Patent Owner SimpleAir’s Disclosure of Demonstrative Slides
`SIMPLEAIR EXHIBIT 2044
`Google v. SimpleAir
`IPR2015-00180
`
`1
`
`
`SIMPLEAIR EXHIBIT 2044
`Google v. SimpleAir
`IPR2015-00180
`
`1
`
`
`
`If neither Yan or Kane disclose an element:
`
`no argument or evidence that it would have
`been obvious to modify Yan or Kane to fill in
`the element
`
`15 Q When you just reviewed your declaration,
`16 did you identify anyplace where you offered the
`17 opinion that a limitation may be met by modifying
`18 Yan or Kane, if the limitation is deemed to be not
`19 disclosed in Yan or Kane?
`20 A I reviewed my declaration, and I don't see
`21 a specific disclosure to that. And I --
`
`Madisetti (2006) 17:15-21
`
`2
`
`
`
`Office Patent Trial Practice Guide
`77 Fed. Reg. at 48767
`
`3
`
`
`
`Elements Missing from Yan-Kane
`
`1
`
`2
`
`3
`
`4
`
`
`
`a central broadcast server: “one or more servers
`that are configured to receive data from a plurality of
`information sources and process the data prior to its
`transmission to one or more selected remote
`computing devices”
`
`Board’s construction
`
`5
`
`
`
`Convention: separate systems for each information source
`
`Provider
`1
`
`server
`
`Provider
`2
`
`server
`
`Provider
`3
`
`server
`
`Provider
`4
`
`server
`
`6
`
`
`
`Convention: separate systems for each information source
`
`Provider
`1
`
`server
`
`unrebutted
`
`Dr. James Knox
`
`Knox Decl. (2005) ¶ 19
`
`7
`
`
`
`Convention: separate systems for each information source
`
`Provider
`1
`
`server
`
`unrebutted
`
`Dr. James Knox
`
`Knox Decl. (2005) ¶ 20
`
`8
`
`
`
`‘154 patent: central broadcast server
`
`Provider
`1
`
`Provider
`2
`
`Provider
`3
`
`Provider
`4
`
`central
`broadcast
`server
`
`9
`
`
`
`Two independent servers is not a central broadcast server
`
`Provider
`1
`
`server
`
`Provider
`2
`
`server
`
`10
`
`
`
`Two independent servers is not a central broadcast server
`
`11
`
`
`
`Two independent servers is not a central broadcast server
`
`central broadcast server
`
`12
`
`
`
`Petition’s
`Information
`source
`NetNews
`server
`
`Petition’s
`central broadcast
`server
`SIFT
`server
`
`Petition at 23
`
`13
`
`
`
`Petition’s
`Information
`source
`NetNews
`server
`
`Petition’s
`central broadcast
`server
`SIFT
`server
`
`16 For Element A, you've identified as the
`17 information source a Netnews server; is that right?
`18 A As a -- yes, it's the -- the information
`19 source would be a Netnews server that would be on
`20 that particular site, yes.
`
`Madisetti (2006) 33:16-20
`6 Q Is it the case that Yan discloses only one
`7 information source that's connected to the Netnews
`8 SIFT server?
`9 MR. MESSINGER: Objection, form.
`10 THE WITNESS: There is just one Netnews
`11 server that is connected to the Netnews SIFT
`12 server in Yan.
`
`Madisetti (2006) 52:6-12
`
`Pet. 19
`Ex. 2033 at 41
`
`14
`
`
`
`Yan teaches away
`
`NetNews
`server
`
`NetNews
`SIFT
`
`Yan (1042) 181 § 3.3
`
`C.S. Tech
`Reports
`
`Tech. Rep.
`SIFT
`
`15
`
`
`
`Yan teaches away
`
`NetNews
`server
`
`central SIFT
`server
`
`C.S. Tech
`Reports
`
`16
`
`
`
`Yan teaches away
`
`NetNews
`server
`
`NetNews
`SIFT
`
`Dr. James Knox
`
`unrebutted
`
`C.S. Tech
`Reports
`
`Tech. Rep.
`SIFT
`
`Knox Decl. (2005) ¶ 108
`
`Knox Decl. (2005) ¶ 112
`
`17
`
`
`
`Yan teaches away
`
`NetNews
`server
`
`NetNews
`SIFT
`
`19 You mentioned that Yan does not disclose
`20 that the Netnews SIFT server has a connection to the
`21 Technical Report SIFT server; is that right?
`22 MR. MESSINGER: Objection, form.
`23 THE WITNESS: I mentioned that Yan does
`24 not show a connection between the Computer
`25 Science Technical Reports and the Netnews SIFT
`1 server.
`
`Madisetti (2006) 54:19-55:1
`21 Q It's not inherent that they would be on
`22 the same server and -- or would have a connection
`23 between the two, right?
`24 MR. MESSINGER: Objection, scope.
`25 THE WITNESS: I mean, it's possible, but
`1 it's not inherent.
`
`Madisetti (2006) 55:21-56:1
`
`C.S. Tech
`Reports
`
`Tech. Rep.
`SIFT
`
`18
`
`
`
`What Yan taught:
`
`What no one ever did:
`
`19
`
`
`
`central broadcast server coupled to information gateway
`
`20
`
`
`
`Petitioner’s three theories:
`
`1
`
`2
`
`Petition at 29
`
`Petition at 29
`
`3
`
`Petition at 30
`
`21
`
`
`
`“connected via the Internet”
`
`unrebutted Dr. James Knox
`
`Knox Decl. (2005) ¶161
`
`Knox Decl. (2005) ¶164
`
`22
`
`
`
`Ex. 2035 at 58
`
`23
`
`
`
`Internet
`
`Fiber line
`
`ISP Network
`
`ISP Network
`
`PoP
`
`PoP
`
`PSTN
`
`central office
`
`DSL
`
`DSL customer
`
`Connection “via the Internet”
`
`University LAN
`
`
`
`Connection via LAN not via the Internet
`
`unrebutted Dr. James Knox
`
`. . .
`
`Knox Decl. (2005) ¶165
`
`25
`
`
`
`Connection via “intranet” not via the Internet
`
`unrebutted Dr. James Knox
`
`Knox Decl. (2005) ¶ 170
`
`26
`
`
`
`Internet
`
`Fiber line
`
`ISP Network
`
`ISP Network
`
`PoP
`
`PoP
`
`PSTN
`
`central office
`
`DSL
`
`DSL customer
`
`Connection via local area network
`
`University LAN
`
`
`
`“connected via an online service”
`
`unrebutted Dr. James Knox
`
`Knox Decl. (2005) ¶203
`
`28
`
`
`
`Theory 1: Yan access local news host
`
`• Petition does not address
`
`“whether the remote computing devices are or are not
`connected via the Internet or another online service to
`a data channel associated with each computing device
`at the time the addressed data block is received by the
`receivers, wherein the data channel is for accessing
`information from the information source that sent the
`data”
`
`Board’s construction
`
`not expressly disclosed
`and not inherent:
`
`Yan, 181 §3.3 (Ex. 1042)
`
`29
`
`
`
`Not inherent to access local news host “via the Internet or
`another online service”
`
`unrebutted Dr. James Knox
`
`Knox Decl. (2005) ¶ 206
`
`30
`
`
`
`Teaching to “access local news host” teaches to not
`access via the Internet
`
`Dr. James Knox
`
`Knox Decl. (2005) ¶ 207
`
`31
`
`
`
`Theory 1: Yan access local news host
`
`• Petition does not address
`
`“whether the remote computing devices are or are not
`connected via the Internet or another online service to
`a data channel associated with each computing device
`at the time the addressed data block is received by the
`receivers, wherein the data channel is for accessing
`information from the information source that sent the
`data”
`
`Board’s construction
`
`“his own local news host”
`
`SIFT
`Server’s
`News Host
`
`32
`
`
`
`whether the remote computing devices are online or
`offline from a data channel: “A device is not online
`to an associated data channel merely because it is able
`to receive data transmissions (directly or indirectly)
`from the central broadcast server.”
`
`Markman Order (Ex. 3001 at 61-62)
`
`central broadcast server
`
`data channel
`
`transmission
`
`‘154, Fig. 1
`
`33
`
`
`
`Theory 2: Yan user accessing SIFT server
`whether the remote computing devices are online or
`offline from a data channel: “A device is not online
`to an associated data channel merely because it is able
`to receive data transmissions (directly or indirectly)
`from the central broadcast server.”
`
`Petition’s
`central broadcast server
`
`NetNews
`host
`
`SIFT
`server
`
`remote
`computing
`device
`
`34
`
`
`
`Theory 2: Yan user accessing SIFT server
`
`If “data channel” is path from SIFT
`server, then no transmission when
`offline from a data channel
`
`Petition’s
`central broadcast server
`
`NetNews
`host
`
`SIFT
`server
`
`transmission
`
`Yan 180 § 3.2 (ex. 1042)
`
`‘154, Claim 1(c)(iii)
`
`remote
`computing
`device
`
`35
`
`
`
`Theory 2: Yan user accessing SIFT server
`
`If “data channel” is path from SIFT
`server, then no transmission when
`offline from a data channel
`
`Petition’s
`central broadcast server
`
`NetNews
`host
`
`SIFT
`server
`
`transmission
`
`‘154, Claim 1(c)(iii)
`
`remote
`computing
`device
`
`22 Q In Yan, for the SIFT system, when a user's
`23 computing device receives information from the SIFT
`24 server via e-mail, is it online to a data channel
`25 associated with the device?
`1 MR. MESSINGER: Objection, form.
`2 THE WITNESS: Yes, it is. That's one way
`3 it's online.
`
`Madisetti (2006) 148:22-149:3
`
`36
`
`
`
`Theory 3: Kane modem connection via PSTN
`
`Kane Fig. 1 (Ex. 1009 at 20)
`
`37
`
`
`
`Modem connection via PSTN not via the Internet
`
`unrebutted Dr. James Knox
`
`Knox Decl. (2005) ¶ 174
`
`Ex. 2012 at 4
`
`38
`
`
`
`Modem connection via PSTN not via the Internet
`
`unrebutted Dr. James Knox
`
`Knox Decl. (2005) ¶ 177
`
`39
`Knox Decl. (2005) ¶ 180
`
`
`
`Internet
`
`Fiber line
`
`ISP Network
`
`ISP Network
`
`PoP
`
`PoP
`
`PSTN
`
`central office
`
`Connection via PSTN
`
`POTS
`
`University LAN
`
`
`
`Theory 3: Kane modem connection via PSTN
`
`unrebutted Dr. James Knox
`
`Knox Decl. (2005) ¶ 215
`
`41
`
`
`
`“associated with the remote
`computing device”
`
`unrebutted
`
`Dr. James Knox
`
`‘154, Claim 1(c)(iii)
`
`Knox Decl. (2005) ¶ 83
`
`42
`
`
`
`“associated with the remote
`computing device”
`
`unrebutted
`
`Dr. James Knox
`
`‘154, Claim 1(c)(iii)
`
`Knox Decl. (2005) ¶ 84
`
`43
`
`
`
`“associated with the remote
`computing device”
`
`‘154, Claim 1(c)(iii)
`
`‘154, Fig. 24(d)
`
`44
`
`
`
`Yan: nothing on the remote device
`that associates it with a channel to
`the local news host or SIFT
`
`‘154, Claim 1(c)(iii)
`
`unrebutted
`
`Dr. James Knox
`
`Yan, 181 §3.3 (ex. 1042)
`
`Knox Decl. (2005) ¶ 144
`
`45
`
`
`
`Kane: nothing on the remote device
`that associates it with a channel to
`the central terminal
`
`‘154, Claim 1(c)(iii)
`
`Dr. James Knox
`
`Knox Decl. (2005) ¶ 146
`
`Kane Fig. 1 (Ex. 1009 at 20)
`
`46
`
`
`
`to “assign addresses to the data blocks” the
`data blocks must already have been built
`
`Facebook, Inc. v. Software Rights Archive, LLC,
`Case IPR2013-00480 (P.T.A.B. Jan., 29, 2015)
`
`47
`
`
`
`Petition
`
`Petition at 26
`
`asserted address assignment
`
`24 Q It's your view the caller -- the call
`25 receiver address is looked up in block 406; is that
`1 right?
`2 A Yes.
`3 Q And in your view, it's used in block 412;
`4 is that right?
`5 A When you look up, you're assigning -- as I
`6 said, there's a logical assignment when you have
`7 assigned that data block with the subscriber. So
`8 the 406 meets the assignment limitation.
`
`Madisetti (2006) 111:24-112:8
`
`48
`
`
`
`Petition
`
`asserted building of data block
`
`Petition at 26
`
`15 Q With the completion of steps 408 and 410,
`16 would you agree that we have then built the data
`17 block that you've identified in your testimony in
`18 paragraph 103?
`19 A Yes, those are the steps that you would
`20 build the data block. Yes.
`
`Madisetti (2006) 119:15-20
`
`49
`
`
`
`Petition
`
`asserted address assignment
`
`asserted building of data block
`
`Kane (1009) 11:35-12:5
`
`50
`
`
`
`The same “data block” must be built, addressed, and transmitted
`
`2
`
`51
`
`
`
`The asserted “data block” is not transmitted
`
`Asserted data block
`
`Petition at 26
`
`Kane (1009) Fig. 2
`
`52
`
`
`
`The asserted “data block” is not transmitted
`
`Asserted data block
`
`21 Q You say, "To build a data block, the
`22 central terminal 102 adds 'message ID information
`23 208' and 'time tag information 210' to the message,"
`24 which includes 212, 214 and 216; is that right?
`25 A That's right.
`1 Q The data block when it's built, then, is
`2 going to consist of items 208, 210, 212, 214 and
`3 216?
`4 A Yes.
`
`Madisetti (2006) 114:21-115:4
`
`Kane (1009) Fig. 2
`
`53
`
`
`
`The asserted “data block” is not transmitted
`
`Asserted data block
`
`Dr. James Knox
`
`Knox Decl. (2005) ¶ 130
`
`Kane (1009) Fig. 2
`
`54
`
`
`
`The asserted “data block” is not transmitted
`
`Asserted data block
`
`7 Q When the message is sent to the -- from
`8 the central unit to the remote call receiver, before
`9 we've got a reply --
`10 A Before you've got a reply, okay.
`11 Q -- when it's sent there, it does not
`12 include with it the X.400 originator identification
`13 212; is that correct?
`14 A That's right. It includes this other
`15 information that can be used to reverse it.
`16 Q It includes the originator alias rather
`17 than the originator identification 212?
`18 A Yes.
`
`Madisetti (2006) 122:7-18
`
`Kane (1009) Fig. 2
`
`55
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