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`trials@uspto.gov
`IPR2015-00662, Paper No. 39
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`April 21, 2016
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`571-272-7822
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
`GOOGLE INC.,
`Petitioner,
`v.
`AT HOME BONDHOLDERS' LIQUIDATING TRUST,
`Patent Owner.
`__________
`Case IPR2015-00657 (Patent 6,286,045 B1)
`Case IPR2015-00662 (Patent 6,014,698)
`__________
`
`Hearing Held: April 7, 2016
`__________
`
`
`
`BEFORE MIRIAM L. QUINN, KARL D. EASTHOM (via
`videoconference), and JUSTIN T. ARBES (via videoconference),
`Administrative Patent Judges.
`
`
`
`Oral Argument Hearing held on Thursday, April 7, 2016, at
`12:32 p.m., in Hearing Room 155, taken at the Terminal Annex Federal
`Building, 207 S. Houston Street, Dallas, Texas.
`
`REPORTED BY BETH HOWARD, CSR
`
`
`
`A P P E A R A N C E S:
`
`ON BEHALF OF THE PETITIONER:
`MICHELLE K. HOLOUBEK, ESQ.
`ZHU HE, ESQ.
`MICHAEL V. MESSINGER, ESQ.
`Sterne Kessler Goldstein Fox
`1100 New York Avenue, NW
`Washington, DC 20005
`202.371.2600 - Fax 202.371.2600
`holoubek@skgf.com
`zhe@skgf.com
`
`MATTHIAS A. KAMBER, ESQ.
`Keker & Van Nest, LLP
`633 Battery Street
`San Francisco, California 94111
`415.391.5400
`mkamber@kvn.com
`
`ON BEHALF OF THE PETITIONER:
`EMILY O'BRIEN, ESQ.
`Patent Litigation Counsel
`Google, Inc.
`1600 Amphitheater Parkway
`Mountain View, California 94043
`650.253.0000
`emilyobrien@google.com
`
`
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`
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`APPEARANCES: (Continued)
`
`ON BEHALF OF THE PATENT OWNER:
`
`GARLAND STEPHENS, ESQ.
`JUSTIN L. CONSTANT, ESQ.
`Weil, Gotshal & Manges LLP
`700 Louisiana, Suite 1700
`Houston, Texas 77002-2755
`713.546.5011 - Fax 713.224.9511
`garland.stephens@weil.com
`justin.constant@weil.com
`
`ALSO PRESENT:
`Mr. Thomas Todd
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`P R O C E E D I N G S
`
`(12:32 p.m.)
`JUDGE QUINN: So we are gathered here
`today to hear the oral arguments of IPRs 2015- 660 and
`657, which are consolidated, and IPR2015- 662 and 666
`which are also consolidated, filed by Google, Inc. against
`At Home Bondholders' Liquidating Trust, and concerning
`the following patents; Patent Number 6,286,045 and
`6,014,698.
`
`Presiding over this proceeding are Judges
`Justin Arbes and Karl Easthom, appearing on the screen.
`And they're present in Courtroom D in the Madison
`Building of the USPTO Alexandria Complex. And
`presiding here, I am Judge Miriam Quinn, and I'm present
`in the Texas Regional Office, in Dallas, Texas.
`So at this time, the counsel for Petitioner,
`would you please state your appearances.
`MS. HOLOUBEK: Good morning -- or good
`afternoon, Your Honor.
`My name is Michelle --
`MR. TODD: Is the microphone on?
`MS. HOLOUBEK: Is the microphone on?
`Can everyone --
`JUDGE QUINN: Can you see the light on, is
`
`it green?
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`MS. HOLOUBEK: It is green.
`MR. TODD: Push it. There you go.
`MS. HOLOUBEK: Oh, it's more green.
`
`Sorry.
`
`I'm Michelle Holoubek, counsel for
`Petitioner Google, Inc.
`JUDGE QUINN: And counsel for Patent
`
`Owner?
`
`MR. STEPHENS: Garland Stephens, of
`Weil, Gotshal & Manges, representing the At Home
`Bondholders' Liquidating Trust. And with me today is
`my colleague, Justin Constant.
`JUDGE QUINN: Thank you.
`Okay. So first of all, some preliminary
`matters. According to our Order of March 8th, 2016,
`which is Paper 40 in the record, a copy of the
`demonstratives should have been provided to the court
`reporter. If you haven't done so, can you do that at this
`time?
`
`MR. STEPHENS: Yes.
`MS. HOLOUBEK: We've done that, Your
`
`Honor.
`
`JUDGE QUINN: Okay. Thank you.
`Then before we proceed, we want to
`memorialize that we received a request by Petitioner to --
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`for a conference call on April 5th to raise objections to
`Patent Owner's demonstrative slides, and the Board
`denied Petitioner's request.
`The question for the parties is: Has the
`dispute been resolved?
`MS. HOLOUBEK: No, Your Honor, the
`dispute has not been resolved. Some issues were, but
`unfortunately some issues still remain.
`JUDGE QUINN: So here's some instructions
`on how we're going to proceed with that.
`So Petitioner, during your allotted time for
`argument, you can make a statement of the reasons why
`the Panel should not consider whatever is in the slides of
`Patent Owner that's considered objectionable, but during
`only your argument time. There will be no speaking
`objections at this time.
`And, Patent Owner, during your rebuttal
`time, you may have an opportunity to discuss the
`objections to Patent Owner's [sic] argument.
`Again, I want you to raise whatever issues
`you have in your initial presentation, so that Patent
`Owner may address this during their response.
`And the parties are reminded again that the
`demonstratives are not evidence and they're not part of
`the record. And we're not going to rule on the objections
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`here. We're going to take everything under advisement.
`We will determine the propriety of the objections during
`our preparation and final decision; and will take into
`consideration arguments pursuant to the Rules, which
`state that oral argument may be requested on an issue
`raised in a paper. So if it's raised in a paper, they're
`okay.
`
`Are there any questions regarding these
`instructions?
`MR. STEPHENS: No, Your Honor.
`MS. HOLOUBEK: No, ma'am.
`JUDGE QUINN: So Petitioner, the party
`with the burden to prove unpatentability, you may
`proceed first. You have one hour total argument time,
`but you may reserve time for rebuttal.
`How much time would you like to reserve?
`MS. HOLOUBEK: Thank you, Your Honor.
`I'd like to reserve 20 minutes for rebuttal.
`JUDGE QUINN: If you're ready, you may
`
`proceed.
`
`MS. HOLOUBEK: Thank you. May it
`please the Board.
`My name is Michelle Holoubek, as I had
`mentioned before, representing Petitioner Google.
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`The Board deemed 22 claims of the '045
`patent and 40 claims of the '698 patent as likely to be
`unpatentable over Angles, Merriman, and HTTP1.0,
`which I'll refer to here as simply "HTTP." Davis was
`also used in the combination for a few of the dependent
`claims. None of the evidence or argument that Patent
`Owner has presented since disturbs this result.
`The subject matter here is simple and
`obvious, and facing strong prior art references, Patent
`Owner complicates the facts with incorrect statements.
`And the record that has been developed since the
`Institution Decision shows that the Board's initial
`findings should not be changed.
`The Angles, Merriman, and HTTP1.0
`combination and the '045 and '698 patents are all drawn
`to a well-known method of distributing a banner
`advertisement over a network. This involves sending an
`unblockable signal from the user's computer to a server,
`followed by a redirect from the server.
`Angles discloses the majority of the
`limitations of the independent claim, leaving only minor
`modifications that would have been obvious to a person
`skilled in the art.
`The first of these is replacing Angles'
`location signal --
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`JUDGE QUINN: Let me you ask something
`
`about that.
`
`MS. HOLOUBEK: Yes, Your Honor.
`JUDGE QUINN: The -- the claims -- 49, for
`example, I was looking at that earlier, and it does say
`that the banner must have been previously stored
`somewhere.
`So isn't that then meaning that the claims
`require that some caching had occurred previously before
`this method was working?
`MS. HOLOUBEK: Yes, Your Honor.
`So we've put Claim 49 -- this is for Slide 4 -
`- on the screen. And that's right. The -- that limitation
`that you're asking about is in the "first banner request
`signal" paragraph, and what it says is that the "signal
`includes information intended to make said first banner
`request signal not blockable by the device or
`intermediary server as a result of storage in the device or
`intermediary server of said requested banner prior to the
`generation of said first banner signal by the device."
`So there's a couple of things I would like to
`point out there.
`First of all, it says that what's stored in the
`cache or -- or in the device, the intermediary server, and
`this is talking about caching, is the requested banner. So
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`I think it's important to first look at and take this in a
`few steps.
`
`First, it would have been obvious to a person
`skilled in the art that Angles had a cache that would be
`operating according to standard caching behaviors, and
`that does not appear to be in dispute, that Angles has a
`cache. The question is --
`JUDGE QUINN: And you're relying on
`HTTP1.0 for that proposition; is that right?
`MS. HOLOUBEK: That's right, Your Honor.
`So in the expert declaration, when he was
`talking about the state of the art, he stated that it was
`well- known for browsers to have a cache. And the expert
`further indicated, in Paragraph 142 of his declaration,
`that Angles is a standard browser that would have a
`cache.
`
`And what HTTP tells us, as stated on Pages
`23 to 24, and this is of the '660 IPR, is that a cache
`stores cacheable responses in order to reduce the
`response time, the network bandwidth consumption, on
`future equivalent requests.
`And so here we have Angles operating as a
`standard web browser. It has a cache. And that was all
`laid out in our Petition, along with HTTP.
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`JUDGE QUINN: Does it matter what HTTP
`version we're speaking of? Angles -- Angles says
`HTTP2.0.
`
`MS. HOLOUBEK: It doesn't matter. HTTP
`is -- The -- the caching functionality of HTTP, I believe,
`hasn't changed throughout those initial drafts. We're
`relying on HTTP1.0 just because it was the one with the -
`- you know, that was submitted, that had the dates, but
`the caching aspects of it, I don't believe, are unchanged -
`- or are changed.
`JUDGE QUINN: So you contend that
`whether it's HTTP1.0 or 2.0, your contentions apply
`equally to either version?
`MS. HOLOUBEK: Yes, Your Honor. That's
`
`correct.
`
`So if we go to -- Let me pull the slide here.
`If we go to Slide 16, so we're talking about the
`unblockable signal here, and the un -- So it says, "First
`request signal cannot be blocked," and then follow-on to
`that is that the first signal cannot be blocked due to the
`previous caching. And so that's the point that you were
`asking about.
`To begin, let's remember what Angles is
`doing. Angles is serving not just any advertisement, but
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`dynamic advertisements, and those advertisements may
`be --
`
`JUDGE QUINN: So let me ask you
`something.
`MS. HOLOUBEK: Um-hmm.
`JUDGE QUINN: Because if -- if Angles is
`operating under the standard default of caching, and the
`claims require there were -- there was previous caching -
`-
`
`MS. HOLOUBEK: Um-hmm.
`JUDGE QUINN: -- so you contend that
`Angles is using an unblockable signal. So when is there
`ever caching in Angles?
`MS. HOLOUBEK: So in Angles, there's two
`different signals that are happening, right? There's the
`first request signal -- And so we have two pairs. We
`have the first request signal in Angles, which is the CGI
`script that reads on the unblockable aspect, and what's
`sent back in response is the redirect signal.
`Then there is a second signal, which is the
`banner request signal. It's the signal that requests a
`specific banner. And the response to that second signal
`is the banner.
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`When you look at the claim language, it says
`that the first request signal isn't blocked due to storage
`of the banner.
`When you look at the -- the pairs of signals
`that are happening here, under normal caching, if the
`response to a particular signal is cacheable, a cache will
`store it. There are types of signals where the response is
`not cacheable.
`And so it's, I think, important for -- for your
`question to remember that there's two pairs of signals
`here.
`
`So let's talk about the first signal. The first
`signal is the CGI request, and that gets to the
`advertisement provider computer, and what's being sent
`back there is the redirect signal.
`Now, as we'll talk about, the redirect signal
`would not be cached, because a person of skill in the art
`understands that CGI scripts, the responses thereto are
`not cached. And so regardless of what was in cache
`when that first signal goes out, there's never going to be
`a corresponding redirect signal that's been stored in
`cache that would prevent the CGI script signal from
`being sent. And it --
`JUDGE ARBES: Counsel --
`MS. HOLOUBEK: Yes.
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`JUDGE ARBES: -- are all calls to a CGI
`script, is the response never cached in -- in all
`circumstances or are there circumstances where that
`could be cached?
`MS. HOLOUBEK: The -- the default for a
`CGI script is for it to be cached. Now, there are ways
`that the default functionality can be changed. The CGI
`script may be input improperly.
`But the default functionality -- And Angles
`gives us no reason to assume that it's anything other than
`the default. The default functionality is that the CGI
`script would be -- would be unblockable.
`And I will turn to that question. I just want
`to -- to put further explanation of why that's the case and
`why the evidence that's developed in the record since
`shows that.
`
`I want to make sure I -- I finish Judge
`Quinn's discussion about the -- the unblockable aspect of
`it.
`
`So when we have these signals -- So we have
`the unblockable CGI request that's being sent out. The
`response to that is a redirect request. The response to
`that isn't a banner, and so there's no connection. Even if
`the banner that is ultimately going to be served is in
`cache, there's no link between this initial general request
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`for some advertisement to be specifically linked to that
`banner, because that banner is a response to a second
`type of signal.
`JUDGE QUINN: Excuse me. You're talking
`about a redirect that Angles doesn't teach. I'm asking
`you about Angles himself.
`MS. HOLOUBEK: Um-hmm. Sure. So
`there's signal in Angles -- Still in Angles, there's two
`signals: You have the initial CGI request that goes out.
`There is a location signal that goes back, and that is in
`Angles, and that's when the ad provider computer sends a
`specific location of the banner ad. It's not sending the ad
`itself; it's sending the location of the banner ad where
`it's located on the advertisement storage medium 44.
`Once the browser gets that location signal
`back, that's when the second request is issued, and that
`second request is now for that particular banner. The
`banner's identified in that request. And so if the banner
`is previously in cache, now there's something that
`matches that signal, right? So that's where the -- the --
`that second signal can be served from cache.
`But on the CGI script that goes out, it's a
`general request signal. It's not requesting a particular
`banner, and so there's no reason that cache would see the
`banner that's stored as linked for any particular response,
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`because what's responding to that -- Say you have five
`banners in cache. That particular first signal, the CGI
`signal, isn't specifying any of those particular five
`banners. So when the cache looks at it, there's nothing
`that matches. It's just requesting "provide me with a
`banner" through the -- through its CGI script.
`The ad provider computer executes that
`script, identifies a particular banner, located -- and
`identifies its location, sends the location back to the
`requesting computer, which in Angles is the consumer
`computer.
`
`And then now that the consumer computer
`says, "Okay. I know exactly what I'm asking for now. I
`have a particular banner. I can now send a request signal
`for the banner at the location that's been provided."
`JUDGE QUINN: Right. And so you're
`referring to the alternative embodiment, where there is a
`local storage of the banners at the computer. But there is
`a preferred embodiment, which is the one in which the
`advertisement provider's computer serves the banner
`itself. So is there caching in that situation?
`MS. HOLOUBEK: So in that situation --
`And I'd first like to point out that that is not the
`embodiment that Petitioner is relying on for its ground
`here.
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`But in -- in that embodiment where the
`banner is coming directly from the ad provider computer,
`then, yes, there would be something in cache, because
`this -- Well, hold on. Let me think about that, just
`because this is a different situation than what we've been
`analyzing in our Petition.
`So we have a CGI that went out. So in that
`particular instance, no, then there wouldn't be anything
`in the -- there wouldn't be a banner in the -- in the cache
`in that instance, because the CGI script comes, and the
`caches knew -- as the evidence will show, the caches
`knew not to store responses from those dynamic requests.
`So in that situation where you have the
`consumer computer sending the CGI script to the ad
`provider computer, because that was requesting dynamic
`information, it's the advertisement computer that's
`selecting a banner in that particular embodiment, sending
`the banner back, that wouldn't be cached, because the
`cache knew not to store the responses to dynamic
`requests.
`
`JUDGE QUINN: So -- so your contention is
`that there are no requests from -- in Angles that -- from
`the consumer computer that are cacheable when it --
`when it comes to the advertisement itself?
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`MS. HOLOUBEK: No, Your Honor, that's
`not our contention.
`So, again, that's the first request. And,
`again, I'd like to point out that there are two
`embodiments in Angles, and what we've talked about was
`that first embodiment.
`There is a different embodiment, and the two
`are not the same, and it's not like the second embodiment
`is just a follow- on to -- to the first one.
`JUDGE QUINN: So then in which
`embodiment is there caching?
`MS. HOLOUBEK: The second embodiment
`that we've relied on in our Petition, and that's because
`what's different in the first embodiment and the second
`embodiment, in the first embodiment that we just talked
`about, there is a banner that is actually returned from
`that initial request signal. There's just one request that
`goes out and a banner is brought back.
`The difference with the second embodiment
`is that there's a request that goes out, but instead of
`sending a banner back, there's just an identification of a
`location where the banner can be found. And, as Angles
`describes it, that location is on the advertising storage
`medium.
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`And so then you can see there's arrows
`between the consumer browsing module and the
`advertising storage medium. So when the consumer
`browser module receives that location information from
`the ad provider computer, then it requests -- That's the
`second request. It requests the actual banner from the
`advertising storage medium, and that's what can be
`cached. That particular signal can be cached, because it
`doesn't have to be a CGI script and Angles doesn't
`disclose it as a CGI script. That's just a standard request
`for contact from the storage.
`JUDGE QUINN: So now my question to you
`regarding that embodiment you're relying on, Angles
`refers to using special software for that alternative
`embodiment. Do you have any positions on what that
`special software is or isn't?
`MS. HOLOUBEK: I don't believe that
`there's any special software required for Angles. It says
`that it may alternatively -- if we pull out -- just pull out
`Angles, I can direct you to a particular location where
`it's talking about it.
`But Angles just indicates that instead of
`being stored, having the advertisement stored on the ad
`provider computer, that the advertisements can be stored
`on the advertising storage medium.
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`And if we look at Angles -- and this is in
`Column 23, right about Line 27, and this is where it says,
`"In another embodiment, the consumer computer 12
`stores the customized advertisements on the
`advertisement storage medium 44."
`So rather than receiving a copy of the
`advertisement over the Internet, instead, the consumer
`control module 42 receives an advertisement command,
`which directs the consumer control module to retrieve the
`customized advertisement from the advertisement storage
`medium.
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`And so there -- and then if you follow on in
`the following paragraphs, it says that it -- it retrieves it
`from the advertising storage medium. So there's no
`indication that it's some special software. And, in fact,
`Angles states that the browser is standard Internet
`Explorer, Netscape-type software.
`JUDGE QUINN: I've got you. What do you
`make out of Column 3, Lines 24 to 28, where he says, "In
`an alternate embodiment" -- which I read that to be this
`local storage embodiment -- "the consumer is sent unique
`software which enhances the consumer's Internet browser
`so that custom advertisements can be merged with
`electronic documents obtained from the contents of that
`ad."
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`MS. HOLOUBEK: Oh -- oh, that --
`JUDGE QUINN: Does that have any impact
`on your position?
`MS. HOLOUBEK: It doesn't have any
`impact on our position. That particular software is
`actually what inserts a cookie into the original CGI
`request signal, and that includes information about the
`user.
`
`So previously they would have registered,
`signed up, had some sort of demographic information, for
`example, and so that particular software is like a browser
`plug- in or a cookie. There's a couple different ways they
`describe it. That's all in the initial set- up.
`And so when the first request signal goes
`out, that CGI script, in addition to including the request
`for an ad, it includes a cookie or some additional
`information about the demographics of the user so that
`the ad provider computer can select the appropriate
`advertisement.
`But there's -- That's where that particular
`software comes in, but there's nothing about the
`transmissions -- You know, even when what cookie is
`inserted into the CGI script, it's still operating according
`to normal HTTP protocol, as CGI scripts were then. And
`then the location signal that goes back, which is then --
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`provides the location to the consumer browser module
`and provides a location to where the banner is located,
`when the browser then sends the request for the banner,
`that's just -- that doesn't require that -- that demographic
`information. There's nothing different about that signal.
`It's really just acting on, "Okay. I've been told where to
`pull the ad from, and so now I'm going to go retrieve the
`ad from the location I was provided and display it." So
`that special software that you're talking about is only to -
`- to provide demographic information.
`JUDGE QUINN: Okay. Now, talk to us
`about the addition of Merriman's redirect into Angles.
`MS. HOLOUBEK: Sure. Sure. So what --
`what Merriman states -- let me just --
`And from the perspective of -- of looking at
`it in context, we do have this combination. And the
`important thing to remember is so Merriman is a
`secondary reference, and so we've turned to -- We can
`look at Slide 24.
`So just to start with, we have the
`combination of Angles and Merriman. And as we've been
`talking about, Angles discloses nearly every limitation
`that are in the claims, and so here it's a -- the secondary
`reference, Merriman, is being used to show what was in
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`the tool kit of a person of skill in the art reading the base
`reference of Angles.
`So Angles, as we've mentioned, it says that
`the consumer computer, including its storage -- it says it
`can be distributed across the network and that
`appropriate protocols would be used to do that.
`So a person of skill in the art reading Angles
`and trying to implement retrieving a banner ad from the
`storage, as described in Angles, would have known to use
`the standard HTTP redirect.
`Merriman says that it was certainly within
`the knowledge of those of skill in the art dealing with
`advertising systems.
`So the -- the issue here is we're not relying
`on -- on Merriman for the various other teachings. What
`we're focused on Merriman is to show that a person of
`skill in the art in the advertising context would have
`known that 302 redirects were how you get from browser
`computer to retrieve something from storage across a
`network.
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`So if I may, I'd like to go back to the
`question about the -- how do we know that the CGI script
`in Angles is unblockable. So let's turn to Slide 16 here.
`So to begin, you know, what is Angles doing
`here? Angles is not just serving advertisements; Angles
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`is serving dynamic advertisements. And these
`advertisements are specifically tailored to the user, and
`different advertisements may be displayed to the user at
`different times. So after all -- I mean, Angles is actually
`titled "System and method for delivering customized
`advertisements." So there's no question that the point of
`Angles is to get this dynamic advertisement, this
`customized resource, it's different each time, to the user
`for a different display each time.
`If you'll turn to Slide --
`JUDGE ARBES: Is there disclosure -- I'm
`sorry. Is there disclosure in Angles of changing the
`advertisement that's displayed based purely on time?
`For instance, if the user makes a particular
`request and then one minute later makes the same type of
`request, does Angles say that the advertisement would be
`different then? I'm not sure that I remember that from
`the reference.
`MS. HOLOUBEK: There is -- Your Honor, I
`need to find the citation to it. But Angles does indicate
`that after a certain amount of time passes, a different
`advertisement would be served to -- to the user, so that
`the user wouldn't constantly see the same advertisement
`over and over again; that the user would see different
`advertisements.
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`JUDGE ARBES: What about the example
`that I mentioned, where I make a request, and then one
`minute later, I make the same request? Theoretically,
`you could have -- you could perform caching of that so
`that I -- you don't need to pull that from the ultimate
`server, right, and it wouldn't make a difference.
`MS. HOLOUBEK: Well, if this were a
`normal request, that would be the case. But what Angles
`is specifically using is a CGI script, and it's that CGI
`script that makes this a nonblockable signal.
`So if it were just a random URL request to,
`you know, Yahoo.com/ad and there were a banner that
`responded to that, then -- then yes, that simple URL
`request could be blocked by a cache. But what we have
`in Angles, and what Angles specifically talks about, is a
`CGI script.
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`So I'd like to focus on, okay, we have a CGI
`script in Angles, how do we know that's unblockable. Is
`that sort of where your question is coming from?
`JUDGE ARBES: Yes.
`MS. HOLOUBEK: Okay. So let's turn to
`Slide 17 and let's take a look at what's required by the
`patent claims here and what does the patent describe as
`being unblockable, so we know what we're comparing it
`to. Because if we have the claim term that's described in
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`the patent and the description in the patent describes a
`particular feature as unblockable, then that same feature
`in the reference would also be understood as
`unblockable, because the reference would teach the same
`thing as the patent. And the patent describes a cgi- bin
`string as a variable component used in standard operation
`of HTTP and HTML.
`And so looking at the patent spec -- and I'll
`refer you to paragraph -- or, sorry, to the '045 patent
`spec. And if you look at Column 18, at Line 18, the
`patent states -- Okay. I'll give you a second to get there.
`So at Line 18, the patent states, "Another
`option for implementing the method 110 of the present
`invention using standard HTML and HTTP protocols is to
`incorporate variable components into the links...such that
`the variable components are incorporated into the general
`content URL addresses sent by the terminal.... For
`example" --
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`And then if you keep looking further, around
`Line 27, it, quote, "can contain a variable component
`such as, for example...a cgi-bin string."
`Then at the end of the paragraph, it says,
`"Since the variable component URL addresses are, by
`definition, different every time, the initial banner request
`signal...will be different every time, thereby preventing
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