Control No.: 95/000,635
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`In re: Patent of Rorabaugh et al.
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`U.S. Patent Nos.: 7,831,926
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`Issue Date: 11/09/2010
`Filing Date: 04/21/2007
`Title: Scalable Display of Internet
`Content on Mobile Devices
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`AND
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`Control No.: 95/000,634
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`
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`In re: Patent of Rorabaugh et al.
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`U.S. Patent Nos.: 7,461,353
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`Issue Date: 12/02/2008
`Filing Date: 01/28/2005
`Title: Scalable Display of Internet
`Content on Mobile Devices
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`USPTO
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`) Confirmation No.: 4626
`) Art No.: 3992
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`Examiner: KOSOWSKI, Alexander
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`Confirmation No.: 8853
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`Art No.: 3992
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`) Examiner: STEELMAN, Mary J
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`Declaration of Jack D. Grimes, Ph.D.
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`I, Jack D. Grimes, Ph.D., declare:
`I.
`INTRODUCTION
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`
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`My name is Jack D. Grimes, and I reside at 5025 Wine Cellar Drive, Sparks, NV. I am
`1.
`an independent consultant. I have prepared this Declaration for consideration by the USPTO. I
`am over eighteen years of age and I would otherwise be competent to testify as to the matters set
`forth herein if I am called upon to do so.
`2.
`I have written this Declaration at the request of Apple Computer (herein “the Third Party
`Requester”). This declaration is written in support of Apple’s Ex Parte Reexamination Requests
`of U.S. Patent Nos. 7,831,926 and 7,461,353.
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`3.
`In forming my opinions, I rely on my knowledge and experience in the field and on
`documents and information referenced in this Declaration.
`
`II.
`
`BACKGROUND AND EXPERTISE
`
`4.
`I earned B.S. and M.S. degrees in Electrical Engineering, and a Ph.D. degree in Electrical
`Engineering (with a minor in Computer Science), all from Iowa State University. I also earned
`an M.S. degree in Experimental Psychology from the University of Oregon. I have been active
`in several professional societies and have worked in the computer and electronics field for over
`forty (40) years. Details of my education and work experience are set forth in my curriculum
`vitae, which is attached as Appendix A.
`5.
`I have worked in the area of computer graphics and video systems and consider myself to
`be at least a person of ordinary skill in the art.
`6.
`I have been retained by Apple Computer as an expert for these reexamination
`proceedings. No part of my compensation is dependent upon the outcome of these
`reexamination proceedings or any issue in it.
`
`III.
`
`INFORMATION CONSIDERED
`
`7.
`In forming my opinions, in addition to my knowledge and experience, I have considered
`the following documents and things that I have obtained, or that have been provided to me:
`a. U.S. Patent No. 7,831,926 (herein “ ’926 patent”);
`b. U.S. Patent No. 7,461,353 (herein “ ’353 patent”);
`c. File history for the ’926 patent and for the ’353 Patent;
`d. The Pad++ references cited in the ’926 Inter Partes request and the ’353 Inter Partes
`request;
`e. The JP ’169 reference cited in the ’926 Inter Partes request and the ’353 Inter Partes
`request;
`f. The Pad++ Reference Manual Version 0.2.7 (herein “Pad++ Reference Manual”);
`g. The Pad++ Programmer’s Guide version 0.2.7 (herein “Pad++ Programmer’s Guide”);
`h. A Brief Tour Through Pad++, published April 1997 (herein “Pad++ Brief Tour”);
`i. Matthews, et al., Vector Markup Language (VML), World Wide Web Consortium Note,
`May 13, 1998, Note-VML-19980513, http://www.w3.org/TR/1998/Note-
`VML_19980513 (“VML”)
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`IV.
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`PRIOR ART REFERENCES
`
`A.
`
`VML prior art reference
`1.
`Overview of the VML prior art references
`8.
`VML “defines a format for the encoding of vector information together with additional
`markup to describe how that information [for example, webpage content] may be displayed and
`edited.” [p. 1, VML].
`9.
`VML was used, among other things, to represent computer graphics (which include
`webpage content) in accordance with a “vector” format to allow for zooming and panning of
`webpages in response to user-entered inputs. [pp. 3-4, VML].
`10.
`“In the VML case, the workflow generates locations and related information for vector
`paths and related objects (such as bitmaps) which are then rendered using native system
`functionality.” [p.4, VML].
`11.
`In other words, VML provides an encoder for encoding coordinate values as vectors
`which represent information, such as webpage content, and how they may be displayed and
`edited, for example, when the content is zoomed and panned in response to user-entered inputs.
`12.
`For example, VML specifically recites that “2D coordinates are defined as single
`attributes ‘x,y’ rather than pairs of attributes.” [p.7, VML].
`13.
`VML further recites that “Vector 2D [is] numeric data in the from X,Y, usually used to
`list a coordinate in 2D space, may be in form ‘x y’ or ‘x, y’.” [p. 11, VML].
`14.
`“The shape and group elements are containing blocks for their content . . . Inside the
`containing block a local coordinate system is defined for any sub-elements using the
`coordsize and coordorigin attributes. All CSS2 positioning information is expressed in
`terms of this local coordinate space.” [p. 10, VML]
`“The coordorigin attribute defines the coordinate at the top left corner of the
`15.
`containing block. . . . The rationale behind this is that the vectors defining a shape can be
`specified in a local coordinate system.” [p. 10, VML].
`VML recites that the default for the coordorigin is (0,0). [p. 15, VML]. Thus,
`16.
`according to the VML specification, a coordinate (x,y) represents, by default, a vector from (0,0)
`to (x,y) for that containing block.
`2.
`Those of Ordinary Skill in the Art would have Combined the VML
`Prior Art References with Any of the JP 169 reference and the Pad++
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`references when Considering the Problem Presented by the ’926
`Patent and the ’353 Patent.
`
`17.
`Because the VML specification, the Pad++ system, and the JP 169 system are vector
`based, those of ordinary skill in the art would have considered one or more of these references
`together.
`18.
`Additionally, since the Pad++ references discuss improving current web browsers and
`graphical user interfaces and since VML was publicly available as early as May 1998, those of
`ordinary skill in the art would have considered VML in improving on the Pad++ system.
`a.
`Combining VML with Either of the Pad++ References or the
`JP 169 Reference Yields Predictable Results
`
`19.
`One of ordinary skill in the art would have found that combining the Pad++ system or the
`JP 169 system with the VML specification yields predictable results.
`20.
`For example, both the Pad++ system and the JP 169 system teach a method of zooming
`and panning webpages. As discussed above, VML was a publicly available and well-known way
`of presenting images and objects, such as those found on webpages, in a vector format that
`simplified and increased the efficiency of presenting, zooming and panning such information.
`21.
`Those of ordinary skill in the art looking to enhance the presentation of webpages on
`small devices (such as personal digital assistants (PDAs)), similar to the problem presented in the
`’926 patent and the ’353 patent, would have considered combining the Pad++ system with VML
`to further enhance, increase the efficiency of, and broaden the applicability to existing operating
`systems and platforms of the zoomable web browser described in the Pad++ references. Since
`the Pad++ references disclosed a zoomable and pannable web browser, applying the VML
`specification to the Pad++ references would have yielded the predictable results of a webpage
`capable of being zoomed and panned in response to user-entered inputs, wherein the coordinate
`values of the Pad++ references were encoded using the VML specification and Pad++
`implemented the vector format and utilized the vector-based panning and zooming techniques
`disclosed in the VML specification.
`22.
`Similarly, those of ordinary skill in the art looking to enhance the presentation of
`webpages on small devices (such as personal digital assistants (PDAs)), similar to the problem
`presented in the ’926 patent and the ’353 patent, would have considered combining the JP 169
`system with VML to further enhance, increase the efficiency of, and broaden the applicability to
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`existing operating systems and platforms of the zoomable web browser described in JP 169.
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`Since the JP 169 reference taught a zoomable and pannable web browser that can include a
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`webpage having an image associated with clickable data described by the coordinates of the
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`bounding box of the clickable data, applying the VML specification to JP 169 would have
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`yielded the predictable results of a webpage capable of being zoomed and panned in response to
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`user-entered inputs, wherein the coordinate values of JP 169 were encoded using the VML
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`specification and JP 169 implemented the vector format and utilized the vector-based panning
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`and zooming techniques disclosed in the VML specification.
`
`v.
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`23.
`
`SUMMARY
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`I note that my analysis is continuing and that I may modify or supplement my
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`conclusions as I receive additional information. I declare under penalty of perjury that the
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`foregoing Declaration is true and correct.
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`Dated: April 2, 2012
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