BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`INTERNATIONAL BUSINESS MACHINES CORPORATION
`Petitioner
`
`v.
`
`INTELLECTUAL VENTURES II LLC
`Patent Owner
`
`
`
`Case IPR2015-00089
`U.S. Patent No. 6,546,002
`
`
`
`
`DECLARATION OF TIM A. WILLIAMS, PH.D. IN SUPPORT OF
`PATENT OWNER’S RESPONSE TO PETITION
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`
`
`
`
`IV 2005
`IPR2015-00089
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`
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`

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`TABLE OF CONTENTS
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`I.
`
`Introduction ......................................................................................................... 1
`
`II. Qualifications ...................................................................................................... 4
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`III. Legal standards .................................................................................................... 7
`
`A. Anticipation ........................................................................................... 7
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`B.
`
`C.
`
`Obviousness ........................................................................................... 7
`
`Level of skill in the art .......................................................................... 9
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`IV. The ’002 Patent ................................................................................................... 9
`
`V. Technical analysis .............................................................................................14
`
`A.
`
`Claim construction ..............................................................................14
`
`1.
`
`2.
`
`“mobile interface” .....................................................................14
`
`“pointer” ....................................................................................17
`
`B.
`
`Grounds based on Richardson .............................................................17
`
`1.
`
`2.
`
`Overview of Richardson ...........................................................18
`
`Richardson does not anticipate claims 1, 2, 7, 8, 11, 12,
`17, and 18 ..................................................................................20
`
`a)
`
`
`b)
`
`c)
`
`
`d)
`
`Richardson does not disclose “the mobile interface
`including a plurality of pointers” ....................................22
`
`Richardson does not disclose a “mobile interface” ........27
`
`Richardson does not disclose “retrieving the user specific
`resources and information using the plurality of pointers
`displayed on the mobile interface” .................................28
`
`Richardson does not disclose “retrieving user profile and
`configuration data from the network server to the local
`device, wherein the user profile and configuration data is
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`used to update the data associated with the mobile
`interface” .........................................................................29
`
`Richardson does not disclose “wherein the user specific
`resources and information comprise . . . bookmarked
`URLs . . . and user profiles” ...........................................32
`
`
`e)
`
`3.
`
`4.
`
`5.
`
`The combination of Richardson and Davis does not
`render claims 6, 16, 39, and 46 obvious ...................................34
`
`The combination of Richardson, with Arnold or
`Raman/Arnold, does not render claims 9, 19, and 21-24
`obvious ......................................................................................36
`
`The combination of Richardson, with Pezzullo and/or
`Pocock, does not render claims 4, 10, 14, and 20 obvious .......37
`
`C.
`
`Grounds based on Murray ...................................................................38
`
`1.
`
`Overview of Murray..................................................................38
`
`2. Murray does not anticipate claims 1, 2, 8, 11, 12, and 18 ........41
`
`a) Murray does not disclose a “mobile interface” ..............42
`
`b) Murray does not disclose “the mobile interface including
`a plurality of pointers corresponding to the user specific
`resources and information” .............................................45
`
`
`c) Murray does not disclose “retrieving a mobile interface
`from the network server to the local device”..................46
`
`
`d) Murray does not disclose “retrieving user profile and
`configuration data from the network server to the local
`device, wherein the user profile and configuration data is
`used to update the data associated with the mobile
`interface” .........................................................................47
`
`3. Murray does not render claims 7 and 17 obvious .....................48
`
`4.
`
`The combination of Murray with Davis does not render
`claims 6 and 16 obvious ............................................................48
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`5.
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`The combination of Murray, with Arnold or
`Raman/Arnold, does not render claims 9, 19, and 21-24
`obvious ......................................................................................48
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`VI. Conclusion .........................................................................................................49
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`I.
`
`Introduction
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`I, Tim A. Williams, Ph.D., a resident of Alamo, California, declare as
`
`follows:
`
`1.
`
`I have been retained on behalf of Intellectual Ventures II LLC, to
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`provide declaratory evidence in inter partes reviews of U.S. Patent 6,546,002 (“the
`
`’002 Patent”).
`
`2.
`
`I am being compensated for my work related to these inter partes
`
`review proceedings. My compensation is not dependent on, and in no way affects,
`
`the substance of my statements in this Declaration.
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`3.
`
`I have reviewed and am familiar with the specification and the
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`claims of the ’002 Patent. I will cite to the specification using the following format:
`
`(Ex. 1004, ’002 Patent, 1:1-10). This example citation points to the ’002 Patent
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`specification at column 1, lines 1-10.
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`4.
`
`Along with the petition for inter partes review of the ’002 Patent
`
`(IPR 2015-00089, Paper 2 (“Petition”)), I have reviewed and am familiar with the
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`following references:
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`• U.S. Patent 6,546,002 to Kim (Ex. 1004, “’002 Patent”);
`
`• Richardson, et al., Virtual Network Computing, IEEE Internet
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`Computing, Jan.-Feb. 1998 (Ex. 1006, “Richardson”);
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`• Murray, et al., Effective Use of Individual User Profiles with
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`Software Distribution, Digest of the Large Scale System
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`Administration of Windows NT Workshop, Aug. 1997 (Ex. 1008,
`
`“Murray”);
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`• U.S. Patent 5,615,257 to Pezzullo, et al. (Ex. 1011, “Pezzullo”);
`
`• U.S. Patent 5,473,692 to Davis (Ex. 1012, “Davis”);
`
`• Int’l App. Pub. No. WO 98/12833 to Arnold, et al. (Ex. 1013,
`
`“Arnold”);
`
`• Eur. Patent No. 0396062 to Pocock, et al. (Ex. 1014, “Pocock”);
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`• File History of the ’002 Patent (Exs. 1015-1017, “’002 File History”);
`
`and
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`• Raman, Emacspeak—A Speech Interface, Proceedings of the SIGCHI
`
`Conference on Human Factors in Computing Systems, Apr. 1996 (Ex.
`
`1018, “Raman”).
`
`5.
`
`I have also reviewed and refer to the following:
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`• The Declaration of Henry A. Lieberman (Ex. 1001, “Lieberman
`
`Decl.”);
`
`• The Board’s Decision to Institute Inter Partes Review in this
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`proceeding (Paper 8, “Decision”);
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`• The IEEE Standard Dictionary of Electrical and Electronic Terms, 6th
`
`ed., IEEE Std. 100-1996, Institute of Electrical and Electronics
`
`Engineers (1996) (Ex. 2001, “1996 IEEE Dictionary”);
`
`• Windows NT Server 4.0 Advanced Technical Reference (Ex. 2002);
`
`• Heywood, Windows NT User Profiles, WindowsITPro, August 31,
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`1997 (Ex. 2003, “Windows NT User Profiles”);
`
`• Guide to MS Windows NT 4.0 User Profiles and Policies (Ex. 2004);
`
`• Richardson, et al., The RFB Protocol, The Olivetti & Oracle
`
`Laboratory, ver. 3.3 (1998) (Ex 2007, “The RFB Protocol”);
`
`• Wood, et al., Global Teleporting with Java: Toward Ubiquitous
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`Personalized Computing, IEEE Computer (1997) (Ex. 2008, “Global
`
`Teleporting with Java”);
`
`• Corcoran, et al., User Interface Technologies for Home Appliances
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`and Networks, IEEE Transactions on Consumer Electronics, vol. 44,
`
`issue 3, Aug. 1998 (Ex. 2009, “User Interface Technologies for Home
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`Appliances and Networks”); and
`
`• The transcript from the deposition of Henry A. Lieberman,
`
`Petitioner’s declarant (Ex. 2010, “Lieberman Dep.”).
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`6.
`
`I am familiar with the technology at issue and the state of the art at
`
`the time of filing the application leading to the ’002 Patent.
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`I have been asked to provide my technical review, analysis,
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`7.
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`insights, and opinions regarding the above-noted references, as well as various
`
`industry practices in the mobile computing and user interface fields.
`
`II. Qualifications
`8. My academic and professional pursuits are closely related to the
`
`subject matter of the ’002 Patent.
`
`9.
`
`I have over 35 years of professional experience in wireless
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`communications and telecom technology, participating in the organization and
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`operation of companies that brought wireless LAN, software VoIP PBX, and 2-
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`way paging technologies to the marketplace.
`
`10.
`
`I received a Bachelor of Science (S.B.) degree in Electrical
`
`Engineering from the Michigan Technological University in 1976. In 1982, I
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`received a Master of Science (M.S.) degree in Electrical Engineering from the
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`University of Texas at Austin. My master’s dissertation was titled “Cepstral
`
`Processing of Speech Signals” and, in 1985, I received a Doctor of Philosophy
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`(Ph.D.) degree in Electrical Engineering from the University of Texas at Austin.
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`My Ph.D. dissertation was titled “Digital Signal Processing Techniques for
`
`Acoustic Log Data.”
`
`11. From 1976 to 1979, I was employed as an Engineer in the Digital
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`Voice Privacy Group of the Communications Sector of Motorola, Inc., in Chicago,
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`Illinois. As part of that group, I built the first commercial digitally encrypted two-
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`way FM land mobile radio system.
`
`12. From 1979 to 1991, I was employed as a Sr. Engineer in the
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`Semiconductor Sector of Motorola, Inc., in Austin, Texas. I was a project leader
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`and senior technical member of teams responsible for product development of
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`various communication products.
`
`13. From 1991 to 1998, I was the Co-Founder, Chief Technical
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`Officer, Vice President of Engineering, and Vice President of Business Strategy,
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`for Wireless Access, Inc., in Santa Clara, CA. Wireless Access was a startup
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`company focusing on the Narrow Band Personal Communications Service
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`equipment market. The company developed over-the-air protocols, subscriber
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`equipment, and integrated circuits for 2-way paging services. These products
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`included the creation of user interfaces for our subscriber device products. These
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`user interfaces used both third party and Wireless Access specific operating
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`systems. They presented and organized the messaging information for the user and
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`interfaced with the operating systems.
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`14. From 1998 to 2000, I was Chief Technology Officer and Advisory
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`Board Member of Picazo Communications. Picazo built software private branch
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`exchanges, a telephone exchange or switching system. Picazo’s products included
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`PC-based interfaces to control the administration, configuration, and control of its
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`servers. These were lightweight interfaces allowing for minimal local computer
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`requirements. These interfaces used third party operating systems. They allowed
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`system administrators to control and configure the environment for multiple users.
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`The user interface software allowed users to conduct phone calls and messaging
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`sessions and enabled control of the users’ environment.
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`15. From 1999 to 2000, I was the interim CEO and Advisory Board
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`Member for Atheros Communications in Palo Alto, CA, a company that built
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`wireless LAN integrated circuits.
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`16. From 2001 to 2004, I was the founder and CEO of JetQue, Inc. in
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`Danville, CA. JetQue designed messaging solutions for the mobile professional.
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`JetQue’s user software included user interfaces for mobile subscriber devices. The
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`administration software included interfaces for PC operating systems and allowed
`
`for manipulation of system parameters.
`
`17. From 2004 to 2006, I was the founder and CEO of SiBEAM Inc. in
`
`Sunnyvale, CA. SiBEAM is a fabless semiconductor company developing high-
`
`speed wireless networking integrated circuits.
`
`18. From 2006 to 2012, I was the founder and a board member of
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`BEEcube Inc. in Fremont, CA. BEEcube built electronic design automation
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`solutions for the integrated circuits industry.
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`I am an inventor on over 27 U.S. patents in communications,
`
`19.
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`wireless, and signal processing technologies. Additional information on my
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`education, technical experience and professional associations can be found in my
`
`curriculum vitae, which is submitted as Exhibit 2006.
`
`III. Legal standards
`A. Anticipation
`I understand that a patent claim is anticipated if every element as
`20.
`
`recited in the claim is actually disclosed in a single reference as recited in the
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`claim. The disclosure may be explicit, implicit, or inherent. I understand that a
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`reference is read from the perspective of a person of ordinary skill in the art at the
`
`time of the invention.
`
`B. Obviousness
`I understand that a patent claim is invalid if the claimed invention
`21.
`
`would have been obvious to a person of ordinary skill in the field at the time the
`
`application was filed. This means that even if all of the requirements of the claim
`
`cannot be found in a single prior art reference that would anticipate the claim, the
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`claim can still be invalid.
`
`22.
`
`As part of this inquiry, I have been asked to consider the level of
`
`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 field;
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`• the types of problems encountered in the field; and
`
`• the sophistication of the technology.
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`23.
`
`To obtain a patent, the claimed invention must have, as of the
`
`priority date, been nonobvious in view of the prior art in the field. I understand that
`
`an invention is obvious when the differences between the subject matter sought to
`
`be patented and the prior art are such that the subject matter as a whole would have
`
`been obvious at the time the invention was made to a person having ordinary skill
`
`in the art.
`
`24.
`
`I understand that to prove that prior art or a combination of prior
`
`art renders a patent obvious, it is necessary to: (i) identify the particular references
`
`that, singly or in combination, make the patent obvious; (ii) specifically identify
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`which elements of the patent claim appear in each of the asserted references; and
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`(iii) explain how the prior art references could have been combined in order to
`
`create the inventions claimed in the asserted claim.
`
`25.
`
`I understand that certain objective indicia can be important
`
`evidence regarding whether a patent is obvious or nonobvious. Such indicia
`
`include: commercial success of products covered by the patent claims; a long-felt
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`need for the invention; failed attempts by others to make the invention; copying of
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`the invention by others in the field; unexpected results achieved by the invention as
`
`compared to the closest prior art; praise of the invention by the infringer or others
`
`in the field; the taking of licenses under the patent by others; expressions of
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`surprise by experts and those skilled in the art at the making of the invention; and
`
`the patentee proceeded contrary to the accepted wisdom of the prior art.
`
`C. Level of skill in the art
`Based on the technologies disclosed in the ’002 Patent, a person
`26.
`
`of ordinary skill in the art would have a Bachelor of Science degree in Electrical
`
`Engineering, Computer Engineering, Computer Science, or an equivalent field, as
`
`well as at least one (1) year of industry experience designing mobile computing
`
`applications and/or user interfaces.
`
`IV. The ’002 Patent
`Before analyzing the differences between the prior art references
`27.
`
`submitted by Petitioner and the ’002 Patent, I would like to provide insight on the
`
`technical challenges addressed by the ’002 Patent and how these challenges are
`
`addressed by the ’002 Patent claims. This will help define certain terms in the ’002
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`Patent claims in view of its specification as well as what a person of ordinary skill
`
`in the art would have understood during the timeframe when the application
`
`leading to the ’002 Patent was filed.
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`The ’002 Patent addresses issues with prior computer systems, in
`
`28.
`
`particular retrieving files and documents from different computers at different
`
`locations: “a computer used at work may be the only device that includes a
`
`spreadsheet program while a computer used at home may be the only device that
`
`includes bookmarked URLs. Thus, the user will not have access to the bookmarks
`
`from the user’s work computer and likewise, will not have access to the
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`spreadsheet program from the user’s home computer.” (’002 Patent, 2:40-46.) A
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`need therefore existed to retrieve user-specific data using different computers from
`
`different locations. (Id. at 3:57-60.)
`
`29.
`
`The claimed inventions of the ’002 Patent met this need by
`
`providing a mobile interface1 that uses pointers to dynamically retrieve the user-
`
`specific data such as files, documents, and programs. (Id. at 6:13-15.) The mobile
`
`interface with pointers is recited in independent claims 1 and 11:
`
`A method for retrieving user specific resources and
`1.
`information stored either on a local device or a network server,
`the method comprising the steps of:
`retrieving a mobile interface from the network server to the
`local device;
`
`
`1 I note that the ’002 Patent claims a “mobile interface,” which is described
`
`throughout the specification as a “mobile interface agent.”
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`displaying the mobile interface on the local device, the
`mobile interface including a plurality of pointers corresponding
`to the user specific resources and information; and
`retrieving the user specific resources and information using
`the plurality of pointers displayed on the mobile interface.
`
`A method for retrieving user specific resources and
`11.
`information stored either on a local device or a network server,
`the method comprising the steps of:
`displaying the mobile interface on the local device, the
`mobile interface including a plurality of pointers corresponding
`to the user specific resources and information;
`retrieving user profile and configuration data from the
`network server to the local device, wherein the user profile and
`configuration data is used to update the data associated with the
`mobile interface;
`retrieving the user specific resources
`and information using the plurality of
`pointers displayed on
`the mobile
`interface.
`
` (’002 Patent, claims 1 and 11, emphasis added.) The mobile
`
`interface uses pointers to dynamically retrieve the user-
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`specific data across different operating systems and
`
`networks, thus conferring significant advantages over the
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`prior computer systems described above. (Id. at 3:18-23 and 4:26-28.)
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`30.
`
`Figure 1B of the ’002 Patent (reproduced at right) illustrates an
`
`exemplary mobile interface. The mobile interface includes a list of pointers to user-
`
`specific data such as “URLs,” “Apps,” “Images,” and “Docs.” Each of the pointers
`
`includes a reference associated with the location of an item of interest. (’002
`
`Patent, 6:13-15.)
`
`31.
`
`The mobile interface allows users to retrieve user-specific data
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`across different operating systems and networks, a capability lacking in prior
`
`computer systems. (Id. at 1:48-65.) The mobile interface retrieves the data using
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`pointers: “the menu items/pointers shown in the user interface [of Figure 1B
`
`above] can be used to access and retrieve user specific resources and information.”
`
`(Id. at 6:13-15.)
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`32.
`
`Figure 8 of the ’002 Patent illustrates an exemplary mobile
`
`interface that retrieves documents using pointers.
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`Figure 8 of the ’002 Patent
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`
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`At Location 1, a mobile interface can include a pointer to a Microsoft (MS) Word
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`application running on a Windows 95 PC. (Id. at 13:15-27.) Here, a user can open
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`the MS Word application using the pointer to the application in the mobile
`
`interface. (Id.) When the user moves from Location 1 to Location 2, the mobile
`
`interface also moves to Location 2. (Id.) At this location, the mobile interface
`
`adjusts the pointer data to local applications running on the Apple MacOS
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`computer so that the pointer to MS Word in the mobile interface at Location 2 can
`
`retrieve the application. (Id.) Once the MS Word document is retrieved to Location
`
`2, that computer executes the Word application using its own processor and
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`memory. As a result, using the mobile interface, the user is able to seamlessly
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`access MS Word across different computing platforms.
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`The ’002 Patent explains that a mobile interface “can be
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`33.
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`accessible using any computer from any geographical location so long as the
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`computer can be connected to a network.” (’002 Patent, Abstract.) For example,
`
`“the mobile interface agent can be accessible using a computer, cable set top box,
`
`cellular phone, or other device from any geographical location.” (Id. at 4:44-46.)
`
`The mobile interface is not restricted to a particular operating system or platform.
`
`V. Technical analysis
`A. Claim construction
`I understand that patent claims are to be given their broadest
`34.
`
`reasonable construction in light of the specification as would be read by a person
`
`of ordinary skill in the relevant art. I also understand that, if the inventor clearly
`
`defines the meaning of a term, then that meaning should be used when interpreting
`
`claims.
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`35.
`
`I address my interpretation of specific terms used in the ’002
`
`Patent below. I also comment on the Board’s interpretation of claim terms in its
`
`Decision.
`
`1. “mobile interface”
`Independent claims 1 and 11 recite the term “mobile interface.” I
`36.
`
`interpret this term to mean “a user interface accessible on different computing
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`devices and capable of dynamically accessing user-specific data on a network
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`server and local device.”
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`37.
`
`The ’002 Patent specification supports my interpretation:
`
`The present invention is further directed to a mobile interface
`agent that can be used to dynamically access resources stored
`either locally in the computer device or across a network
`including programs, applications, bookmarked URLs, user
`profiles, IP addresses, telephone numbers, television channels,
`radio stations, and the like that are specific to a user via any
`computer device.
`
`(’002 Patent, 1:11-16, emphasis added.) In other words, the mobile interface can be
`
`accessed by different computing devices to dynamically access user-specific data.
`
`38.
`
`Once deployed on the computing device, the ’002 Patent states
`
`that the mobile interface is capable of dynamically accessing user-specific data
`
`stored on a network server and local device: “The present invention is further
`
`directed to a mobile interface agent that can be used to dynamically access
`
`resources stored either locally in the computer device or across a network.” (Id. at
`
`1:11-13, emphasis added; see also id. at 12:56-65.)
`
`39.
`
`The dynamic access aspect of the mobile interface is achieved by
`
`“periodically updat[ing] or query[ing] user profile data:” (’002 Patent, 5:61-62.)
`
`“When the MIA . . . is first used, it will contact the profile manager . . . to initialize
`
`itself. From then on, the MIA . . . will periodically update and synchronize itself
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`with the profile data.” (Id. at 7:52-55.) In other words, data associated with the
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`mobile interface may be dynamically updated during use, including data used to
`
`access user-specific resources. Dynamic access to local data on different devices
`
`can also be achieved by adjusting pointer data to local resources: “For example,
`
`MIA . . . could have a pointer to Microsoft Word program in location 1 on the
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`Windows 95 machine but cannot resolve that pointer now that the user has moved
`
`to location 2 on the Apple Macintosh machine. Thus, the MIA . . . may search for
`
`Word locally on the Macintosh and adjust the pointer to point to the copy of
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`Microsoft Word on the Macintosh.” (’002 Patent, 13:21-27.)
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`40.
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`The Board’s broad construction of “mobile interface” does not
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`take into account the teachings of the specification: “a user interface accessible on
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`different devices.” (Decision, p. 9.) This preliminary construction is inconsistent
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`with the ’002 Patent specification.
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`41.
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`In the context of the ’002 Patent, a mobile interface is more than
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`just an interface accessible on different computing devices; it is an interface
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`capable of dynamically accessing user-specific data stored on a network server and
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`local device. The Board’s construction encompasses any interface—even those that
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`are incapable of dynamically accessing data from different devices, locations, and
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`computing platforms.
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`2. “pointer”
`Independent claims 1 and 11 recite the term “pointer.” The
`42.
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`inventor defined this term in the specification: “A pointer in this context is a
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`reference to a type of menu item that can be accessible on the computer, PDA or a
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`server.” (’002 Patent, 1:36-38 and 10:8-10.) Since the inventor chose to define
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`“pointer,” I understand that this definition is controlling and I apply this definition
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`in my analysis of the claims.
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`43.
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`The Board’s construction, in contrast, is incomplete. In its
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`Decision, the Board relies on column 10, lines 8-10 from the specification to
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`support its preliminary construction of “pointer” as “a link or shortcut to an item.”
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`(Decision, p. 10.) This portion of the specification describes Figure 4, a detailed
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`block diagram of the mobile interface. (’002 Patent, 9:62-11:4.) In this section, the
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`patent describes that when a user activates a pointer, a pointer resolver of the
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`mobile interface decodes this input and accesses the corresponding item. (Id. at
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`10:10-16.) That is, the pointer points to an item that “can be accessible on the
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`computer, PDA or a server.”
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`B. Grounds based on Richardson
`I understand that the Board instituted the following grounds of
`44.
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`unpatentability based on Richardson (See Decision, p. 36):
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`45.
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`Reference(s)
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`Richardson
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`Richardson and Pezzullo
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`Richardson and Davis
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`Richardson and Arnold
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`Richardson and Pocock
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`Richardson, Raman, and
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`Arnold
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`Basis
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`§ 102
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`§ 103
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`§ 103
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`§ 103
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`§ 103
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`§ 103
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`1, 2, 7, 8, 11, 12, 17, and 18
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`4 and 14
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`6 and 16
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`9, 19 and 21-23
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`10 and 20
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`24
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`Summary of Instituted Grounds of Unpatentability Based on Richardson
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`
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`1. Overview of Richardson
`Richardson discloses a Virtual Network Computing (VNC)
`46.
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`system that includes a VNC client (viewer) and a VNC server. When a user clicks
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`on an icon, the VNC client sends a message to the VNC server that communicates
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`the x-y position of the cursor on the client display and communicates that a “click”
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`was made. (See The RFB Protocol, p. 18.) No pointers are included in the message.
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`(Id.)
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`47.
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`For example, an icon for a Microsoft (MS) Word document
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`displayed at the VNC client in Richardson is not a pointer. The client computer
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`does not retrieve the MS Word document when the icon is clicked. Instead, if the
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`MS Word document icon in Richardson is clicked, Richardson’s VNC server
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`updates the client’s display with a new screenshot, this time showing an opened
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`MS Word document. The VNC server translates and processes a click event and x-
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`y coordinates and sends changes to the screen displayed at the VNC client. (See
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`Global Teleporting with Java, pp. 54-55.) Depending on the extent of the screen
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`change, “the server would send as many rectangle specifications as are required to
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`describe the changes.” (Id.)
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`48.
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`Instead of using pointers, Richardson operates at the frame buffer
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`level. (See User Interface Technologies for Home Appliances and Networks, p.
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`682 (“[W]e describe the remote frame buffer (RFB) technology which was recently
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`released by Oracle research laboratories under the GNU Public License. This RFB
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`technology forms the core of their virtual network computer (VNC) application.”)
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`emphasis in original.) A frame buffer is a memory array that stores pixel data of a
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`screen device. In Richardson, when a connection between the VNC server and
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`client is established, “the server and client [ ] exchange messages to negotiate
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`desktop size, pixel format, and encoding schemes. The client requests an update for
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`the entire screen, and the session begins.” (Richardson, p. 36.) The client and
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`server communicate using an input side and a display side of the VNC protocol.
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`“The input side of the VNC protocol is based on a standard workstation model of a
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`keyboard and multibutton pointing device. The client sends input events to the
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`server whenever the user presses a key or pointer button, or moves the pointing
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`device.” (Id. at p. 35.)
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`49.
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`The user’s desktop display at the VNC client is merely pixel data.
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`The VNC server uses the display side of the protocol to provide the pixel data
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`(screenshots) to the client: “Put a rectangle of pixel data at a given x, y position.”
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`(Id.) Through a series of framebuffer updates representing a change from one valid
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`framebuffer state to another, the VNC client redraws the VNC server’s desktop
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`image-by-image, thus providing a mirror image of the display. (Id.)
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`2. Richardson does not anticipate claims 1, 2, 7, 8, 11, 12, 17, and 18
`Richardson does not disclose the following claim elements:
`50.
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`i.
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`“the mobile interface including a plurality of pointers”
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`(independent claims 1 and 11);
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`ii.
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`“retrieving the user specific resources and information using the
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`plurality of pointers” (independent claims 1 and 11);
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`iii.
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`“retrieving user profile and configuration data from the network
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`server to the local device, wherein the user profile and
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`configuration data is used to update the data associated with the
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`mobile interface” (independent claim 11);
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`“wherein the user specific resources and information comprise . . .
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`iv.
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`bookmarked URLs . . . and user profiles” (dependent claims 2 and
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`12).
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`51.
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`Independent claims 1 and 11 recite these missing elements as
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`follows:
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`A method for retrieving user specific resources and
`1.
`information stored either on a local device or a network server,
`the method comprising the steps of:
`retrieving a mobile interface from the network server to the
`local device;
`displaying the mobile interface on the local device, the
`mobile interface including a plurality of pointers corresponding
`to the user specific resources and information; and
`retrieving the user specific resources and information using
`the plurality of pointers displayed on the mobile interface.
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`A method for retrieving user specific resources and
`11.
`information stored either on a local device or a network server,
`the method comprising the steps of:
`displaying the mobile interface