throbber
IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
`
`
`
`CIVIL ACTION NO. 4:12-CV-00647-RAS
`
`
`
`JURY DEMANDED
`
`
`
`MOTIO, INC.,
`
`
`
`
`
`Plaintiff,
`
`
`v.
`
`BSP SOFTWARE LLC, and
`BRIGHTSTAR PARTNERS, INC.,
`
`
`
`Defendants.
`
`PLAINTIFF’S P.R. 3-1 DISCLOSURE OF
`ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS,
`AND P.R. 3-2 DISCLOSURES
`
`In compliance with P.R. 3-1 and 3-2, Plaintiff Motio, Inc. (“Plaintiff”), by and through its
`
`
`
`
`
`
`
`
`designated counsel, hereby serves its Disclosure of Asserted Claims and Infringement
`
`Contentions (“Infringement Contentions”) and accompanying Document Production
`
`to
`
`Defendants BSP Software LLC and BrightStar Partners, Inc. (“Defendants”).
`
`Because discovery has just begun and Defendants have not yet produced any information
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`in this litigation, these disclosures are based solely upon publicly available information.
`
`Plaintiff’s investigation of the matters disclosed in its Infringement Contentions is ongoing.
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`Plaintiff anticipates that the production and review of documents and information by Defendants
`
`may lead to the modification of these Infringement Contentions. Accordingly, Plaintiff reserves
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`the right to amend, modify or supplement these disclosures based upon further discovery and
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`investigation.
`
`Further, pursuant to the Local Patent Rules, these Infringement Contentions are being
`
`served before claim construction disclosures and proceedings are scheduled to begin. Consistent
`
`PLAINTIFF’S P.R. 3-1 DISCLOSURE OF ASSERTED CLAIMS AND
`INFRINGEMENT CONTENTIONS, AND P.R. 3-2 DISCLOSURES
`000001
`
`BSP SOFTWARE LLC 1011
`
`PAGE 1
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`
`

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`with P.R. 3-6, Plaintiff reserves the right to amend, modify or supplement these Infringement
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`Contentions based upon the manner in which the claim terms in the Patent-in-Suit are construed
`
`by the Court and/or based upon claim construction positions taken by Defendants.
`
`I.
`
`P.R. 3-1(a) Disclosure – Infringed Claims
`
`Plaintiff asserts
`
`that Defendants
`
`infringe claims 1-4 and 7-10 of U.S. Patent
`
`No. 8,285,678 (the “Patent-in-Suit”) as set forth in the following sections. The specific claims
`
`therein that Defendants are accused of infringing are hereinafter collectively referred to as
`
`“Asserted Claims.”
`
`II.
`
`P.R. 3-1(b) Disclosure – Accused Instrumentalities
`
`Based on the information presently available to Plaintiff, at least the following products
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`are accused of infringing each Asserted Claim of the Patent-in-Suit: the Integrated Version
`
`Control (“IVC”) and the Integrated Control Suite (“ICS”) products. Plaintiff asserts that
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`Defendants directly and/or indirectly infringe the Asserted Claims by making, using, offering for
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`sale, selling and/or importing into the United States the IVC and the ICS products; and/or
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`actively inducing others to use the IVC and the ICS products in an infringing manner; and/or
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`otherwise contributing to the infringement of others.
`
`Defendants’ products that are accused of infringing the Patent-in-Suit are hereinafter
`
`collectively referred to as “Accused Instrumentalities.” Because discovery has just begun and
`
`Defendants have yet to produce any documents in this litigation, Plaintiff reserves the right to
`
`add or modify the identification of the Accused Instrumentalities to identify additional infringing
`
`apparatuses, products, devices, processes, methods, acts or other instrumentalities after
`
`conducting discovery in this matter.
`
`PLAINTIFF’S P.R. 3-1 DISCLOSURE OF ASSERTED CLAIMS AND
`INFRINGEMENT CONTENTIONS, AND P.R. 3-2 DISCLOSURES
`000002
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`PAGE 2
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`III.
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`P.R. 3-1(c) Disclosure – Infringement Chart
`
`Subject to the above limitations, attached hereto as Exhibit A is a claim chart setting forth
`
`the Asserted Claims of the Patent-in-Suit and how each Accused Instrumentality infringes the
`
`Asserted Claims, respectively. This chart also describes, by way of illustration, the features
`
`and/or functionalities of the Accused Instrumentalities believed to infringe the Asserted Claims
`
`of the Patent-in-Suit.
`
`Because discovery has just begun and Defendants have yet to produce any documents in
`
`this litigation, Plaintiff reserves the right to add or modify the identification of the Accused
`
`Instrumentalities to identify additional infringing apparatuses, products, devices, processes,
`
`methods, acts or other instrumentalities after conducting discovery in this matter.
`
`IV.
`
`P.R. 3-1(d) Disclosure – Literal and/or Doctrine of Equivalents Infringement
`
`Plaintiff asserts that each element of each Asserted Claim is literally present in the
`
`Accused Instrumentalities. To the extent that any elements of the Asserted Claims are not
`
`literally present, Plaintiff asserts that each element of the Asserted Claims is present under the
`
`doctrine of equivalents because any differences between the features of the Accused
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`Instrumentalities and the corresponding claim elements are insubstantial and/or that these
`
`features perform substantially the same functions in substantially the same way to achieve
`
`substantially the same result as the corresponding claim elements.
`
`V.
`
`P.R. 3-1(e) Disclosure – Priority Date
`
`The claims of the Patent-at-Issue are entitled to a priority date no later than January 3,
`
`2006.
`
`PLAINTIFF’S P.R. 3-1 DISCLOSURE OF ASSERTED CLAIMS AND
`INFRINGEMENT CONTENTIONS, AND P.R. 3-2 DISCLOSURES
`000003
`
`PAGE 3
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`

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`VI.
`
`P.R. 3-1(f) Disclosure – Other Instrumentalities Practicing the Claimed Inventions
`
`Plaintiff identifies its MotioCI product that practices and/or has the capability for
`
`practicing the Asserted Claims of the Patent-in-Suit.
`
`VII. P.R. 3-2 Document Production Accompanying Disclosure
`
`Accompanying this statement, Plaintiff is producing relevant, non-privileged documents
`
`required under P.R. 3-2. Note that certain documents produced concurrently herewith have been
`
`marked “Confidential – Outside Attorneys Eyes Only” pursuant to P.R. 2-2.
`
`Plaintiff’s production of documents under P.R. 3-2 should not be considered an
`
`admission that such documents relate to information or products that fall within the scope of the
`
`Asserted Claims of the Patent-in-Suit. Plaintiff reserves the right to supplement its production
`
`under P.R. 3-2 as deemed appropriate and necessary in the future.
`
`PLAINTIFF’S P.R. 3-1 DISCLOSURE OF ASSERTED CLAIMS AND
`INFRINGEMENT CONTENTIONS, AND P.R. 3-2 DISCLOSURES
`000004
`
`PAGE 4
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`
`

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`Respectfully submitted,
`
`
`
` /s/ Kelly J. Kubasta
`Kelly J. Kubasta
`Texas Bar No. 24002430
`Todd C. Basile
`Texas Bar No. 24078205
`KLEMCHUK KUBASTA LLP
`8150 N. Central Expwy., 10th Floor
`Dallas, Texas 75206
`Tel: 214-367-6000
`Fax: 214-367-6001
`
`ATTORNEYS FOR MOTIO, INC.
`
`
`
`
`
`DATED: February 22, 2013
`
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`PLAINTIFF’S P.R. 3-1 DISCLOSURE OF ASSERTED CLAIMS AND
`INFRINGEMENT CONTENTIONS, AND P.R. 3-2 DISCLOSURES
`000005
`
`PAGE 5
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`
`

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`CERTIFICATE OF SERVICE
`
`
`I hereby certify that on February 22, 2013, all counsel of record who are deemed to have
`consented to electronic service are being served with a copy of this document via e-mail.
`
`
`
`
`/s/ Kelly J. Kubasta
`
` Kelly J. Kubasta
`
`
`
`
`
`
`
`
`
`
`PLAINTIFF’S P.R. 3-1 DISCLOSURE OF ASSERTED CLAIMS AND
`INFRINGEMENT CONTENTIONS, AND P.R. 3-2 DISCLOSURES
`000006
`
`PAGE 6
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` PAGE 1
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`
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`history.”
`lifecycle and growth as well as the ability to revive and revert historical content from the archived
`the system as a whole. In addition, IVC enables authors the ability to gain insight on a report’s
`“The IVC system enables administrators to gain insight on the activity of an individual report, author or
`“Capture, maintain & manage previous versions of IBM Cognos content”
`[IVC Product Brochure]
`
`
`
`business intelligence system.
`products comprise, in a general purpose computer, a method for providing automatic version control to a
`While there is nothing to currently suggest that the preamble to this claim is limiting, the IVC and ICS
`
`system, comprising:
`control to a business intelligence
`method for providing automatic version
`1. In a general purpose computer, a
`
`000007
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`otio, Inc. v. BSP Software, LLC and BrightStar Partners, Inc., Case No. 4:12-cv-00647-RAS
`
`MM
`
`EXHIBIT A - INFRINGEMENT CLAIM CHART: U.S. PAT. NO. 8,285,678
`
`
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`

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` PAGE 2
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`groups, roles, packages, models, jobs or any other object within the system.”
`“Version control extends beyond reporting, providing auditing and revision history for data sources,
`or through custom reporting.”
`complete revision history which is easily accessible from the IBM Cognos Studios, Cognos Connection
`development lifecycle are captured in real-time and stored alongside previous versions to provide a
`business policies, processes and regulatory requirements. Modifications made to reports during the
`“Integrated Version Control provides a scalable, feature-rich versioning platform to fully support
`[ICS Product Web Page - http://www.bspsoftware.com/Products/IntegratedControlSuite/Version]
`
`
`
`
`
`000008
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 3
`
`
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`
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`
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`
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`
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`IBM Cognos Studios, Cognos Connection or through custom reporting.”
`alongside previous versions to provide a complete revision history which is easily accessible from the
`“Modifications made to reports during the development lifecycle are captured in real-time and stored
`[ICS Product Web Page - http://www.bspsoftware.com/Products/IntegratedControlSuite/Version]
`
`
`
`of: a report specification and an analysis cube.
`intelligence system, and wherein the business intelligence artifact is selected from the group consisting
`object that produces output when the business intelligence artifact is executed in the business
`artifact in the business intelligence system, wherein the business intelligence artifact is a user-authored
`The IVC and ICS products comprise a method that creates an initial version of a business intelligence
`
`cube;
`a report specification and an analysis
`selected from the group consisting of:
`business intelligence artifact is
`intelligence system, and wherein the
`is executed in the business
`when the business intelligence artifact
`authored object that produces output
`business intelligence artifact is a user-
`intelligence system, wherein the
`intelligence artifact in the business
`
`creating an initial version of a business
`
`
`
`000009
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 4
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`The IVC and ICS products comprise an automated agent that automatically stores the initial version of
`
`version of the business intelligence
`
`automatically storing the initial
`
`or through custom reporting.”
`complete revision history which is easily accessible from the IBM Cognos Studios, Cognos Connection
`development lifecycle are captured in real-time and stored alongside previous versions to provide a
`business policies, processes and regulatory requirements. Modifications made to reports during the
`“Integrated Version Control provides a scalable, feature-rich versioning platform to fully support
`[ICS Product Web Page - http://www.bspsoftware.com/Products/IntegratedControlSuite/Version]
`
`
`
`business intelligence system to provide automated version control to the business intelligence artifact.
`The IVC and ICS products comprise a method that provides an automated agent that interfaces with the
`
`performing the steps of:
`automated agent independently
`business intelligence artifact; the
`automated version control to the
`intelligence system to provide
`interfaces with the business
`
`providing an automated agent that
`
`000010
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 5
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`
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`unparalleled opportunities throughout the development life cycle of IBM Cognos content.”
`[Voiceover] “Integrated Version Control is a revolutionary offering that greatly enhances and provides
`[00:00 – 00:10]
`http://www.youtube.com/watch?v=uNSkKuFglrk&list=PL551389A7C779DDB3&index=18]
`[Product Demonstration Video -
`
`
`
`000011
`
`IBM Cognos Studios, Cognos Connection or through custom reporting.”
`alongside previous versions to provide a complete revision history which is easily accessible from the
`“Modifications made to reports during the development lifecycle are captured in real-time and stored
`[ICS Product Web Page - http://www.bspsoftware.com/Products/IntegratedControlSuite/Version]
`
`the business intelligence artifact with a version control system.
`
`
`
`system;
`artifact with a version control
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 6
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`
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`author to comment on the changes made, and apply an optional change request number.”
`[Voiceover] “On each save, ICS captures a version of the report, along with annotation allowing the
`[00:20 – 00:30]
`
`
`
`
`
`000012
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 7
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`
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`
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`
`
`
`
`
`
`many capabilities that parallel the development lifecycle of the report.”
`connection, showing all changes made over time by various authors. This revision history provides
`[Voiceover] “The report version history can be accessed from within the authoring studio or Cognos
`[00:34 – 00:50]
`
`
`
`
`
`000013
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 8
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`000014
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 9
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`“Capture, maintain & manage previous versions of IBM Cognos content”
`[IVC Product Brochure]
`
`
`
`subsequent version of the business intelligence artifact that includes the requested modification.
`intelligence system to modify the initial version of the business intelligence artifact to create a
`The IVC and ICS products comprise an automated agent that detects a request to the business
`
`requested modification; and
`intelligence artifact that includes the
`subsequent version of the business
`intelligence artifact to create a
`initial version of the business
`intelligence system to modify the
`detecting a request to the business
`
`
`
`
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`000015
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
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`

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` PAGE 10
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`[00:34 – 00:50]
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`
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`000016
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`author to comment on the changes made, and apply an optional change request number.”
`[Voiceover] “On each save, ICS captures a version of the report, along with annotation allowing the
`[00:20 – 00:30]
`http://www.youtube.com/watch?v=uNSkKuFglrk&list=PL551389A7C779DDB3&index=18]
`[Product Demonstration Video -
`
`
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 11
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`000017
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`many capabilities that parallel the development lifecycle of the report.”
`connection, showing all changes made over time by various authors. This revision history provides
`[Voiceover] “The report version history can be accessed from within the authoring studio or Cognos
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 12
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`
`
`[00:20 – 00:30]
`http://www.youtube.com/watch?v=uNSkKuFglrk&list=PL551389A7C779DDB3&index=18]
`[Product Demonstration Video -
`
`
`
`version of the business intelligence artifact in the version control system.
`The IVC and ICS products comprise an automated agent that automatically stores the subsequent
`
`system.
`artifact in the version control
`version of the business intelligence
`automatically storing the subsequent
`
`
`
`
`
`000018
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 13
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`
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`many capabilities that parallel the development lifecycle of the report.”
`connection, showing all changes made over time by various authors. This revision history provides
`[Voiceover] “The report version history can be accessed from within the authoring studio or Cognos
`[00:34 – 00:50]
`
`
`
`
`
`000019
`
`author to comment on the changes made, and apply an optional change request number.”
`[Voiceover] “On each save, ICS captures a version of the report, along with annotation allowing the
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 14
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`000020
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
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`U.S. Patent No. 8,285,678
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`

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` PAGE 15
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`subsequent version of the business intelligence artifact.
`The IVC and ICS products comprise an automated agent recording metadata associated with the
`
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`with the subsequent version of the
`agent recording metadata associated
`further comprising the automated
`
`2. The method according to claim 1,
`
`
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`000021
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
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`U.S. Patent No. 8,285,678
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`

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` PAGE 16
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`000022
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`author to comment on the changes made, and apply an optional change request number.”
`[Voiceover] “On each save, ICS captures a version of the report, along with annotation allowing the
`[00:20 – 00:30]
`http://www.youtube.com/watch?v=uNSkKuFglrk&list=PL551389A7C779DDB3&index=18]
`[Product Demonstration Video -
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`
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`business intelligence artifact.
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`

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` PAGE 17
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`system a current version of the business intelligence artifact whenever modifications to the business
`The IVC and ICS products comprise an automated agent that automatically stores in the version control
`
`storing in the version control system a
`
`the automated agent automatically
`
`
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`
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`further comprising:
`3. The method according to claim 1,
`
`
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`000023
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
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`

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` PAGE 18
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`000024
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`author to comment on the changes made, and apply an optional change request number.”
`[Voiceover] “On each save, ICS captures a version of the report, along with annotation allowing the
`[00:20 – 00:30]
`http://www.youtube.com/watch?v=uNSkKuFglrk&list=PL551389A7C779DDB3&index=18]
`[Product Demonstration Video -
`
`intelligence artifact are detected.
`
`
`
`intelligence artifact are detected.
`modifications to the business
`intelligence artifact whenever
`current version of the business
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
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`

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` PAGE 19
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`000025
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`many capabilities that parallel the development lifecycle of the report.”
`connection, showing all changes made over time by various authors. This revision history provides
`[Voiceover] “The report version history can be accessed from within the authoring studio or Cognos
`[00:34 – 00:50]
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 20
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`version control to a business intelligence artifact authored by a user of the business intelligence system.
`software forming at least part of a business intelligence system, a method for providing automatic
`products comprise, in a general purpose computer, with installed and running business intelligence
`While there is nothing to currently suggest that the preamble to this claim is limiting, the IVC and ICS
`
`
`
`
`
`
`
`method for providing automatic version
`part of a business intelligence system, a
`intelligence software forming at least
`installed and running business
`4. In a general purpose computer, with
`
`
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`000026
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
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`U.S. Patent No. 8,285,678
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`

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` PAGE 21
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`000027
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`history.”
`lifecycle and growth as well as the ability to revive and revert historical content from the archived
`the system as a whole. In addition, IVC enables authors the ability to gain insight on a report’s
`“The IVC system enables administrators to gain insight on the activity of an individual report, author or
`“Capture, maintain & manage previous versions of IBM Cognos content”
`[IVC Product Brochure]
`
`
`
`comprising:
`intelligence system, the method
`authored by a user of the business
`control to a business intelligence artifact
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 22
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`“Modifications made to reports during the development lifecycle are captured in real-time and stored
`[ICS Product Web Page - http://www.bspsoftware.com/Products/IntegratedControlSuite/Version]
`
`selected from the group consisting of: a report specification and an analysis cube.
`The IVC and ICS products comprise a method in which the user creates a business intelligence artifact
`
`
`
`the user creating a business intelligence
`
`and an analysis cube;
`consisting of: a report specification
`artifact selected from the group
`
`
`
`000028
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`groups, roles, packages, models, jobs or any other object within the system.”
`“Version control extends beyond reporting, providing auditing and revision history for data sources,
`or through custom reporting.”
`complete revision history which is easily accessible from the IBM Cognos Studios, Cognos Connection
`development lifecycle are captured in real-time and stored alongside previous versions to provide a
`business policies, processes and regulatory requirements. Modifications made to reports during the
`“Integrated Version Control provides a scalable, feature-rich versioning platform to fully support
`[ICS Product Web Page - http://www.bspsoftware.com/Products/IntegratedControlSuite/Version]
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 23
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`complete revision history which is easily accessible from the IBM Cognos Studios, Cognos Connection
`development lifecycle are captured in real-time and stored alongside previous versions to provide a
`business policies, processes and regulatory requirements. Modifications made to reports during the
`“Integrated Version Control provides a scalable, feature-rich versioning platform to fully support
`[ICS Product Web Page - http://www.bspsoftware.com/Products/IntegratedControlSuite/Version]
`
`
`
`business intelligence system.
`The IVC and ICS products comprise a method that provides an automated agent that interfaces with the
`
`IVC and ICS products operate.
`be present either in the IVC and ICS product and/or in the business intelligence system with which the
`This claim element is an inherent characteristic of an operational business intelligence system, and must
`
`
`
`operation of a business.
`business intelligence system, wherein the business metric data corresponds to information related to the
`in the business intelligence system, generates output based upon business metric data obtained from the
`The IVC and ICS products comprise a method wherein the business intelligence artifact, when executed
`
`
`
`providing an automated agent that
`
`intelligence system; and
`interfaces with the business
`
`of a business;
`to information related to the operation
`the business metric data corresponds
`business intelligence system, wherein
`metric data obtained from the
`generates output based upon business
`business intelligence system,
`artifact, when executed in the
`wherein the business intelligence
`
`000029
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`IBM Cognos Studios, Cognos Connection or through custom reporting.”
`alongside previous versions to provide a complete revision history which is easily accessible from the
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
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`U.S. Patent No. 8,285,678
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`

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` PAGE 24
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`IBM Cognos Studios, Cognos Connection or through custom reporting.”
`alongside previous versions to provide a complete revision history which is easily accessible from the
`“Modifications made to reports during the development lifecycle are captured in real-time and stored
`[ICS Product Web Page - http://www.bspsoftware.com/Products/IntegratedControlSuite/Version]
`
`“Capture, maintain & manage previous versions of IBM Cognos content”
`[IVC Product Brochure]
`
`
`
`
`
`intelligence artifact in a version control system.
`recording the modified version of the business intelligence artifact as a new revision of the business
`the business intelligence artifact, and if modifications to the business intelligence artifact are detected,
`independently performs the steps of: monitoring the business intelligence system for modifications to
`The IVC and ICS products comprise a method that, at a predetermined interval, the automated agent
`
`artifact in a version control system.
`revision of the business intelligence
`business intelligence artifact as a new
`recording the modified version of the
`intelligence artifact are detected,
`modifications to the business
`intelligence artifact, and if
`modifications to the business
`the business intelligence system for
`performing the steps of: monitoring
`automated agent independently
`
`at a predetermined interval, the
`
`000030
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`
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`or through custom reporting.”
`
`

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` PAGE 25
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`unparalleled opportunities throughout the development life cycle of IBM Cognos content.”
`[Voiceover] “Integrated Version Control is a revolutionary offering that greatly enhances and provides
`[00:00 – 00:10]
`http://www.youtube.com/watch?v=uNSkKuFglrk&list=PL551389A7C779DDB3&index=18]
`[Product Demonstration Video -
`
`
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`000031
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 26
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`author to comment on the changes made, and apply an optional change request number.”
`[Voiceover] “On each save, ICS captures a version of the report, along with annotation allowing the
`[00:20 – 00:30]
`
`
`
`
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`000032
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 27
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`many capabilities that parallel the development lifecycle of the report.”
`connection, showing all changes made over time by various authors. This revision history provides
`[Voiceover] “The report version history can be accessed from within the authoring studio or Cognos
`[00:34 – 00:50]
`
`
`
`
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`000033
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 28
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`000034
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 29
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`7. The method according to claim 4,
`
`
`
`reports and other content when first installing the IVC or ICS products.
`or ICS products are shut down for a period of time and/or for importing a large volume of existing
`Moreover, the IVC and ICS products must have an option for reconciling versions if and when the IVC
`
`
`
`
`
`000035
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

`
` PAGE 30
`
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`
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`
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`
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`author to comment on the changes made, and apply an optional change request number.”
`[Voiceover] “On each save, ICS captures a version of the report, along with annotation allowing the
`[00:20 – 00:30]
`http://www.youtube.com/watch?v=uNSkKuFglrk&list=PL551389A7C779DDB3&index=18]
`[Product Demonstration Video -
`
`“Capture, maintain & manage previous versions of IBM Cognos content”
`[IVC Product Brochure]
`
`
`
`
`
`business intelligence artifact that includes the requested modification.
`business intelligence system to modify the business intelligence artifact to create a new version of the
`The IVC and ICS products comprise a method in which the automated agent detects a request to the
`
`000036
`
`modification.
`artifact that includes the requested
`version of the business intelligence
`intelligence artifact to create a new
`system to modify the business
`request to the business intelligence
`the automated agent detecting a
`
`further comprising
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

`
` PAGE 31
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`
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`
`
`
`
`many capabilities that parallel the development lifecycle of the report.”
`connection, showing all changes made over time by various authors. This revision history provides
`[Voiceover] “The report version history can be accessed from within the authoring studio or Cognos
`[00:34 – 00:50]
`
`
`
`
`
`000037
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 32
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`000038
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

`
` PAGE 33
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`The IVC and ICS products comprise a method in which the automated agent automatically records with
`
`
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`
`
`
`
`
`
`recording with the version control
`the automated agent automatically
`
`comprising
`8. The method of claim 7, further
`
`
`
`000039
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 34
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`000040
`
`author to comment on the changes made, and apply an optional change request number.”
`[Voiceover] “On each save, ICS captures a version of the report, along with annotation allowing the
`[00:20 – 00:30]
`http://www.youtube.com/watch?v=uNSkKuFglrk&list=PL551389A7C779DDB3&index=18]
`[Product Demonstration Video -
`
`the version control system the new version of the business intelligence artifact.
`
`
`
`business intelligence artifact.
`system the new version of the
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

`
` PAGE 35
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`000041
`
`many capabilities that parallel the development lifecycle of the report.”
`connection, showing all changes made over time by various authors. This revision history provides
`[Voiceover] “The report version history can be accessed from within the authoring studio or Cognos
`[00:34 – 00:50]
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

`
` PAGE 36
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`The IVC and ICS products comprise a method in which the automated agent records metadata
`
`
`
`
`
`
`
`
`
`metadata associated with the new
`the automated agent recording
`
`comprising
`9. The method of claim 7, further
`
`
`
`000042
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

`
` PAGE 37
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`000043
`
`author to comment on the changes made, and apply an optional change request number.”
`[Voiceover] “On each save, ICS captures a version of the report, along with annotation allowing the
`[00:20 – 00:30]
`http://www.youtube.com/watch?v=uNSkKuFglrk&list=PL551389A7C779DDB3&index=18]
`[Product Demonstration Video -
`
`associated with the new version of the business intelligence artifact.
`
`
`
`artifact.
`version of the business intelligence
`
`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

`
` PAGE 38
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`the version control system a current version of the business intelligence artifact whenever modifications
`The IVC and ICS products comprise a method in which the automated agent automatically records in
`
`recording in the version control
`the automated agent automatically
`
`
`
`
`
`
`
`
`
`comprising
`10. The method of claim 7, further
`
`
`
`000044
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`Integrated Version Control (“IVC”) and Integrated Control Suite (“ICS”)
`
`U.S. Patent No. 8,285,678
`
`

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` PAGE 39
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`000045
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`author to comment on the changes made, and apply an optional change request number.”
`[Voiceover] “On each save, ICS captures a

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