UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`RICOH AMERICAS CORPORATION
`XEROX CORPORATION
`Petitioners
`
`v.
`
`MPHJ TECHNOLOGY INVESTMENTS LLC
`Patent Owner
`____________________
`CASE: IPR2013-00302
`U.S. Patent No. 7,986,426
`
`Petitioners’ Demonstratives
`Hearing Date: August 18, 2014
`
`RIC 1014
`IPR of U.S. Pat. No.7,986,426
`
`

`

`‘426 Patent (1996)
`
`XNS (1985)
`
`Petition, Paper 1 at 15-16, 53.
`
`2
`
`

`

`‘426 Patent (1996)
`
`Salgado (1995)
`
`Petition, Paper 1 at 35-36, 53.
`
`3
`
`

`

`• Mr. Weadock lacks the relevant education for this technology:
`o B.S. in General Engineering, majoring in Energy Technology:
`
`o For degree, did not take any courses in circuit design or hardware:
`
`Weadock Depo., at 126:5-9
`
`Weadock Depo., at 116:22-25.
`
`R-POR, Paper 39 at 2-3.
`
`4
`
`

`

`• Mr. Weadock lacks experience in this technology:
`o IT consultant that specifies and configures hardware/software
`o Never been employed by a scanner or copier company
`o Never developed software primarily for printing, scanning, copying, fax
`
`o Never written software for a commercial device
`
`Weadock Depo., at 114:22-115:2.
`
`R-POR, Paper 39 at 2-3.
`
`Weadock Depo., at 116:5-13.
`
`5
`
`

`

`• Mr. Weadock stated at least eight times during cross examination that he
`lacked sufficient time and money to prepare his Declaration:
`
`Weadock Depo., at 202:1-7.
`
`R-POR, Paper 39 at 4.
`
`6
`
`

`

`• Until deposed by counsel for Petitioners, Mr. Weadock forgot to mention
`that he authored a book (published in 1995) describing technology akin
`to the putative invention:
`
`R-POR, Paper 39 at 12-13.
`
`7
`
`

`

`B}? eontrast, Petitioners’ Expert, Dr. Roger Melen, is ideallyr qualified to
`
`ooine on the teehnology at issue; he holds a Ph.D. in Eleetrieal Engineering from
`
`Stanlord University and was developing networked digital seannen’eopier
`
`teehnology as the Viee President of R d: [J at Canon Researeh Center Anteriea
`
`from 199(3 to soar, whieit ineludes the earliest possible priority date ofthe “426
`
`Patent. (Es. 2003 (“Helen Deed“), 2fl:9r21:4; Melen DeeL, 1H4, Att. 1.)
`
`R-POR, Paper 39 at 3.
`
`8
`
`

`

`Independent Claim 1 (Ex. 1001)
`
`MPHJ Admissions (Ex. 1013)
`
`Weadock Depo., at 209:18-24.
`
`Weadock Depo., at 210:11-13.
`
`Weadock Depo., at 215:14-16.
`
`Weadock Depo., at 214:21-24.
`
`R-POR, Paper 39 at 12-13.
`
`9
`
`

`

`• MPHJ bases many of its arguments on its narrow construction of “application”:
`
`POR, Paper 30 at 6.
`
`• But this term is not limited to “a discrete software program.” Mr. Weadock admitted
`that MS Office (an example application in the ‘426) is a “suite” of programs:
`
`‘426 Patent, 52:50-53
`
`Weadock Depo., at 98:12-23.
`
`R-POR, Paper 39 at 8-9.
`
`10
`
`

`

`• Mr. Weadock admitted that an “electronic filing system” (another example
`application in the ‘426) is not a discrete program:
`
`‘426 Patent, 46:49-50 (highlighted)
`
`Weadock Depo., at 98:1-4.
`
`• Mr. Weadock admitted that “application” in ‘426 not even limited to software:
`
`‘426 Patent, 46:49-50 (highlighted)
`
`Weadock Depo., at 85:22-86:2.
`
`R-POR, Paper 39 at 9.
`
`11
`
`

`

`•
`
`In the ‘426, applications may be implemented using distributed architectures:
`
`R-POR, Paper 39 at 8.
`
`12
`
`

`

`• MPHJ takes issue with the Board’s construction of “module”:
`
`• But Mr. Weadock agreed with the Board:
`
`POR, Paper 30 at 7.
`
`Weadock Depo., at 192:11-15.
`
`R-POR, Paper 39 at 9.
`
`13
`
`

`

`• Dr. Melen views the term “module” as a piece software.
`
`• Responding during cross examination, Dr. Melen explained:
`
`R-POR, Paper 39 at 10-11.
`
`Melen Depo., Ex. 2003 at 143:23-144:4.
`
`14
`
`

`

`• MPHJ argues, “XNS does not disclose a single software application, as required
`by the claims.”
`o But when properly construed, “application” not limited to single program.
`
`• MPHJ argues, “Petitioner[s’] analysis of claim 5 fails to even mention the word
`‘module’ much less ‘input module.’”
`o But when properly construed, “module” is just piece of software.
`
`R-POR, Paper 39 at 14-15.
`
`15
`
`

`

`
`
`
`CLAIM CHART I
`
`l
`
`
`
`
`RES) may be sent to a specified file in a File Service for
`storage, or to a Print Service for printing (using Printer Subset
`Claim 1 is anticipated by XNS
`of the Filing Protocol). A user interface exists at the scanner to
`|1.P] A computer data management system including at least one of an electronic
`allow a user to perform this fiinction, as well as other functions
`image, graphics and document management system capable of transmitting at least
`such as cropping or scaling the image. The scanner is an XNS
`one of an electronic image. electronic graphics and electronic document to a
`
`system element which uses XNS protocols to communicate
`plurality of external destinations including one or more of external dewces and
`
`with other devices and services on the intemet.
`applications responsivel) connectable to at least one of locally and via Internet,
`
`1.
`(RIC 1002;} 112; FIG. 11-2;see also id. at 126-35.)
`comprising:
`[1.2] at least one memory storing a plurality of interface protocols for
`[LP]: XNS provides a “system overview” describing a data and document
`
`management system:
`interfacing and communicating,
`[1.2]: XNS discloses a plurality of interface protocols for interfacing and
`The general objectives of XNS is therefore to increase the
`communicating:
`ROIA by
`facilitating
`the
`creation,
`capture,
`storage,
`
`licatin of electronic orandrintincommunication a er
`
`
`
`The XNS architectureis particularly open-endedin respect to
`multiple transmission protocols corresponding to different types
`documents within the office, especially at the work group and
`of communication services,
`and to multiple application
`departmental
`levels. This
`is what Xerox calls document
`protocols corresponding to different fiinctions performed within
`management.”
`the architectural boundaries.
`(RIC 1002, p. 8.)
`XNS also discloses many netw0rk configurations for document management
`and transmission both locally and via Internet (lot at 21-42), such as FIG.
`1 1-2 on
`I page 112, and FIG. 11-3 on page 113:
`
`
`
`
`I l
`
`(RIC 1002, p. 14-20; FIG. 2—4.)
`XNS explains, “The devices that use XNS protocols and connect to the
`These system elements are generally
`' network are called system elements. .
`.
`.
`- classified as workstations or servers.” (1d. at 17), and “a directly-connected device
`is expected to implement all the layers of XN S appropriate to its function, which
`would include at
`least all
`layers upward through Courier .
`.
`. plus selected
`application protocols.” (id. at 18). XNS also explains that a scanner can be a
`system element: “The scanner is an XNS element which uses XNS protocols to
`.
`communicate with other devices and services on the internet.” (Id. at 1 12.)
`System elements—such as workstations, servers, scanners, etc—inherently '
`incl udc memory storing the protocols in order to implement and use the protocols.
`(Melon Dec-L, RIC 1008,
`11 34; See, e.g., In re Oelrich, 666 F.2d 578 (C.C.P.A.
`
`198]); M.P.E.P. § 21 12(1V) (regarding inherencfl.)
`[1.33] at least one processor responsively connectable to said at least one
`memory, and [l.3b| implementing the plurality of interface protocols as a software
`application for interfacing and communicating with the plurality of external
`destinations including the one or more of the external devices and agolications,
`[1.33]: XNS discloses system elements (sec [1.21). System elements—such
`as workstations, servers, scanners, etc—inherently include a processor used to
`implement the protocols. (Melon Dccl., RIC 1008, 11 34.)
`[l.3b|: XNS discloses implementing protocols as a software application:
`“These application protocols—mailing, printing, filing, and gateway accessifl
`
`
`
`
`
`
`
`16
`
`
`
`
`
`hunt-tiommhmm
`
`n,.nlhmmmwmhmh
`
`
`
`(See also id. at 71- 76; (network filing); 83- 90 (Email); 91- 106 (network
`pr1nt1ngt__10716 (network scanningl)
`[1.1] at least one scanner digital copier or other multifunction peripheral
`capable of rendermg at least one ofsaid electronic image electronic graphics and
`electronic document;
`[1.1]: XNS discloses network scanning, and at least one scanner:
`[The graphic input] model enables a user to digitize a hardcopy
`Petition, Paper 1 at 15-16.
`
`image by scannigg it at the scanner. The digitized image (in
`
`

`

`
`
`1002, p. 16.) XNS also discloses interfacing and communicating with external
`destinations using protocols: “[The graphic input] model enables a user to digitize
`
`a hardcopy image by scanning it at the scanner. The digitized image (in RES) may I
`be sent to a specified file in a File Service for storage, or to a Print Sprvice for'
`printing (using Printer Subset of the Filing Protocol)?“ (Id. at 112; see also id. at
`'
`149-54 (“Examples ofXNS Protocol Usage”).)
`[1.4] wherein the computer data management system inciua'es integration of l
`at ieast one of said electronic image, eiectronic graphics and eiectronic document I
`using software so that said electronic image, etectronic graphics and electronic
`document gets seamicssiy replicated and transmitted to at least one of said
`fiat-airy; (fexternai destinations.
`|l.4|: XNS discloses seamless replication and transmission: “[The graphic
`input] model enables a user to digitize a hardcopy image by scanning it at the
`
`scanner. The digitized image (in RES) may be sent to a specified file in a E
`
`Service for storage, or to a Print Service for printing (using Printer Subset of the
`Filing Protocol).” (RIC 1002, p. 112); “These documents can be manipulated and
`printed using the power of Interpress and print services, M using XNS filing,
`
`distributed with XNS mail, edited at a workstation, or sent to any device that is
`directly or
`indirectly connected to the internet
`(including remote facsimile
`machines)” (RIC 1002, p. 115; see aiso 1d. at pp. 71-76; (filing to/from file
`server); 83-90 (Email); 91-106 (printing using printer(s)); 107-16 (scanning using
`scanner(s); Melen Dec1., RIC 1008, 1|"| 40-41).
`XNS also discloses integration using sofiware: “The scanned image may be
`combined with text to form a composite document. The combining can take place
`at a workstation or at a printer, using the lnterpress Se_quenceInsertFile.” RIC 1002,
`p.
`112); “Where graphic elements are acquired from other
`sources
`(e.g.,
`photographs), they can be scanned. .
`. and subsequently edited. These electronic
`gtliphlc elements can be automatically integrated with the text to form electronic
`final-form page masters, ready for production.” (id. at 128; Melen Decl., RIC
`1008,1]1| 40-41).
`XNS also explains that integration, replication, and transmission is seamless
`Petition, Paper 1 at 17.
`to the user: “[M]ost important, [the characteristics of XNS services] are provided
`to the network users on a transparent basis, leaving them free to concentrate on
`_ their professional, managerial, and clerical tasks.“ (RIC 1002, p. 121.)
`
`
`
`
`
`.
`
`17
`
`

`

`
`
`Claim Sis anticipated by XNS
`wherein the software application comprises:
`[5.4al at least one input
`module managing data comprising at least one ofpaper and electronic input to the
`computer data management system, and managing said at least one scanner,
`digital copier or other multifiinction peripheral and [5.4b] managing the
`; electronic input from at least one thirdparty software application;
`[5. 4a]: XNS, as illustrated1n FIG. 2-4—including the application protocols,
`-Courier {see RIC 1002, pp. 43 -48), transport protocols and the like—manages
`electronic input/output and input/output devices connected to the system (id. at 14-
`17). Application protocols “are implemented in hardwarelsofi‘ware.” (id. at 16.)
`For example, “|_The graphic input] model enables a user to digitize a hardcopy.
`
`image by scanning it at the scanner. The digitized image [in ES) may be sent to a
`specified file in a File Service for storage, or to a Print Service for printing (using
`Printer Subset of the Filing Protocol)." (id at 112.)
`[5.4b]: XNS explains non-Xerox systems (hardware and software) are
`supported: “Techniques are also provided within XNS for bi-directional protocol
`
`and format conversion, permitting other systems to achieve integration with XNS.”
`(id. at 16.) Example non-Xerox systems include equipment from: Kurzweil (1d. at
`113); IBM and DEC (1d. at 117); “m personal computer, workstation, or other
`that supports the standard asynchronous ASCII communications can
`connect to the network via the Interactive Terminal Service and send or receive
`
`mail messages and documents." Id. at 120; and “any Xerox or non-Xerox facsimile
`device that is compatible with CCITT Group 1, 2, or 3” (Id).
`In one example, XNS discloses managing electronic input from a “Kurzweil
`Intelligent Scanning System, which not only scans a document but converts it into
`its textual rather than bit-map representation" and “uses the 860 gateway service to
`connect to the internet .
`.
`. to store files no a file server or mail them to a user for
`
`editing at a workstation. (Id. at 117.) (See Melen Dccl., RIC 1008, 111' 42-46.)
`XNS also discloses the “Gateway Access Protocol," for interfacing with
`
`other, non-Xerox, networks and equipment. (id. at 65-70.)
`[5.5a] at least one output module managing the data output fiom the
`
`computer data management system, managing at least one imaging device to
`Petition, Paper 1 at 19-20.
`
`
`
`—
`
`
`
`. output the data to at least one ofa standard windows printer, on image printer .
`anda digital copier and [55m managing the output oftlie data to the third—.pargt
`I so More a licoiion.‘
`|5.53]: See [54a] of Claim Chart Land XNS discloses managingda—ta
`output from the system to a printer. "The digitizedimage {in RES) may be H
`to. .
`. a Print Service for printing (using Printer Subset ol' the Filing Protocol)”
`{RIC 1002, p. 112], and to facsimile devices {ld at 120}. [See Mclen Dec1., RIC
`1008, '11. 42-46.)
`5_.51:I|: See [5.4M ofClaim Chan. I.
`[5.6] at least one process module apphxing at least one data processing to
`the data comprising the at least one oftlie paper and the electronic input as it is
`being copied, applying additional functionality including at least one ofwortl: ow
`and processing functionality to the data comprising the at least one ofpaper and
`electronic input as it is being copied and appbing multiple processes to a single
`|
`virtual co 1;
`. at the scanner to allow a user t_o '
`.
`|5.6|: XNS discloses “[a] user interface .
`perform .
`.
`. functions such as cropping or scaling the image.” [RIC [002, p.
`l 12.)
`XNS also discloses combining a scanned image with text: “The scanned image
`may be combined with text to form a composite document." lid.)
`GIS 151] discloses the following processes that can be applied to a scanned
`image: document sizing (RIC 1003, p. 5-3); automatic labeling (id at 5-4};
`Cropping (id. at 5—5); document orientation (id. at 541).
`
`
`So, XNS gas further evidenced by GIS 150! disclose |5.6|.
`[5.7] at least one client module presenting the data comprising the at least
`one ofpaper and electronic input as it is being copied, and information related to
`at least one of input and output fflnctions. and
`[57!: XNS discloses the “graphic input model" of network scanning where
`“the scanner is an XNS system element with a user interface ofits own’to allow a
`user to scan, send, apply settings, etc. {RIC ”102, pp. lll—l 2.) XNS also discloses
`the “peripheral device model“ of network scanning where a “workstation [coupled
`to the scanner] controls the scanner [and has] a bit map display and image editing
`capabilities.” (id. at l 13.)
`[5.3] at least one server module communicable with said at least one input,
`output, client. and process modules and external applications, and capable ofi
`dynamically combining the external applications will: at least one of digital -
`
`cgturing devices and digital imaging devices.
`I5.8|: See [Sela-bl ofClaim Chart [.
`
`
`
`fl
`
`18
`
`

`

`
`
` Claim 6 is Intici _.
`
`
`A com lilE‘l‘ data mona ment system according to claim 5, wherein the server
`
`-211]-
`
`Inter Parties Review of {1.5. Patent No. $136,426
`
`[6.1] enable virtual copy; operation means for initiating,
`module includes:
`cancelin and resetting said computer data management gstem;
`_
`
`
`6.1|: See [10.llofClaim thrt I
`[6.2.] maintain list of available mdule means fior maintaining a registry
`containing a list ofsaid input OHWI andpt'ocess modules that can be usedin said
`computer data management system, said list being read on startup. and
`maintaining another copy ofsaid list in a modules abject accessible by said input.
`
`on utclient [grocess and server modules;
`
`6.2: Sec 10.23- b of Claim Cth
`
`[6.3| maintain currently actiw modules means for maintaining said input
`output and process modules currently being used for a current computer data
`management system copy operation in a program object. and saving tire currently
`active modules in a recess t
`lalefile; and
`[6.3]: See [10.2343] and [10.3] ofClaim Chan I.
`[6.4] maintain complete document
`information means for maintaining
`information regarding a currentJtile being copied, and saving tire information in a
`document tentgiate file.
`_
`I6.4]: See [10.4] ofClaim ChartI.
`
`
`
`_,
`
`
`
`Petition, Paper 1 at 20-23.
`
`
`
`xns
`Claim to is antui ated
`[10.1"] A computer data management
`system including a server module
`comgrising.‘
`
`|lU.P|:Scc[1.P]ofClaim Chart I.
`_
`
`[10.I] enable virtual copy operation means for initiating. canceling. and
`
`resetting at least one operation managed by said computer data management
`
`M— _ -—
`[llLl]: XNS discloses the Xerox 150 Scanner. [RIC H102, p. 112.) GIS 150
`shows that initiating. calm-cling, and resetting are inherent features of the Xerox
`ISO Scanner. (RIC 1003, pp. 4-3 - 4-4.)
`50, XNS (evidemed by (315 150) discloses [10.1].
`[16.23] maintain list of available module means for maintaining a list of
`input, cutout, and process modules that can be used in said computer data
`management system,
`[111.213] said list being used by at least one module object
`accessible 615 said server module;
`[10.2341]: XNS discloses ‘tleminghousc” (RIC 1002, pp, 49-63), which “is '
`essentially a data base of objects" (id. at 50). The “objects” correspond to devices
`and services available on the network. (id)
`XNS also discloses “Database replication"
`where Clearinghouse “is
`decentralized and replicated." (id. at 52-53.) So, more than one database or “list"
`
`may be maintained.
`[10.3] maintain currently active modules means tor maintaining input,
`
`
`
`
`
`
`
`
`
`
`
`-22-
`
`inter Pattie: Review of LES. Patent No. 7,936,426
`
`output] and process modules currently being used far a current computer data
`
`_managengent system operation in a program object; and
`[10.3]: Again, XNS discloses “Clearinghouse." (RIC 1002, pp. 49-63.)
`XNS also discloses that a protocol may allow a client
`to obtain status
`information: "The Printing Protocol allows clients to ohlaln information on the
`to carries and the statusofia printer.” {id at 103.}
`[10.4] maintain complete document
`information means for maintaining
`in ormation re
`rain it cunentfile
`[1|].4]: XNS disclosrm that documents can be filed and stored. (RIC l002
`pp. 71-4'6) XNS also discloses maintaimng “attributes,” which‘are additional
`information about a file.” id. st74.
`
`
`
`19
`
`

`

`20
`
`
`
`
`
`
`
`
`
`£73 ”6.6
`
`
`
`
`
`
`
`[1.1] at least one scanner, digital copier or other multifunction peripheral
`capable ofrendering at least one of said electronic image, electronic graphics and
`
`electroniadocument;
`least one scanner or digital copier: “[Tjhe
`|ll1|z Salgado discloses at
`network 100
`includes devices for input including scanner or digital copier
`
`Log." (RIC 1005, '13:25-28;_FIG. 6.)
`[[2] at least one memory storing a plurality of interface protocols for
`interfacing and communicating;
`[l.2]: Salgado discloses that a profile for each component connected to the
`network is stored in a database at the server: “[T]he application server includes .
`.
`.
`the relational database 126. .
`.
`. For each component coupled with the network 134,
`a profile representing the coupled component is developed .
`.
`. for storage in the
`database 126.” (RIC 1005, 14:26-39.) Profiles can be used in a “plug-and-piay”
`manner
`to generate document processing workflows using the networked
`equipment. (Id. at 14:51-54, 22:6-17.) Dr. Melen explains “a component’s profile
`[includes] an interface protocol
`for interfacing and communicating so that
`the
`system, via the profile, can exploit and use the fiinctions of the underlying
`component.” (Melon Decl, RIC 1008, 'I[ 68.)
`Salgado also discloses protocols—such as, a protocol to implement fax
`functions (RIC 1005, 10:51-67), network protocols implemented in software and
`hardware from Novel] Corp. (Id. at 12:23-30), the protocols made available by
`XNS (Id. at 19:63-67), and an event notification protocol (e.g., SNiwa) (Id. at
`20:12-14)—the components of‘ the network document processing system use to
`interface and communicate. (See Melen Decl., RIC 1008,11 67.)
`[LSaI at least one processor responsiveb» connectable to said at least one
`memory, and [l.3b| implementing the plurality of interface protocols as a software
`application for interfacing and communicating with the plurality of external
`destinations including the one or more oftlre external devices and applications,
`[1.33]: Salgado discloses that “the server is configured to serve as an
`
`
`
`
` _
`
`
`
`CLAIM CHART 1n
`__7
`Claim 1 is anticipated by Salgado
`[LP] A computer data management system including at least one of an electronic
`image, graphics and document management system capable oftransmitting at least
`one of an electronic image, electronic graphics and electronic document to a?
`plurality of external destinations including one or more of external devices and '
`applications responsively connectable to at least one of locally and via Internet,
`
`comprising:
`_
`[1 .P]: Salgado discloses a data and document management system:
`is
`FIG. 6, a network document processing system,
`.
`.
`.
`designated by the reference numeral 100. .
`.
`. the network 100
`. ..
`includes devices for
`input
`including scanner or digital
`copier 102,
`. .. devices for output including display terminal
`112, printer 114, and speakers 116. Inputloutput ([20) devices
`include facsimile 120,l file server 122, and telgphone 124.
`(RIC 1005, 13:22-33, FIG. 6.)
`Salgado discloses local and Internet connections: “[Wjorkstation 82 is
`connected to other Systems and devices through local area network (LAN) or wide
`area network (WAN) 134, gateway 136, andlor modem 138." (Id. at 13:51-54,
`
`
`Petition, Paper 1 at 33-34.
`
`

`

`
`
`
`
`and storage device 306 are added to the system automatically.
`M an instances ofscan-to‘file may be available.
`
`
`(RIC 1005, 22:8-15.) m
`
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`processors and appropriate storage capacity could be used to provide the
`functionality of 122." (RIC 1005, 14:24-34.) FIG. 6 of Salgado illustrates the
`server 122 includes/is “connectable” to the database 126.
`
`scanners, and printers—
`[1.3b]: Salgado discloses that workstations,
`connected to the server—implement a user interface (1d. at 1358-149) that is used
`to build document processing workflows using the profiles stored in the database.
`(See Melen Dee-1., RIC 1008,1‘5166-67.)
`Salgado states: “ Plrofiles are mapped to one or more metaphor elements, I
`respectively. In one example, the metaphor elements are conventioflctograms
`mapped with the profiles in a known manner,. In one application .
`. ., a profile of
`print attributes is mapped to a printer icon.
`In one embodiment,
`the user is
`provided with a selection from a plurality of metaphor elements. These may be
`provided by way of a common file which is accessible to users across the
`network.” (1d. at 16:58-67.)
`Salgado discloses that “providing the operator with a visual means of
`interacting with these components is the basis of the metaphorical workflow
`.
`. provided to the operator is a means of describing a complex workflow
`scenario based upon its component parts and interactions between those parts. ”
`(1d. at 16:2—9.)
`[1.4] wherein the computer data management system includes integration of
`at least one ofsaid electronic image. electronic graphics and electronic document
`using software so that said electronic image, electronic graphics and electronic
`document gets seamlessly replicated and transmitted to at
`least one of said
` 99 u
`pluralitv of external destinations.
`scan-to—Em ai l ,” “sc an—to- fax,"
`[1.4]: Salgado discloses “scan~t0-print,
`“scan-to-file,” and “scan-to-print” functions:
`[A] metaphor representing a scanner. a printer, a facsimile
`
`device or an E-mail destination is coupled with the initiating
`metaphor element by way of a connector arrow of the type
`shown in FIGS. 12 and 13. The connector is associated with
`
`
`
`., to be executed in accordance
`.
`code that permits a document, .
`with a device profile. .
`.
`. As will be understood, by reference to
`FIGS.
`12 and 13, a given template can include multiple
`combinations so that, for example, output can be provided to
`multiple locations.
`(RIC 1005, 17:16-29, FIGS. 12 and 13.) (Melen Decl, RIC
`1008, w 62-65.)
`
`Petition, Paper 1 at 35-36.
`
`[Tghe user provides the system with a heuristic indicating that
`s/he desires a scan-to-file process. Accordingly, the scanner 282
`
`21
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`

`

`Claim Sisanflcl
`
`tad 11: 5a ado
`
`[5.4a] at ions! one inpnt
`wherein the software appiieotion comprises:
`modnie managing data comprising at ieast one ofpaper and eiectronic input to the
`computer data management system, and managing said at least one scanner.
`digttoi copier or other maitgfiinction peripheral and [SAM managing the
`
`_eiecgtronie input fi'om at ieast one third-flirty .sofnaare application;
`[Esta-M: The U1 142 (see RH: 1005, 13:58-14:91, server 122 (see id. at
`14:22-34], and the profiles (see id. at 14:51-67; FIG. If: (reproduced belowj)
`described in Claim I oFCIaim Chart III achicvc the functions oftho "input,"
`client."
`“output," “process," “
`and “scrvcr” modules.
`Salgado discloses non-Xerox software applications: T144445 (regarding
`Nowell. Microsoft, fl sofiwarc applications]; 12:23-30 tflovcll snfiware
`applications); 12:31 -39 (Adobe Companion soflware application}. {See Melon
`Dccl.. RIC 1008, 'l 66.}
`
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`[5.5:] at ieast—one oaipnt moduie managing the-Idem output fiom the
`computer data management system. managing at teas! one imaging device to
`arrow: the data to at least one ofa standard windmvs printer. on image printer.
`and a at itai copier. and |5.5h| mono '
`the on at o the data to the third-
`
`
`
`
`
`
`
`
`
`
`
`_33.
`
`Petition, Paper 1 at 37-38.
`
`
`
`_s
`
`
`
`'are gggiicattio_n,'
`|5.5a-h|: Sec |54a-b| ofClaim Chart III.
`[5.6] at ieast one process modttie appiying at ieast one data processing to
`the data comprising the at teas: one of the paper and the eiectronio input as it is
`being copied, appiying additionaifitnctionoiity incintiing at ieost one ofworfiiiow
`and processing fonctionaiint to the data comprising the or feast one ofpaper and
`eiectrontc input as it is being copied, and qopiytng maitipie processes to a singie
`virtnai c5133:
`__
`_
`|5.6|: Sac [5.4n-b] of Claim Chart III.
`Again, Salgado discloses “[P]roviding the operator with a visual means of .
`interacting with these components is the basis of the metaphorical workflow
`stratch which is a significant concept underlying the subject matter of the present
`disclosure. [...] provided to the operator is a means of describing a complex
`workflow scenario based upon its component parts and interactions between thosc
`parts. [...], a visual description of what is currently happening could casin he
`provided, along with providing controls at each important 'Servicc Provider in
`order to modify the total workflow progress." tRlC 1005, 162-13.}
`[5.1'] at feast one ciient modaie presenting the data comprising the at least
`one ofpaoer and eieotronic input as it is being copied and information rotated to
`at ieast oneo i
`at ondont
`t nnctions; and
`_
`[5.7|: See [5.41a--|Jl, and [Sail (regarding the “visual means of interacting
`with these oomwcnts”! of Chaim Chart III.
`[5.3] at ieost one server modnie oommnnicairie with said at ieast one input
`amput. oiient, and process modnies and extent-at appiications, and cap-atria of
`dmamicaity combining the ester-not appiicotions with at toast one of digitoi
`_
`jcgmring devices and digitai imaging devices.
`|5.3'|: Scc [Esta-b], and [1.4] of Claim Chart III.
`
`
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`
`22
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`

`

`Claim 6 ii antici ated
`
`
`5a ado
`
`
`A computer data management system according to ciaim 5, wherein tire server
`moduie inciudes: [6.1] enabie virtue! copy operation means for initiating.
`canceiin analI resetting said computer data management spstem;
`[El]: See [10.1] ofClaim Chart III.
`[fill maintain fist afm'aiia‘bie moduie means for maintaining a regain-y
`containing a tist ofsaid input. output, and process moduies that can be used in said
`computer data management system, said iist being read on starttgo, and
`maintaining another copy at“said iist in a moduies object access ibis by said input,
`output ct'ient mass and server moduies,
`{15.2}: See [10.2a-b] ofCIaim Chart III.
`[6.3 maintain currentiy active moduies meansfor maintaining said'In ut
`
`
`
`
`
`-33-
`
`inter Parties Review of HS. Patent No. 1,936,426
`
`output, andprocess modules currentiy being usedfor a current computer data
`management system copy operation in a program object. and saving the currentbi
`
`Educ fliduies in a rocess tern fate tie; and _
`_
`|6.3|: See |1[1.2a-1I| and |lUI.3| of Claim Chart [11.
`[6.4] maintain comptete document information means for maintaining
`information regarding a currentfiie being copied, and saving the information in a
`
`document tempiate itie.
`__
`_
`|Ifi.4|: See |Ifl.4| of Claim Chart III.
`
`
`
`
`
`
`
`Petition, Paper 1 at 38-41.
`
`
`
`
`
`
`
`
`“Claim misaufi ' atetl
`_
`system inctuding a server moduie
`[II].P] A computer data management
`
`comprising:
`
`[II].P]: Salgado discloses “FIG.6. anne—tworkdocument messing sEtcmf
`
`.
`. is designated by the reference numeral 100..
`.the network 100_ _includes
`
`.
`. file server 122 .
`.
`. ." (RIC 1005, 13:22-32, FIG. 6.)
`__ [IDJ] enabte virtuai copy operation means for initiating, counting, and
`resetting at toast one operation managed by said computer data management
`
`5 stem;
`
`[ll].l|: Salgado discloses "[O]ne or more control graphic indicators . .
`provided for each metaphor clement .
`.
`.
`.°’ {RIC 1005, l9:S?—59, FIG. I3; see
`Mclcn Dch, RIC 1008, ‘[‘| 59, 65. )
`
`. is
`
`I:must|:|seam
`,
`
`
`CONTROLS
`'
`[11.1.2.3] maintain iist of avaiiobtc modutefimeans for maintaining a fist ofl
`input output, and process moaia‘es that can be used in said computer data
`management system,
`[10.11:] said its! being used by at feast one mcuiuie object
`
`occessibie by said server module;
`.tl1_e
`[11]2a—b]:Sa1gado discloses‘[T]hc app[ication server includes.
`relational database 126..
`.For each cogponent coupled with the network 134, a
`profile representing the coupled component is developed _for storage in the
`database 126.“ (RIC 1905, 14:26-39.)
`Snlgado further discloses “[0]ne or more profiles are mapped to one or
`more metaphor elements, respectively. _
`_
`_ [T]l1e user is provided with a scluction
`from a plurality of metaphor elements. These may be provided by way 0st
`
`common file uhich'Is accessible to users across the_network” (id. at 16:58-67. )
`|lD.3| maintain currenti): active modut'es means for maintaining input.
`
`output and process moduies cmrentbi being used for a current computer data
`management system opemttbn in a program obi'ect; and
`J
`[10.3“ Salgado discloses that “application server queries 3 device to obtain l
`suitable state information," and “it is desirable to maintain a relationship in which
`i
`each device automatically informs the application server of its current status.
`i
`Accordingly, .
`_
`_ a device .. . is registered with the application server for event
`'
`notification." (RIC 101.15, 20:142.;
`___
`'
`
`I
`
`-4l].
`
`Inter Parties Review of LIE-5'. Patent No. 3936.426
`
`[10.4] maintain camptete document information means for maintaining
`
`23
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`
`
`
`

`

`Claim 1
`
`Claim 1
`
`l. r'l't. computer data management system including at least
`one oi'att electronic image. graphics and document manage-
`mettt system capable of transmitting at least one ofan elec-
`tronic image. clcctronic graphics and electronic document to
`a plurality of external destinations including otte