functionality, and design of content on the Web page;
`in response to a user request to access the Web page, retrieving the Web page via the
`wireless communication means, and translating at least a portion of the HTML‐based
`Web content from its original format into scalable content that supports a scalable
`resolution‐independent representation of the Web page that preserves the original page
`layout, functionality and design of the content defined by its original format when scaled
`and rendered; and
`scaling the scalable content to render the Web page on the display such that a width of the
`Web page is rendered to fit across the display.
`
`Ex. 1001 (‘353 Patent), Col. 22:15‐43 (emphasis added)
`
`DX28
`
`
`
`‘353 Claim 33
`
`33. The wireless device of claim 1, wherein a portion of the
`scalable content comprises vector‐based content.
`
`Ex. 1001 (‘353 Patent), Col. 25:20‐21
`
`DX29
`
`
`
`‘353 Claim 36
`
`36. A mobile hand‐held device, comprising:
`a processor,
`a wireless communications device, to facilitate wireless communication with a network
`that supports access to the Internet;
`a display; and
`flash memory, operatively coupled to the processor, in which a plurality of instructions
`are stored that when executed by the processor enable the mobile hand‐held device to
`perform operations including,
`rendering a browser interface via which a user is enabled to request access to a Web
`page comprising HTML‐based Web content defining an original page layout,
`functionality, and design of content on the Web page;
`retrieving the Web page via the wireless communications device, and processing
`HTML‐based Web content to produce scalable content; and
`employing at least one of the scalable content or data derived therefrom to,
`render the Web page on the display; and
`re‐render the display in response to associated user inputs to enable the Web
`page to be browsed at various zoom levels and panned views while
`preserving the original page layout, functionality, and design of the Web
`page content at each zoom level and panned view.
`
`Ex. 1001 (‘353 Patent), Col. 25:31‐57 (emphasis added)
`
`DX30
`
`
`
`‘353 Claim 43
`
`43. The mobile hand‐held device of claim 36, wherein at least a
`portion of the scalable content comprises scalable vector‐
`based content.
`
`Ex. 1001 (‘353 Patent), Col. 26:19‐21
`
`DX31
`
`
`
`‘353 Claim 48
`
`48. The mobile hand‐held device of claim 36, wherein
`execution of the instructions performs further operations
`comprising
`
`enabling a user to zoom on a column of the Web content
`via a corresponding user input,
`
`wherein in response thereto, the display is re‐rendered
`such that content corresponding to the selected column
`is rendered to fit across the display.
`
`Ex. 1001 (‘353 Patent), Col. 26:41‐46
`
`DX32
`
`
`
`‘353 Claim 51
`
`51. The mobile hand‐held device of claim 36, wherein
`
`the Web content includes at least one image, and wherein
`
`execution of the instructions performs further operations
`comprising
`
`enabling a user to zoom on an image via a
`corresponding user input,
`
`wherein in response thereto, the display is re‐rendered
`such that the image is rendered to fit across the
`display.
`
`Ex. 1001 (‘353 Patent), Col. 26:54‐60
`
`DX33
`
`
`
`‘353 Claim 52
`
`52. The mobile hand‐held device of claim 51, wherein the
`corresponding user input comprises tapping on the image via
`the display.
`
`Ex. 1001 (‘353 Patent), Col. 26:61‐62
`
`DX34
`
`
`
`‘353 Claim 58
`
`58. The mobile hand‐held device of claim 36, wherein execution of the
`instructions performs further operations comprising:
`parsing HTML‐based code corresponding to the retrieved Web page
`to determine the original page layout of the content on the Web
`page;
`logically grouping selected content into objects;
`defining a primary datum corresponding to the original page layout;
`and,
`for each object,
`defining an object datum corresponding to a layout location
`datum for the object's associated display content;
`generating a vector from the primary datum to the object datum
`for the object; and
`creating a reference that links the object to the vector that is
`generated.
`
`Ex. 1001 (‘353 Patent), Col. 27:27‐42 (emphasis added)
`
`DX35
`
`
`
`‘353 Claim 59
`
`59. The mobile hand‐held device of claim 58, wherein
`execution of the instructions performs further operations
`comprising:
`
`generating a bounding box for each object, the bounding box
`representing a portion of a rendered display page occupied by
`the object's associated group of content.
`
`Ex. 1001 (‘353 Patent), Col. 27:43‐45
`
`DX36
`
`
`
`‘353 Claim 66
`
`66. The mobile hand‐held device of claim 36, wherein a
`portion of the HTML‐based Web content comprises cascaded
`style sheet data defining aspects of the Web page design that
`are preserved at each zoom level and panned view.
`
`Ex. 1001 (‘353 Patent), Col. 28:33‐36
`
`DX37
`
`
`
`‘353 Claim 118
`
`118. A method, comprising:
`rendering a browser interface on a display of a device via which a user is
`enabled to request access to a Web page, the Web page comprising HTML‐
`based Web content having an original format defining an original width and
`height of the Web page and an original page layout, functionality, and
`design of content on the Web page;
`in response to a user request to access the Web page,
`retrieving the Web page via the device, and translating at least a portion of
`the HTML‐based Web content from its original format into scalable
`content that supports a scalable resolution‐independent representation of
`the Web page that preserves the original page layout, functionality and
`design of the content defined by its original format when scaled and
`rendered; and
`scaling the scalable content to render the Web page on the display such that
`a width of the Web page is rendered to fit across the display.
`
`Ex. 1001 (‘353 Patent), Col. 32:28‐45 (emphasis added)
`
`DX38
`
`
`
`‘353 Claim 138
`
`138. The method of claim 118, further comprising:
`parsing markup language code corresponding to the
`retrieved Web page to determine the original page layout
`of the content on the Web page;
`logically grouping selected content into objects;
`defining a primary datum corresponding to the original
`page layout; and,
`for each object,
`defining an object datum corresponding to a layout location
`datum for the object's associated display content;
`generating a vector from the primary datum to the object
`datum for the object; and
`creating a reference that links the object to the vector that
`is generated.
`
`Ex. 1001 (‘353 Patent), Col. 34:6‐19 (emphasis added)
`
`DX39
`
`
`
`‘353 Claim 139
`
`139. The method of claim 138, further comprising: generating
`a bounding box for each object, the bounding box representing
`a portion of a rendered display page occupied by the object's
`associated group of content.
`
`Ex. 1001 (‘353 Patent), Col. 34:20‐23
`
`DX40
`
`
`
`‘353 Claim 149
`
`149. A method, comprising:
`rendering a browser interface on a hand‐held device via which a user is
`enabled to request access to a Web page comprising HTML‐based
`Web content defining an original page layout, functionality, and
`design of content on the Web page;
`retrieving the Web page via the hand‐held device, and processing
`HTML‐based Web content to produce scalable content; and
`employing at least one of the scalable content or data derived
`therefrom to,
`render the Web page on a display of the hand‐held device; and
`re‐render the display in response to associated user inputs to enable the
`Web page to be browsed at various zoom levels and panned views
`while preserving the original page layout, functionality, and design
`of the Web page content at each zoom level and panned view.
`
`Ex. 1001 (‘353 Patent), Col. 35:4‐22 (emphasis added)
`
`DX41
`
`
`
`‘353 Claim 183
`
`183. The method of claim 149, wherein a portion of the
`scalable content comprises vector‐based content.
`
`Ex. 1001 (‘353 Patent), col. 37:54‐55
`
`DX42
`
`
`
`‘353 Claim 252
`
`252. A machine‐readable medium having a plurality of instructions comprising a Web
`browser tangibly stored thereon, which when executed enable a device to
`perform operations comprising:
`rendering a browser interface on a display associated with the device via which a
`user is enabled to request access to a Web page comprising HTML‐based Web
`content defining an original page layout, functionality, and design of content on
`the Web page;
`retrieving the Web page and processing HTML‐based Web content to produce
`scalable content; and
`employing at least one of the scalable content or data derived therefrom to,
`render the Web page on the display; and
`re‐render the display in response to associated user inputs to enable the Web page
`to be browsed at various zoom levels and panned views while preserving the
`original page layout, functionality, and design of the Web page content at each
`zoom level and panned view of the Web page,
`wherein the Web browser enables a user of the device to browse, zoom, and pan
`billions of Web pages in a manner that preserves the original layout, functionality,
`and design of the HTML‐based Web page content of each Web page at each zoom
`level and panned view.
`
`Ex. 1001 (‘353 Patent), Col. 43:18‐43 (emphasis added)
`
`DX43
`
`
`
`‘353 Claim 283
`
`283. The machine‐readable medium of claim 252, wherein
`a portion of the scalable content comprises vector‐based
`content.
`
`Ex. 1001 (‘353 Patent), Col. 46:23‐25
`
`DX44
`
`
`
`‘353 Claim 317
`
`317. A hand‐held wireless device, comprising:
`a processor,
`a wireless communications interface, to facilitate wireless communication with a network that supports access to
`the Internet;
`a display; and
`non‐volatile memory, operatively coupled to the processor, in which software comprising a browser is stored, the
`browser comprising a plurality of instructions that when executed by the processor enable the device to perform
`operations including,
`rendering a browser interface on the display via which a user is enabled to request access to a Web page including
`at least one image, at least one column, at least one hyperlink to an external reference and having a width
`and height;
`retrieving the Web page via the wireless communications interface;
`rendering the Web page on the display such that at least one of the width and height of the Web page is fully
`displayed; and
`enabling the user to,
`zoom and pan a view of the Web page;
`activate a currently displayed hyperlink to an external reference while at a given zoom level and panned
`view, wherein in response to an activation of a hyperlink to an external reference, Web content
`associated with the external reference is retrieved and rendered on the display;
`zoom in on an image of the Web page by tapping on the image via the display;
`zoom in on a column of the Web page by tapping on the column via the display; and
`zoom out to a previous view of the Web page.
`
`Ex. 1001 (‘353 Patent), Col. 48:55‐50:3
`
`DX45
`
`
`
`‘926 Claim 30
`
`30. A mobile phone, comprising:
`a processor,
`wireless communications means operatively coupled to the processor, to facilitate communication with
`a mobile service provider network via which Web content may be accessed;
`a touch‐sensitive display;
`a memory, operatively coupled to the processor; and
`storage means, operatively coupled to the processor, in which a plurality of instructions are stored that
`when executed by the processor enable the mobile phone to perform operations including,
`rendering a browser interface via which a user is enabled to request to access to a Web page
`having an original format comprising HTML‐based content defining an original page
`layout, functionality, and design of content on the Web page;
`retrieving HTML‐based content associated with the Web page;
`translating at least a portion of the HTML‐based content from its original format to produce
`translated content including scalable vector‐based content that supports a scalable
`resolution‐independent representation of the HTML‐based content that preserves an
`original page layout, functionality and design of the at least a portion of the HTML‐based
`content when scaled and rendered; and
`employing the scalable vector‐based content to render a view of at least a portion of the Web
`page on the display using a first scale factor, wherein preservation of the functionality
`defined by the HTML‐based content includes preservation of hyperlink functionality.
`
`Ex. 1001 (‘926 Patent), Col. 26:1‐34 (emphasis added)
`
`DX46
`
`
`
`‘926 Claim 31
`
`31. The mobile phone of claim 30, wherein execution of the
`instructions performs further operations comprising
`
`enabling the user to zoom in on a user‐selectable portion of a
`display of the Web page in response to a user interface input made
`via the touch‐sensitive display.
`
`Ex. 1001 (‘926 Patent), Col. 26:35‐39
`
`DX47
`
`
`
`‘926 Claim 40
`
`40. The mobile phone of claim 30, wherein execution of the
`instructions performs further operations comprising
`
`enabling a user to view a column of the Web content at a higher
`resolution than a current resolution by tapping on the column via
`the touch‐sensitive display, wherein in response thereto, the display
`is re‐rendered such that content corresponding to the selected
`column is displayed to fit across the touch‐sensitive display.
`
`Ex. 1001 (‘926 Patent), Col. 27:28‐35
`
`DX48
`
`
`
`‘926 Claim 41
`
`41. The mobile phone of claim 30,
`
`wherein the Web content includes at least one image, and
`
`wherein execution of the instructions performs further operations
`comprising enabling a user to view an image at a higher resolution
`than a current resolution by tapping on the image via the touch‐
`sensitive display, wherein in response thereto, the display is re‐
`rendered such that the image is displayed to fit across at least one
`of a width and height of a display area of the touch‐sensitive
`display.
`
`Ex. 1001 (‘926 Patent), Col. 27:36‐44
`
`DX49
`
`
`
`‘926 Claim 43
`
`43. The mobile phone of claim 30, wherein execution of the
`instructions performs further operations comprising:
`
`generating a display list associated with the scalable vector‐
`based content; and
`
`employing the display list to re‐render the display at different
`scale factors to enable rapid zooming of the Web
`page.
`
`Ex. 1001 (‘926 Patent), Col. 27:55‐61
`
`DX50
`
`
`
`‘926 Claim 52
`
`52. A mobile device, comprising:
`a processor,
`wireless communications means, to facilitate wireless communication with a network via which
`Web content may be accessed;
`a touch‐sensitive display;
`flash memory, operatively coupled to the processor, in which a plurality of instructions are stored
`that when executed by the processor enable the mobile device to perform operations including,
`rendering a browser interface via which a user is enabled to request access to a Web page
`comprising HTML‐based Web content defining an original page layout, functionality, and
`design of content on the Web page;
`retrieving and processing the HTML‐based Web content to produce scalable content; and
`employing the scalable content and/or data derived therefrom to,
`render a view of the Web page on the touch‐sensitive display; and
`re‐render the Web page in response to associated user inputs to enable the user to
`iteratively zoom in and out views of the Web page while preserving an original page
`layout, functionality, and design defined by the HTML‐based Web content as
`interpreted by a rendering engine,
`wherein preservation of the functionality defined by the HTML‐based Web content includes
`preservation of hyperlink functionality.
`
`Ex. 1001 (‘926 Patent), Col. 29:7‐35 (emphasis added)
`
`DX51
`
`
`
`‘926 Claim 55
`
`55. The mobile device of claim 52, wherein execution of the
`instructions performs further operations comprising
`
`enabling the user to zoom in on a user‐selectable portion of a
`display of the Web page in response to a user interface input
`made via the touch‐sensitive display.
`
`Ex. 1001 (‘353 Patent), Col. 29:41‐45
`
`DX52
`
`
`
`‘926 Claim 59
`
`59. The mobile device of claim 52, wherein at least a
`portion of the scalable content comprises scalable vector‐
`based content.
`
`Ex. 1001 (‘353 Patent), Col. 29:63‐65
`
`DX53
`
`
`
`‘926 Claim 72
`
`72. The mobile device of claim 52, wherein execution of the instructions
`performs further operations comprising:
`parsing HTML‐based code corresponding to the received Web content to
`identify content on the Web page;
`logically grouping selected content into objects;
`defining a primary datum corresponding to the original page layout; and,
`for each object,
`defining an object datum corresponding to a layout location
`datum for the object's associated display content;
`generating a vector from the primary datum to the object
`datum for the object; and
`creating a reference that links the object to its corresponding
`vector.
`
`Ex. 1001 (‘353 Patent), Col. 31:18‐31
`
`DX54
`
`
`
`‘926 Claim 75
`
`75. The mobile device of claim 52, wherein the original
`format of the Web page defines a width for the Web page, and
`wherein execution of the instructions performs further
`operations comprising:
`
`determining an applicable scale factor to fit the width of the
`Web page across a display area of the touch‐sensitive
`display; and
`
`employing the scale factor to render the display area.
`
`Ex. 1001 (‘353 Patent), Col. 31:41‐48
`
`DX55
`
`
`
`Overview
`
`• The Invention
`• Claim Groups
`• Claim Construction
`• Patentability
`– Prior Art Combinations
`– Objective Evidence of Non‐Obviousness
`• Motion to Exclude
`
`DX56
`
`
`
`The Parties’ Proposed Constructions
`
`SoftView
`Preserving the “original
`layout” requires preserving
`the layout as designed for
`a desktop computer
`
`Kyocera & Motorola
`Preserving the “original
`layout” includes preserving
`the layout as interpreted
`by the browser
`
`SoftView’s Claim Construction Brief (Paper No. 37),
`at 1 (IPR2013‐00007)
`
`Petitioners’ Claim Construction Brief (Paper No. 36),
`at 5 (IPR2013‐00007)
`
`DX57
`
`
`
`SoftView’s Construction Requires Preserving Web
`Page As Designed For A Desktop Computer
`
`Desktop
`
`Mobile
`
`Zoom
`
`Ex. 2030 (screenshots)
`
`DX58
`
`
`
`Petitioners’ Construction Does Not Require Preserving
`Web Page As Designed for A Desktop Computer
`
`Mobile
`
`Zoom
`
`Desktop
`
`SoftView’s Claim Construction Brief (Paper No. 37), at 1‐3 (IPR2013‐00007)
`
`DX59
`
`
`
`“Original Page Layout” is a Web Page as Viewed
`on a Conventional Desktop Browser
`
`SoftView’s construction is supported by:
`• Claim language
`• Specification
`• Prosecution history
`
`DX60
`
`
`
`Exemplar ‘353 Claim Requires
`Preserving Original Page Layout
`
`1. A wireless device, comprising:
`. . .
`a plurality of instructions . . . to perform operations including,
`rendering a browser interface via which a user is enabled to request access to
`an original Web page,
`the Web page comprising HTML‐based Web content having an original
`format defining an original width and height of the Web page and
`an original page layout, functionality, and design of content on the Web
`page;
`in response to a user request to access the Web page, retrieving . . . and
`translating at least a portion of the HTML‐based Web content from its
`original format into scalable content that supports a scalable resolution‐
`independent representation of the Web page that preserves the original
`page layout, functionality and design of the content defined by its
`original format when scaled and rendered;
`
`. . .
`
`Ex. 1001 (‘353 Patent), Col. 22:15‐43 (emphasis added)
`
`DX61
`
`
`
`Exemplar ‘926 Claim Requires
`Preserving Original Page Layout
`
`30. A mobile phone, comprising:
`. . .
`a plurality of instructions . . . to perform operations including,
`rendering a browser interface via which a user is enabled to request to
`access to a Web page having an original format comprising
`HTML‐based content defining an original page layout,
`functionality, and design of content on the Web page;
`
`. . .
`translating at least a portion of the HTML‐based content from its
`original format to produce translated content including scalable
`vector‐based content that supports a scalable resolution‐
`independent representation of the HTML‐based content that
`preserves an original page layout, functionality and design of the
`at least a portion of the HTML‐based content when scaled and
`rendered; and
`
`. . .
`
`Ex. 1001 (‘926 Patent), Col. 26:1‐33 (emphasis added)
`
`DX62
`
`
`
`“Original Page Layout” is a Web Page as Viewed
`on a Conventional Desktop Browser
`
`BRIEF SUMMARY OF THE INVENTION
`“The methods and software enable users of
`various devices, from handheld devices with
`small screens, to desktop PC's and laptops, to
`very large screen devices, to view and interact
`with Web pages in a manner independent of
`the screen resolution of such device's built‐in
`or associated display, while maintaining the
`look and feel of browsing such pages with a
`conventional desktop browser.”
`
`Ex. 1001 (‘353 Patent), Col. 2:20, 49‐56 (emphasis added)
`
`DX63
`
`
`
`“Original Page Layout” is a Web Page as Viewed
`on a Conventional Desktop Browser
`
`BRIEF SUMMARY OF THE INVENTION
`“Moreover, the rendered displays
`provide substantially the same or
`identical layout as the original Web
`page, enabling users to easily
`navigate to selected content and
`features on familiar Web pages.
`
`Ex. 1001 (‘353 Patent), Col. 2:20, 31‐34 (emphasis added)
`
`DX64
`
`
`
`“Original Page Layout” is a Web Page as Viewed
`on a Conventional Desktop Browser
`
`ABSTRACT
`“Moreover, the rendered displays
`provide substantially the same or
`identical layout as the original Web
`page, enabling users to easily
`navigate to selected content and
`features on familiar Web pages.
`
`Ex. 1001 (‘353 Patent), Abstract (emphasis added)
`
`DX65
`
`
`
`Prosecution History Supports
`SoftView’s Construction
`
`Ex. 1002_206‐207 (‘353 File History, Remarks of SoftView) (highlight and red underline added)
`
`DX66
`
`
`
`Prosecution History Supports
`SoftView’s Construction
`
`Ex. 1002_218 (‘353 File History, Remarks of SoftView) (highlight and red underline added)
`
`DX67
`
`
`
`Prosecution History Supports
`SoftView’s Construction
`
`Ex. 1002_433 (‘353 File History, Remarks of SoftView) (highlight added)
`
`DX68
`
`
`
`Prosecution History Supports SoftView’s
`Construction
`
`Desktop
`
`Mobile
`
`Ex. 1002_221, 223 (‘353 File History)
`
`DX69
`
`
`
`Examiner’s Understanding Consistent
`With SoftView’s Construction
`
`Notice of Allowance, ‘353 Patent File History
`
`Ex. 1002_55 (‘353 File History, Examiner’s Statements) (highlight and red underline added)
`
`DX70
`
`
`
`Petitioners’ Construction is Contrary
`to Teachings of Patents
`
`• Reads out the claim requirement of preserving
`the original page layout
`• Merely requires preserving the layout as
`initially rendered by the device, regardless of
`how much the device has altered the original
`page layout on a conventional desktop browser
`• Improperly covers mobile browsers that strip
`out a web page’s original layout, functionality
`and design
`
`DX71
`
`
`
`Petitioners’ Construction is Contrary
`to Teachings of Patents
`
`BRIEF SUMMARY OF THE INVENTION
`“The methods and software enable users of
`various devices, from handheld devices with
`small screens, to desktop PC's and laptops, to
`very large screen devices, to view and interact
`with Web pages in a manner independent of
`the screen resolution of such device's built‐in
`or associated display, while maintaining the
`look and feel of browsing such pages with a
`conventional desktop browser.”
`
`Ex. 1001 (‘353 Patent), Col. 2:20, 49‐56 (emphasis added)
`
`DX72
`
`
`
`Petitioners’ Belated Constr
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