IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`March 7, 2005
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`August 7, 2007
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`In re U.S. Patent No. 7,254,621
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`Filed:
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`Issued:
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`Inventor: Singhal et al.
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`Assignee: Clouding IP, LLC
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`Title:
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`Technique for Enabling Remote Data Access and Manipulation from
`a Pervasive Device
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`
`
`Mail Stop PATENT BOARD, PTAB
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`
`
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,254,621
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. § 42.100 ET SEQ.
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`i
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`TABLE OF CONTENTS
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`TABLE OF CONTENTS ............................................................................................................. ii
`EXHIBIT LIST ............................................................................................................................ iv
`I.
`INTRODUCTION ................................................................................................................. 1
`II. MANDATORY NOTICES ................................................................................................... 3
`A. Real Party-In-Interest .................................................................................................... 3
`B. Related Maters ................................................................................................................ 3
`C. Lead And Back-Up Counsel ........................................................................................... 3
`D.
`Service Information ........................................................................................................ 3
`III. PAYMENT OF FEES ........................................................................................................... 4
`IV. REQUIREMENTS FOR INTER PARTES REVIEW ........................................................ 4
`A. Grounds For Standing .................................................................................................... 4
`B.
`Identification of Challenge ............................................................................................. 5
`1. The Specific Art and Statutory Ground(s) on Which the Challenge is Based ........ 5
`2. How the Construed Claims Are Unpatentable Under the Statutory Grounds
`Identified in 37 C.F.R. § 42.204(B)(2) and Supporting Evidence Relied upon to
`Support the Challenge .................................................................................................. 6
`V. FACTUAL BACKGROUND ............................................................................................... 6
`A. Declaration Evidence ...................................................................................................... 6
`B.
`The State of the Art......................................................................................................... 7
`C. The ‘437 Patent Application .......................................................................................... 9
`D.
`Prosecution History of the ‘621 Patent ....................................................................... 11
`VI. BROADEST REASONABLE CONSTRUCTION ........................................................... 11
`A. Reference ....................................................................................................................... 12
`B.
`Location ......................................................................................................................... 13
`VII. REPRESENTATIVE PROPOSED REJECTIONS SHOWING THAT PETITIONER
`HAS A REASONABLE LIKELIHOOD OF PREVAILING ................................................. 14
`A. Claims 1-9 and 17 are Anticipated by Schilit under 35 U.S.C. § 102(e) .................. 14
`B. Claims 1-9 and 17 are Rendered Obvious by Flynn in View of Schilit Under 35
`U.S.C. § 103.................................................................................................................... 28
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`ii
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`C. Claims 1-9 and 17 are Rendered Obvious by Barrett in view of Schilit Under 35
`C.
`Claims 1-9 and 17 are Rendered Obvious by Barrett in view of Schilit Under 35
`U.S.C. § 103.................................................................................................................... 45
`U.S.C. § 103 .................................................................................................................. .. 45
`VIII. CONCLUSION ............................................................................................................. 58
`VIII.
`CONCLUSION ........................................................................................................... .. 58
`CERTIFICATE OF SERVICE ................................................................................................. 59
`CERTIFICATE OF SERVICE ............................................................................................... .. 59
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`EXHIBIT LIST
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`U.S. Patent No. 7,254,621 to Singhal et al.
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`Excerpts from the Prosecution History of Application No.
`11/075,437, which matured into the ‘621 patent.
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`U.S. Patent No. 6,670,968 to Schilit et al.
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`Flynn, M., et al., “The Satchel System Architecture: Mobile
`Access to Documents and Services,” Mobile Networks and
`Applications, Vol. 5 (December 2000).
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`Barrett, R., et al., “Intermediaries: New Places for Producing
`and Manipulating Web Content,” Computer Networks and
`ISDN Systems, Vol. 30 (April 1998).
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`U.S. Patent No. 6,925,481 to Singhal et al.
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`Declaration of Dr. Benjamin B. Bederson, Ph.D.
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`1001
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`1002
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`1003
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`1004
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`1005
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`1006
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`1007
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`I.
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`INTRODUCTION
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`Petitioner Oracle Corporation (“Oracle” or “Petitioner”) respectfully
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`requests inter partes review for claims 1-9 and 17 of U.S. Patent No. 7,254,621
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`(the “‘621 patent,” attached as Ex. 1001) in accordance with 35 U.S.C. §§ 311–319
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`and 37 C.F.R. § 42.100 et seq.
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`The ‘621 patent, which is a continuation of U.S. Patent No. 6,925,481
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`(subject to a separate inter partes review request), is generally directed to methods
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`and systems for enabling pervasive computing devices (e.g., the Palm Pilot PDA or
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`the Compaq iPAQ Home Internet Appliance IA-1(Ex. 1001 at 1:30-35, 2:30-32))
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`to access and manipulate data, such as, for example, an internet web page or a
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`document stored on a file server. (See id. at 3:31-38). More particularly, the ‘621
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`patent is directed to methods, computer program products, and systems wherein a
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`series of proxy servers are used to (1) obtain data that was requested by a pervasive
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`device, and (2) return information regarding one or more data manipulation
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`operations (e.g., printing and faxing) determined to be available for the obtained
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`data. (See, e.g., id. at 3:31-42, claim 1).
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`As demonstrated by various references which were not before the Examiner,
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`this technique was developed and published years prior to the earliest effective
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`filing date of the ‘621 patent. For instance, by 1997 proxy servers were being used
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`to transform web page content for optimized display on web browsers. (Ex. 1007
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`1
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`at ¶ 21). Moreover, by the mid-1990s, context-aware or location based computing
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`had rapidly spread across the academic community, leading to the development of
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`the “ParcTab” mobile computer. (Id. at ¶¶ 22-24). ParcTab allowed users to
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`wirelessly share a document with other nearby devices or manipulate a document –
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`by faxing or printing it – to a nearby printer or fax machine. (Id.)
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`The natural progression of this research led to the development of various
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`proxy based systems in which data requested by a pervasive device was not only
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`manipulated for optimal display on the requesting device, but also linked to
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`services that could print or fax the requested data. For instance, U.S. Patent No.
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`6,670,968 to Schilit et al. (“Schilit,” Ex. 1003) discloses a server which, in
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`response to a data access request received from a mobile device, obtains the
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`requested web documents, parses the content into selectable hyperlinks, and
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`determines “situation, or context-appropriate services, such as printing or faxing,”
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`which may be carried out on the obtained data. (Ex. 1003 at 5:30-51; Ex. 1007 at
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`¶¶ 35, 36).
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`Schilit and similar references were not before the Examiner during
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`prosecution of the ‘621 patent. These references anticipate or render obvious the
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`challenged claims of the ‘621 patent, as shown in the following discussion.
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`II. MANDATORY NOTICES
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`Pursuant to 37 C.F.R. § 42.8(a)(1), Oracle provides the following mandatory
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`disclosures.
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`A. Real Party-In-Interest
`Pursuant to 37 C.F.R. § 42.8(b)(1), Petitioner certifies that Oracle is the real
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`party-in-interest.
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`B. Related Maters
`Pursuant to 37 C.F.R. § 42.8(b)(2), Petitioner states that the ‘621 Patent is
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`asserted in co-pending litigation captioned Clouding IP, LLC v. Oracle Corp.,
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`D.Del., Case No. 1:12-cv-00642. This litigation remains pending. The patents-in-
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`suit are U.S. Patents 6,631,449; 6,918,014; 7,596,784; 7,065,637; 6,738,799;
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`5,944,839; 5,825,891; 5,678,042; 5,495,607; 7,254,621; 6,925,481. This IPR
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`petition is directed to U.S. Patent 7,254,621; however, petitions corresponding to
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`the remaining patents will be filed in the forthcoming weeks.
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` 
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`C. Lead And Back-Up Counsel
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`Pursuant to 37 C.F.R. § 42.8(b)(3), Petitioner provides the following
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`designation of counsel: Lead counsel is Greg Gardella (Reg. No. 46,045) and
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`back-up counsel is Scott A. McKeown (Reg. No. 42,866).
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`Service Information
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`D.
`Pursuant to 37 C.F.R. § 42.8(b)(4), papers concerning this matter should be
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`served on the following.
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`3
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`Address: Greg Gardella or Scott McKeown
`Oblon Spivak
`1940 Duke Street
`Alexandria, VA 22314
`cpdocketgardella@oblon.com and
`cpdocketmckeown@oblon.com
`Telephone: (703) 413-3000
`Fax:
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`(703) 413-2220
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`Email:
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`III. PAYMENT OF FEES
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`The undersigned authorizes the Office to charge $27,200 to Deposit Account
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`No. 15-0030 as the fee required by 37 C.F.R. § 42.15(a) for this Petition for inter
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`partes review. The undersigned further authorizes payment for any additional fees
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`that might be due in connection with this Petition to be charged to the above
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`referenced Deposit Account.
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`IV. REQUIREMENTS FOR INTER PARTES REVIEW
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`As set forth below and pursuant to 37 C.F.R. § 42.104, each requirement for
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`inter partes review of the ‘621 patent is satisfied.
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`A. Grounds For Standing
`Pursuant to 37 C.F.R. § 42.104(a), Petitioner hereby certifies that the ‘621
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`patent is available for inter partes review and that the Petitioner is not barred or
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`estopped from requesting inter partes review challenging the claims of the ‘621
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`patent on the grounds identified herein. The ‘621 patent has not been subject to a
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`previous estoppel based proceeding of the AIA and the complaint served on Oracle
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`referenced above in Section II(B) was served within the last 12 months.
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`B.
`Identification of Challenge
`Pursuant to 37 C.F.R. §§ 42.104(b) and (b)(1), Petitioner requests inter
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`partes review of claims 1-9 and 17 of the ‘621 patent, and that the Patent Trial and
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`Appeal Board (“PTAB”) invalidate the same.
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`1.
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`The Specific Art and Statutory Ground(s) on Which the
`Challenge is Based
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`Pursuant to 37 C.F.R. § 42.204(b)(2), inter partes review of the ‘621 patent
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` 
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`is requested in view of the following references, each of which is prior art to the
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`‘621 patent under 35 U.S.C. § 102(a), (b), and/or (e):
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`(1) U.S. Patent No. 6,670,968 to Schilit et al. (“Schilit,” Ex. 1003), issued
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`December 30, 2003 from an application filed July 10, 2000. Schilit is prior art to
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`the ‘621 patent under at least 35 U.S.C. § 102(e).
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`(2)
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`The Satchel System Architecture: Mobile Access to Documents and
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`Services by Flynn, M., et al. (“Flynn,” Ex. 1004) published December 2000 in
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`Mobile Networks and Applications, Vol. 5, Issue 4, pgs. 243-258. Flynn is prior
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`art to the ‘621 patent under at least 35 U.S.C. § 102(a).
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`(3)
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`Intermediaries: New Places For Producing And Manipulating Web
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`Content by Barrett, R., et al. (“Barrett,” Ex. 1005) published April 1998 in
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`Computer Networks and ISDN Systems, volume 30, pgs. 509-518. Barrett is prior
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`art to the ‘621 patent under at least 35 U.S.C. § 102(b).
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`Schilit (Ex. 1003) anticipates claims 1-9 and 17 of the ‘621 patent under 35
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`U.S.C. § 102(e).
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`Flynn (Ex. 1004) taken in view of Schilit renders obvious claims 1-9 and 17
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`of the ‘621 patent under 35 U.S.C. § 103.
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`Barrett (Ex. 1005) taken in view of Schilit renders obvious claims 1-9 and
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`17 of the ‘621 patent under 35 U.S.C. § 103.
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`2.
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`How the Construed Claims Are Unpatentable Under the
`Statutory Grounds Identified in 37 C.F.R. § 42.204(B)(2)
`and Supporting Evidence Relied upon to Support the
`Challenge
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`Pursuant to 37 C.F.R. § 42.204(b)(4), an explanation of how claims 1-9 and
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`  
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`17 of the ‘621 patent are unpatentable under the statutory grounds identified above,
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`including the identification of where each element of the claim is found in the prior
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`art, is provided in Section VII, below, in the form of claims charts. Pursuant to 37
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`C.F.R. § 42.204(b)(5), the exhibit numbers of the supporting evidence relied upon
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`to support the challenges and the relevance of the evidence to the challenges
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`raised, including identifying specific portions of the evidence that support the
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`challenges, are provided in Section VII, below, in the form of claim charts.
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`V.
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`FACTUAL BACKGROUND
`A. Declaration Evidence
`This Petition is supported by the declaration of Professor Benjamin B.
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`Bederson from the University of Maryland. (Ex. 1007). Prof. Bederson offers his
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`opinion with respect to the content and state of the prior art.
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`Prof. Bederson is a Professor in the Computer Science Department and the
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`Institute of Advanced Computer Studies at the University of Maryland. Prof.
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`Bederson is also Co-Founder and Chief Scientist for Zumobi, Inc., a venture
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`capital funded startup created to commercialize mobile media for cell phones, and
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`the Co-Founder and Technical Director for the International Children’s Digital
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`Library Foundation, which provides free online children’s books to its members.
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`(Ex. 1007 at ¶ 1). Prof. Bederson is the author or co-author of 10 book chapters
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`and over 100 technical articles directed to web browsing, mobile computing, user
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`interfaces, user experience, and the software and technology underlying these
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`systems. (Id. at ¶ 9). Prof. Bederson is also a co-inventor on 7 U.S. patents
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`generally directed to user interfaces/experience. (Id. at ¶ 5). In 2011, Prof.
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`Bederson was recognized as an Association of Computing Machinery (“ACM”)
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`distinguished scientist and elected to the Computer-Human Interaction (“CHI”)
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`Academy for his substantial contributions made in the field of CHI. (Id. at ¶ 7).
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`Prof. Bederson is also one of the principal inventors of the PadPrints’ proxy-based
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`web browser that offered a graphical web history to users by visually showing
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`what web pages a user had visited. (Id. at ¶ 19).
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`The State of the Art
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`B.
`Proxies work by intercepting all web traffic coming from and going to a web
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`browser and, once intercepted, the proxy can manipulate the requested web page in
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`any number of different ways. (Ex. 1007 at ¶ 19). By 1997, proxy servers were
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`being used to modify web content based on the location of the client computer and
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`to automatically re-author a web page designed for a desktop computer to
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`appropriately display on a mobile web browser. (Id. at ¶ 21). By 1998, web
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`proxies were enhanced to automatically manipulate requested content by “adding
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`annotations, highlighting links, adding toolbars, translating document format (e.g.,
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`from Rich Text Format to HTML), changing form information, and adding scripts”
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`all before returning the content to the requesting device. (Id. at ¶ 44).
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`Ubiquitous computing was developing in parallel with the aforementioned
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`proxies. Ubiquitous computing was based on broadly available mobile computing
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`devices. (Id. at ¶ 22). These devices, known as “Tabs” or “Pads,” continually
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`tracked their location and, based on the device’s sensed location, offered various
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`services to the user, such as document sharing, printing, or faxing. (Id. at ¶¶ 22-
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`25). The ubiquitous computing field quickly evolved into calling its work “context
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`aware computing” upon the realization that location awareness, and the ability of a
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`mobile device to interact with nearby printers, displays, facsimiles, etc. was at the
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`core of the technology. (Id. at ¶ 28).
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`With this deep research focus in mobile web browsing and contextual
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`computing, the natural and obvious technological progression was to put all of
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`these features together to offer mobile, web-based contextualized document
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`services. (Id. at ¶¶ 30, 31). In this manner, rather than simply returning a
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`requested web page that has been optimized for display on a requesting device, the
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`returned data could also be contextualized, such that nearby services (e.g., printing
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`and faxing) could be executed. (Id.) For instance, U.S. Patent No. 6,670,968 to
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`Schilit et al. (“Schilit,” Ex. 1003) discloses a server which, in response to a data
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`access request received from a mobile device, obtains the requested web document,
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`parses the content into selectable hyperlinks, and determines “situation, or context-
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`appropriate services, such as printing or faxing,” which may be carried out on the
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`obtained data. (Ex. 1003 at 5:30-51; Ex. 1007 at ¶¶ 35, 36).
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`C. The ‘437 Patent Application
`Application No. 11/075,437 (“the ‘437 application”) was filed March 7,
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`2005, as a continuation of Application No. 08/848,394, which matured into U.S.
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`Patent No. 6,925,481 (“the ‘481 patent,” attached as Ex. 1006). Petitioner has filed
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`a separate inter partes review petition directed to the claimed subject matter of the
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`‘481 patent. The ‘437 application discussed methods, computer program products,
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`and systems for enabling pervasive computing devices to access and manipulate
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`data, such as, for example, content stored on a web server, or a document stored on
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`a file server. (See, e.g., Ex. 1001 at 3:32-42). First, the pervasive device submits a
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`request for information (e.g., through a web browser), which is received by a
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`protocol proxy. (See id. at 6:38-46, 10:21-26). Second, the protocol proxy
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`forwards the data request from the pervasive device to the appropriate information
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`source, such as a web server. (See id. at 5:46-60, 10:33-39). Third, after receiving
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`the requested data from the appropriate information source, the protocol proxy, by
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`querying a data manipulation server (“DMS”), determines what services are
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`available to manipulate the retrieved content. (See id. at 10:39-57). The DMS
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`maintains a repository of available services for different types of data (See id. at
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`7:55-61) and forwards content to be manipulated to the appropriate output agent.
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`(See id. at 7:19-28). Services may include, for example, printing, faxing, or e-
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`mailing the retrieved content. (See id. at 3:38-42). Fourth, the protocol proxy
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`forwards the retrieved content, along with a list of available services, to the
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`requesting device. (See id. at 15:58-60, Fig. 1, message flow 7).
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`It is with respect to steps three and four described above that the independent
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`claims of the ‘481 patent differ from the independent claims of the ‘437
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`application. For example, the third and fourth steps of claim 1 of the ‘481 patent
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`are directed to the process described above. (See Ex. 1006 at claim 1).
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`Specifically, claim 1 of the ‘481 patent requires “determining what data
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`manipulation operations are available for the obtained data, as well as a location of
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`each available data manipulation operation;” and “returning the determined data
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`manipulation operations and locations to the pervasive device, in addition to the
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`obtainedd data.” (IId.) Howevver, the eqquivalent liimitations oof claim 1
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`of the ‘43
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`perations aare availabble
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`applicattion require “determiining what data maniipulation o
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`for the oobtained data;” and ““providing referencess to the dettermined ddata
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`manipulation operrations to tthe pervasiive device.
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`” (See Ex.. 1002 at ‘4437
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`tion transmmittal claimm set) (empphasis addded). As wwill be desccribed in
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`VI, beloww, the term “referencees” is not uused or deffined in thee specificattion.
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`D.
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`Prosecuttion History of the ‘‘621 Patennt
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`CClaims 1-244 of the ‘4337 applicattion were aallowed affter the appplicant filedd a
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`terminaal disclaimeer to overccome a nonnstatutory oobviousnesss-type douuble patentting
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`rejectionn based onn the ‘481 ppatent. (Exx. 1002 at
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`January 88, 2007 Offfice Action,,
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`Januaryy 26, 2007 applicant response).. The Januuary 8, 20007 Office AAction
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`includinng the folloowing stateement regaarding the tteachings oof the priorr art:
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`(Id. at JJanuary 8, 2007 Officce Action). The ‘4377 applicatioon issued aas U.S. Pat
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`ent
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`No. 7,254,621, thee subject oof the instannt petition..
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`N RUCTIONCONSTRONABLE ST REASOVI. BBROADES
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`PPursuant to 37 C.F.R. § 42.204((b)(3), the cclaims subbject to inteer partes
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`review sshall receivve the “brooadest reassonable connstruction
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`specificcation of thhat patent inn which [thhey] appeaar[].” See 442 C.F.R.
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`in light of f the
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`§ 100(b).
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`11
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`Because the standards of claim interpretation used by the federal courts are
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`different from the standards used by the Patent Office in claim examination
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`proceedings (including this inter partes review), any claim interpretations used or
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`applied in these proceedings are neither binding upon Petitioner in patent
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`infringement litigation or on any other litigants, nor do such claim interpretations
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`correspond to the construction of claims under the legal standards used by the
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`courts. Accordingly, any interpretation of claims presented either implicitly or
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`explicitly herein should not be viewed as constituting, in whole or in part,
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`Petitioner’s own interpretation and/or construction of such claims for the purposes
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`of litigation. Instead, any constructions in this proceeding should be viewed only
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`under the “broadest reasonable construction” standard required here.
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`All claimed terms not specifically addressed in this section have been
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`accorded their broadest reasonable interpretation in light of the patent specification
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`including their plain and ordinary meaning. None of the challenged claims
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`contains a means-plus-function or step-plus-function limitation.
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`A. Reference
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`Challenged claims 1, 8, 9, and 17 recite “providing references to the
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`determined data manipulation operations to the pervasive device.” The
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`specification does not use the term “reference” as it pertains to returning
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`determined data manipulation operations to a pervasive device. Webster’s Third
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`12
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`New International Dictionary (unabridged) defines reference as “something that
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`refers to something else.” Thus, under the broadest reasonable interpretation of
`
`this limitation in light of the ‘621 patent’s specification, the term reference refers
`
`to an identifier, such as a URL link, that provides a way of locating and accessing
`
`the determined data manipulation operations. (See Ex. 1001 at 8:62 – 9:1; Ex.
`
`1007 at ¶¶ 17-18).
`
`B. Location
`
`Claim 6 requires “determining a current location of the pervasive device;
`
`and determining what data manipulation operations are available for the current
`
`location of the pervasive device.” Viewed in light of the specification and given its
`
`usage in the claims, the term “location” most closely corresponds to a physical
`
`location of the pervasive device. (See Ex. 1001 at 11:32-37 (“When information
`
`about the location of the WID is used as a factor in determining available services,
`
`this location information may also be obtained in various ways … for example, []
`
`by querying a global positioning system (“GPS”) function on the client...). This is
`
`in contrast to the construction of this term provided in the co-pending inter partes
`
`review petition of the ‘481 patent which, in light of the term’s usage in that patent,
`
`broadly corresponded to a URL or other similar network address. (See e.g., id. at
`
`9:16-20; Ex. 1007 at ¶ 15).
`
`
`
`13
`
`

`

`VII. REPRESENTATIVE PROPOSED REJECTIONS SHOWING THAT
`PETITIONER HAS A REASONABLE LIKELIHOOD OF
`PREVAILING
`
`The references addressed below each provide the teaching believed by the
`
`
`
`Examiner to be missing from the prior art and variously anticipate or render
`
`obvious the claimed subject matter. It should be understood that rejections may be
`
`premised on alternative combinations of these same references.
`
`A.
`
`Claims 1-9 and 17 are Anticipated by Schilit under 35
`U.S.C. § 102(e)
`
`U.S. Patent No. 6,670,968 to Schilit et al. (“Schilit,” Ex. 1003) was not
`
`considered during the original prosecution of the ‘621 or ‘481 patents, nor is it
`
`cumulative of any prior art considered by the Examiner. Schilit was filed July 10,
`
`2000 and issued December 30, 2003. The effective filing date of the ‘621 patent is
`
`May 3, 2001, which is the filing date of the ‘481 patent. Therefore, Schilit is
`
`available as prior art against all claims of the ‘621 patent under 35 U.S.C. § 102(e).
`
`The following claim chart demonstrates, on a limitation-by-limitation basis, how
`
`claims 1-9 and 17 of the ‘621 patent are anticipated by Schilit under 35 U.S.C. §
`
`102(e). (See Ex. 1007 at ¶ 52).
`
`US 7,254,621 Claim
`Language
`1. A method of
`enabling data access and
`manipulation from a
`pervasive device,
`comprising the steps of:
`
`Correspondence to Schilit
`Schilit discloses a system and method for enabling data
`access and manipulation from a pervasive device by
`providing a Web browser that requests, accesses, and displays
`Web page content, along with selectable hyper-links from the
`requested Web page:
`
`
`
`14
`
`

`

`
`
`receiving a data acceess
`
`
`asive request froom a perva
`device;
`
`
`
`
`A Web
`browser pprovides tthe ability
`to separaate
`content
`
`
`and hypeer-links froom a We
`
`b page annd
`
`
`
`providess a list of thhe links foor viewing
`
`on a mobiile
`
`
`
`
`
`device ddisplay screeen enablinng more efffective Weeb
`
`
`
`
`page navigating uusing the llimited moobile devi
`ce
`display.
`
`
`
`
`… Furthher, once a a link is seelected usinng
`
`
`
`
`the mobbile devicce, a serrvices porrtal link
`is
`
`
`
`
`
`providedd to the mmobile deviice displayy to providde
`
`
`
`
`
`selectionn of servvices to bbe performmed on thhe
`
`
`or printingg. (Ex. 10003
`selected
`
`link, such h as faxing
`
`at Abstraact).
`35). (Seee also Ex. 1007 at ¶ 3
`
`
`
`
`
`
`
`Schhilit disclooses a Weeb Browseer, called
`
`“m-link,”” which
`
`
`acceesses a seerver to re
`
`
`
`trieve a ddocument aas identifieed by a
`
`
`userr-selected UURL:
`er, eb Browsevides a Wention provThe present inven
`
`
`
`
`
`referred
`
`
`
`
`to hereinn as “m-llink”, whiich converrts
`HTML
`
`
`
`
`documentts for dispplaying onn a mobiile
`display.
`to
`
`
`
`The m-linnk programm accessess a server
`retrieve
`
`by a useer-
`
`
`a documment as iddentified
`5:30-34).
`
`URL. (Exx. 1003 at 5
`selected
`
`
`
`
`
`shown in FFig. 7, beloow, the m--link browsser receivees a data
`As
`
`
`acceess requesst from a
`element
`pervasive
`
`device (sshown as
`
`11).
`
`
`
`15
`
`
`
`

`

`obtaining the requested
`data;
`
`determining what data
`manipulation operations
`are available for the
`obtained data; and
`
`(Id. at Fig. 7).
`(See also Ex. 1007 at ¶ 35).
`The m-link browser of Schilit accesses a web server 12
`(shown in Fig. 7, above) to obtain the document request by
`the user of the pervasive device.
`M-link browser 10 accesses a server 12 to retrieve
`a document as identified by the user selected URL.
`The URL is used to identify a document on
`another server, such as server 14. (Ex. 1003 at
`11:1-4).
`(See also Ex. 1007 at ¶ 35).
`The m-link browser also determines and creates a list of
`“situation, or context-appropriate services, such as printing or
`faxing,” for the requested data. (Ex. 1003 at 5:45-51). The
`context-appropriate services may
`include, for example,
`reading, emailing, sending, and discussing. (See id. at 8:62-
`65). A database of potentially available services is stored on
`the host computer providing m-link:
`A database of services will be provided on a host
`computer providing m-link in accordance with the
`present invention. The database will be configured
`to include standard services, such as printing of
`faxing shown in FIG 6B. The database is made
`dynamic by including specialized services for
`individual links based on the link owner or link
`type. (Id. at 9:66 - 10:4).
`The database is accessed by the m-link browser in
`determining available service operations:
`With m-link providing dynamic services, a
`service portal database 19 is provided which is
`accessible by the m-link browser software 10.
`When a link is selected by a user 11, services
`designated for the link are accessed from the
`service portal database 19 and provided with
`the link to the user’s mobile device 11. For user
`dependent services, m-link can be configured to
`include software to determine user preferences
`
`
`
`16
`
`

`

`providing references to
`the determined data
`manipulation operations
`to the pervasive device.
`
`based on user selections and update the database
`19 accordingly. (Id. at 11:38-45) (emphasis
`added).
`The situation, or context-appropriate services of Schilit
`correspond to the data manipulation operations of the ‘621
`patent which “may include viewing, faxing, printing, and
`projecting the data …” (Ex. 1001 at 3:38-42).
`(See also Ex. 1007 at ¶ 36).
`
`After the disclosed system receives a data access request, the
`requested data is obtained, hyperlinked, and returned to the
`requesting device:
`The m-link program accesses a server to retrieve
`a document as identified by a user-selected URL.
`The document received from the server is then
`parsed and hyper-links provided in the document
`are separated from the content. The hyper-links
`are processed, re-organized, and provided for
`display on the mobile device. (Ex. 1003 at 5:32-
`37).
`Once a displayed hyperlink is selected, the list of situation, or
`context-appropriate services is determined and returned to the
`requesting device.
`Once the links are displayed, the mobile-device
`keypad can then be used to navigate to and select
`one of the displayed links. A list of situation, or
`context-appropriate services, such as printing or
`faxing, is then provided to the mobile device
`display after a link is selected enabling a service
`selected from a list to be performed on the
`selected link. (Id. at 5:45-52).
`Schilit’s list of situation, or context-appropriate services
`returned to the pervasive device (as shown in Fig. 6C, below)
`comprises a listing of links. (See id. at 8:52-9:5). Each link
`comprises a URL for the available service:
`
`
`
`17
`
`

`

`
`
`
`be provideed on a hoost
`
`
`A databaase of servvices will
`
`
`
`
`
`computeer providinng m-link iin accordannce with thhe
`present
`
`inventionn.
`
` Thee databas
`
`e will bbe
`
`
`
`
`configurred to incllude standdard servicces, such
`as
`printing
`or faxing
`
`
`
`shown in FFig. 6B. TThe databaase
`is made
`
`
`
`
`dynamic bby includinng specialiized servicces
`
`
`
`
`
`for indivvidual linkss based onn the link oowner or linnk
`
`
`
`
`
`type. TThe individdual linkss in the daatabase caan
`
`
`
`
`
`be idenntified byy the URRL code oof the linnk
`
`selectedd by the
`
`user. (I(Id. at 9:
`66 – 10:
`6)
`
`(emphassis added).
`
`
`
`
`Thee service linnks providde the pervvasive devi
`
`
`
`
`to thhe networkk locationss of the deetermined
`
`
`opeerations. (EEx. 1007 a
`
`t ¶¶ 17, 366).
`link assocciated witth the deteermined
`
`noted aboove, each
`
`
`
`As
`a URL.
`
`
`
`ppropriate context-apsituuation, or c
`
`services ccomprises
`
`
`
`
`
`Ex. 1007 a– 10:10; E(Seee Ex. 1003 at 8:62-99:5, 9:66 –
`t ¶¶ 17,
`36)
`.
`in the ‘62
`1 patent
`described resses are dcation addrServvice invoc
`
`
`
`
`
`
`
`
`
`
`as identifying the netwoork locationn of availaable servicees to the
`100