throbber
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`In re Inter Partes Review of:
`U.S. Patent No. 8,306,993
`
`For: METHOD, SYSTEM AND COMPUTER
`READABLE MEDIUM FOR
`ADDRESSING HANDLING FROM AN
`OPERATING SYSTEM
`
`
`
`
`
`
`
`
`
`DECLARATION OF PAUL C. CLARK, D.SC.
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`US Patent and Trademark Office
`PO Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`I, Paul C. Clark, hereby declare and state as follows:
`
`1.
`
`I have been retained as a technical consultant on behalf of Samsung
`
`Electronics Co., Ltd., the petitioner in the present proceeding, and I am being
`
`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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`Docket No. 032449.0031-US08
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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.
`
`2.
`
`I have reviewed each of the following:
`
`a. U.S. Patent No. 8,306,993 (“the ’993 Patent”), including the claims,
`
`description, prosecution history, and the certified translation of
`
`Norwegian patent application NO 984066 to which the ’993 Patent
`
`claims priority (which are identified in the Petition as Exhibits 1001,
`
`1002 and 1009, respectively);
`
`b. Bonura, T. and J. Miller, “Drop Zones, An Extension to LiveDoc,”
`
`SIGCHI Bulletin, Vol. 30, No. 2, April 1998, pp. 59-63 (which is
`
`identified in the Petition as Exhibit 1003; hereinafter “Drop Zones”);
`
`c. Pensoft Perspective Handbook (which is identified in the Petition as
`
`Exhibit 1004; hereinafter “Pensoft”);
`
`d. Bonura, T. and J. Miller, “From Documents to Objects, An Overview
`
`of LiveDoc,” SIGCHI Bulletin, Vol. 30, No. 2, April 1998, pp. 53-58
`
`(which is identified in the Petition as Exhibit 1005; hereinafter
`
`“LiveDoc”);
`
`e. U.S. Patent No. 6,112,099 to P. Ketola (which is identified in the
`
`petition as Exhibit 1006; hereinafter “the ’099 patent”);
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`Docket No. 032449.0031-US08
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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
`
`g. U.S. Patent No. 5,434,777 to Luciw (which is identified in the petition
`
`as Exhibit 1014; hereinafter “the ’777 patent”).
`
`3. Upon reviewing the ’993 Patent, I understand that a Norwegian patent
`
`application (NO 984066; “Norwegian Application”) was filed on
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`September 3, 1998, and a non-provisional application was filed on
`
`September 3, 1999 (Appl. No. 09/390,303), which is the parent application
`
`to Appl. No. 11/745,186, filed May 7, 2007, that issued as the ’993 Patent.
`
`For the purposes of my analysis, I assume the time of the purported
`
`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
`
`of work experience relating to the field of computerized information
`
`processing or equivalent graduate education or work experience. I was a
`
`person of skill in this art in 1998.
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`5. My background, qualifications, and experience relevant to the issues in
`
`proceeding are summarized below. My curriculum vitae is submitted
`
`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
`
`of Southern California. In 1994, I received a Doctor of Science degree in
`
`Computer Science from George Washington University.
`
`7. From 1985 to 1989, I worked as a Systems Engineer at Ultrasystems
`
`Defense and Space. As more fully set forth in my curriculum vitae, at
`
`Ultrasystems I designed and implemented large-scale simulation and
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`network-based systems for the United States Department of Defense
`
`(DOD). A high-speed database server I designed and implemented was
`
`used for real- time intelligence collection by the National Security Agency
`
`(NSA).
`
`8. From 1989 to September 1990, as more fully set forth in my curriculum
`
`vitae, I worked as a Technical Lead at GTE Government Systems. While at
`
`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.
`
`9. From 1990 to 1995, as more fully set forth in my curriculum vitae, I worked
`
`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
`
`implementations.
`
`10. From 1995 to 1999, as more fully set forth in my curriculum vitae, I worked
`
`as Chief Scientist at DynCorp Network Solutions, where I served as senior
`
`internal security consultant for a variety of projects. For example, I was
`
`architect and Technical Director of the IRS Secure Submission and
`
`Retrieval System that allowed the digitally signed and encrypted
`
`submission of tax data over the Internet. The successful deployment of this
`
`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
`
`was marketed and sold to the DOD and other parts of the federal
`
`government.
`
`11. From 1999 to the present, I have served as President and Chief Technology
`
`Officer of SecureMethods, Inc. and Paul C. Clark LLC. SecureMethods
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`specializes in the design, implementation, and deployment of advanced
`
`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
`
`through the use of the SM Gateway. The SM Gateway is a next-generation
`
`security appliance developed by SecureMethods that is available on UNIX-
`
`based platforms using commercial, government, and Type I cryptography,
`
`implemented in both hardware and software. In my capacity as President
`
`and Chief Technology Officer of SecureMethods, I have technical and
`
`operational oversight of all projects and corporate technical operations. I
`
`provide guidance to senior technical personnel for design, implementation,
`
`and troubleshooting for a wide range of systems both internal and external.
`
`My work includes network systems and security, cryptographic
`
`applications, certification, key management, authentication, and integrity
`
`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
`
`software and hardware systems for commercial and DoD clients.
`
`12. I was also a member of the Federal Advisory Committee for Key
`
`Management Infrastructure (KMI), serving as Chairman of the
`
`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
`
`The George Washington University, where I have taught doctoral-level
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`cryptography, network and computer security courses. I also appeared
`
`before a Congressional committee to provide testimony on “Advanced
`
`Technology for Border Control.”
`
`State of the Art in 1998
`
`13. The development and rapid proliferation of personal computing platforms
`
`in the 1980’s created a requirement for easy to use applications. The
`
`dominant systems in the market during this time period were the Apple II
`
`GS/OS and Windows 3.1 shown below:
`
`
`
`
`
`14. As illustrated above, both platforms provided a graphical user interface and
`
`the ability to run multiple user applications at once. The Apple further had
`
`hypertext capability that utilized buttons and contained much of the user
`
`interface functionality of an Internet web browser
`
`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
`
`experience and provide seamless support for multiple data types. Microsoft
`
`included a registry with its operating system that define object types and
`
`actions that could be associated with objects (e.g., .xls, .doc, .zip). Apple
`
`developed data detectors and intelligent agents for use with its platform that
`
`led to LiveDoc and Web Objects. Apple also began work on an early
`
`commercial PDA called the Newton that incorporated many of its ideas.
`
`16. These products together with the explosion of the World Wide Web in the
`
`mid 1990’s caused a convergence of user interface features and object
`
`oriented strategies to shape the look and feel of the user’s computing
`
`experience that persists to the present day. However those same features,
`
`functions and object-oriented approach that we enjoy were known
`
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`Docket No. 032449.0031-US08
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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.
`
`17. The claims of the ’993 Patent require “analyzing” “without user
`
`designation” in order to “identify a portion of the document as first contact
`
`information.” Analysis of data to determine its type or classification was
`
`well-known in the art well before 1998.
`
`18. Performing analysis of user-entered text to identify recognizable data was
`
`known in the art well before 1998. The ability to programmatically detect
`
`and identify data structures had long been regarded as advantageous in
`
`designing user interfaces. For example, Apple had by that time been for
`
`some years selling systems that incorporated algorithms and programs for
`
`improving user interfaces by detecting data structures. The ’777 patent,
`
`assigned to Apple, and which had a filing date of March 18, 1994, describes
`
`one approach to this problem. It describes features of a user interface in a
`
`handheld computer, like the contemporaneously-sold Apple Newton. (FIG.
`
`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
`
`that will quickly and accurately identify and map natural language input
`
`phrases. What is further needed is a natural language processor that
`
`identifies phrases according to a dynamic set of rules and data.” ’777
`
`Patent, 2:64-66. To accomplish this end, it describes breaking user input
`
`into substrings of data and using three dynamic mapping routines to analyze
`
`the data: a phrasal processor, a pattern processor, and a database query
`
`processor. Id. at 9:1-5; FIG. 9; 16:23-29.
`
`20. The LiveDoc and Drop Zones publications (also referred to collectively as
`
`the “Data Detectors” publications) all describe further refinements of the
`
`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
`
`Zones publications are authored by same people, and appeared
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`consecutively in the SIGCHI Bulletin.
`
`21. These publications include, for example, further refinements of the details
`
`of integration of the Data Detector functionality into a user interface, for
`
`automation of actions based on the detected data structures.
`
`22. In each of these cases, the analysis of text is programmatic and automatic,
`
`requiring no intervention by the user or user-identification of the relevant
`
`data structure or data to be analyzed.
`
`23. In addition, these publications include, for example, further refinements of
`
`the functionality for automation of actions based on the detected data
`
`structures. The use of detected structures to carry out actions desired by the
`
`user was well known before 1998.
`
`24. For example, 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.
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`25. Drop Zones is an extension to LiveDoc, and 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 below,
`
`Figure 2 of Drop Zones illustrates 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 action by the Drop Zones
`
`Assistants. For example, as shown in Figure 2 below from Drop Zones, if
`
`the user drops the name on the E-mail Assistant, a set of four possible
`
`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
`
`26. Based upon my review of the ’993 Patent, it relates to a method, system,
`
`and computer readable medium for name and address handling and a
`
`“button” provided in a computer program or operating system, and coupled
`
`to an information management source, such as a database, for providing
`
`address handling with a document created by the computer program or
`
`within the operating system. Ex. 1001, 1:19-2:49.
`
`27. As shown in FIG. 1, after the user has inserted the address in the word
`
`processor, the user commands the button at step 2 and the program analyzes
`
`what the user has typed in the document at step 4. At step 6, the program
`
`decides what was found in the document and if the program found nothing
`
`in the document or what it found was un-interpretable the program goes to
`
`step 8 and outputs an appropriate message to the user and then quits at step
`
`16. Id. at 4:55-62.
`
`28. As discussed in column 5, lines 38-61 of the ’993 Patent, the flowchart
`
`shown in FIG. 2 is similar to the flowchart in FIG. 1, with some additional
`
`steps. At step 6, if the program only finds a name or a similar name then
`
`the name is looked up in the database at step 12, then at step 18 if the
`
`program found more than one possible contact/address match, the program
`
`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
`
`the document. If the user does not decide to select the address into the
`
`document the program quits execution at step 16. If the user decides to
`
`insert the selected address into the document, the program inserts the
`
`address and name into the document at step 22 and then quits at step 16. If
`
`the program finds a name and address in the database at step 6, then at step
`
`14 the program looks up the name in the database and at step 26 the
`
`program determines what it has found. If the program does not find the
`
`name at step 26, at step 27 the program prompts the user for a decision and
`
`review and whether to insert the contact and address. If the user does not
`
`decide to insert the contact address, the program quits at step 16. If the user
`
`decides to insert the contact address, at step 28 the program inserts the
`
`address and name which may be possibly corrected by the user or program
`
`in the database and then execution quits at step 16. ’993 Patent, 5:40-61.
`
`Claim Construction
`
`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
`
`understand that in the present proceeding, claim terms are interpreted as the
`
`broadest reasonable interpretation consistent with the specification or
`
`“BRI.”
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`31. I have been asked to offer my opinion regarding the understanding of a
`
`person skilled in the art regarding the claim term “analyzing . . . textual
`
`information in a document . . . to identify a portion of the document as first
`
`contact information, . . . , wherein the first contact information is at least
`
`one of a name, a title, an address, a telephone number, and an email
`
`address” that appears in each of independent claims 1, 9, and 17 of the ’993
`
`Patent. In particular, I have been asked to consider the understanding of
`
`one skilled in the art of the phrase “first contact information.”
`
`32. I have reviewed the specification of the ’993 Patent, and find that in every
`
`example the user first types or enters the contact information, which is then
`
`analyzed. See, e.g., Ex. 1001, Figs. 1 & 2, Step 4 (“analyze what the user
`
`has typed in the document”); 6:24-26 (“Fig. 3 illustrates a starting point in a
`
`word processor document, such as a WORD™ document, wherein the user
`
`has typed a name 40.”); 6:39-41 (“Fig. 5 illustrates a starting point in a
`
`word processor document, such as a WORD™ document, wherein the user
`
`has typed a name and address of a new contact 46.”); 7:6-8 (“Fig. 3
`
`illustrates a starting point in a word processor document, such as a
`
`WORD™ document, wherein the user has typed a name of a contact 40.”);
`
`see also, id. at 7:27-29; 7:58-61; 8:40-42; and 9:16-18. In addition, there is
`
`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
`
`can be done other than by the user.
`
`33. Based on the above, a person of ordinary skill in the art would understand
`
`the BRI of “first contact information” as “text that is entered into the
`
`document by the user, including, but not limited to, a name, a title, an
`
`address, a telephone number, or an email address.”
`
`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
`
`information in a document . . . to identify a portion of the document as first
`
`contact information, without user designation of a specific part of the
`
`textual information to be subject to the analyzing, . . .”. In particular, I have
`
`been asked to consider the understanding of one skilled in the art of the
`
`phrase “without user designation.”
`
`35. Based upon my review, the specification of the ’993 Patent does not
`
`contain any description or reference to “without user designation.” During
`
`the examination of the ’993 Patent, the applicants explained in Response D,
`
`March 29, 2010 at page 17, that the “key point” for “without user
`
`designation” is that the “analyzing” takes place “without the user first
`
`having to ‘help’ the program specify the ‘contact information’.” (emphasis
`
`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
`
`user designation” to be “without the user having to specify the
`
`information.”
`
`36. I have also been asked to offer my opinion regarding the understanding of
`
`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
`
`sufficient to case the performing.” In particular, I have been asked to
`
`consider the understanding of one skilled in the art of the phrase “input
`
`device.”
`
`37. The ’993 Patent explains at 3:59-62 and 4:6-7 that “single button
`
`addressing” is achieved by providing an “input device” or button, such as a
`
`touch screen, touch screen button, keyboard, keyboard button, icon, menu,
`
`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
`
`provide input into a computer program, for example, a touch screen, touch
`
`screen button, keyboard, keyboard button, icon, menu, menu choice, voice
`
`command device, or button.”
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`Disclosure of the Norwegian Application No. 984066
`
`38. I have been asked to offer my opinion regarding whether one of ordinary
`
`skill in the art would understand whether the Norwegian Application
`
`discloses “analyzing in a 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,” an element recited in each of
`
`independent claims 1, 9, and 17 of the ’993 Patent.
`
`39. The concept of “analyzing” is discussed in the ’993 Patent at, for example,
`
`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
`
`Norwegian patent application NO 984066 (Ex. 1009), and “analyzing in a
`
`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
`
`984066 does not include the subject matter of 4:55-5:2 of the ’993 Patent,
`
`or FIG. 1.
`
`40. Based on my review, NO 984066 (Ex. 1009) is concerned with “searching”
`
`in a database. As explained on page 6 of Ex. 1009, the user enters the
`
`addressee’s name or part of a name, and then taps the function button or
`
`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
`
`not describe, or explain to a person skilled in the art how to carry out,
`
`“analyzing in a 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.”
`
`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
`
`out specific user actions on the identified structures. Id.
`
`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
`
`structures identified by LiveDoc and drags them to the assistants.
`
`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
`
`action by the Drop Zones Assistants. For example, if the user drops the
`
`name on the E-mail Assistant, a set of four possible actions are presented,
`
`the first two of which operate on people’s names and the last two of which
`
`operate on people’s e-mail addresses, even though the object is a personal
`
`name. Id. at pp. 60-61.
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`47. As explained on page 61, the Drop Zones representation system provides
`
`two ways through which an Assistant can gain access to information.
`
`Mappings can be built between the objects inside the Drop Zones
`
`representations system (e.g., the PERSON object has attributes such as
`
`PhoneNumber and EmailAddress) and databases or other applications.
`
`Such a mapping can be combined with a script or other programmatic way
`
`of manipulating application to enable, for example, the E-mail Assistant to
`
`search inside an address book application for a person with a stated phone
`
`number. Drop Zones, p. 61.
`
`48. As another example, Drop Zones provides on page 62 the example of a
`
`Meeting Assistant, which offers the action “[a]dd this meeting to your
`
`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.
`
`at p. 62.
`
`49. A person of ordinary skill in the art would understand that the “add this
`
`meeting to your calendar” action would store data in a calendar database.
`
`Pensoft
`
`50. Pensoft describes “Perspective,” a computer program that runs in the
`
`PenPoint operating system that enables a number of applications including
`
`Perspective Day Planner, Perspective Month Planner, Perspective List
`
`Paper and Perspective ProfileBook. With Perspective, information is
`
`coordinated to provide access to relevant information in any Perspective
`
`document. Pensoft, p. 6. A document is like a predesigned piece of paper
`
`with areas to hold particular kind of information, and each document
`
`specifies a set of items it displays. For example, the Address Book displays
`
`all items in the People and Company categories. Id. at pp. 8-9. As
`
`explained on page 17 of Pensoft, the Address book lists addresses and
`
`phone numbers for all people and companies entered into Perspective, with
`
`the names alphabetized, as shown in the figure below. Thus, the
`
`Perspectives Address Book includes at least three fields for storing contact
`
`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)
`
`write and track names, phone numbers and addresses for everyone in one
`
`place and (2) update information when it changes. The Address Book
`
`database entries may be “separately accessed and edited by a user” and may
`
`also be “updated.” As such, the Pensoft reference discloses the use of a
`
`relational database.
`
`52. Additionally, Pensoft discloses that each item in the Address Book includes
`
`a profile that contains further details relating to the item. For example, the
`
`Company profile depicted on p. 11 of Pensoft lists information in fields
`
`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
`
`discloses that the Address Book database includes at least three fields for
`
`storing contact information such as name, address, and telephone number.
`
`53. Additionally, the Address Book database is “integrated” (in the sense
`
`discussed by the applicant regarding the Miller ’647 Patent in the Third
`
`Supplement to Response H dated November 3, 2011 (see Ex. 1002, p.
`
`149)), because the three fields and the corresponding information for them
`
`all appear in the Address Book database. See, e.g., Pensoft, figure at p. 11
`
`shown below (depicting the “Company” profile for an item in the Address
`
`Book database).
`
`
`
`54. As explained on pages 11 and 36 of Pensoft, Perspective establishes a
`
`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,
`
`which is displayed in italics. A person's profile shows a link detail name
`
`Company. The content of the link is the name of the company where the
`
`person works. Similarly, a Company profile shows a link detail named
`
`Employees. The Employees link contains the names of the people who
`
`work at the company. Pensoft also discloses that Perspective is capable of
`
`determining that entered text corresponds to the name of a person not yet
`
`having an entry or any information in the Perspective databases, and
`
`creating a new entry and links for such names. Ex. 1004, p. 41.
`
`55. As further explained on page 11 of Pensoft, to get information from links
`
`beyond link details, a user can open the profile for any linked item.
`
`Additionally, Pensoft discloses that a known or derived e-mail address or
`
`other contact information can be displayed. As explained in page 66, you
`
`can view the information for the service in any Perspective document or
`
`profile. For example, if you install electronic mail as a service, then the e-
`
`mail address for each person can be displayed in a column in a list
`
`document or in a profile for the person. Pensoft, p. 66
`
`56. The Associate is the part of Perspective that automatically establishes links
`
`by recognizing the names of people, companies, etc. Links are displayed as
`
`bold text in documents and profiles, so that they can be easily located. For
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`Docket No. 032449.0031-US08
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`example, as explained on page 38 of Pensoft, if the user has two or more
`
`people named Dan in Perspective, and writes “Meet Dan” the Associate
`
`asks which Dan the user is meeting. If the user has not previously entered a
`
`Dan, the Associate asks if the user wants to create a new profile for Dan.
`
`The Combination of LiveDoc, Drop Zones and Pensoft
`
`57. LiveDoc, Drop Zones and Pensoft are all directed to computer-
`
`implemented methods for information handling that involve analyzing
`
`textual information and data structures in order to identify contact
`
`information, and performing actions related to the contact information. As
`
`noted above, Drop Zones is an extension of the LiveDoc functionality, Drop
`
`Zones manages LiveDoc programmable objects in the context of user
`
`actions, the articles were authored by the same people, and appeared
`
`consecutively in the SIGCHI Bulletin. As such, one skilled in the art would
`
`combine the features of LiveDoc and Drop Zones.
`
`58. A person skilled in the art would have combined the features of
`
`LiveDoc/Drop Zones and Pensoft because the documents all relate to
`
`mappings or linkages between information objects, and one skilled in the
`
`art would appreciate the advantages of using the Perspective Address Book
`
`disclosed in Pensoft with the LiveDoc

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