`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`In re Inter Partes Review of:
`U.S. Patent No. 8,306,993
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`For: METHOD, SYSTEM AND COMPUTER
`READABLE MEDIUM FOR
`ADDRESSING HANDLING FROM AN
`OPERATING SYSTEM
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`DECLARATION OF PAUL C. CLARK, D.SC.
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`US Patent and Trademark Office
`PO Box 1450
`Alexandria, Virginia 22313-1450
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`
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`I, Paul C. Clark, hereby declare and state as follows:
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`1.
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`I have been retained as a technical consultant on behalf of Samsung
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`Electronics Co., Ltd., the petitioner in the present proceeding, and I am being
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`compensated at my usual and customary hourly rate. The petition names
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`Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and
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`Samsung Telecommunications America, LLC as real parties-in-interest. I have
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`no financial interest in, or affiliation with, the petitioner, real parties-in-
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`interest, or the patent owner, which I understand to be ARENDI S.A.R.L. My
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`compensation is not dependent upon the outcome of, or my testimony in, the
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`present inter partes review or any litigation proceedings.
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`2.
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`I have reviewed each of the following:
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`a. U.S. Patent No. 8,306,993 (“the ’993 Patent”), including the claims,
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`description, prosecution history, and the certified translation of
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`Norwegian patent application NO 984066 to which the ’993 Patent
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`claims priority (which are identified in the Petition as Exhibits 1001,
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`1002 and 1009, respectively);
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`b. Bonura, T. and J. Miller, “Drop Zones, An Extension to LiveDoc,”
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`SIGCHI Bulletin, Vol. 30, No. 2, April 1998, pp. 59-63 (which is
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`identified in the Petition as Exhibit 1003; hereinafter “Drop Zones”);
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`c. Pensoft Perspective Handbook (which is identified in the Petition as
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`Exhibit 1004; hereinafter “Pensoft”);
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`d. Bonura, T. and J. Miller, “From Documents to Objects, An Overview
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`of LiveDoc,” SIGCHI Bulletin, Vol. 30, No. 2, April 1998, pp. 53-58
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`(which is identified in the Petition as Exhibit 1005; hereinafter
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`“LiveDoc”);
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`e. U.S. Patent No. 6,112,099 to P. Ketola (which is identified in the
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`petition as Exhibit 1006; hereinafter “the ’099 patent”);
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`f. U.S. Patent No. 6,005,549 to D.K. Forest (which is identified in the
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`petition as Exhibit 1007; hereinafter “the ’549 patent”); and
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`g. U.S. Patent No. 5,434,777 to Luciw (which is identified in the petition
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`as Exhibit 1014; hereinafter “the ’777 patent”).
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`3. Upon reviewing the ’993 Patent, I understand that a Norwegian patent
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`application (NO 984066; “Norwegian Application”) was filed on
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`September 3, 1998, and a non-provisional application was filed on
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`September 3, 1999 (Appl. No. 09/390,303), which is the parent application
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`to Appl. No. 11/745,186, filed May 7, 2007, that issued as the ’993 Patent.
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`For the purposes of my analysis, I assume the time of the purported
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`invention to be the years 1998 and 1999.
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`4. A person of ordinary skill in the art at the time would typically have had an
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`undergraduate degree in computer science in addition to two or more years
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`of work experience relating to the field of computerized information
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`processing or equivalent graduate education or work experience. I was a
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`person of skill in this art in 1998.
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`5. My background, qualifications, and experience relevant to the issues in
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`proceeding are summarized below. My curriculum vitae is submitted
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`herewith as Samsung Exhibit 1011.
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`6. In 1986, I received a Bachelor of Science degree in Mathematics from the
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`University of California, Irvine. In 1988, I received a Master of Science
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`degree in Electrical Engineering and Computer Science from the University
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`of Southern California. In 1994, I received a Doctor of Science degree in
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`Computer Science from George Washington University.
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`7. From 1985 to 1989, I worked as a Systems Engineer at Ultrasystems
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`Defense and Space. As more fully set forth in my curriculum vitae, at
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`Ultrasystems I designed and implemented large-scale simulation and
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`network-based systems for the United States Department of Defense
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`(DOD). A high-speed database server I designed and implemented was
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`used for real- time intelligence collection by the National Security Agency
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`(NSA).
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`8. From 1989 to September 1990, as more fully set forth in my curriculum
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`vitae, I worked as a Technical Lead at GTE Government Systems. While at
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`GTE, I designed and implemented network and load generators for OS/2
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`LAN Manager to measure network-performance load metrics for the
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`Central Intelligence Agency (CIA). I also developed X Windows interfaces
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`for a large-scale event-driven network system for the NSA.
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`9. From 1990 to 1995, as more fully set forth in my curriculum vitae, I worked
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`as a Senior Security Engineer at Trusted Information Systems. While at
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`Trusted Information Systems I designed and implemented high-assurance
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`security systems, including cryptographic systems and applications for the
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`NSA and the Defense Advanced Research Projects Agency (DARPA). My
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`work at Trusted Information Systems involved cryptography, operating
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`systems, smartcards, and other security technology developments and
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`implementations.
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`10. From 1995 to 1999, as more fully set forth in my curriculum vitae, I worked
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`as Chief Scientist at DynCorp Network Solutions, where I served as senior
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`internal security consultant for a variety of projects. For example, I was
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`architect and Technical Director of the IRS Secure Submission and
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`Retrieval System that allowed the digitally signed and encrypted
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`submission of tax data over the Internet. The successful deployment of this
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`system resulted in three Al Gore Hammer Awards. I also created a suite of
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`security products for providing secure wide area user access to servers that
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`was marketed and sold to the DOD and other parts of the federal
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`government.
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`11. From 1999 to the present, I have served as President and Chief Technology
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`Officer of SecureMethods, Inc. and Paul C. Clark LLC. SecureMethods
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`specializes in the design, implementation, and deployment of advanced
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`secure network applications for commercial and government clients,
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`including the DOD. SecureMethods provides a comprehensive scalable,
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`Commercial-Off-The-Shelf (COTS) secure architecture, implemented
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`through the use of the SM Gateway. The SM Gateway is a next-generation
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`security appliance developed by SecureMethods that is available on UNIX-
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`based platforms using commercial, government, and Type I cryptography,
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`implemented in both hardware and software. In my capacity as President
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`and Chief Technology Officer of SecureMethods, I have technical and
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`operational oversight of all projects and corporate technical operations. I
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`provide guidance to senior technical personnel for design, implementation,
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`and troubleshooting for a wide range of systems both internal and external.
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`My work includes network systems and security, cryptographic
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`applications, certification, key management, authentication, and integrity
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`strategies for network applications. I also provide a wide range of high-end
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`technical and legal consulting services. My firm specializes in complex
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`software and hardware systems for commercial and DoD clients.
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`12. I was also a member of the Federal Advisory Committee for Key
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`Management Infrastructure (KMI), serving as Chairman of the
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`Interoperability Working Group for Cryptographic Key Recovery. I have
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`also served as an adjunct professor in the Computer Science Department at
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`The George Washington University, where I have taught doctoral-level
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`cryptography, network and computer security courses. I also appeared
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`before a Congressional committee to provide testimony on “Advanced
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`Technology for Border Control.”
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`State of the Art in 1998
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`13. The development and rapid proliferation of personal computing platforms
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`in the 1980’s created a requirement for easy to use applications. The
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`dominant systems in the market during this time period were the Apple II
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`GS/OS and Windows 3.1 shown below:
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`
`
`
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`14. As illustrated above, both platforms provided a graphical user interface and
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`the ability to run multiple user applications at once. The Apple further had
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`hypertext capability that utilized buttons and contained much of the user
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`interface functionality of an Internet web browser
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`http://apple2history.org/history/ah17/ - 08.
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`15. By 1990 these personal computers became increasingly connected and the
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`Internet as a widely available user tool was born. Through the mid 1990’s
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`Apple and Microsoft continued to develop ways to improve the user
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`experience and provide seamless support for multiple data types. Microsoft
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`included a registry with its operating system that define object types and
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`actions that could be associated with objects (e.g., .xls, .doc, .zip). Apple
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`developed data detectors and intelligent agents for use with its platform that
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`led to LiveDoc and Web Objects. Apple also began work on an early
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`commercial PDA called the Newton that incorporated many of its ideas.
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`16. These products together with the explosion of the World Wide Web in the
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`mid 1990’s caused a convergence of user interface features and object
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`oriented strategies to shape the look and feel of the user’s computing
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`experience that persists to the present day. However those same features,
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`functions and object-oriented approach that we enjoy were known
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`separately and in combination prior to 1995. Only a few examples of
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`publicly available technologies are detailed in this filing.
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`17. The claims of the ’993 Patent require “analyzing” “without user
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`designation” in order to “identify a portion of the document as first contact
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`information.” Analysis of data to determine its type or classification was
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`well-known in the art well before 1998.
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`18. Performing analysis of user-entered text to identify recognizable data was
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`known in the art well before 1998. The ability to programmatically detect
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`and identify data structures had long been regarded as advantageous in
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`designing user interfaces. For example, Apple had by that time been for
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`some years selling systems that incorporated algorithms and programs for
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`improving user interfaces by detecting data structures. The ’777 patent,
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`assigned to Apple, and which had a filing date of March 18, 1994, describes
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`one approach to this problem. It describes features of a user interface in a
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`handheld computer, like the contemporaneously-sold Apple Newton. (FIG.
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`2 of the ’777 patent and the Apple Newton MessagePad 120 shown below).
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`19. The ’777 patent notes that “[w]hat is needed is a natural language processor
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`that will quickly and accurately identify and map natural language input
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`phrases. What is further needed is a natural language processor that
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`identifies phrases according to a dynamic set of rules and data.” ’777
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`Patent, 2:64-66. To accomplish this end, it describes breaking user input
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`into substrings of data and using three dynamic mapping routines to analyze
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`the data: a phrasal processor, a pattern processor, and a database query
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`processor. Id. at 9:1-5; FIG. 9; 16:23-29.
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`20. The LiveDoc and Drop Zones publications (also referred to collectively as
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`the “Data Detectors” publications) all describe further refinements of the
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`ideas set out in the ’777 patent, all in the Apple operating environment.
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`Drop Zones is an extension to LiveDoc. Indeed, the Live Doc and Drop
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`Zones publications are authored by same people, and appeared
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`consecutively in the SIGCHI Bulletin.
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`21. These publications include, for example, further refinements of the details
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`of integration of the Data Detector functionality into a user interface, for
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`automation of actions based on the detected data structures.
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`22. In each of these cases, the analysis of text is programmatic and automatic,
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`requiring no intervention by the user or user-identification of the relevant
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`data structure or data to be analyzed.
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`23. In addition, these publications include, for example, further refinements of
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`the functionality for automation of actions based on the detected data
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`structures. The use of detected structures to carry out actions desired by the
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`user was well known before 1998.
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`24. For example, in LiveDoc, a structure detection process runs in the
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`background on the document’s visible text that has been entered by the
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`user. LiveDoc, p. 55. The results of LiveDoc’s analysis are automatically
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`presented to the user by visually highlighting the discovered structures,
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`which need not be searched for and highlighted manually. Id.
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`25. Drop Zones is an extension to LiveDoc, and provides users with an
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`interface for managing LiveDoc objects in the context of a set of typical
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`user actions. A Drop Zone assistant can be thought of as an interpreter that
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`takes features identified by LiveDoc, interprets their meaning with respect
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`to its context, and recommends appropriate actions. As shown below,
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`Figure 2 of Drop Zones illustrates a document in which LiveDoc has
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`identified the structure “Tom Bonura” with its “personalName” recognizer.
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`Drop Zones, p. 60. By selecting the identified “Tom Bonura” structure, it is
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`sent to the Drop Zone control system for action by the Drop Zones
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`Assistants. For example, as shown in Figure 2 below from Drop Zones, if
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`the user drops the name on the E-mail Assistant, a set of four possible
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`actions are presented, the first two of which operate on people’s names and
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`the last two of which operate on people’s e-mail addresses, even though the
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`object is a personal name. Id. at pp. 60-61.
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`Overview of the ’993 Patent
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`26. Based upon my review of the ’993 Patent, it relates to a method, system,
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`and computer readable medium for name and address handling and a
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`“button” provided in a computer program or operating system, and coupled
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`to an information management source, such as a database, for providing
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`address handling with a document created by the computer program or
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`within the operating system. Ex. 1001, 1:19-2:49.
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`27. As shown in FIG. 1, after the user has inserted the address in the word
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`processor, the user commands the button at step 2 and the program analyzes
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`what the user has typed in the document at step 4. At step 6, the program
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`decides what was found in the document and if the program found nothing
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`in the document or what it found was un-interpretable the program goes to
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`step 8 and outputs an appropriate message to the user and then quits at step
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`16. Id. at 4:55-62.
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`28. As discussed in column 5, lines 38-61 of the ’993 Patent, the flowchart
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`shown in FIG. 2 is similar to the flowchart in FIG. 1, with some additional
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`steps. At step 6, if the program only finds a name or a similar name then
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`the name is looked up in the database at step 12, then at step 18 if the
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`program found more than one possible contact/address match, the program
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`displays choices to the user to let him choose an address at step 20.
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`29. Then at step 21 the user decides whether to insert the selected address into
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`the document. If the user does not decide to select the address into the
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`document the program quits execution at step 16. If the user decides to
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`insert the selected address into the document, the program inserts the
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`address and name into the document at step 22 and then quits at step 16. If
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`the program finds a name and address in the database at step 6, then at step
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`14 the program looks up the name in the database and at step 26 the
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`program determines what it has found. If the program does not find the
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`name at step 26, at step 27 the program prompts the user for a decision and
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`review and whether to insert the contact and address. If the user does not
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`decide to insert the contact address, the program quits at step 16. If the user
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`decides to insert the contact address, at step 28 the program inserts the
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`address and name which may be possibly corrected by the user or program
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`in the database and then execution quits at step 16. ’993 Patent, 5:40-61.
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`Claim Construction
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`30. I have been asked to offer my opinion regarding the understanding of a
`
`person skilled in the art regarding certain claim terms in the ’993 Patent. I
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`understand that in the present proceeding, claim terms are interpreted as the
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`broadest reasonable interpretation consistent with the specification or
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`“BRI.”
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`31. I have been asked to offer my opinion regarding the understanding of a
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`person skilled in the art regarding the claim term “analyzing . . . textual
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`information in a document . . . to identify a portion of the document as first
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`contact information, . . . , wherein the first contact information is at least
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`one of a name, a title, an address, a telephone number, and an email
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`address” that appears in each of independent claims 1, 9, and 17 of the ’993
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`Patent. In particular, I have been asked to consider the understanding of
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`one skilled in the art of the phrase “first contact information.”
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`32. I have reviewed the specification of the ’993 Patent, and find that in every
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`example the user first types or enters the contact information, which is then
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`analyzed. See, e.g., Ex. 1001, Figs. 1 & 2, Step 4 (“analyze what the user
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`has typed in the document”); 6:24-26 (“Fig. 3 illustrates a starting point in a
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`word processor document, such as a WORD™ document, wherein the user
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`has typed a name 40.”); 6:39-41 (“Fig. 5 illustrates a starting point in a
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`word processor document, such as a WORD™ document, wherein the user
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`has typed a name and address of a new contact 46.”); 7:6-8 (“Fig. 3
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`illustrates a starting point in a word processor document, such as a
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`WORD™ document, wherein the user has typed a name of a contact 40.”);
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`see also, id. at 7:27-29; 7:58-61; 8:40-42; and 9:16-18. In addition, there is
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`no suggestion in the specification or elsewhere in the ’993 Patent or
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`prosecution history that entry of the contact information into the document
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`can be done other than by the user.
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`33. Based on the above, a person of ordinary skill in the art would understand
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`the BRI of “first contact information” as “text that is entered into the
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`document by the user, including, but not limited to, a name, a title, an
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`address, a telephone number, or an email address.”
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`34. I have also been asked to offer my opinion regarding the understanding of a
`
`person skilled in the art regarding the claim term “analyzing . . . textual
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`information in a document . . . to identify a portion of the document as first
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`contact information, without user designation of a specific part of the
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`textual information to be subject to the analyzing, . . .”. In particular, I have
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`been asked to consider the understanding of one skilled in the art of the
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`phrase “without user designation.”
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`35. Based upon my review, the specification of the ’993 Patent does not
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`contain any description or reference to “without user designation.” During
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`the examination of the ’993 Patent, the applicants explained in Response D,
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`March 29, 2010 at page 17, that the “key point” for “without user
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`designation” is that the “analyzing” takes place “without the user first
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`having to ‘help’ the program specify the ‘contact information’.” (emphasis
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`in original). Ex. 1002, p. 854. Based on the applicant’s remarks, it is my
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`opinion that one skilled in the art would understand the BRI of “without
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`user designation” to be “without the user having to specify the
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`information.”
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`36. I have also been asked to offer my opinion regarding the understanding of
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`a person skilled in the art regarding the claim term “an input device
`
`configured so that a single execute command from the input device is
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`sufficient to case the performing.” In particular, I have been asked to
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`consider the understanding of one skilled in the art of the phrase “input
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`device.”
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`37. The ’993 Patent explains at 3:59-62 and 4:6-7 that “single button
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`addressing” is achieved by providing an “input device” or button, such as a
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`touch screen, touch screen button, keyboard, keyboard button, icon, menu,
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`menu choice, voice command device, etc. Based on this, in my opinion one
`
`skilled in the art would understand that the BRI of an “input device” as
`
`recited in the claims of the ’993 Patent is “a device that allows a user to
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`provide input into a computer program, for example, a touch screen, touch
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`screen button, keyboard, keyboard button, icon, menu, menu choice, voice
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`command device, or button.”
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`Disclosure of the Norwegian Application No. 984066
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`38. I have been asked to offer my opinion regarding whether one of ordinary
`
`skill in the art would understand whether the Norwegian Application
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`discloses “analyzing in a computer process textual information in a
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`document configured to be stored for later retrieval to identify a portion of
`
`the document as first contact information,” an element recited in each of
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`independent claims 1, 9, and 17 of the ’993 Patent.
`
`39. The concept of “analyzing” is discussed in the ’993 Patent at, for example,
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`column 4, line 55 to column 5, line 2, with reference to the flow chart in
`
`FIG. 1 of the ’993 Patent. I have reviewed the certified translation of
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`Norwegian patent application NO 984066 (Ex. 1009), and “analyzing in a
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`computer process textual information in a document configured to be stored
`
`for later retrieval to identify a portion of the document as first contact
`
`information” function is nowhere described. Based upon my review, NO
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`984066 does not include the subject matter of 4:55-5:2 of the ’993 Patent,
`
`or FIG. 1.
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`40. Based on my review, NO 984066 (Ex. 1009) is concerned with “searching”
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`in a database. As explained on page 6 of Ex. 1009, the user enters the
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`addressee’s name or part of a name, and then taps the function button or
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`clicks on the icon to perform a search in a database or file in order to find
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`the part of the name or address that was already entered. NO 984066 does
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`not describe, or explain to a person skilled in the art how to carry out,
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`“analyzing in a computer process textual information in a document
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`configured to be stored for later retrieval to identify a portion of the
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`document as first contact information.”
`
`41. Additionally, the disclosure of NO 984066 does not disclose performing
`
`any analysis “without user designation”-- that is, without the user
`
`specifying the data -- as required by the claims of the ’993 Patent.
`
`LiveDoc and Drop Zones
`
`42. In LiveDoc, a structure detection process runs in the background on the
`
`document’s visible text that has been entered by the user. LiveDoc, p. 55.
`
`The results of LiveDoc’s analysis are automatically presented to the user by
`
`visually highlighting the discovered structures, which need not be searched
`
`for and highlighted manually. Id.
`
`43. As its title states, Drop Zones is an extension to LiveDoc, which utilizes the
`
`Apple Data Detectors functionality. See LiveDoc, at 54.
`
`44. Drop Zones discloses analysis of documents to recognize structured
`
`information used to achieve specific actions. Drop Zones, p. 59. Various
`
`kinds of recognizers are used to describe the structures to be identified, and
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`code can be associated with each structure to instruct applications to carry
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`out specific user actions on the identified structures. Id.
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`45. Drop Zones provides users with an interface for managing LiveDoc objects
`
`in the context of a set of typical user actions. A Drop Zone assistant can be
`
`thought of as an interpreter that takes features identified by LiveDoc,
`
`interprets their meaning with respect to its context, and recommends
`
`appropriate actions. As shown in Figures 1 and 2, the window labeled
`
`“Activities” is a Drop Zone interface to a set of interpreters or “assistants.”
`
`The assistants make their capabilities visible when the user selects various
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`structures identified by LiveDoc and drags them to the assistants.
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`46. Figure 2 (shown below) of Drop Zones shows a document in which
`
`LiveDoc has identified the structure “Tom Bonura” with its
`
`“personalName” recognizer. Drop Zones, p. 60. By selecting the identified
`
`“Tom Bonura” structure, it is sent to the Drop Zone control system for
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`action by the Drop Zones Assistants. For example, if the user drops the
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`name on the E-mail Assistant, a set of four possible actions are presented,
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`the first two of which operate on people’s names and the last two of which
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`operate on people’s e-mail addresses, even though the object is a personal
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`name. Id. at pp. 60-61.
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`47. As explained on page 61, the Drop Zones representation system provides
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`two ways through which an Assistant can gain access to information.
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`Mappings can be built between the objects inside the Drop Zones
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`representations system (e.g., the PERSON object has attributes such as
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`PhoneNumber and EmailAddress) and databases or other applications.
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`Such a mapping can be combined with a script or other programmatic way
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`of manipulating application to enable, for example, the E-mail Assistant to
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`search inside an address book application for a person with a stated phone
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`number. Drop Zones, p. 61.
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`48. As another example, Drop Zones provides on page 62 the example of a
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`Meeting Assistant, which offers the action “[a]dd this meeting to your
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`calendar,” and can aggregate date, time, venue, and name information
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`spread throughout a message into a record saved in the user’s calendar. Id.
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`at p. 62.
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`49. A person of ordinary skill in the art would understand that the “add this
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`meeting to your calendar” action would store data in a calendar database.
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`Pensoft
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`50. Pensoft describes “Perspective,” a computer program that runs in the
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`PenPoint operating system that enables a number of applications including
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`Perspective Day Planner, Perspective Month Planner, Perspective List
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`Paper and Perspective ProfileBook. With Perspective, information is
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`coordinated to provide access to relevant information in any Perspective
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`document. Pensoft, p. 6. A document is like a predesigned piece of paper
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`with areas to hold particular kind of information, and each document
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`specifies a set of items it displays. For example, the Address Book displays
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`all items in the People and Company categories. Id. at pp. 8-9. As
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`explained on page 17 of Pensoft, the Address book lists addresses and
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`phone numbers for all people and companies entered into Perspective, with
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`the names alphabetized, as shown in the figure below. Thus, the
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`Perspectives Address Book includes at least three fields for storing contact
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`information - name, address, and telephone number.
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`51. As explained on page 17 of Pensoft, the Address Book can be used to (1)
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`write and track names, phone numbers and addresses for everyone in one
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`place and (2) update information when it changes. The Address Book
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`database entries may be “separately accessed and edited by a user” and may
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`also be “updated.” As such, the Pensoft reference discloses the use of a
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`relational database.
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`52. Additionally, Pensoft discloses that each item in the Address Book includes
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`a profile that contains further details relating to the item. For example, the
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`Company profile depicted on p. 11 of Pensoft lists information in fields
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`including one for the name of the company, one for the phone number of
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`the company, and one for the address of the company. Thus, Pensoft
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`discloses that the Address Book database includes at least three fields for
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`storing contact information such as name, address, and telephone number.
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`53. Additionally, the Address Book database is “integrated” (in the sense
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`discussed by the applicant regarding the Miller ’647 Patent in the Third
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`Supplement to Response H dated November 3, 2011 (see Ex. 1002, p.
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`149)), because the three fields and the corresponding information for them
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`all appear in the Address Book database. See, e.g., Pensoft, figure at p. 11
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`shown below (depicting the “Company” profile for an item in the Address
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`Book database).
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`
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`54. As explained on pages 11 and 36 of Pensoft, Perspective establishes a
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`relationship or link between two items. For example, a person is linked to
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`the company at which they work. Each link in Perspective has a name,
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`which is displayed in italics. A person's profile shows a link detail name
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`Company. The content of the link is the name of the company where the
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`person works. Similarly, a Company profile shows a link detail named
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`Employees. The Employees link contains the names of the people who
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`work at the company. Pensoft also discloses that Perspective is capable of
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`determining that entered text corresponds to the name of a person not yet
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`having an entry or any information in the Perspective databases, and
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`creating a new entry and links for such names. Ex. 1004, p. 41.
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`55. As further explained on page 11 of Pensoft, to get information from links
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`beyond link details, a user can open the profile for any linked item.
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`Additionally, Pensoft discloses that a known or derived e-mail address or
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`other contact information can be displayed. As explained in page 66, you
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`can view the information for the service in any Perspective document or
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`profile. For example, if you install electronic mail as a service, then the e-
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`mail address for each person can be displayed in a column in a list
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`document or in a profile for the person. Pensoft, p. 66
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`56. The Associate is the part of Perspective that automatically establishes links
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`by recognizing the names of people, companies, etc. Links are displayed as
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`bold text in documents and profiles, so that they can be easily located. For
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`example, as explained on page 38 of Pensoft, if the user has two or more
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`people named Dan in Perspective, and writes “Meet Dan” the Associate
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`asks which Dan the user is meeting. If the user has not previously entered a
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`Dan, the Associate asks if the user wants to create a new profile for Dan.
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`The Combination of LiveDoc, Drop Zones and Pensoft
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`57. LiveDoc, Drop Zones and Pensoft are all directed to computer-
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`implemented methods for information handling that involve analyzing
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`textual information and data structures in order to identify contact
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`information, and performing actions related to the contact information. As
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`noted above, Drop Zones is an extension of the LiveDoc functionality, Drop
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`Zones manages LiveDoc programmable objects in the context of user
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`actions, the articles were authored by the same people, and appeared
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`consecutively in the SIGCHI Bulletin. As such, one skilled in the art would
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`combine the features of LiveDoc and Drop Zones.
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`58. A person skilled in the art would have combined the features of
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`LiveDoc/Drop Zones and Pensoft because the documents all relate to
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`mappings or linkages between information objects, and one skilled in the
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`art would appreciate the advantages of using the Perspective Address Book
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`disclosed in Pensoft with the LiveDoc