`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`GOOGLE INC. AND MOTOROLA MOBILITY LLC
`Petitioners
`v.
`
`ARENDI S.A.R.L.
`alleged Patent Owner
`
`Patent No. 6,323,853
`Issue Date: Nov. 27, 2001
`
`Title: METHOD, SYSTEM AND COMPUTER READABLE MEDIUM FOR
`ADDRESSING HANDLING FROM A COMPUTER PROGRAM
`
`_______________
`
`Inter Partes Review No. Unassigned
`____________________________________________________________
`
`DECLARATION OF DENNIS R. ALLISON
`
`1
`
`Google Inc. 1002
`
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`I.
`
`INTRODUCTION AND QUALIFICATIONS ........................................... 1
`
`II.
`
`SUMMARY OF OPINION ........................................................................... 3
`
`III. UNDERSTANDING OF THE LAW ........................................................... 4
`
`IV. RELEVANT TIMEFRAME FOR OBVIOUSNESS.................................. 6
`
`V.
`
`LEVEL OF ORDINARY SKILL IN THE ART ........................................ 7
`
`VI. OVERVIEW OF THE '853 PATENT SPECIFICATION ......................20
`
`VII. SIMILARITY OF CLAIM SETS ..............................................................29
`
`A. Claims 17-22 ....................................................................................... 31
`
`B.
`
`Claims 23-29 ....................................................................................... 33
`
`C. Claims 30-37 ....................................................................................... 34
`
`D.
`
`claims 38-46 ........................................................................................ 35
`
`E.
`
`claims 47-56 ........................................................................................ 35
`
`F.
`
`claims 57-67 ........................................................................................ 36
`
`G.
`
`claims 68-79 ........................................................................................ 37
`
`VIII. CONSTRUCTION OF CLAIM TERMS ..................................................37
`
`A.
`
`"INPUT DEVICE" ........................................................................... 38
`
`B.
`
`PERFORMING THE STEPS RECITED IN ONE OF CLAIMS 1-
`14
` ................................................................................................... 39
`
`C.
`
`"IDENTIFICATION OF A LIST OF ADDRESSEES" ................ 39
`
`IX. FIRST GROUND FOR INVALIDITY: GOODHAND ..........................41
`
`
`
`i
`
`
`
`
`
`A. DISCLOSURE OF GOODHAND PATENT .................................. 41
`
`B.
`
`INVALIDITY IN LIGHT OF GOODHAND ................................. 55
`
`1. Claim 1: Information handling in a document including first
`information ......................................................................................... 56
`
`2. Claim 1: Record retrieval program ................................................. 56
`
`3. Claim 1: Input device to initiate retrieval from an information
`source .................................................................................................. 58
`
`4. Claim 1: Upon a single entry of the execute command ................. 59
`
`5. Claim 1: Analyzing the document for first information ................ 60
`
`6. Claim 1: Using the first information to search the information
`source for associated second information ....................................... 61
`
`7. Claim 1: Displaying the second information .................................. 62
`
`8. Claim 1: Inserting the second information ..................................... 63
`
`9. Claim 1: Completing the first information based on the second
`information ......................................................................................... 63
`
`10. Claim 2: Changing the second information based on similarities
`and differences ................................................................................... 64
`
`11. Claim 2: Completing the first information with the second
`information ......................................................................................... 65
`
`12. Claim 2: Storing the first information in the information source if
`second information is absent ............................................................ 65
`
`13. Claim 2: Adding document information associated with second
`information ......................................................................................... 66
`
`14. Claim 3: Second information including certain types of contact
`information ......................................................................................... 67
`
`
`
`ii
`
`
`
`
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`15. Claim 3: Completing or correcting certain types of contact
`information based on the second information ................................ 69
`
`16. Claim 4: Second information including certain types of contact
`information ......................................................................................... 70
`
`17. Claim 4: Automatically completing or correcting certain types of
`contact information based on the second information .................. 71
`
`18. Claim 5: Second information including certain types of contact
`information ......................................................................................... 72
`
`19. Claim 5: User-assisted completing or correcting of certain types of
`contact information ........................................................................... 72
`
`20. Claim 6: Addressing the document to a list of addressees based on
`the second information ...................................................................... 73
`
`21. Claim 7: Allowing changes to the second information directly in
`the information source. ..................................................................... 75
`
`22. Claim 8: Using the application program to enter certain types of
`first information ................................................................................ 76
`
`23. Claim 8: Searching the information source for certain types of
`second information ............................................................................ 77
`
`24. Claim 9: Certain types of input device, configured to retrieve
`from the information source ............................................................. 78
`
`25. Claim 9: Displaying a message screen or providing a voiced
`response .............................................................................................. 80
`
`26. Claim 11: Information source is one of the recited types .............. 81
`
`27. Claim 13: Indicating which information in the document is the
`first information ................................................................................ 82
`
`28. Claim 14: Automatically interpreting which information in the
`document is the first information .................................................... 83
`
`
`
`iii
`
`
`
`
`
`29. Claims 15 & 16. A computer system configured, or storage media
`storing a program, to perform the steps recited in one of claims 1-
`14. ........................................................................................................ 85
`
`30. The Remaining Dependent Claims .................................................. 85
`
`SECOND GROUND FOR INVALIDITY: PADWICK IN LIGHT OF
`X.
`GOODHAND ..........................................................................................................86
`
`A. DISCLOSURE OF THE PADWICK MANUAL ........................... 86
`
`B. OBVIOUSNESS OF CLAIMS 6, 10, 12, 21, 27, 30-37, 42, 46-56,
`65, 67, 76 AND 78 OVER PADWICK IN VIEW OF GOODHAND
`
`
` ................................................................................................... 92
`
`XI. THIRD GROUND FOR INVALIDITY: ALLEN .................................100
`
`A. DISCLOSURE OF ALLEN PATENT .......................................... 100
`
`B.
`
`INVALIDITY IN LIGHT OF ALLEN ......................................... 113
`
`1. Claim 1: Information handling in a document including first
`information ....................................................................................... 114
`
`2. Claim 1: Record retrieval program ............................................... 114
`
`3. Claim 1: Input device to initiate retrieval from an information
`source ................................................................................................ 116
`
`4. Claim 1: Upon a single entry of the execute command ............... 117
`
`5. Claim 1: Analyzing the document for first information .............. 117
`
`6. Claim 1: Using the first information to search the information
`source for associated second information ..................................... 118
`
`7. Claim 1: Displaying the second information ................................ 118
`
`8. Claim 2: Storing the first information in the information source if
`second information is absent .......................................................... 119
`
`
`
`iv
`
`
`
`
`
`
`
`
`
`9. Claim 7: Allowing changes to the second information directly in
`the information source. ................................................................... 121
`
`10. Claim 8. ............................................................................................. 121
`
`11. Claim 9. ............................................................................................. 122
`
`12. Claim 10: Using a word processing program or a spreadsheet
`program ............................................................................................ 124
`
`13. Claim 11: Information source is of certain type ........................... 124
`
`14. Claim 13: Indicating which information in the document is the
`first information .............................................................................. 125
`
`15. Claim 14: Automatically interpreting which information in the
`document is the first information .................................................. 126
`
`16. Claims 15 & 16. A computer system configured, or media storing
`a program, to perform the steps recited in one of claims 1-14. .. 126
`
`
`
`v
`
`
`
`
`
`
`
`
`I.
`
`INTRODUCTION AND QUALIFICATIONS
`
`1.
`
`I, Dennis R. Allison, make this declaration in connection with the
`
`petition for inter partes review of U.S. Patent No. 6,323,853 ("the '853 patent";
`
`Exhibit 1001 to the petition). All statements made herein are true to the best of my
`
`knowledge. I am over the age of 18 and otherwise competent to make this
`
`declaration. Although I am being compensated for my time in preparing this
`
`declaration, the opinions herein are my own, and I have no stake in the outcome of
`
`the inter partes review or any related litigation.
`
`2.
`
`Attached as Exhibit 1008 is my curriculum vitae. As shown in my
`
`CV, I have an A.B. from the University of California, Berkeley in Physics (1961).
`
`Since 1975, I have been a Lecturer at Stanford University in the Computer Systems
`
`Laboratory, Electrical Engineering Department. At Stanford, I have taught
`
`graduate and upper division courses in Computer Architecture, Advanced
`
`Computer Architecture, Software Engineering, Software Projects, Computer
`
`Programming.
`
`3.
`
`From 1962-1972, I worked as a Physicist at the Radio Physics
`
`Laboratory of SRI International (aka Stanford Research Institute).
`
`4.
`
` Since 1972, I have been a consultant in the computer industry. I
`
`have worked with a diverse client base with an equally diverse project base
`
`
`
`1
`
`
`
`
`
`including programming language design and implementation, operating systems
`
`design, distributed system architectures, microprocessor architecture, memory
`
`management systems architecture, DSP architecture, architectural evaluation,
`
`benchmark studies and comparative evaluation, network hosted micro-payment
`
`systems design, electronic money systems design, financial cryptography,
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`multimedia education curriculum development, web site design, media encryption
`
`risk evaluation, special purpose client server system design reviews, technical
`
`writing and review, patent preparation and prior art search, and litigation support.
`
`5.
`
`Some of my current projects involve support systems for drug
`
`development, social networking, emerging cellular telephone systems, computer
`
`gaming, reliable computing, Web 2.0 and Web 3.0 support tools, programming
`
`language compilation for distributed sensor networks, website framework
`
`development, and hardware acceleration in monolithic application-oriented
`
`supercomputer systems. My current research includes restructuring classical
`
`economic theory for use in modeling, modeling emergent systems, decision
`
`support, programming parallel systems, exploring the conceptual framework of
`
`programming languages, exploring mobile enterprise architectures for investment
`
`banking and venture finance, defining the architecture for large scale, energy
`
`efficient server clusters, architecture and software support for embedded low-
`
`power embedded computers, architecture of accelerators for high performance
`
`
`
`2
`
`
`
`
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`computing clusters using FPGAs and GPGPUs, concurrent programming
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`languages and parallel systems, artificial intelligence, neuroscience based
`
`interfaces, very high speed computing, the semantic web, and design tools for
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`FPGAs.
`
`6.
`
`I believe that I can competently testify from the perspective of the
`
`person of ordinary skill in the art in the relevant timeframe (defined in ¶18, below).
`
`II.
`
`SUMMARY OF OPINION
`
`7.
`
`Based on my analysis discussed herein, I am of the opinion that
`
`claims 1-79 of the '853 patent are invalid for anticipation and/or obviousness, as
`
`detailed below.
`
`8.
`
`Specifically, I am of the opinion that claims 1-9, 11, 13-29, 38-45, 57-
`
`64, 66, 68-75, 77 and 79 are invalid as obvious in view of U.S. Patent No.
`
`5,923,848, issued to Goodhand et al. ("Goodhand")(Ex. 1003).
`
`9.
`
`I am of the opinion that claims 6, 10, 12, 21, 27, 30-37, 42, 46-56, 61,
`
`65, 67, 72, 76 and 78 are invalid as obvious over the combination of the Goodhand
`
`patent and Padwick, et al., "Using Microsoft Outlook 97" (Microsoft Press 1996)
`
`("Padwick")(Ex. 1004).
`
`10.
`
`I am of the opinion that claims 1-2, 7-11, 13-17, 22-23, 28-30, 35-38,
`
`43-46, 57, 62-66, 68, 73-77 and 79 are invalid as anticipated by U.S. Patent No.
`
`6,026,401, issued to Allen et al. ("Allen")(Ex. 1005).
`
`
`
`3
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`
`
`
`
`III. UNDERSTANDING OF THE LAW
`
`11.
`
`I have been informed about certain aspects of patent law that are
`
`relevant to my analysis and opinions.
`
`12.
`
`I understand that a claim term in an inter partes review is to be
`
`interpreted according to the broadest reasonable construction in light of the
`
`specification of the patent in which it appears. I understand that a claim term can
`
`be expressly defined by the specification, but absent such an express definition, the
`
`claim should be construed as broadly as a person of ordinary skill would
`
`reasonably have done in light of the specification.
`
`13.
`
`I understand that a claim is invalid because of anticipation when every
`
`element of the claim is described in a single prior art reference, such that the
`
`elements are arranged as required by the claim. I further understand that the
`
`description of a claim element in a prior art reference can be express or inherent.
`
`For a prior art reference to describe a claim element inherently, the claim element
`
`must necessarily be present. Probabilities are not sufficient to establish inherency.
`
`14.
`
`I understand that a claim can be invalid for obviousness even if it is
`
`not anticipated. I understand that a claim is obvious if the differences between the
`
`claim and the prior art are such that the subject matter as a whole would have been
`
`obvious. I understand that the evaluation of obviousness must be carried out from
`
`the perspective of a person having ordinary skill in the art to which the claims
`
`
`
`4
`
`
`
`
`
`pertain. I will describe the level of ordinary skill in the relevant art in ¶¶19-44,
`
`below. I further understand that the obviousness evaluation is made at the "time
`
`the invention was made." I will describe this timeframe in §IV, below.
`
`15.
`
`I understand that when evaluating obviousness, I must consider the
`
`scope and content of the prior art, the differences between the prior art and the
`
`claimed invention, the level of ordinary skill in the art, and any secondary
`
`considerations.
`
`16.
`
`I further understand that secondary considerations include evidence of
`
`real-world events that can shed light on the obviousness or non-obviousness of a
`
`claim. For example, evidence of commercial success of a product embodying a
`
`claim can provide evidence tending to show that the claim is not obvious. This
`
`evidence will be stronger or weaker depending on the causal connection (nexus)
`
`between one or more claim elements not found in a single prior art reference and
`
`the commercial success, and the presence of one or more other factors (such as
`
`market power, advertising or other desirable features of the product) that could
`
`explain the commercial success. The product having commercial success must be
`
`reasonably commensurate with the scope of the claim, but need not incorporate all
`
`embodiments of the claims. Other examples of secondary considerations that
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`could lead to evidence of non-obviousness include attempts at copying a
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`commercial product of the patent owner, attempts to make a product embodying a
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`
`
`5
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`
`
`
`
`claim without success, a long-felt need in the industry without a solution before the
`
`claimed invention, and praise of the claimed invention.
`
`17.
`
`I further understand that a claim is likely to be obvious where it
`
`represents the combination of familiar elements according to known methods and it
`
`does no more than yield predictable results. I further understand that when a work
`
`is available in one field of endeavor, design incentives and other market forces can
`
`prompt variations of it, either in the same field or a different one. If a person of
`
`ordinary skill can implement a predictable claim, the claim is likely obvious.
`
`Likewise I understand that if a technique has been used to improve one device, and
`
`a person of ordinary skill in the art would recognize that it would improve similar
`
`devices in the same way, using the technique is obvious unless its actual
`
`application is beyond ordinary skill.
`
`IV. RELEVANT TIMEFRAME FOR OBVIOUSNESS
`
`18. Obviousness must be considered from the perspective of a person of
`
`ordinary skill in the art at the time the invention was made. I understand that the
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`earliest possible filing date (anywhere in the world) for the application leading to
`
`the '853 patent is September 3, 1998, from the face of the '853 patent in field (22).
`
`I have not analyzed whether the '853 patent is entitled to that filing date, but have
`
`analyzed obviousness as of that date or somewhat before. I may refer to this
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`
`
`6
`
`
`
`
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`timeframe as "the relevant timeframe." My testimony relates to the relevant
`
`timeframe, even if it may occasionally be phrased in tenses other than a past tense.
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`V. LEVEL OF ORDINARY SKILL IN THE ART
`
`19.
`
`It is my opinion that a person of ordinary skill in the art pertaining to
`
`the '853 patent in the relevant timeframe would have at least a Bachelor's degree in
`
`Computer Science or Electrical Engineering or related discipline and about two
`
`years' experience designing applications that use databases.
`
`20. The next few paragraphs provide some examples of the kinds of skills
`
`a person of ordinary skill in the art would have possessed, without intending to
`
`state every such skill. My opinions regarding these skills have been formed from
`
`my own experience in the industry during the relevant timeframe, the teachings in
`
`the prior art, and the '853 patent's assumption throughout the specification that one
`
`of ordinary skill would have been able to design and build the software
`
`functionality described in the '853 patent.
`
`21. The person of ordinary skill would have obtained, through education
`
`or experience, facility with common programming languages, algorithms, data
`
`structures, and programming logic (decision trees, control flow, etc.) sufficient to
`
`enable him or her to develop tools to interact with these end-user applications, or
`
`improve existing tools designed for this purpose.
`
`
`
`7
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`
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`
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`22. The person of ordinary skill would have understood how to design
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`and code the common elements of a graphical user interface to modify a user's
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`interaction with a system. This would include the ability to add graphical control
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`elements such as buttons, menus, checkboxes, radio buttons, text fields and boxes,
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`graphical panes, etc., into the components of the graphical user interfaces that
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`applications use (windows, frames, panels, etc.). The person of ordinary skill
`
`would have known how to link executable code to specific GUI actions, and how
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`to design such code so that it ran in a stable and error-free fashion.
`
`23. Furthermore, the person of ordinary skill in the art would have
`
`understood how to take advantage of inter-application and inter-process
`
`communication. Such communication allows different system applications to
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`communicate with one another. For example, a person of ordinary skill would
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`have known how to access a system database from an application by using or
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`designing the necessary Application Programming Interfaces ("APIs") to do so. A
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`person of ordinary skill would have been able to cause an application program to
`
`access a database in order to send the database a particular read-query and then to
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`receive and use the information returned, or to query the database to add records or
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`update existing records.
`
`24. A person of ordinary skill would also have had familiarity with the
`
`most common electronic communication methods, including email messaging,
`
`
`
`8
`
`
`
`
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`telephone calling (e.g. through the Telephony API), HTTP messages (POST or
`
`GET, for example), FTP, and FAXing. A person of ordinary skill would have
`
`known how to interface general application programs with application programs
`
`that provide the functionality for these kinds of communications.
`
`25. A person of ordinary skill would further have been familiar with text
`
`recognition systems. Such systems evaluate text in a document, looking for useful
`
`structures. Once a useful structure was found, the system would allow a user to do
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`something with it by executing code. The mechanism for allowing the user to
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`execute an associated function was often accomplished by means of a context-
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`dependent graphical user interface element, such as a context menu or a pop-up
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`window. The user's selection from the user interface element would lead to a
`
`specific code module being executed to do something useful with the information.
`
`26. For example, U.S. Patent No. 5,859,636 to Pandit (Ex. 1011), filed at
`
`the end of 1995, describes a text recognition system that identifies useful
`
`information and presents the user with options to take certain actions. Ex. 1011,
`
`Fig. 2, Abstract. The Abstract of Pandit states:
`
`"Text of a predetermined class is recognized in a body of text. After
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`recognition, operations relevant to the recognized text may be
`
`performed. For example, text such as telephone numbers, telefax
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`numbers, and dates can be recognized in a body of text. Options are
`
`
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`9
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`
`
`
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`provided for selecting and running operations and programs relevant
`
`to the recognized text." Ex. 1011 at Abstract.
`
`27. Pandit shows in Fig. 1f, for example, how a telephone number can be
`
`recognized, and the user presented with options to make a call, send a FAX, or add
`
`the number to a contact database. Figure 1f is shown below:
`
`
`28. Similarly, by way of background, U.S. Pat. No. 5,644,735 to Luciw
`
`(Ex. 1006), first-filed as early as 1993, shows how structures, such as text
`
`representing a first name, can be entered into a document can be recognized, and
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`suggestions for the full name presented in a context menu using a template-based
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`system. Figures 6a and 6b of Luciw, showing this functionality, are reproduced
`
`below:
`
`
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`10
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`
`
`
`
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`29. As another example, the article entitled "Drop Zones, an extension to
`
`LiveDoc", by Thomas Bonura and James R. Miller ("Bonura")(Ex. 1007) describes
`
`how text structures (such as name, phone numbers and email addresses)(Ex. 1007
`
`at Fig. 1, caption of Fig. 1, and Fig. 3) can be recognized in a document and
`
`associated with actions that can be performed on that text:
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`"Various kinds of recognizers, including context-free grammars, are
`
`used to describe the structures to be found; these structures can be
`
`made up of either a single lexical term (either a variable structure like
`
`a phone number, or a collection of static strings, like company names)
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`or multiple terms (for instance, a meeting can be defined as a
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`combination of date, time, and venue structures). Small pieces of code
`
`
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`11
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`
`
`
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`can then be associated with each structure to instruct applications to
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`carry out specific user actions on the discovered structures—perhaps
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`to tell a telephony application to 'Dial this phone number.' These
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`actions can then be offered to users by visually highlighting the
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`discovered structures and attaching pop-up menus to the highlights."
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`Ex. 1007 at p. 59, left column, Introduction.
`
`30. Like Luciw, Bonura was intended to be integrated into common
`
`applications like word processors:
`
`"An interaction with the Drop Zone interface is shown in Figures 1
`
`and 2. The window named 'test' in Figure 1 belongs to a LiveDoc-
`
`enabled word processor, LiveSimpleText (see [6]), and shows a
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`number of structures within the document in view having been
`
`recognized by the analyzers. The window labeled Activities is a Drop
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`Zone interface to a set of interpreters or 'assistants'. Each of these
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`assistants, E-mail, Telephony, Finance and Appointment, implements
`
`a knowledge base that can operate on appropriate sets of LiveDoc
`
`structures. These assistants make their capabilities visible when the
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`user selects various structures identified by LiveDoc and drags them
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`to the assistants." Ex. 1007 at p.60.
`
`31. A person of ordinary skill would further have been familiar with
`
`contact databases or address books for storing information about people, including
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`information about how to reach people. Such contact databases ("address books")
`
`were in widespread use in the relevant timeframe. In that timeframe, it was typical
`
`to store names, postal addresses, email addresses, telephone numbers, FAX
`
`
`
`12
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`
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`
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`numbers, and notes about a person in such databases. It was also typical to provide
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`contact databases or address books that could be accessed by other applications.
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`Of course, people had also long been using paper-based address books and manual
`
`processes to do exactly the same sorts of things described in the '853 patent. In this
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`sense, the '853 patent represents no more than the automation of long-known
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`processes.
`
`32. For example, the Pandit, Luciw and Bonura references discussed
`
`above all show interaction with a contact database. The article entitled
`
`"ACADEMIA: An Agent-Maintained Database based on Information Extraction
`
`from Web Documents" by Magnanelli, et al. ("Magnanelli", Ex. 1012), likewise
`
`showed how an application program can interact with a contact database in Fig. 1.
`
`In Fig. 1, reproduced below, the contact database is called the "Academia
`
`Database" and holds information about people, including contact information.
`
`
`
`13
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`
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`33. U.S. Pat. No. 5,923,848 to Goodhand (Ex. 1003), discussed in greater
`
`detail below, also discloses the use of a contact database. In Goodhand, this is
`
`called an "address book provider." Ex. 1003 at Fig. 3 and 13:40-45. As Goodhand
`
`states:
`
`"all address book providers 335 store a recipient's name, address, and
`
`address type and organize the data using one or more containers….
`
`MAPI's Personal Address Book is an example of a modifiable address
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`book container that allows new entries to be added and exiting (sic)
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`entries to be modified or deleted." Ex. 1003 at 13:43-53.
`
`34. Goodhand also listed as part of the preferred embodiment the contact
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`manager found in Microsoft Outlook®. Ex. 1003 at 15:38-42. One of ordinary
`
`skill in the art would have understood the Outlook® contact manager referred to by
`
`Goodhand to be a database of contacts that could include names, email addresses,
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`
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`14
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`
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`physical addresses, phone numbers, fax numbers, and other information related to
`
`each contact. This understanding is further evidenced by, for example, the
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`extensive discussions of the Microsoft Outlook 97 Contacts subfolder in Padwick.
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`Exhibit 1004 at pp. 122-150.
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`35. Contact databases (address books) in the relevant timeframe had
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`extensive functionality. This included querying, scripting, indexing, etc. Such
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`functionality allowed a user to add new contacts and edit existing contacts, exactly
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`as one would expect. Contact databases (address books) also generally included
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`Application Programming Interfaces ("APIs") to allow the address book to be
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`accessed by different application programs, so that the contact data could be used,
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`entered or updated by other programs.
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`36. Several examples of the advanced state of contact databases are
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`provided in exhibits 1009-1010. Exhibit 1009, U.S. Pat. No. 5,754,306 ("Taylor"),
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`originally filed in 1993, describes an integrated communications system (ICU)
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`having a "communications address book" (CAB). As Taylor notes:
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`"The purpose of the CAB is to organize in a data base a collection of
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`names, telephone numbers, and other relevant data on the electronic
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`mail, fax, or host computer systems at the recipients (or
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`"destinations") of communications. As illustrated in FIG. 3 above, the
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`CAB supports other components of the ICU by supplying information
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`to these components in a convenient manner." Ex. 1009 at 10:29-34.
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`15
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`
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`37. As described in Taylor, data can be edited and entered by a user (Ex.
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`1009 at 10:44 – 11:9), and the CAB can be accessed and manipulated by other
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`software running on the system. Ex. 1009 at 21:5-12; 10:29-34; 11:10-20. The
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`functionality of the address book is extensive. Ex. 1009 at 9, l. 55 – col. 23, l. 51.
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`38. Similarly, Padwick (Ex. 1004) discusses the extensive functionality of
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`the Microsoft Outlook 97 Contacts and address books. As taught in Padwick, a
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`user can create new contact items with the name, job title, company, address,
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`phone number, email address, web page address and miscellaneous notes for each
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`contact. Ex. 1004 at p. 123. Padwick teaches that the Contacts Subfolder (the
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`address book) could also be saved as an Outlook® Address Book (Ex. 1004 at p.
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`139) such that when a user sends an email, "Outlook automatically checks the
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`names you type in the To, Cc, and Bcc boxes against the names in the Address
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`Books." Ex. 1004 at p. 342. Padwick also describes how the Outlook 97 Contacts
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`and address books could be used to send faxes, address emails, place telephone
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`calls, and address conventional mail. Ex. 1004 at 121-150.
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`39. Likewise, Exhibit 1010, U.S. Patent No. 5,790,532 ("Sharma"),
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`originally filed in 1993, describes personal communications system for telephony,
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`FAX, email and multimedia communications. Sharma describes its address book
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`function as follows:
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`"The address book function of the present system is a versatile
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`16
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`
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`database that is built by the user and operates in conjunction with
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`the other components of the present system to dial and establish
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`communication links with remote sites to enable data communication,
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`voice mail, facsimile, file transfer all in an automated mode without
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`user intervention." Ex. 1010 at 2:38-43 (emphasis added).
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`40. As Sharma teaches, the address book (contact database) can be
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`accessed by all other system components. Ex. 1010 at 7:52-64.
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`41. This level of education and experience would have provided extensive
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`opportunities to use, write software for and otherwise interact with end-user
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`applications themselves, including graphical operating systems such as Windows
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`95 and the Macintosh OS, word-processing programs such as MS Word® and
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`WordPerfect, e-mail programs such as Lotus Notes and Microsoft Outlook®, and
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`Web browsers such as Internet Explorer and Netscape Navigator.
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`42. Similarly, Goodhand, first filed as early as 1996 (field [22] on its front
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`page), teaches a "system and method for resolving nam