`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`In re inter partes review of:
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`U.S. Patent 8,346,894 to
`ARUNACHALAM
`Filed: Herewith
`For: Real-Time Web Transactions from
`Web Applications
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`Atty. Docket: 2187.051IPR6
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`Declaration of Dr. Marvin Sirbu in Support of
`Petition for Inter Partes Review of U.S. Patent No. 8,346,894
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`Mail Stop Inter Partes Review
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`Attn: Patent Trial and Appeal Board
`Commissioner for Patents
`PO Box 1450
`Alexandria, VA 22313-1450
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`Commissioner:
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`I, Marvin Sirbu, Sc.D., declare as follows:
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`1.
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`I have been retained on behalf of SAP America, Inc. (“SAP”) for
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`the above-captioned inter partes review proceeding. I understand that this
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`proceeding involves U.S. Patent No. 8,346,894 (“the ‘894 patent”), titled “Real-
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`Time Web Transactions from Web Applications.”
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`2.
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`I have reviewed and am familiar with the specification of the ‘894
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`patent issued on January 1, 2013. I will cite to the specification using the
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`following format: (the ‘894 patent, 1:1-10). This example citation points to the
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`‘894 patent specification at column 1, lines 1-10.
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`3.
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`I have reviewed and am familiar with the following prior art used
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`in the Petition for Inter Partes Review of the ‘894 patent:
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` U.S. Publication No. 2008/0275779 to Lakshminarayanan (“the ‘779
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`application”). Lakshminarayanan is provided as SAP 1004.
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` “Developing Enterprise Web Services. An Architect’s Guide.,” by
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`Chatterjee et al. (“Chatterjee”) Chatterjee is provided as SAP 1005.
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` U.S. Publication No. 2006/0161513 to Drumm et al. (“Drumm”).
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`Drumm is provided as SAP 1006
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` U.S. Publication No. 2009/0006614 to Le et al. (“Le”). Le is provided
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`as SAP 1007
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` U.S. Publication No. 2004/0054610 to Amstutz et al. (“Amstutz”).
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`Amstutz is provided as SAP 1008.
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`4.
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`I am familiar with the technology at issue as of the earliest possible
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`priority date of the ‘894 patent: November 30, 2009.
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`5.
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`I have been asked to provide my technical review, analysis,
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`insights and opinions regarding the above-noted references that form the basis
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`for the grounds of rejection set forth in the Petition for Inter Partes Review of
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`U.S. Patent No. 8,346,894.
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`I.
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`Qualifications
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`6. My academic and professional pursuits are closely related to the
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`subject matter of the ‘894 patent. In 1989, I founded the Information
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`Networking Institute at Carnegie Mellon University, dedicated to the integration
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`of communication, computing and business studies. My efforts placed me at the
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`cutting edge of early 1990’s Internet commerce. My work was instrumental in
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`the research and development of distributed transaction processing systems,
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`including my work on the NetBill micropayment system from 1994-96.
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`7.
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`I am a named inventor on two U.S. Patents relating to ecommerce
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`payment systems.
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`8.
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`I hold SB (‘66) / SM (‘68) / Sc.D. (‘73) degrees in Electrical
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`Engineering and Computer Science, an SB (‘67) degree in Mathematics and an
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`EE (‘70) (electrical engineer) degree, all from Massachusetts Institute of
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`Technology, in Cambridge, Massachusetts.
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`9. My recent research is directed to telecommunications and Internet
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`policy, as well as competition and pricing on ecommerce platforms. In my
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`professional and academic experience, I have considered various usability and
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`implementation problems of ecommerce platforms.
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`10. My Curriculum Vitae is attached as SAP 1003, which contains
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`further details on my education, experience, publications and other
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`qualifications to render an expert opinion. My work on this case is being billed
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`at a rate of $375 per hour, with reimbursement for actual expenses. My
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`compensation is not contingent upon the outcome of this inter partes review.
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`II. My Understanding of Claim Construction
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`11.
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`I understand that, at the Patent Office, claims are to be given their
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`broadest reasonable construction in light of the specification as would be read
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`by a person of ordinary skill in the relevant art.
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`III. My Understanding of Obviousness
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`12.
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`I understand that a patent claim is invalid if the claimed invention
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`would have been obvious to a person of ordinary skill in the field at the time the
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`application was filed. This means that even if all of the requirements of the
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`claim cannot be found in a single prior art reference that would anticipate the
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`claim, the claim can still be invalid.
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`13. As part of this inquiry, I have been asked to consider the level of
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`ordinary skill in the field that someone would have had at the time the claimed
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`invention was made. In deciding the level of ordinary skill, I considered the
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`following:
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` the levels of education and experience of persons working in the
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`field;
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` the types of problems encountered in the field; and
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` the sophistication of the technology.
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`14. To obtain a patent, a claimed invention must have, as of the
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`priority date, been nonobvious in view of the prior art in the field. I understand
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`that an invention is obvious when the differences between the subject matter
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`sought to be patented and the prior art are such that the subject matter as a
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`whole would have been obvious at the time the invention was made to a person
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`having ordinary skill in the art.
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`15.
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`I understand that to prove that prior art or a combination of prior
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`art renders a patent obvious, it is necessary to (1) identify the particular
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`references that, singly or in combination, make the patent obvious; (2)
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`specifically identify which elements of the patent claim appear in each of the
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`asserted references; and (3) explain how the prior art references could have been
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`combined in order to create the inventions claimed in the asserted claim.
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`16.
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`I understand that certain objective indicia can be important
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`evidence regarding whether a patent is obvious or nonobvious. Such indicia
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`include: commercial success of products covered by the patent claims; a long-
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`felt need for the invention; failed attempts by others to make the invention;
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`copying of the invention by others in the field; unexpected results achieved by
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`the invention as compared to the closest prior art; praise of the invention by the
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`infringer or others in the field; the taking of licenses under the patent by others;
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`expressions of surprise by experts and those skilled in the art at the making of
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`the invention; and the patentee proceeded contrary to the accepted wisdom of
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`the prior art.
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`IV. Level of Ordinary Skill in the Art
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`17. Based on the technologies disclosed in the ‘894 patent, one of
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`ordinary skill in the art would have a B.S. degree in Computer Science or
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`Engineering or equivalent field, as well as at least 3-5 years of academic or
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`industry experience in the relevant field.
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`V. The ‘894 Patent Claims
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`18.
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`I understand that the ‘894 patent is related to three other patents
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`subject to similar proceedings before the U.S. Patent Trademark Office’s Patent
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`and Trial Appeal Board (“Board”): U.S. Patent No. 8,108,492 (“the ‘492
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`patent”) is the subject of an inter partes review in proceeding IPR2013-00194;
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`U.S. Patent No. 5,987,500 (“the ‘500 patent”) is the subject of an inter partes
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`review in proceeding IPR2013-00195; and U.S. Patent No. 8,037,158 (“the ‘158
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`patent”) is the subject of covered business method reviews in proceedings
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`CBM2013-00013 and CBM2014-00018. I also understand that the ‘894 patent
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`is related to and shares substantially the same specification as the ‘492 patent,
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`the ‘500 patent and the ‘158 patent.
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`19. The following section provides constructions of specific terms used
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`in the ‘894 patent. I also comment on the Board’s interpretation of similar terms
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`in the other related proceedings.
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`A.
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`“point-of-service Web application”
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`20.
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`“Point-of-service Web application” appears, for example, in claims
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`1-3, 12 and 19. The ‘894 patent describes the term “point-of-service
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`application” as “an application that can execute the type of transaction that the
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`user may be interested in performing.” (‘894 patent, 6:45-46.) The ‘894 patent
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`also provides an explicit definition of the term “transaction” as “any type of
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`commercial or other type of interaction that a user may want to perform.” (‘894
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`patent, 5:35-37.)
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`21.
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`I understand that in IPR2013-00194, the Board construed the term
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`“point-of-service application” to mean “a software program that facilitates
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`execution of transactions requested by a user.” IPR2013-00194, Paper 14, p. 10.
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`I also understand that, in CBM2013-00013, the Board construed the term “Web
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`application” to mean “a software program . . . that can be accessed by an
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`internet user.” CBM2013-00013, Paper 15, p. 14.
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`22. For this proceeding, applying the Board’s constructions, I interpret
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`the term “point-of-service Web application” as “a software program that
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`facilitates execution of transactions requested by a user over the Web.”
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`B.
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`“overlay service network” / “service network on the Web” /
`“service network atop the Web”
`23. The term “overlay service network” is recited once in claim 1: “an
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`overlay service network running on top of an IP-based facilities network
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`selected from a group consisting of the physical TCP/IP-based Internet, the
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`Web and email networks.” I note that independent claim 1 later recites three
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`times that “the service network” is “on the Web.” Therefore, in the context of
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`independent claim 1, the selection in the claim (“selected from a group
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`consisting of the physical TCP/IP-based Internet, the Web and email networks”)
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`must be “the Web.”
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`24. Similarly, independent claim 3 recites: “service network on the
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`Web running on top of a facilities network selected from a group consisting of
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`the physical TCP/IP-based Internet, the Web and email networks.” I note that
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`the explicit language of the claim requires the service network to be “on the
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`Web.” Therefore, the selection in the claim (“selected from a group consisting
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`of the physical TCP/IP-based Internet, the Web and email networks”) must
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`again be the “the Web” to maintain logical consistency. I also note that the
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`selection clause of independent claim 3 is redundant given that the claim
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`requires the service network to be “on the Web.”
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`25. The term “service network atop the Web” appears, for example, in
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`claims 9-11. In CBM2013-00013, the Board construed the term “service
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`network running atop the World Wide Web” to mean “a network on which
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`services other than underlying network communications services are provide[d]
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`over the internet.” CBM2013-00013, Paper 15, p. 15. 1 Therefore, for the
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`purposes of this IPR, the terms “[overlay] service network on the Web” and
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`“service network atop the Web” are construed as a network on which one or
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`more services other than an underlying network communications service is
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`provided over the Web.
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`C.
`“value-added network service”
`26. The term “value-added network service” appears, for example, in
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`claims 1-3, 5, 7, 8, 15 and 17. In IPR2013-00195, the Board construed the term
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`“value-added network service provider” as “a provider of services, other than
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`underlying network communication services, on a network.” IPR2013-00195,
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`Paper 9, p. 15. For the purposes of this IPR, “value-added network service” is
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`construed as a service, other than underlying network communication services,
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`1 It appears that, in its construction of the term “service network running
`atop the World Wide Web,” the Board interprets the phrase “atop the Web” as
`equating to “provide over the internet.” I note that “to provide over the
`[I]nternet” means using the Transmission Control Protocol of the Internet
`Protocol suite (TCP/IP) as the transport mechanism for communications over
`the Internet. Web-based communications such as, for example, Web pages use
`the Hypertext Transport Protocol (HTTP) as its transport mechanism. TCP/IP
`and HTTP reside at two different layers of the IP suite—TCP/IP is at the
`transport layer and HTTP is at the application layer. For this proceeding, I
`assume that the term “atop the Web” means to use HTTP as the transport
`mechanism for Web-based communications.
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`on a network.
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`D.
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` “one or more objects in the Web application” / “object in the
`Web application”
`27. The term “one of more objects in the Web application” appears, for
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`example, in independent claims 1 and 3. Claim 1 defines “one or more objects
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`in the Web application” as “one or more individual data structures in and
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`specific to the POSvc Web application is said request.” Claim 3 includes a
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`similar definition.
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`28.
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`Independent claim 2, however, does not provide an explicit
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`definition of the term “object in the Web application.” In the ‘894 patent, an
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`object is described as having a “name, a syntax and an encoding.” (‘894 patent,
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`8:31-32.) Under the broadest reasonable interpretation, the term “object” in
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`independent claim 2 is construed as a data structure with one or more of a name,
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`a syntax and an encoding.
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`E.
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`29.
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`“real-time”
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`“Real-time” appears, for example, in claims 1-10, 12, 13, 16, 18
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`and 19. The ‘894 patent describes this term in the context of what is considered
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`“real-time.” I understand that, in IPR2013-00194, the Board construed this term
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`to mean “non-deferred.” IPR2013-00194, Paper 14, p. 12. For this proceeding,
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`this interpretation of the term “real-time” is adopted.
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`F.
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` “Exchange”
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`30.
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`“Exchange” appears, for example, in claim 10. This term is
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`described in the specification as a component that creates and allows for
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`management (or distributed control) of a service network, operating within a
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`facilities network. See the ‘894 patent, 6:33-36. The broadest reasonable
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`interpretation for the term “Exchange” is a component that creates and allows
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`for management (or distributed control) of a service network operating within a
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`facilities network.
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`G.
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`31.
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` “back-end application”
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`“Back-end application” appears, for example, in claim 12. In
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`IPR2013-00194, the Board construed “back-end” to mean “a computer system
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`or database accessed by a user via an application.” IPR 2013-00194, Paper 14,
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`p. 12. For purposes of this IPR, this construction of “back-end” is adopted.
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`H.
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`“the service network running on top of the facilities network”
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`32. The term “the service network running on top of the facilities
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`network” appears, for example, in claim 12. The term “the facilities network” in
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`claim 12 lacks antecedent basis. Claim 12 depends from claim 2 which recites
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`that “the service network” is “on the Web.” Therefore, in the context of the
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`claims the phrase “running on top of the facilities network” is construed to mean
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`“running on the Web.” The term “the service network running on top of the
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`facilities network” is therefore “the service network on the Web.”
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`I.
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`“Internet cloud application”
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`33.
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`“Internet cloud application” appears, for example, in claim 16.
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`This term does not appear in the ‘894 patent outside the claims. In the field of
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`computer science, the term “cloud computing” is a colloquial expression that
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`typically refers to a sharing of computing resources for distributed computing
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`over a network. For this proceeding, under the broadest reasonable
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`interpretation consistent with the ’894 patent, I interpret the term “Internet
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`cloud application” as an application executed by shared computing resources
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`for distributed computing over the Internet.
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`VI. Priority Claim
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`34.
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`I understand that a U.S. application is entitled to benefit of the
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`filing date of an earlier filed U.S. application if the subject matter of the claim is
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`disclosed in the manner provided by 35 U.S.C. § 112, first paragraph, in the
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`earlier filed application. I understand the 35 U.S.C. § 112, first paragraph
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`includes three separate requirements - written description, enablement, and best
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`mode.
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`35.
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`I understand that the relevant inquiry for existence of sufficient
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`written description is whether a patent sets forth enough detail to allow a person
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`skilled in the relevant art to understand what is being claimed and to reasonably
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`conclude that the inventor had possession of the claimed invention.
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`36.
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`I understand that the ‘894 patent claims benefit as a divisional of
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`an earlier filed patent, U.S. Patent No. 8,037,158 (“the ‘158 patent”). I
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`understand that as a divisional the ‘158 patent shares the same specification as
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`the ‘894 application. In my opinion, based on the disclosure of the ’158 patent,
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`a person of ordinary skill in the art would not conclude that the inventor had
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`possession of the subject matter of claims 1-19 of the ’894 patent.
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`37. Specifically, independent claims 1 and 2 and their corresponding
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`dependent claims 4-19 each recite the negative limitation – “wherein the object
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`in the POSvc Web application is not an SNMP object.” The specification of
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`the ‘158 patent only refers to SNMP once: “VAN switch 520 provides multi-
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`protocol object routing, depending upon the specific VAN services chosen. This
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`multi-protocol object routing is provided via a proprietary protocol,
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`TransWebTM Management Protocol (TMP). TMP incorporates the same security
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`features as the traditional Simple Network Management Protocol, SNMP.”
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`(‘158 patent, 7:53-58.) I note that this passage does not even refer to SNMP
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`objects let alone provide any reason that a point-of-service Web application
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`could not be an SNMP object. To the contrary, this passage implies that the
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`passage implies that the TMP used by the ‘158 patent actually incorporates
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`SNMP concepts. In fact, reading through the ’158 patent, it appears that the
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`discussion regarding TMP being incorporated with DOLSIBs is merely a
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`description of SNMP’s Management Information Base. (See ’158 patent 7:60-
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`8:5 and 8:18-20.)
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`38. Each of the independent claims further recites the negative
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`limitation “utilizing an object in the Web application … to connect in real-time
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`to the value added-network service of the Web merchant without executing
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`Common Gateway Interface (CGI) scripts.” That is, the connection to the
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`value added-network service of the Web merchant is made “without executing”
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`CGI scripts. In my opinion, based on the specification of the ’158 patent, a
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`person of ordinary skill in the art would not conclude that the inventor had
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`possession of this subject matter.
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`39. As an initial matter, the ‘158 patent (and correspondingly the ‘894
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`patent) alleges a number of deficiencies of CGI related to transactions.
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`However, the deficiencies noted are unfounded. One criticism levied against
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`CGI in the ‘158 patent is that an external program must be customized for each
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`application. This is an incoherent objection: a checking application is different
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`from a loan application so some part of the software must be different so that
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`the correct steps are performed either to process a check or to secure a loan.
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`The use of CGI to invoke the application software is irrelevant to the fact that
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`the software for the two applications must differ. If a bank has many services
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`there is no escaping the need to write software that executes the different steps
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`required for each service. Thus, the objection that the use of CGI may require
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`many scripts is not a valid objection. Nor is there anything in the ‘158 patent
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`disclosure which suggests how a bank could avoid having different software for
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`a loan transaction than it has for a checking transaction.
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`40. Furthermore, the specification alleges that “CGI applications
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`provide user 100 with a limited ability for two-way interaction with car dealer
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`Web page 105, but due to the lack of interaction and management between the
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`car dealer and the bank, he will not be able to obtain a loan and complete the
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`purchase of the car via a CGI application.” (‘158 patent, 2:27-48.) This is
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`simply not true. A car dealer can offer cars for sale via its web server. When
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`the user desires to purchase the car, the purchase signal from the user’s browser
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`causes the car dealer’s http server software to launch, via CGI, an external
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`program, which then communicates with the bank’s computer using any number
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`of possible mechanisms, from http to CORBA, to coordinate the transaction.
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`Indeed, nothing prevents the external application from communicating with
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`multiple servers before it completes the transaction. When the transaction is
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`complete, the result is returned to the user from the external application via the
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`CGI interface, to the http server software and then to the user. The fact that the
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`car dealer’s application was launched via CGI is irrelevant to how the car dealer
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`application will communicate with the bank, or whether the two have agreed on
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`standards for such communication.
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`41.
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`In short, it is simply not true that robust two-way transactions
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`involving multiple parties cannot be implemented using web software that
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`communicates with external programs running on the Web server machine
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`using CGI, and techniques for doing so would have been obvious to one
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`familiar with the state of the art.
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`42. Additionally, regardless of the discussion of the exclusion of CGI
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`scripts for processing transactions, the claim explicitly recites that it is the
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`connection to the value added-network service of the Web merchant that is
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`made “without executing” CGI scripts. The failure to explicitly disclose an http
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`server, and its relation to other features of the proposed technology, such as the
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`Exchange, renders much of the disclosure incomplete. For example, Fig 5C
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`suggests that the Exchange software runs on the Web server machine 104.
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`However, there is no disclosure of how the http server software, which must be
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`present to receive http requests from browsers, relates to the Exchange software.
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`If the Web server is a machine, the specification does not disclose what
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`software on the machine receives the request. Furthermore, if it is understood
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`that the Web server, in this context, is the software that listens for http requests,
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`it is also not disclosed how the request is “handed over” from the http server
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`software to the Exchange component. The specification also acknowledges
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`that the Web servers and web server software can be separate. However the
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`specification does not disclose any method by which the http server software
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`interfaces with separately and conventionally loadable modules. If the
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`Exchange is running on a separate machine, the specification does not disclose
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`how the http server software running on the Web Server communicates with
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`Exchange software running on a separate machine. All of this is relevant to the
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`discussion of CGI, because CGI is a standardized method for an http server
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`software program to communicate with an external program running on the
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`same machine. For these reasons, in my opinion, a person of ordinary skill in
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`the art would not recognize that the inventor had possession of the recited
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`“utilizing an object in the Web application … to connect in real-time to the
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`value added-network service of the Web merchant without executing Common
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`Gateway Interface (CGI) scripts.”
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`VII. Summary of the Claimed Subject Matter in the ‘894 Patent
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`43. To help understand the subject matter disclosed in claim 1 of the
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`‘894 patent, I partitioned FIG. 5D into a three-tier network communication
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`model. This partitioned illustration of FIG. 5D with annotations is provided
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`below as FIG. 1 of my declaration (also referred to herein as “Sirbu Dec. FIG.
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`1”).
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`FIG. 1
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`44.
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`In referring to Sirbu Dec. FIG. 1 above, the “Client” represents a
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`user 100 who communicates with a merchant at the “Server” via software such
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`as a Web browser. The “Server” is illustrated as incorporating both a Web
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`Server 104 and a Computer System 200 because, as explained in the ‘894
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`patent, “exchange 501 in FIG. 5D is shown as running on a different computer
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`system (Web server 104) from the computer systems of the Web merchants
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`running POSvc applications (computer system 200) . . . [e]xchange 501 may,
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`however, also be on the same computer system as one or more of the computer
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`systems of the Web merchants.” the ‘894 patent, 6:62-67. Lastly, the “Back
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`End” represents a Bank “Back Office,” in which “user 100 will be able to
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`connect to Bank services and utilize the application to perform banking
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`transactions, thus accessing data from a host of data repository 575 in the Bank
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`‘Back Office.’” Id., 7:1-5.
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`45.
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`I note that the claims incorporate explicit definitions of certain
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`terms. To aid in understanding, I describe the limitations of independent claim
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`1. Each of independent claims 2 and 3 contain similar limitations. The
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`following table summarizes the definitions from claim 1:
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`Term
`“Web application”
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`“digital network on the
`Web”
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`“facilities network”
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`“on-line service over a
`digital network on the
`Web”
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`Definition in Claim 1
`“wherein the Web application is a point-of-service
`(POSvc) Web application”
`“wherein the digital network is an overlay service
`network running on top of an IP-based facilities
`network selected from a group consisting of the
`physical TCP/IP-based Internet, the Web and
`email networks”
`“wherein the facilities network is a physical
`network”
`“real-time Web transaction specific to a Web
`merchant’s value-added network service on the
`Web offered as the online service over the digital
`network on the Web”
`“wherein the online service is a loan Web
`application”
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`A.
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`Preamble
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`46. The preamble of claim 1 recites “[a] computer-implemented
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`method for completing a real-time Web transaction from a Web application in
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`an on-line service over a digital network on the Web . . .” In the claim, the
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`recited “Web application” is defined as the “point-of-service (POSvc) Web
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`application” and the “on-line service” as a “loan Web application.”
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`47. As illustrated in Sirbu Dec. FIG. 1 above, the banking application
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`on Web Server 104 is the “Web application” and provides “a real-time Web
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`transaction.” For example, “if Bank decided to include in their POSvc
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`application access to checking and savings accounts, user 100 will be able to
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`perform real-time transactions against his checking and savings accounts.” the
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`‘894 patent, 7:14-18.
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`48. The claims repeatedly refer to “an on-line service over a digital
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`network on the Web.” The banking application on Web Server 104 is an
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`example of “an on-line service over a digital network on the Web.” On-line
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`services can refer to services provided by a communication network (e.g., the
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`Internet) and applications used to access the services over the communication
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`network (e.g., the World Wide Web or “the Web”). See, e.g., the ‘894 patent,
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`1:36-39. The Web provides users access to on-line services through its system
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`of hyperlinked documents accessible over the Internet (e.g., via a TCP/IP
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`connection). The Internet is an example of a digital network in which the on-
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`line services provided by the Web can run on top of. For example, the
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`underlying digital network of the Client/Server/Back End architecture in Sirbu
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`Dec. FIG. 1 is the Internet, in which users can access on-line services provided
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`by the banking Web application.
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`B. Displaying Limitation
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`49. The displaying limitation of claim 1 includes two separate portions.
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`The first portion has two limitations: (1) “displaying at least one Web
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`application specific to an on-line service over a digital network on the Web”;
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`and (2) “wherein the Web application is a point-of-service (POSvc) Web
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`application.” Thus, this portion indicates that at least one point-of-service
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`(POSvc) Web application is displayed specific to an on-line service over a
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`digital network on the Web.
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`50. This is illustrated by the banking Web application (e.g., checking
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`and/or savings application) being displayed to user 100 via a Web page. See,
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`e.g., the ‘894 patent, 6:8-19. As discussed in the preamble above, on-line
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`services can refer to services provided by a communication network (e.g., the
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`Internet) and applications used to access the services over the communication
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`network (e.g., the Web). In referring to Sirbu Dec. FIG. 1 above, the banking
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`Web application is “specific to an on-line service over a digital network on the
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`Web” since it is a banking application that can be accessed via the Web. Also,
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`as described above, the Web can be accessed over a communication network
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`such as the Internet. The banking Web application is an example of a POSvc
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`Web application since it is “an application that can execute the type of
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`transaction that the user may be interested in performing.” Id., 6:44-46.
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`51. The second portion of the displaying limitation of claim 1 recites
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`“wherein the digital network is an overlay service network running on top of an
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`IP-based facilities network selected from a group consisting of the physical
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`TCP/IP-based Internet, the Web and email networks, wherein the facilities
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`network is a physical network.” In my view, the “IP-based facilities network” is
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`“the Web.” For example, the preamble recites “digital network on the Web”
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`and the executing limitation recites “over the service network on the Web.”
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`Emphasis added. Therefore, I assume for the purposes of this proceeding that
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`the recited “IP-based facilities network” is “the Web.”
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`52. The Web and email are applications that utilize lower layer
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`communications protocols such as TCP/IP. It is inherent in all electronic
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`communications that the communications signals are carried by a physical
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`medium. Indeed, the ‘894 patent specification does not describe or even use the
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`term “physical network.”
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`C. Accepting Limitation
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`53. The accepting limitation recites “accepting a first signal
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`comprising a request from the point-of-service (POSvc) Web application for a
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`real-time Web transaction specif
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