UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICROSOFT CORPORATION and
`INTERNATIONAL BUSINESS MACHINES CORPORATION,
`Petitioners,
`v.
`PARALLEL NETWORKS LICENSING, LLC,
`Patent Owner.
`
`Oral Hearing
`
`IPR2015-00483
`IPR2015-00485
`
`1
`
`Microsoft and IBM v. Parallel Networks, IPR2015-00483 & IPR2015-00485
`PN EXHIBIT 2109
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICROSOFT CORPORATION and
`INTERNATIONAL BUSINESS MACHINES CORPORATION,
`Petitioners,
`v.
`PARALLEL NETWORKS LICENSING, LLC,
`Patent Owner.
`
`Oral Hearing
`
`IPR2015-00483
`IPR2015-00485
`
`1
`
`Microsoft and IBM v. Parallel Networks, IPR2015-00483 & IPR2015-00485
`PN EXHIBIT 2109
`
`
`
`“Dynamic Web Page
`Generation Request”
`
`2
`
`
`
`Request
`
`3
`
`Exhibit 1009, p. 8
`PO Response, p. 8, 51
`
`
`
`Request
`
`4
`
`Exhibit 1009, p. 10
`PO Response, p. 22, 25, 26 et al.
`
`
`
`Request
`
`5
`
`Petitioner’s Reply, p. 11
`
`
`
`
`
`Figure 6Figure 6
`
`6
`
`Exhibit 1009, p. 11
`PO Response, p. 18, 24-26 et al.
`
`
`
`Request
`
`1007 at 1] 203. SWEB 95 discloses that users may request Web pages that require
`
`execution of a Common Gateway Interface (CGI) program that dynamically
`
`generates Web pages. In that case, the returned Web page is the output generated
`
`by executing the CGI program. EX. 1007 at1l1[ 198-205; EX. 1009 at 5. SWEB 95
`
`therefore discloses this claim element.
`
`7
`
`Petition, p. 25
`
`
`
`Request
`
`8
`
`483 Exhibit 1007, ¶ 201
`Petition, p. 25
`
`
`
`Request
`
`9
`
`Petitioner’s Reply, p. 4
`
`
`
`
`
`RequestRequest
`
`15 Q. And so if the client wanted to make
`16 another request after that connection is closed, it
`17 would then have to go through the same process we
`18 just discussed of looking up the DNS name of the
`19 server, opening the connection, sending the
`20 request, correct?
`21 A. So let me just to be clear. If the
`22 connection was terminated and -- then they would
`23 certainly have to reestablish a new connection. It
`24 may or may not have to do all the steps that you
`25 suggested. I believe it's possible under certain
`(cont.)
`
`10
`
`Ex. 2086, p. 104:15-25
`PO Response, p. 25
`
`
`
`
`
`RequestRequest
`
`2 circumstances to cache DNS entries, so it may or
`3 may not have to go to the domain name system again.
`4 But other than that, I would agree that once a
`5 connection is closed, you would have to reopen the
`6 connection to make another request of that server.
`7 Q. So the normal process of making an HTTP
`8 request would involve first opening a connection to
`9 the server that the request is going to be sent to,
`10 correct?
`11 A. Yes.
`12 Q. A TCP/IP connection to be precise?
`13 A. Yes.
`14 Q. Sending the request, right?
`15 A. Yes.
`16 Q. The connection stays open and, ultimately,
`17 a response is returned, right?
`18 A. Yes.
`19 Q. And then eventually the connection will be
`20 closed, correct?
`21 A. I would say that those are typical steps
`22 in an HTTP transaction.
`
`Ex. 2086, p. 105:2-22
`PO Response, p. 25, 33
`
`11
`
`
`
`
`
`RequestRequest
`
`2 Q. What is your understanding of how URL
`3 redirection works?
`4 A. So again, probably best to use the
`5 description in the appropriate context, so looking
`6 at how it's used within the paper itself. So in so
`7 doing, the typical approach for redirection is that
`8 a client after making a request would receive sort
`9 of what it refers to as a rewritten, or you can
`10 think of as an alternative URL, where the
`11 information is located as a response that
`12 suggests I do not have the exact information you
`13 are seeking but I can give you the location where
`14 it is, as described, I guess, on page 10 of the
`15 SWEB paper.
`
`12
`
`Ex. 2086, p. 106:2-15
`PO Response, p. 29
`
`
`
`
`
`RequestRequest
`
`14 Q. So then let's talk about the next
`15 connection that the client needs to make. Assuming
`16 that the browser on the client has been configured
`17 to respond to the redirection response code from
`18 the browser, okay?
`19 A. Okay.
`20 Q. The first thing that would have to be
`21 done, just like the original request, would be a
`22 lookup if it's not cached through DNS of the IP
`23 address of the new server, correct?
`24 A. Yes.
`25 Q. And then once the IP address is either
`***
`2 found in cache or received from the DNS server, a
`3 TCP/IP connection would have to be opened to this
`4 new server, correct?
`5 A. That would be my understanding.
`
`Ex. 2086, p. 109:14-110:5
`PO Response, p. 25
`
`13
`
`
`
`
`
`RequestRequest
`
`6 Q. Next, the new request needs to get sent to
`7 the new server, right?
`8 A. That would be my understanding, yes.
`
`14
`
`Ex. 2086, p. 110:6-8
`PO Response, p. 25
`
`
`
`
`
`RequestRequest
`
`22 Q. Okay. You agree that there are two
`23 messages that the client sends out, correct, as
`24 represented in Figure 6 of SWEB 95?
`25 A. That I believe I could agree with.
`
`15
`
`Ex. 2086, p. 132:22-25
`PO Response, p. 25 n. 9
`
`
`
`
`
`RequestRequest
`
`15 Q. My question is in Figure 6, Figure 7, and
`16 in the discussion in 4.3, does SWEB 95 teach that
`17 in the URL redirection embodiment two HTTP
`18 formatted requests are sent?
`19 A. I believe with the explanation that I gave
`20 with the previous question or the clarification I
`21 gave with the previous question, that I could agree
`22 with that part of the statement.
`
`16
`
`Ex. 2086, p. 167:15-22
`PO Response, p. 24
`
`
`
`
`
`RequestRequest
`
`15 Q. So the request at some point has to get
`16 from the mind of the user into some concrete form,
`17 fair?
`18 A. There are various ways, but yes, the
`19 request for a specific piece of information must be
`20 formatted in some way and there are protocols that
`21 do that to allow actions to be taken on the
`22 request.
`23 Q. In the context of SWEB95, HTTP is the
`24 context for sending and receiving and processing
`25 requests, correct?
`2 A. Yes. I'd agree that their implementation
`3 utilizes HTTP to manage the requests in the various
`4 ways that we've been describing.
`
`Exhibit 2107, p. 63:15-64:4
`PO Motion for Observations,
`Observation No. 9
`
`17
`
`
`
`
`
`RequestRequest
`
`7 Q. Would you agree in the HTTP protocol that
`8 an HTTP request is a message?
`9 A. I agree that an HTTP request, yes, could
`10 be a message or typically would be a message of
`11 some kind.
`
`18
`
`Exhibit 2107, p. 75:7-11
`PO Motion for Observations,
`Observation No. 3
`
`
`
`
`
`RequestRequest
`
`24 So if you go back to Figure 6 of SWEB
`25 Exhibit 1009, you agree that there is in Figure 6
`2 two HTTP requests that necessarily must be made by
`3 the client, right?
`4 A. There are two HTTP requests: One sent to
`5 S0 and S1.
`6 Q. And one of the HTTP requests is sent to
`7 S0, one is sent to S1, correct?
`8 A. Let me clarify that. There are two HTTP
`9 requests in the forms of those messages. But
`10 again, they correspond to the same request from the
`11 client. The redirection simply forwards the
`12 original HTTP request with a rewritten URL.
`
`19
`
`Exhibit 2107, p. 141:24-142:12
`PO Motion for Observations,
`Observation No. 8
`
`
`
`No Obviousness
`No Obviousness
`
`20
`
`
`
`Patent Architecture
`
`Page Server
`
`Client
`
`Web Server
`
`Page Server
`
`Page Server
`
`21
`
`
`
``554, Figure 4
`
`22
`
`Exhibit 1001, Figure 4
`PO Response, p. 3-4
`
`
`
`Prior Art Architecture
`
`Client
`
`Web Server
`
`Web Server
`
`23
`
`
`
`Prior Art Architecture
`
`Client
`
`Page Server
`
`Page Server
`
`Page Server
`
`24
`
`
`
`Prior Art Architecture
`
`25
`
`Exhibit 1001, Figure 3
`
`
`
`Prior Art Architecture
`
`Client
`
`Web Server
`
`Web Server
`
`26
`
`
`
`
`
`’554 Patent, Claim 12’554 Patent, Claim 12
`
`27
`
`Exhibit 1001, Claim 12
`
`
`
`
`
`‘554 Patent, Figure 4‘554 Patent, Figure 4
`
`28
`
`Exhibit 1001, Figure 4
`
`
`
`
`
`’335 Patent, Claim 43’335 Patent, Claim 43
`
`29
`
`Exhibit 2007, Claim 43
`
`
`
`
`
`SWEB, Figure 6SWEB, Figure 6
`
`Figure 6: The URL redirection
`
`Exhibit 1009, Figure 6
`PO Response, p. 18, 24-26 et al.
`
`30
`
`
`
`
`
`SWEB, Figure 6SWEB, Figure 6
`
`https://www.youtube.com/watch?v=
`oV0wDDFV0NY
`
`Figure 6: The URL redirection
`
`Exhibit 1009, Figure 6
`PO Response, p. 18, 24-26 et al.
`
`31
`
`
`
`
`
`SWEBSWEB
`
`32
`
`Exhibit 1009, p. 8
`PO Response, p. 2, 51
`
`
`
`“Routing”
`
`“Routing”
`“Transferring”
`
`“Transferring”
`
`33
`
`
`
`
`
`RoutingRouting
`
`34
`
`Patent Owner’s Response, p. 16
`
`
`
`
`
`RoutingRouting
`
`35
`
`483 Exhibit 1007, p. 77
`Petition, p. 16-17
`
`
`
`
`
`RoutingRouting
`
`Exhibit 1009, Figure 6
`PO Response, p. 18, 24-26 et al.
`
`Figure 6: The URL redirection
`
`36
`
`Exhibit 1009, p. 10
`PO Response, p. 22, 25, 26 et al.
`
`
`
`
`
`RoutingRouting
`
`37
`
`Exhibit 1009, p. 10
`PO Response, p. 22, 25, 26 et al.
`
`
`
`No Obviousness
`No Obviousness
`
`38
`
`
`
`“Releasing”
`“Releasing”
`
`39
`
`
`
`
`
`ReleasingReleasing
`
`40
`
`Exhibit 1009, p. 5
`PO Response, p. 24, 25 n.8, 28 et al.
`
`
`
`
`
`ReleasingReleasing
`
`7 Q. So the normal process of making an HTTP
`8 request would involve first opening a connection to
`9 the server that the request is going to be sent to,
`10 correct?
`11 A. Yes.
`12 Q. A TCP/IP connection to be precise?
`13 A. Yes.
`14 Q. Sending the request, right?
`15 A. Yes.
`16 Q. The connection stays open and, ultimately,
`17 a response is returned, right?
`18 A. Yes.
`19 Q. And then eventually the connection will be
`20 closed, correct?
`21 A. I would say that those are typical steps
`22 in an HTTP transaction.
`Exhibit 2086, p. 105:7-22
`PO Response, p. 25, 33
`
`41
`
`
`
`“Connection Cache”
`“Connection Cache”
`
`42
`
`
`
`
`
`Connection CacheConnection Cache
`
`43
`
`Patent Owner’s Response, p. 17
`
`
`
`
`
`Connection CacheConnection Cache
`
`44
`
`Petition, p. 18-19
`
`
`
`
`
`Connection CacheConnection Cache
`
`45
`
`483 Exhibit 1007, ¶158
`
`
`
`
`
`Connection CacheConnection Cache
`
`46
`
`Exhibit 1001, 6:59-65
`PO Response, p. 17
`
`
`
`
`
`’554 Patent, Claim 12, 15’554 Patent, Claim 12, 15
`
`47
`
`Exhibit 1001, Claim 12, 15
`
`
`
`
`
`Connection CacheConnection Cache
`
`48
`
`Exhibit 1009, p. 6
`PO Response, p. 33-34, 44
`
`
`
`
`
`Connection CacheConnection Cache
`
`49
`
`Petition, p. 34
`
`
`
`
`
`Connection CacheConnection Cache
`
`50
`
`Exhibit 1017, p. 12
`Petition, p. 34
`
`
`
`
`
`Connection CacheConnection Cache
`
`51
`
`Exhibit 1058, 7:42-59
`Petitioner Reply, p. 15
`
`
`
`
`
`Connection CacheConnection Cache
`
`52
`
`Exhibit 1059 at Section 2.1
`Petitioner Reply, p. 15
`
`
`
`
`
`Connection CacheConnection Cache
`
`53
`
`Exhibit 1017, p. 473
`Petitioner Reply, p. 15
`
`
`
`
`
`Connection CacheConnection Cache
`
`54
`
`Exhibit 1060, 6:49-61
`PO Response, p. 44-46
`
`
`
`“Page Cache”
`“Page Cache”
`
`55
`
`
`
`
`
`Page CachePage Cache
`
`56
`
`Exhibit 1009, p. 3
`PO Response, p. 46-47
`
`
`
`
`
`’554 Patent, Claim 12, 17’554 Patent, Claim 12, 17
`
`57
`
`Exhibit 1001, Claim 12, 17
`
`
`
`
`
`Page CachePage Cache
`
`58
`
`Exhibit 1009, p. 13
`PO Response, p. 34-35, 46-47
`
`
`
`
`
`Page CachePage Cache
`
`59
`
`Exhibit 1009, p. 6
`PO Response, p. 34-35, 46-47
`
`
`
`
`
`Page CachePage Cache
`
`60
`
`Exhibit 1048, Fig. 1
`PO Response, p. 20-21
`
`
`
`
`
`’554 Patent, Claim 12, 29’554 Patent, Claim 12, 29
`
`61
`
`Exhibit 1001, Claim 12, 29
`
`
`
`
`
`’554 Patent, Claim 20, 49’554 Patent, Claim 20, 49
`
`62
`
`Exhibit 1001, Claim 20, 49
`
`
`
`“Consists of”
`“Consists of”
`
`63
`
`
`
`
`
`’554 Patent, Claim 12, 21’554 Patent, Claim 12, 21
`
`64
`
`Exhibit 1001, Claim 12, 21
`
`
`
`“Web requests”
`“Web requests”
`
`65
`
`
`
`
`
`’554 Patent, Claim 12, 22-23’554 Patent, Claim 12, 22-23
`
`66
`
`Exhibit 1001, Claim 12, 22-23
`
`
`
`“Logging into . . . data source”
`
`67
`
`
`
`
`
`’554 Patent, Claim 12, 14’554 Patent, Claim 12, 14
`
`68
`
`Exhibit 1001, Claim 12, 14
`
`
`
`
`
`’554 Patent, Claim 14, 16’554 Patent, Claim 14, 16
`
`69
`
`Exhibit 1001, Claim 14, 16
`
`
`
`
`
`Logging IntoLogging Into
`
`70
`
`Exhibit 1001, 7:15-19
`PO Response, p. 34
`
`
`
`
`
`Logging IntoLogging Into
`
`71
`
`Exhibit 1009, p. 6
`PO Response, p. 34
`
`
`
`
`
`Logging IntoLogging Into
`
`72
`
`Exhibit 1042, p. 8
`Petition, p. 34-35
`PO Response, p. 34
`
`
`
`“Custom HTML Extension
`Templates”
`
`“Tag-based Text Templates”
`
`73
`
`
`
`
`
`’554 Patent, Claim 12, 14’554 Patent, Claim 12, 14
`
`74
`
`Exhibit 1001, Claim 12, 14
`
`
`
`
`
`’554 Patent, Claim 14, 18-19’554 Patent, Claim 14, 18-19
`
`75
`
`Exhibit 1001, Claim 14, 18-19
`
`
`
`
`
`custom HTML extension templatecustom HTML extension template
`
`76
`
`Exhibit 1001, 6:33-49
`PO Response, p. 39-40
`
`
`
`
`
`custom HTML extension templatecustom HTML extension template
`
`77
`
`Exhibit 1009, p. 1
`PO Response, p. 39
`
`
`
`
`
`custom HTML extension templatecustom HTML extension template
`
`78
`
`Exhibit 1013, 3:39-42
`PO Response, p. 39-40
`
`
`
`
`
`custom HTML extension templatecustom HTML extension template
`
`79
`
`Exhibit 1060, 8:51-59
`PO Response, p. 39-40
`
`
`
`
`
`custom HTML extension templatecustom HTML extension template
`
`80
`
`Exhibit 1060, 9:43-65
`PO Response, p. 39-40
`
`
`
`Page Server-Specific
`Dynamic Information
`
`81
`
`
`
`
`
`’554 Patent, Claim 12’554 Patent, Claim 12
`
`82
`
`Exhibit 1001, Claim 12
`
`
`
`
`
`’554 Patent, Claim 12’554 Patent, Claim 12
`
`83
`
`Exhibit 1001, Claim 32
`
`
`
`
`
`’554 Patent, Claim 34’554 Patent, Claim 34
`
`84
`
`Exhibit 1001, Claim 34
`
`
`
`
`
`SWEBSWEB
`
`85
`
`Exhibit 1009, p. 12
`PO Response, p. 31-32
`Petitioner Reply, p. 12
`
`
`
`
`
`SWEBSWEB
`
`86
`
`Exhibit 1009, p. 13
`PO Response, p. 31-32
`Petitioner Reply, p. 12
`
`
`
`Secondary Considerations
`
`87
`
`
`
`
`
`Secondary ConsiderationsSecondary Considerations
`
`88
`
`Exhibit 2086, p. 172:17-20
`PO Response, p. 53 n.20
`
`
`
`
`
`iXpressiXpress
`
`89
`
`Exhibit 2065, p. 11
`PO Response, p. 54
`
`
`
`
`
`Secondary ConsiderationsSecondary Considerations
`
`90
`
`Exhibit 2072, p. 1
`PO Response, p. 57
`
`
`
`
`
`Secondary ConsiderationsSecondary Considerations
`
`91
`
`Exhibit 2031, p. 1
`PO Response, p. 54, 57
`
`
`
`
`
`Secondary ConsiderationsSecondary Considerations
`
`92
`
`Exhibit 2031, p. 52
`PO Response, p. 54, 57
`
`
`
`
`
`Secondary ConsiderationsSecondary Considerations
`
`93
`
`Exhibit 2032, p. 1
`PO Response, p. 9-10, 54, 55, 57
`
`
`
`
`
`Secondary ConsiderationsSecondary Considerations
`
`94
`
`Exhibit 2032, p. 15
`PO Response, p. 9-10, 54, 55, 57
`
`
`
`
`
`Secondary ConsiderationsSecondary Considerations
`
`95
`
`Exhibit 2032, p. 24
`PO Response, p. 9-10, 54, 55, 57
`
`
`
`
`
`Secondary ConsiderationsSecondary Considerations
`
`96
`
`Exhibit 2075, p. 1
`PO Response, p. 57
`
`
`
`
`
`Secondary ConsiderationsSecondary Considerations
`
`97
`
`Exhibit 2075, p. 7
`PO Response, p. 57
`
`
`
`Conception and
`Reduction to Practice
`
`98
`
`
`
`
`
`Conception DateConception Date
`
`99
`
`Exhibit 2016
`PO Response, p. 6, 10, 11
`
`
`
`
`
`Conception DateConception Date
`
`100
`
`Exhibit 2018, p. 1
`PO Response, p. 6, 11
`
`
`
`
`
`Conception DateConception Date
`
`101
`
`Exhibit 2018, p. 2
`PO Response, p. 6, 11
`
`
`
`
`
`Conception DateConception Date
`
`102
`
`Exhibit 2019
`PO Response, p. 6
`
`
`
`
`
`Conception DateConception Date
`
`103
`
`Exhibit 2019
`PO Response, p. 6
`
`
`
`
`
`Conception DateConception Date
`
`104
`
`Exhibit 2019
`PO Response, p. 6
`
`
`
`
`
`Conception DateConception Date
`
`105
`
`Exhibit 2100, p.1
`PO Response, p. 6, 9, 10, 11, 49
`
`
`
`
`
`Conception DateConception Date
`
`106
`
`Exhibit 2100, p. 11
`PO Response, p. 6, 9, 10, 11, 49
`
`
`
`
`
`Conception DateConception Date
`
`107
`
`Exhibit 2100, p. 6
`PO Response, p. 6, 9, 10, 11, 49
`
`
`
`
`
`Conception DateConception Date
`
`108
`
`Exhibit 2100, p.19
`PO Response, p. 6, 9, 10, 11, 49
`
`
`
`
`
`Conception DateConception Date
`
`109
`
`Exhibit 2015, p. 1
`PO Response, p. 7-9, 11-12, 49
`
`
`
`
`
`Conception DateConception Date
`
`110
`
`Exhibit 2015, p. 3
`PO Response, p. 7-9, 11-12, 49
`
`
`
`
`
`Conception DateConception Date
`
`111
`
`Exhibit 2015, p. 3
`PO Response, p. 7-9, 11-12, 49
`
`
`
`
`
`Conception DateConception Date
`
`112
`
`Exhibit 2015, p. 4
`PO Response, p. 7-9, 11-12, 49
`
`
`
`
`
`Conception DateConception Date
`
`113
`
`Exhibit 2015, p. 5
`PO Response, p. 7-9, 11-12, 49
`
`
`
`
`
`Conception DateConception Date
`
`114
`
`Exhibit 2015, p. 6
`PO Response, p. 7-9, 11-12, 49
`
`
`
`
`
`Conception DateConception Date
`
`115
`
`Exhibit 2099, p. 6
`PO Response, p. 9
`
`
`
`
`
`Conception DateConception Date
`
`116
`
`Exhibit 2099, p. 6
`PO Response, p. 9
`
`
`
`
`
`Conception DateConception Date
`
`117
`
`Exhibit 2099, p. 6
`PO Response, p. 9
`
`
`
`
`
`Conception DateConception Date
`
`118
`
`Exhibit 2099, p. 6
`PO Response, p. 9
`
`
`
`
`
`Conception DateConception Date
`
`119
`
`Exhibit 2099, p. 6
`PO Response, p. 9
`
`
`
`
`
`Conception DateConception Date
`
`120
`
`Exhibit 2022, p. 1
`PO Response, p. 10
`
`
`
`
`
`Conception DateConception Date
`
`121
`
`Exhibit 2022, p. 1
`PO Response, p. 10
`
`
`
`
`
`Conception DateConception Date
`
`122
`
`Exhibit 2022, p. 1
`PO Response, p. 10
`
`
`
`
`
`’554 Patent’554 Patent
`
`123
`
``554 Patent, Exhibit 1001
`
`
`
`
`
`’554 Patent, Claim 20’554 Patent, Claim 20
`
`124
`
``554 Patent, Claim 20
`
`
`
`
`
`’554 Patent, Claim 32’554 Patent, Claim 32
`
`125
`
``554 Patent, Claim 32
`
`
`
`
`
`’554 Patent, Claim 34’554 Patent, Claim 34
`
`126
`
``554 Patent, Claim 34
`
`
`
`
`
`’554 Patent, Claim 46’554 Patent, Claim 46
`
`127
`
``554 Patent, Claim 46
`
`
`
`
`
`’554 Patent, Claim 48’554 Patent, Claim 48
`
`128
`
``554 Patent, Claim 48
`
`
`
`
`
`’554 Patent, Figure 4’554 Patent, Figure 4
`
`129
`
``554 Patent, Figure 4
`
`
`
``335 Patent
`‘335 Patent
`
`130
`
`
`
`
`
`’335 Patent’335 Patent
`
`131
`
``335 Patent, Exhibit 1004
`
`
`
`
`
`’335 Patent, Claim 30’335 Patent, Claim 30
`
`132
`
``335 Patent, Claim 30
`
`
`
`
`
`’335 Patent, Claim 43’335 Patent, Claim 43
`
`133
`
``335 Patent, Claim 43
`
`
`
`Prior Art
`
`134
`
`
`
`
`
`Exhibit 1009, Figure 1Exhibit 1009, Figure 1
`
`Figure 1: A simple HTTP transaction. Client
`C looks up the address of server S, sends
`over request r and receives response f.
`
`Exhibit 1009, Figure 1
`PO Response, p. 24, 25 n.8, 28
`
`135
`
`
`
`
`
`Exhibit 1009, Figure 4Exhibit 1009, Figure 4
`
`Figure 4: DNS Rotation. The DNS server
`returns differing IP addresses for a given
`name in Round-robin fashion from a list of
`servers.
`
`Exhibit 1009, Figure 4
`PO Response, p. 24
`
`136
`
`
`
`
`
`Deposition of Michael MitzenmacherDeposition of Michael Mitzenmacher
`
`6 at how it's used within the paper itself. So in so
`7 doing, the typical approach for redirection is that
`8 a client after making a request would receive sort
`9 of what it refers to as a rewritten, or you can
`10 think of as an alternative URL, where the
`11 information is located as a response that
`12 suggests I do not have the exact information you
`13 are seeking but I can give you the location where
`14 it is, as described, I guess, on page 10 of the
`15 SWEB paper.
`16 Q. Okay. And so the client receives this
`17 response from the original server it sent the
`18 request to. How does the client then go about
`19 making the follow-up request for additional
`20 information?
`21 A. It would, in that case, create a
`22 connection with the corresponding machine and
`send
`23 the corresponding request as provided by the
`24 redirection.
`
`August 8, 2015
`
`Ex. 2086, p. 106:6-24
`PO Response, p. 25, 29
`
`137
`
`
`
`
`
`Deposition of Michael MitzenmacherDeposition of Michael Mitzenmacher
`
`14 Q. So then let's talk about the next
`15 connection that the client needs to make. Assuming
`16 that the browser on the client has been configured
`17 to respond to the redirection response code from
`18 the browser, okay?
`19 A. Okay.
`20 Q. The first thing that would have to be
`21 done, just like the original request, would be a
`22 lookup if it's not cached through DNS of the IP
`23 address of the new server, correct?
`24 A. Yes.
`25 Q. And then once the IP address is either
`2 found in cache or received from the DNS server, a
`3 TCP/IP connection would have to be opened to this
`4 new server, correct?
`5 A. That would be my understanding.
`
`Ex. 2086, p. 109:14-110:5
`PO Response, p. 25
`
`August 8, 2015
`
`138
`
`
`
`
`
`Deposition of Michael MitzenmacherDeposition of Michael Mitzenmacher
`
`6 Q. Next, the new request needs to get sent to
`7 the new server, right?
`8 A. That would be my understanding, yes.
`
`August 8, 2015
`
`139
`
`Ex. 2086, p. 110:6-8
`PO Response, p. 25
`
`
`
`
`
`Deposition of Michael MitzenmacherDeposition of Michael Mitzenmacher
`
`22 Q. Okay. You agree that there are two
`23 messages that the client sends out, correct, as
`24 represented in Figure 6 of SWEB 95?
`25 A. That I believe I could agree with.
`
`August 8, 2015
`
`140
`
`Ex. 2086, p. 132:22-25
`PO Response, p. 25 n. 9.
`
`
`
`Leaf is notprior art
`
`141
`
`
`
`
`
`Leaf is notprior artLeaf is notprior art
`
`• As can be seen in the table below, there is corroborating
`evidence supporting the conception of each limitation of
`Claim 12 of the ’554 patent by at least March 1, 1996.
`
`Claim 12 of the ’554 patent
`
`Support before March 1, 1996
`
`A computer implemented method for
`managing a dynamic Web page
`generation request to a Web server,
`said computer implemented method
`comprising the steps of:
`
`“The HTML engine can manage the
`process of retrieving data for dynamic
`HTML content….An additional piece of
`internet technology currently owned
`by the company is a multi-threaded
`NT-based web server.” Ex. 2016.
`
`142
`
`PO Response, p. 10
`
`
`
`
`
`Leaf is notprior artLeaf is notprior art
`
`• As can be seen in the table below, there is corroborating
`evidence supporting the conception of each limitation of
`Claim 12 of the ’554 patent by at least March 1, 1996.
`
`Claim 12 of the ’554 patent
`
`Support before March 1, 1996
`
`routing said request from said Web server
`to a selected page server, said selected page
`server receiving said request and releasing
`said Web server to process other requests,
`wherein said routing step further includes
`the steps of intercepting said request at said
`Web server, routing said request from said
`Web server to a dispatcher, and dispatching,
`by said dispatcher, said request to said
`selected page server;
`
`“The page server will provide page
`caching, logging, connection caching, and
`utilize either web server security or
`database security.” Ex. 2022.
`
`“Virtuoso Page server Feature Complete –
`January 31, 1996” Ex. 2100 at 19.
`
`“Virtuoso intercepts handling of request. . .
`connects to dispatcher . . . sends request to
`dispatcher . . . dispatcher sends request to
`appropriate page server.” Ex. 2015 at 6.
`
`143
`
`PO Response, p. 10-11
`
`
`
`
`
`Leaf is notprior artLeaf is notprior art
`
`• As can be seen in the table below, there is corroborating
`evidence supporting the conception of each limitation of
`Claim 12 of the ’554 patent by at least March 1, 1996.
`Claim 12 of the ’554 patent
`Support before March 1, 1996
`
`processing said request, said processing being
`performed by said selected page server while said
`Web server concurrently processes said other
`requests; and
`
`“Page Server Performance” from “Multithreading
`support” Ex. 2100 at 26.
`
`“An additional piece of internet technology
`currently owned by the company is a
`multithreaded NT-based web server.” Ex. 2016.
`
`“Scalability is achieved within Virtuoso by
`providing the ability to ‘plug and play’ multiple
`page servers to service any web site. In addition to
`providing a feature set that lets a web site
`developer dilute and manage the overhead that
`occurs against the backend, the page server will
`cooperate with other page servers within a multi-
`server environment . . . ” Ex. 2015 at 5.
`
`“Page Server Produces HTML Document” Id. at 6.
`PO Response, p. 11
`
`144
`
`
`
`
`
`Leaf is notprior artLeaf is notprior art
`
`• As can be seen in the table below, there is corroborating
`evidence supporting the conception of each limitation of
`Claim 12 of the ’554 patent by at least March 1, 1996.
`Claim 12 of the ’554 patent
`Support before March 1, 1996
`
`dynamically generating a Web page by said
`selected page server in response to said request,
`said Web page including data dynamically
`retrieved from one or more data sources; and
`
`The infoSpinner product is described as using
`“HTML template technology to produce web pages
`dynamically.” Ex. 2018 at 5.
`
`“[T]he HTML engine can manage the process of
`retrieving data for dynamic HTML content.” Ex.
`2016.
`
`“The Virtuoso Page Server exists as an extension
`to the major commercial web servers and utilizes
`Virtuoso web libraries and data sources to
`dynamically generate pages in response to
`requests from web clients.” Ex. 2015 at 3.
`
`“The page server, in its running state, has available
`a cache of connections to numerous databases.”
`Id. at 4.
`
`PO Response, p. 11
`
`145
`
`
`
`
`
`Leaf is notprior artLeaf is notprior art
`
`• As can be seen in the table below, there is corroborating
`evidence supporting the conception of each limitation of
`Claim 12 of the ’554 patent by at least March 1, 1996.
`Claim 12 of the ’554 patent
`Support before March 1, 1996
`
`wherein dispatching includes: examining said
`request to make a selection of which page server
`should process said request from among a
`plurality of page servers that can each generate
`said Web page requested by said request;
`selecting one of said plurality of page servers to
`dynamically generate said Web page; wherein
`said selection is based on examining dynamic
`information regarding a load associated with each
`of said plurality of page servers; and sending said
`request to said selected page server based on said
`examination.
`
`“Load balancing between page servers.” Ex. 2096.
`
`“Scalability is achieved within Virtuoso by
`providing the ability to ‘plug and play’ multiple
`page servers to service any web site. In addition to
`providing a feature set that lets a web site
`developer dilute and manage the overhead that
`occurs against the backend, the page server will
`cooperate with other page servers within a multi-
`server environment and actually load-balance
`across multiple page servers to assign client
`requests to be serviced by the page server with
`the most available cycles.” Ex. 2015 at 5.
`
`146
`
`“Dispatcher determines which page servers can
`handle request . . . determines which page server
`is processing fewest requests . . . [and] sends
`request to appropriate page server.” Id. at 6.
`PO Response, p. 12
`
`
`
`
`
`Leaf is notprior artLeaf is notprior art
`
`147
`
`PO Response, p. 49-50
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