BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`INTERNATIONAL BUSINESS MACHINES CORPORATION
`Petitioner
`
`v.
`
`INTELLECTUAL VENTURES II LLC
`Patent Owner
`
`
`
`Case IPR2015-00092
`U.S. Patent No. 6,546,002
`
`
`
`
`DECLARATION OF TIM A. WILLIAMS, PH.D. IN SUPPORT OF
`PATENT OWNER’S RESPONSE TO PETITION
`
`
`
`
`
`IV 2005
`IPR2015-00092
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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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`

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`TABLE OF CONTENTS
`
`I. 
`
`Introduction ......................................................................................................... 1 
`
`II.  Qualifications ...................................................................................................... 4 
`
`III.  Legal standards .................................................................................................... 7 
`
`A.  Anticipation ........................................................................................... 7 
`
`B. 
`
`C. 
`
`Obviousness ........................................................................................... 7 
`
`Level of skill in the art .......................................................................... 9 
`
`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 25, 26, 30, 31, 34-
`36, 40-43, and 47-49 ................................................................. 20 
`
`Richardson does not disclose the claim elements in
`Group 1 ........................................................................... 25 
`
`Richardson does not disclose the claim elements in
`Group 2 ........................................................................... 30 
`
`Richardson does not disclose the claim elements in
`Group 3 ........................................................................... 31 
`
`Richardson does not disclose the claim elements in
`Group 4 ........................................................................... 33 
`
`a) 
`
`
`b) 
`
`
`c) 
`
`
`d) 
`
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`Richardson does not disclose the claim elements in
`Group 5 ........................................................................... 33 
`
`Richardson does not disclose the claim elements in
`Group 6 ........................................................................... 34
`
`e) 
`
`
`f) 
`
`3. 
`
`4. 
`
`5. 
`
`The combination of Richardson and Davis does not
`render claims 39 and 46 obvious .............................................. 36 
`
`The combination of Richardson, with Arnold or
`Raman/Arnold, does not render claims 32, 37, and 44
`obvious ...................................................................................... 38 
`
`The combination of Richardson, with Pezzullo and/or
`Pocock, does not render claims 28, 33, 38, and 45
`obvious ...................................................................................... 39 
`
`C. 
`
`Grounds based on Murray ................................................................... 40 
`
`1. 
`
`Overview of Murray.................................................................. 40 
`
`2.  Murray does not anticipate claims 25, 26, 31, 34, 35, 40,
`41, 43, and 47-49 ....................................................................... 43 
`
`a)  Murray does not disclose the claim elements in Group 1
` ........................................................................................ 46 
`
`
`b)  Murray does not disclose the claim elements in Group 2
` ........................................................................................ 48 
`
`
`c)  Murray does not disclose the claim elements in Group 3
` ........................................................................................ 50
`
`3.  Murray does not render claims 30, 36, and 42 obvious ............ 51 
`
`4. 
`
`5. 
`
`The combination of Murray with Davis does not render
`claims 39 and 46 obvious. ......................................................... 51 
`
`The combination of Murray with Arnold does not render
`claims 32, 37, and 44 obvious. .................................................. 51 
`
`VI.  Conclusion ......................................................................................................... 52 
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`I.
`
`Introduction
`
`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
`
`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.
`
`3.
`
`I have reviewed and am familiar with the specification and the
`
`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.
`
`4.
`
`Along with the petitions for inter partes review of the ’002 Patent
`
`(IPR2015-00092, Paper 2 (“Petition”)), I have reviewed and am familiar with
`
`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”);
`
` 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,
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`“Arnold”);
`
` Eur. Patent No. 0396062 to Pocock et al. (Ex. 1014, “Pocock”); and
`
` File History of the ’002 Patent (Exs. 1015-1017, “’002 File History”).
`
`5.
`
`I have also reviewed and refer to the following:
`
` The Declaration of Henry A. Lieberman (Ex. 1001, “Lieberman
`
`Decl.”);
`
` The Board’s Decision to Institute Inter Partes Review in this
`
`proceeding (Paper 8, “Decision”);
`
` 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),
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` 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
`
`Personalized Computing, IEEE Computer (1997) (Ex. 2008, “Global
`
`Teleporting with Java”);
`
` Corcoran et al., User Interface Technologies for Home Appliances
`
`and Networks, IEEE Transactions on Consumer Electronics, vol. 44,
`
`issue 3, Aug. 1998 (Ex. 2009, “User Interface Technologies for Home
`
`Appliances and Networks”); and
`
` The transcript from the deposition of Henry A. Lieberman,
`
`Petitioner’s declarant (Ex. 2010, “Lieberman Dep.”).
`
`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.
`
`7.
`
`I have been asked to provide my technical review, analysis,
`
`insights, and opinions regarding the above-noted references, as well as various
`
`industry practices in the mobile computing and user interface fields.
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`II. Qualifications
`8. My academic and professional pursuits are closely related to the
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`subject matter of the ’002 Patent.
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`9.
`
`I have over 35 years of professional experience in wireless
`
`communications and telecom technology, participating in the organization and
`
`operation of companies that brought wireless LAN, software VoIP PBX, and 2-
`
`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
`
`received a Master of Science (M.S.) degree in Electrical Engineering from the
`
`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
`
`(Ph.D.) degree in Electrical Engineering from the University of Texas at Austin.
`
`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
`
`Voice Privacy Group of the Communications Sector of Motorola, Inc., in Chicago,
`
`Illinois. As part of that group, I built the first commercial digitally encrypted two-
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`way FM land mobile radio system.
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`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
`
`and senior technical member of teams responsible for product development of
`
`various communication products.
`
`13. From 1991 to 1998, I was the Co-Founder, Chief Technical
`
`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
`
`company focusing on the Narrow Band Personal Communications Service
`
`equipment market. The company developed over-the-air protocols, subscriber
`
`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.
`
`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
`
`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.
`
`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.
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`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.
`
`I am an inventor on over 27 U.S. patents in communications, wireless, and signal
`
`processing technologies. Additional information on my education, technical
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`experience and professional associations can be found in my curriculum vitae,
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`which is submitted as Exhibit 2006.
`
`III. Legal standards
`A. Anticipation
`19.
`I understand that a patent claim is anticipated if every element as
`
`recited in the claim is actually disclosed in a single reference as recited in the
`
`claim. The disclosure may be explicit, implicit, or inherent. I understand that a
`
`reference is read from the perspective of a person of ordinary skill in the art at the
`
`time of the invention.
`
`B. Obviousness
`20.
`I understand that a patent claim is invalid if the claimed invention
`
`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
`
`claim can still be invalid.
`
`21.
`
`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
`
`invention was made. In deciding the level of ordinary skill, I considered the
`
`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.
`
`22.
`
`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.
`
`23.
`
`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
`
`which elements of the patent claim appear in each of the asserted references; and
`
`(iii) explain how the prior art references could have been combined in order to
`
`create the inventions claimed in the asserted claim.
`
`24.
`
`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
`
`need for the invention; failed attempts by others to make the invention; copying of
`
`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
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`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
`25.
`Based on the technologies disclosed in the ’002 Patent, a person
`
`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
`26.
`Before analyzing the differences between the prior art references
`
`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
`
`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.
`
`27.
`
`The ’002 Patent addresses issues with prior computer systems, in
`
`particular retrieving files and documents from different computers at different
`
`locations: “a computer used at work may be the only device that includes a
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`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
`
`spreadsheet program from the user’s home computer.” (’002 Patent, 2:40-46.) A
`
`need therefore existed to retrieve user-specific data using different computers from
`
`different locations. (Id. at 3:57-60.)
`
`28.
`
`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 25, 34, and 40:
`
`25. A mobile interface used for accessing user specific
`resources and information stored either on a local computer
`device or a network server, the mobile interface comprising:
` means for interfacing any local computer device with the
`network server;
` means for presenting a plurality of pointers on any local
`device corresponding to the user specific resources and
`information to a user; and
` means for accessing the user specific resources and
`information using the plurality of pointers.
`
`
`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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`34. A mobile interface used for retrieving user specific
`resources and information stored either on a local device or a
`network server, the mobile interface being adapted to move
`from one local device to another and adapted to be displayed on
`the local device, the mobile interface comprising:
`a plurality of pointers that correspond to the user specific
`
`resources and information, wherein upon initiating a pointer, a
`user specific resource or information from either the local
`device or the network server is retrieved.
`
`40. A system for storing and accessing user specific
`resources and information, the system comprising:
`
`a network for accessing the user specific resources and
`information stored in a network server; and
`
`a local device communicating with the network and having
`a local memory and a mobile interface, wherein the local
`memory also includes user specific resources and information,
`and the mobile interface includes pointers corresponding to the
`user specific resources and information that are stored either on
`the local device or the network server, wherein the pointers
`provide
`links
`to access
`the corresponding user specific
`resources and information.
`
`(’002 Patent, claims 25, 34, and 40, emphasis added.) The mobile interface uses
`
`pointers to dynamically retrieve the user-specific data across different operating
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`systems and networks, thus conferring significant advantages over the prior
`
`computer systems described above. (Id. at 3:18-23 and 4:26-28.)
`
`29.
`
`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.)
`
`30.
`
`The mobile interface allows users to
`
`retrieve user-specific data 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
`
`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.)
`
`31.
`
`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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`
`
`At Location 1, a mobile interface can include a pointer to a Microsoft (MS) Word
`
`application running on a Windows 95 PC. (Id. at 13:15-27.) Here, a user can open
`
`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
`
`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
`
`memory. As a result, using the mobile interface, the user is able to seamlessly
`
`access MS Word across different computing platforms.
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`The ’002 Patent explains that a mobile interface “can be
`
`32.
`
`accessible using any computer from any geographical location so long as the
`
`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
`33.
`I understand that patent claims are to be given their broadest
`
`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.
`
`34.
`
`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
`
`Decisions.
`
`1. “mobile interface”
`35.
`Independent claims 25, 34, 40, and 49 recite the term “mobile
`
`interface.” I interpret this term to mean “a user interface accessible on different
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`computing devices and capable of dynamically accessing user-specific data on a
`
`network server and local device.”
`
`36.
`
`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.
`
`37.
`
`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.)
`
`38.
`
`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
`
`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
`
`Windows 95 machine but can not 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
`
`Microsoft Word on the Macintosh.” (’002 Patent, 13:21-27.)
`
`39.
`
`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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`40.
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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”
`41.
`Independent claims 25, 34, and 40 recite the term “pointer.” The
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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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`42.
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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
`43.
`I understand that the Board instituted the following grounds of
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`unpatentability based on Richardson (See Decision, p. 38):
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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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`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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`Challenged Claim(s)
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`25, 26, 30, 31, 34-36, 40-43, and
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`47-49
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`28
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`39 and 46
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`32, 37, and 44
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`33, 38, and 45
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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
`44.
`Richardson discloses a Virtual Network Computing (VNC)
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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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`45.
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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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`46.
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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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`The user’s desktop display at the VNC client is merely pixel data.
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`47.
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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 25, 26, 30, 31, 34-36, 40-43,
`and 47-49
`48.
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`Richardson does not disclose the following claim elements:
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`i.
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`“the mobile interface comprising . . . a plurality of pointers that
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`correspond to the user specific resources and information”
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`(independent claim 34);
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`ii.
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`“the mobile interface [that] includes pointers . . . [to] provide links
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`to access the corresponding user specific resources and
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`information” (independent claim 40);
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`iii.
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`“means for accessing the user specific resources and information
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`using the plurality of pointers” (independent claim 25);
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`iv.
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` “user specific resources or information . . . is retrieved”
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`(independent claim 34);
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`“means for retrieving the requested user specific resource or
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`v.
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`information from either the local device or the network server”
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`(independent claim 49);
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`vi.
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`vii.
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`“the mobile interface” (independent claims 25, 34, 40, and 49);
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`“a local device . . . having a local memory . . . wherein the local
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`memory also includes user specific resources and information”
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`(independent claim 40); and
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`viii.
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`“wherein the user specific resources and information comprise . . .
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`bookmarked URLs . . . and user profiles” (dependent claims 26,
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`35, and 41);
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`49.
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`Independent claims 25, 34, 40, and 49 recite these missing
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`elements as follows:
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`A mobile interface used for accessing user specific
`25.
`resources and information stored either on a local