`
`In the Inter Partes Review of U.S. Patent No. 7,860,131
`Trial No.: Not Yet Assigned
`Issued: December 28, 2010
`Filed: June 7, 1995
`Inventors: John Christopher Harvey, et al.
`Assignee: Personalized Media Communications, LLC
`Title: SIGNAL PROCESSING APPARATUS AND METHODS
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`DECLARATION OF CHARLES J. NEUHAUSER, Ph.D.
`UNDER 37 C.F.R.§ 1.68
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`I, Dr. Charles J. Neuhauser, do hereby declare:
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`1.
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`I am making this declaration at the request of Zynga, Inc. in the matter
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`of the Inter Partes Review of U.S. Patent No. 7,860,131 (“the ‘131 Patent.”)
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`2.
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`I am being compensated for my work in this matter at my standard
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`hourly rate of $375 for consulting services. My compensation in no way depends
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`on the outcome of this proceeding.
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`3.
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`
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`In preparing this Declaration, I considered the following materials:
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`(a) U.S. Patent No. 7,860,131 to Harvey (“Harvey ‘131) (Exhibit
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`1001);
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`
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`(b) U.S. Patent No. 5,470,922 to Higgins (“Higgins”) (Exhibit
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`1007);
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`(c) U.S. Patent No. 4,339,798 to Hedges (“Hedges”) (Exhibit
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`1008); and
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`(d) U.S. Patent No. 4,572,509 to Sitrick (“Sitrick”) (Exhibit 1009).
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`I.
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`Professional Background
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`4.
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`I am an engineer by training and profession. My current CV is
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`attached at Exhibit 1011. I was awarded the degree of BSEE from the University
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`of Notre Dame in 1968. Directly after graduating I was employed by Bell
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`Telephone Laboratories (now Alcatel-Lucent) as a Member of the Technical Staff.
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`In this capacity I worked on the specification, testing and development of computer
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`controlled data and telephone switching systems for deployment in telephone
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`central offices. While I was at Bell Telephone Laboratories I received my MSEE
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`from Northwestern University under a company sponsored program.
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`5.
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`In 1971 I left Bell Telephone Laboratories to pursue a PhD in a newly
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`formed CS/EE program at the Johns Hopkins University. My degree was awarded
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`in 1980 based on my research into the use of emulation techniques in the
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`evaluation of computer architectures.
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`6.
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`In 1974 while working on my Ph.D. research I joined the Digital
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`Systems team at Stanford University as a research associate where I worked on the
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`development of an emulation system used for architectural research. From about
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`1972 I also worked part-time with Palyn Associates, Inc. (later Palyn-Gould
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`2
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`Group) (“Palyn) as a Member of the Technical Staff. At Palyn I worked initially
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`on the development of a range of commercial products based on emulation
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`concepts.
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`7.
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`In 1980 I joined Palyn full time as a member of their technical staff
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`and later as Director of Engineering and by 1985 as Vice President of Engineering.
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`Palyn was a consulting company with a range of international clients in the general
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`field of computer technology. My responsibilities at Palyn related to two broad
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`areas. First, I was responsible for directing product development on behalf of our
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`clients, and second, I consulted directly with clients on issues related to processor
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`and peripheral design. My work here related to main-frame processors, mini-
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`computers, micro-computers and systems that used such components.
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`8.
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`In my role directing product development I was responsible for the
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`specification, design, testing and debugging of a wide range of devices including
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`mini-computers, microprocessors and peripheral controllers, such as printers,
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`communications and printer interfaces. Work on these systems involved both
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`hardware and software development.
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`9.
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`In 1994 I began working as an independent consultant first doing
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`business as CTCS and later as Neuhauser Associates, Inc. Since that time my
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`professional work has focused on technical analysis of system primarily in the
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`support of litigation or potential litigation. I have worked extensively in the
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`3
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`
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`analysis of patent claims both with respect to determining infringement and
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`invalidity. I also have experience in software copyright and technical trade secret
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`matters. From time to time I lead teams of engineers in testing and technical
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`evaluations.
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`10. At this time I have nearly 45 years of continuous professional
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`experience in the field of processors and systems controlled by such processors.
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`The Harvey ‘131 patent relates to system level interconnection of communication
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`and computer devices. It also relates to their control by computers in response to
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`signals. Over my engineering career I have designed many such computer
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`controlled systems.
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`11. Since 1972 I have had extensive experience with microprocessors and
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`systems controlled by such devices. In addition to the specification, design,
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`implementation, testing, debugging and deployment of such hardware systems, I
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`have also developed the support software for many such systems. Commonly, I or
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`the engineers I directed made use of microprocessor based systems to implement
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`communications functions or to control larger processors systems. This included
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`responding to certain protocols or developing our own protocols.
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`12.
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`In my current capacity as an independent consultant I have reviewed
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`and verified the operation of a wide variety of technical systems, including
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`processors, personal computers, television devices, peripherals and bus systems.
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`4
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`13.
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`In forming the opinions expressed in this report I have relied upon my
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`education and my 45 years of professional experience.
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`II. Relevant Legal Standards
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`14.
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`I have been asked to provide my opinion as to whether claims 1, 3, 4,
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`6, 9 and 11 of the ‘131 Patent are anticipated or would have been obvious to a
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`person of ordinary skill in the art at the time of the alleged invention, in view of the
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`prior art.
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`15.
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`I am an engineer by training and profession. The opinions I am
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`expressing in this report involve the application of my engineering knowledge and
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`experience to the evaluation of certain prior art with respect to the Harvey ‘131
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`patent. My knowledge of patent law is no different than that of any lay person.
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`Therefore, I have requested the attorneys from Jones Day, who represent Zynga, to
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`provide me with guidance as to the applicable patent law in this matter. The
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`paragraphs below express my understanding of how I must apply current principles
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`related to patent validity to my analysis.
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`16.
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`It is my understanding that in determining whether a patent claim is
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`anticipated or obvious in view of the prior art, the Patent Office must construe the
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`claim by giving the claim its broadest reasonable interpretation consistent with the
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`specification. For the purposes of this review, I have construed each claim term in
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`5
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`accordance with its plain and ordinary meaning under the required broadest
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`reasonable interpretation.
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`17.
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`It is my understanding that a claim is anticipated under 35 U.S.C.
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`§ 102 if each and every element and limitation of the claim is found either
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`expressly or inherently in a single prior art reference.
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`18.
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`It is my understanding that a claim is unpatentable under 35 U.S.C. §
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`103 if the claimed subject matter as a whole would have been obvious to a person
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`of ordinary skill in the art at the time of the alleged invention. I also understand
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`that an obviousness analysis takes into account the scope and content of the prior
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`art, the differences between the claimed subject matter and the prior art, and the
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`level of ordinary skill in the art at the time of the invention.
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`19.
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`In determining the scope and content of the prior art, it is my
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`understanding that a reference is considered appropriate prior art if it falls within
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`the field of the inventor’s endeavor. In addition, a reference is prior art if it is
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`reasonably pertinent to the particular problem with which the inventor was
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`involved. A reference is reasonably pertinent if it logically would have
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`commended itself to an inventor’s attention in considering his problem. If a
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`reference relates to the same problem as the claimed invention, that supports use of
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`the reference as prior art in an obviousness analysis.
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`6
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`20. To assess the differences between prior art and the claimed subject
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`matter, it is my understanding that 35 U.S.C. § 103 requires the claimed invention
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`to be considered as a whole. This “as a whole” assessment requires showing that
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`one of ordinary skill in the art at the time of invention, confronted by the same
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`problems as the inventor and with no knowledge of the claimed invention, would
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`have selected the elements from the prior art and combined them in the claimed
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`manner.
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`21.
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`It is my further understanding that the Supreme Court has recognized
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`several rationales for combining references or modifying a reference to show
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`obviousness of claimed subject matter. Some of these rationales include:
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`combining prior art elements according to known methods to yield predictable
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`results; simple substitution of one known element for another to obtain predictable
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`results; a predictable use of prior art elements according to their established
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`functions; applying a known technique to a known device (method or product)
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`ready for improvement to yield predictable results; choosing from a finite number
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`of identified, predictable solutions, with a reasonable expectation of success; and
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`some teaching, suggestion, or motivation in the prior art that would have led one of
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`ordinary skill to modify the prior art reference or to combine prior art reference
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`teachings to arrive at the claimed invention.
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`III.
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`Person of Ordinary Skill in the Art
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`7
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`22.
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`It is my understanding that when interpreting the claims of the Harvey
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`‘131 patent I must do so based on the perspective of one of ordinary skill in the art
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`at the relevant priority date. My understanding is that the priority date of the
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`Harvey ‘131 patent is September 1987.
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`23. The Harvey ‘131 patent describes the interconnection and operation of
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`very well-known components. These components include television receivers,
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`radio receivers, amplifiers, micro-computers (“personal computers”), audio
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`recorders and video recorders, among other things. In addition, the Harvey ‘131
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`patent discusses at a general level various types of “signal decoders”, such as
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`television line decoders, used to decode radio and television signals, and switches
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`to direct these types of signals between various components. The Harvey ‘131
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`patent also describes simple signal and message formats.
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`24. The technology scope of the Harvey ‘131 patent may be discerned
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`easily by a simple review of the figures. These figures show components that were
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`very well known in 1987. What they do not show is any unusual circuitry or
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`interconnection of components. This is also true of the text of the Harvey ‘131
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`patent. Although the text of patent is extensive it does not describe the use of any
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`unusual technology beyond what is shown in the figures. For example, there are
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`no formulae, computer programs, descriptions of circuitry or the like. Basically,
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`8
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`the Harvey ‘131 patent relates to the interconnection of well-known components
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`and their control using widely known and understood techniques.
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`25. Based on my review of the specification of the Harvey ‘131 patent, it
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`is my opinion that one of ordinary skill in the art would be an engineer with a
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`Bachelor’s of Science in Electrical Engineering or a closely related field1. This
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`person would have between three and five years of experience beyond graduation
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`in the implementation of communications systems and controlling these systems
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`(or similar types of systems) through the use of computer technology. Someone
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`would be equally qualified if they had a Master’s of Science degree and somewhat
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`less practical experience.
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`26.
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`I am able to make this assessment because by 1987 I worked with,
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`supervised and hired engineers with these types of qualifications. These engineers
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`had the requisite knowledge to make and use systems as described in the claims of
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`the Harvey ‘131. Because I have worked with and supervised engineers with this
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`background I know very well what their capabilities were in September 1987 and
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`1 By the 1980’s most Electrical Engineer students took courses in communications
`and computer programming. Even in college these students would likely have had
`practical experience building systems based techniques similar to those described
`in the Harvey ‘131 patent.
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`
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`9
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`
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`how they would interpret the claims of the Harvey ‘131 patent and the disclosures
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`of the applicable prior art.
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`IV. Summary of the ‘131 Patent
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`27. The Harvey ‘131 patent contains nearly 300 columns of text and 22
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`drawing sheets. For brevity, I have limited my summary of the Harvey ‘131 patent
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`to one example embodiment described in the patent’s specification. I will do this
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`not from today’s perspective over 25 years after the priority date, but rather from
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`the perspective of what one of ordinary skill in the art would have understood in
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`1987.
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`28. One of ordinary skill in the art would recognize various commonly
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`used terms in the Harvey ‘131 patent, such as “control signal”, “device”, “storage”,
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`“computer program” and so forth. Other terminology, such as “complete
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`programming” can be interpreted based on the plain meaning of the words.
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`29. Basically, the Harvey ‘131 patent is related to the reception,
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`distribution, storage and presentation of information carried on various types of
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`electrical signals. Much of the discussion and many of the examples shown in the
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`Harvey ‘131 relate to performing these activities on standard radio and television
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`signals. The Harvey ‘131 patent also assumes at places that such signals can
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`include embedded control signals using what were well-known techniques in 1987.
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`10
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`30. Most of the discussion in the Harvey ‘131 patent and the examples
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`given as preferred embodiments would be understood by one of ordinary skill in
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`the art to be system descriptions at a very high “block diagram” level. Block
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`diagrams are well-known representations used by engineers when they want to
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`convey general relationships between known components without having to give
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`details of their internal operation. This person would understand that the basic
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`technology of the Harvey ‘131 patent is the interconnection and control of various
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`building blocks, such as television receivers, computers, matrix switches and so
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`forth.
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`31. The exemplary figure of the Harvey ‘131 patent is the rather
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`formidable Figure 7, which show a very complex embodiment. However, the
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`basics of the Harvey system can be understood more easily from the much simpler
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`Figure 1 shown below.
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`11
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`32. What is shown in this figure is a basic system that might make use of
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`the concepts expressed in the Harvey ‘131 patent. In this case the basic notion is to
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`generate a presentation on the TV monitor 202M that is a composite of broadcast
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`information (i.e. information that is available at every receiver) and information
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`that is specific to a particular receiver. The components of Figure 1 are all
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`conventional and include a television tuner 215, microcomputer 205, TV signal
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`decoder 203 and TV monitor 202M. The Harvey ‘131 patent characterizes this
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`arrangement as an example of a “subscriber station” [10:41-42]2. A basic
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`2 In this section all references are to the Harvey ‘131 patent.
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`12
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`
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`description of this system and some examples of its operation are provided,
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`generally, at 10:41-15:12.
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`33. Briefly, it is assumed that the signal received by the TV tuner 215
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`includes embedded control signals. Although not described explicitly in the
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`Harvey ‘131 patent, one such transmission protocol for embedding control signals
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`and other information in a television signal might have been the Teletext protocol
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`or one of its variants. These techniques have been widely used since the early
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`1970s. Basically, Teletext3 and similar protocols allow the television station to
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`transmit digital data in an “unused” portion of the television signal. Television
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`tuner receives the TV signal, which includes the embedded data, and provides a
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`video and audio signal. Divider 4 serves to split the received video signal into two
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`copies. One copy of the video signal is sent to TV signal decoder 203 where the
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`embedded data, which is not visible in the signal, is extracted. The line labeled
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`“signals only” represents the extracted data [10:53-63].
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`34. Both the extracted data and the second copy of the video signal from
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`divider 4 are sent to the microcomputer 205. This microcomputer is an IBM
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`Personal Computer, a device that was widely known in 1987 because it or a
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`compatible variant was used in many homes and businesses. Although not shown
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`3 Closed captioning is another such technique, which is more widely used in the
`United States.
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`13
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`in Figure 1, the microcomputer 205 contains a specialized graphic overlay card
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`[11:6-10]. This card serves two purposes. First, under control of program code in
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`microcomputer 205 it can generate graphic letters and symbols. Second, these
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`generated graphics can be combined or overlaid on the video signal to produce an
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`output signal that is sent to the TV monitor 202M [11:15-18]. This combined
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`video signal presents the viewer with the general TV picture received from the
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`television tuner 215, but overlaid with whatever graphics was generated by the
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`graphics overlay card in the microcomputer 205.
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`35. Because microcomputer 205 is a general purpose computer it offers
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`the opportunity for the overlay information presented on TV monitor 202M to
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`reflect
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`information
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`that
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`is particular
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`to each viewer.
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` This
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`is because
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`microcomputer 205 may hold data that is specific to that viewer and an embedded
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`signal received on the general television transmission that is sent to all viewers
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`may trigger the presentation of this user-specific information in a way that is
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`different or unique to each viewer.
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`36. One simple example of how this technique might be applied is given
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`at 11:23-14:16 and involves the program “Wall Street Week in Review”. The
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`basic objective of the example is to provide a combined video display that shows
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`the TV program with an overlay of how the viewer’s particular portfolio did with
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`respect to the market during the week. This is done using control signals sent
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`14
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`
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`along with the television signal. Figure 2 shown below illustrates the example
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`operation of the system from the perspective of a particular viewer.
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`
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`37. Using the system of Figure 1 a viewer would tune to the “Wall Street
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`Week in Review” program, which would be a conventional TV program, but with
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`embedded signals for use in controlling microcomputer 205. The television station
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`transmitting the programs sends embedded signals to all viewers along with the
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`television program. In this example, the particular signals sent are coordinated in
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`time with the program itself. There are, in this particular example, three general
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`groups of signals. The first set of signals is used to initialize all the receiving
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`equipment associated with each viewer [12:6-12]. These signals are interpreted by
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`15
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`each viewer’s microcomputer 205 and used to turn any graphics overlay currently
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`in progress at all viewer devices. [12:31-50].
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`38. Next a second set of signals is sent to all viewers tuned to the
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`program. These instructions are in the form of computer program code and are
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`loaded into microcomputer 205 and executed [13:5-25]. In this example, the
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`loaded program proceeds to calculate the performance of the viewer’s stock
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`portfolio using the current week’s prices and the particular stock portfolio held by
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`the viewer. This user-specific information (i.e. the type and quantity of stock
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`holdings) has been previously stored in the user’s microcomputer 205. Thus, each
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`viewer’s microcomputer 205 contains individual portfolio information. At this
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`point the microcomputer has computed a graph that is similar to that shown in
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`Figure 1A below. This graph of the stock portfolio will be different for each
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`viewer because presumably their individual stock holdings vary. [13:47-52].
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`However, this personalized graphic has not yet been presented to the user.
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`16
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`39.
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`In a final step the television station transmits a third sequence of
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`signals [14:2-16] in coordination with the television program. In the example, the
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`program host shows a graphic depicting how the overall market did during the
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`current week (see Figure 1B). All viewers see this graphic and it is the same for all
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`viewers. The host then announces that you will see your portfolio compared to the
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`general stock average [13:60-14:3]. At this point the television transmits the third
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`17
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`sequence of signals. This sequence causes the microcomputer 205 to enable the
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`graphic overlay and the viewer is presented with a picture that combines the
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`general performance of the market as seen by every viewer with a graphic of the
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`performance of his or her particular portfolio (see Figure 1C) [13:2-16].
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`40. The Harvey ‘131 patent shows a number of other preferred
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`embodiments and describes other similar examples of personalized program
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`presentation. In general, they are just elaborations of this simple example. The
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`exemplary figure is Figure 7. While more complex than the simple example
`
`above, it is simply an extended application of the basic principles that I have
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`described above. That is, it makes use of embedded control signals to manipulate
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`data and control hardware in ways that are specific to each viewer (or “station”)
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`based on information peculiar to that viewer.
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`V. Anticipation in View of Higgins
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`41.
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` It is my opinion that claims 1, 2, 4, 6, 9 and 11 of the ‘131 patent are
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`anticipated by Higgins (U.S. Patent No. 5,270,922) for the following reasons.
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`Background of Higgins
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`42.
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` U.S. patent 5,270,922 (“Higgins”) issued to Gerard M. Higgins and
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`titled “System for Distributing, Processing and Displaying Financial Information”
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`was filed on June 27, 1991. It is a continuation of application number 626,399
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`
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`18
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`
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`from June 29, 1984. It is my understanding that Higgins has a priority date of June
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`29, 1984. Thus it is prior art to the Harvey ‘131 patent.
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`Technical Summary of Higgins
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`43. Briefly, the preferred embodiment of Higgins describes a system for
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`presenting financial information to stockbrokers and other financial industry agents
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`[Higgins Abstract, 1:9-124; 1:17-24]. Figure 1, which is composed of figures 1A
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`and 1B, provides an overall view of the system.
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`4 References in this declaration will be given as (“column number” : “line
`number”)
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`19
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`44. Figure 1 shows a hierarchical organization of computer systems,
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`including a corporate system 14, and area computer 50, branch computer 90 and
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`work station 110. There may be more than one computer at each level in the
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`hierarchy. Information is stored at various levels within the system hierarchy. For
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`instance, customer information is stored in a database 12 attached to the corporate
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`main frame 14. This information is available to all systems that are lower in the
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`hierarchy. Similarly, historical information related to a stock is stored in historical
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`information RAM 95 in each branch computer 90. The lowest level of the
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`hierarchy is a work station 110, which may store information of current interest to
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`the particular financial agent using that station. Such information is stored in
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`RAM 111. Because the work station stores only information that is most relevant
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`20
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`
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`to each broker the storage requirements of the work station (i.e. RAM 111) is
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`reduced, but rapid access to relevant information is still supported [2:27-41].
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`45. The system of Higgins also includes news wire source 24 and ticker
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`plant 25, which represent a real time source of information transmissions. For
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`example, the ticker plant 25 provides information about every stock trade, while
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`news wire source provides current news related to stocks. This information from
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`the news wire source 24 and the ticker plant 35 is transmitted to area, branch and
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`work station computers either wirelessly (see, e.g. Fig. 1, items 28, 40, 80, 81) or
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`via wire (see, e.g. Fig. 1, items 25, 103) [2:58-2:23].
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`46. Below I will discuss why claims of the Harvey ‘131 patent are
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`unpatentable. I will do this particularly with respect to the work station 110,
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`whose operation Higgins describes in detail. One of ordinary skill in the art in
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`1987 would understand the structure of work station 110 to be very similar to that
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`of the very widely used personal computers of that era. The usual computer
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`peripherals and components, such as display 107, CPU (Central Processing Unit)
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`103, ROM (Read Only Memory) 109, RAM (Random Access Memory) 111,
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`keyboard 112 and Mux/Demux 105 are connected by a bus. CPU 103 controls
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`overall workstation operation, which includes receiving commands from the user
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`via the keyboard 112, executing programs stored in ROM 109 (or RAM 111) and
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`displaying information to the user on display 107 [2:15-26]. In the preferred
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`21
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`
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`embodiment the display 107 provides the user with current and historical
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`information about particular financial instruments of interest to the use of each
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`work station [3:66-4:10].
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`47. Operation of the work station 110 is controlled by programs held in
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`the ROM 109 or, alternatively, in RAM 111. [2:21-26]. The operation of each
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`work station 110 is personalized by the agent that makes use of the station by
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`entering commands and data from the keyboard 112. The actual information
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`displayed at each work station 110 is updated in real time by information received
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`from the branch computer receiver 70 or from the news wire source via line 103
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`(also designated as line 25) and passed to the work station 110 via mux/demux
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`105. Mux/demux 105 is under control of the CPU 103 via line 105c, which selects
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`the input source as required [4:21-34].
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`48. Figure 2, shown below, represents the display as seen by the user of a
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`work station 110. This display will be unique to each work station user because
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`the user is able to program the display to show that information that is relevant to
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`their particular financial activities. For example, the user may monitor the current
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`prices of a subset of all the stocks being traded. Figure 2 from Higgins is shown
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`below. I have annotated this figure with rectangular shaded areas that represent the
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`various windows that may be displayed by the user, which I will describe in detail
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`below
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`22
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`49. This figure (above) shows a possible presentation on display 107 and
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`provides the user a wide variety of information. This is done by showing relevant
`
`information in various “windows5” in the display 107, which is described as a
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`“multi-window” display [1:17-24; 4:34-44]. In the preferred embodiment the
`
`display 107 presents several types of information, which I will summarize here.
`
`
`5 Higgins refers to areas of the display 107 screen as both “windows” and “fields”.
`[4:34-44]
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`
`
`23
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`
`
`On Higgins Figure 2, I have highlighted the areas of the display roughly
`
`corresponding to each of the following fields with dashed lines.
`
`Item Function
`142 New York Stock Exchange Ticker
`147
`“TICKER 2”
`149 News from News Wire Service 24
`151 Limit Exceeding Information
`153
`“MONITOR”
`157
`“QUICK-QUOTE”
`
`Reference
`[4:45-59]
`[4:60-5:5]
`[5:6-9]
`[5:6-15]
`[5:16-23]
`[5:23-36]
`
`
`
`50. The particular window arrangement and content shown in Figure 2 is
`
`but one example, and Higgins suggests that other arrangements are possible as
`
`alternatives to the arrangement of Figure 2, or as modifications to Figure 2. [5:37-
`
`40]
`
`51. Briefly, the windows of Figure 2 have the following characteristics:
`
` New York Stock Exchange Ticker – shows “the complete New York Stock
`
`Exchange ticker (a “series of stock exchange transaction messages for stock
`
`executions on that exchange)” [4:48-50].
`
` “TICKER 2” is a user specific ticker. This window shows only those
`
`transaction messages received from the ticker plant that match a criteria
`
`established by the work station user. This criteria is stored in RAM 111.
`
`[4:60-5:5]
`
`
`
`24
`
`
`
` News – This window “forms a scrolling presentation of the news reported
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`via the source 24” [5:6-7]. Source 24 is a news wire service. [4:10-14]
`
` Limit Exceeding Information identifies security that traded outside a bound
`
`(in this case a lower bound) that is stored in RAM 111. [5:6-11]
`
` MONITOR is a window that “contains price information for a
`
`predetermined population of securities of interest to that particular broker”.
`
`[5:16-18]
`
` “QUICK-QUOTE” provides a current quote for a particular stock. The
`
`particular stock of interest is entered at the keyboard 112. [5:23-25]
`
`52. The presentation on a particular workstation is a combination of
`
`information that is general and provided to all users (e.g. New York Stock
`
`Exchange Ticker and News windows 142 149) and information that is tailored to
`
`the particular user based on criteria is stored in RAM 111 via the keyboard 112.
`
`[4:34-44].
`
`53. The presentation shown on display 107 is particular to each
`
`workstation and is generated in real time based on general information received by
`
`the work station via mux/demux 105. Each user of a work station 110 defines a
`
`particular subset of all stock transactions that that particular user is interested in.
`
`This is done through keyboard 112. In the preferred embodiment a user may store
`
`the identification symbols for up to 300 securities in RAM 111. [5:48-59; 6:24-29]
`
`
`
`25
`
`
`
`As information about all security transactions arrives at the work station 110 line
`
`103 and mux/demux 105 the current price information for those specific securities
`
`identified in RAM 111 is captured and stored in RAM 111. Simultaneously, the
`
`presentation on display 107 is updated to reflect the new trade information just
`
`received. [5:65-6:5] Higgins gives an example of where a change to the price of
`
`security “ABC” causes a change to the New York Stock Exchange ticker window
`
`142, the Monitor window 154 and the Quick-Quote window 157. [6:5-15].
`
`54. Higgins provides an example of the interaction of the user with the
`
`work station 110 and other computers in the hierarchy, such as branch computer
`
`90. [Fig. 3; 6:46-7:61] A user may request a quote for a particular stock. There
`
`are two types of quotes: a “quick-quote” which is based on information that may
`
`be currently stored in the work station 107 or a “full quote” that will require
`
`historical or derived information from the branch computer 90. [6:54-64] If the
`
`Quick-Quote relates to a security of particular interest to the workstation user its
`
`current price will be stored in RAM 111. Otherwise, the branch computer 90 will
`
`need to be consulted. Similarly, requests for full quotes will require accessing
`
`historical information RAM 95 in the branch computer 90.
`
`55. RAM 111 contains a list of stock symbols that the user of the work
`
`station 110 is currently interested in. The particular list of stock symbols will
`
`differ from station to station [8:3-8]. Thus, the RAM 111 of each workstation
`
`
`
`26
`
`
`
`contains symbols and associated price information particular to each work station
`
`user. This technique usually allows a quick response to a user quote request
`
`because the request can be fulfilled directly from the RAM 111 of work station 110
`
`and does not required accessing the branch computer 90 [8:9-15].
`
`56. Higgins Figure 4 illustrates the dynamic updating of the presentation
`
`on display 107 as new ticker information is received from the ticker plant 35 [8:16-
`
`
`
`
`
`27
`
`
`
`20]. Each separate field or window shown in Figure 2 has associated with it a
`
`particular list of symbols in the RAM 111 [8:24-31]. During operat