WhatsApp, Inc. and Facebook, Inc., Petitioners v.
`TriPlay,Inc., Patent Owner, Case IPR2015-00740
`Patent Owner’s Oral
`Argument Presentation
`On U.S. Patent No.
`8,332,475 B2
`
`May 19, 2016
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`PATENT TRIAL AND APPEAL BOARD
`
`TriPlay, Inc.
`
`1
`
`
`TriPlay,Inc., Patent Owner, Case IPR2015-00740
`Patent Owner’s Oral
`Argument Presentation
`On U.S. Patent No.
`8,332,475 B2
`
`May 19, 2016
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`PATENT TRIAL AND APPEAL BOARD
`
`TriPlay, Inc.
`
`1
`
`
`
`The ‘475 Patent
`
`TriPlay, Inc.
`
`2
`
`
`
`Benefits Of ‘475 Patented Invention
`• “…the reduction in need of content analysis and ability to
`provide layout delivery instructions based on predefined rules
`and parameters (e.g. in a form of a look up table).” 21:8-13 (emphasis
`added).
`
`• “The delivery instructions or parts thereof … may be predefined
`in the system (e.g. in a form of a lookup table providing matching
`between originating device and/or destination device and format
`and/or layout of the message to be converted for delivery).” 16:63-
`17:4 (emphasis added).
`
`• “Accordingly, for template-based messaging the delivery
`instructions with regard to layout of the message are based on
`predefined layout of message matching to template unique
`identifier and capabilities of destination device.” 21:1-5 (emphasis added).
`
`TriPlay, Inc.
`
`3
`
`
`
`Claim 1: “Configured To Select” Limitation
`
`a
`communication via
`1. A system for message
`communication media between one or more originating
`communication devices assigned to a sender and one or
`more destination communication devices assigned to a
`receiver, the system comprising:
`…
`“a media block operatively coupled to said access block
`and configured to select, before transmitting, at least
`one message format and a message layout for each of
`the at least one message formats fitting to each of said at
`least one destination device”
`
`TriPlay, Inc.
`
`4
`
`
`
`Ordinary And Customary Meaning of “Select”
`
`• “‘[H]eavy presumption’ that a claim term carries its ordinary and
`customary meaning.” CCS Fitness, Inc. v. Brunswick Corp., 288 F.3d
`1359, 1366 (Fed. Cir. 2002) (emphasis added).
`
`• “Select” means “to pick out as a choice among several”
`
`• The American Heritage Dictionary (2000) (Ex. 2006): “[t]o take as
`a choice among several; pick out”
`
`• The Merriam-Webster Dictionary (2004) (Ex. 2007): “to choose
`from a number or group; pick out”
`
`• The Microsoft Computer Dictionary, Fifth Edition (2002) (Ex.
`2008): “to choose from a number of options or alternatives, such as
`subroutines or input/output channels”
`
`TriPlay, Inc.
`
`5
`
`
`
`Specification Supports Ordinary Meaning of “Select”
`
`• The specification uses the term “select” consistent with
`its plain meaning:
`
`• “The receiving subscriber upon receiving such
`select
`message may
`appropriate
`‘Yes/No’
`button/checkbox ….” 20:32-33 (emphasis added).
`
`• “The decision … of these two messages to select”
`17:30-31 (emphasis added).
`
`TriPlay, Inc.
`
`6
`
`
`
`Prosecution History Supports Ordinary Meaning of “Select”
`
`• The specification discloses two delivery embodiments for
`making the delivery decision: “the decision can be based either
`on dynamic information carried with the received message itself,
`or a predefined set of choices.” Petitioners’ Reply (“Reply”) at 7
`(citing 16:63-17:4) (emphasis added).
`
`• Prosecution history changed the claim from “adapt” to “select.”
`Ex. 1008 at 2, 24.
`
`TriPlay, Inc.
`
`7
`
`
`
`“Select” Does Not Mean “Determine”
`
`• Ordinary meaning of
`are not
`and “determine”
`“select”
`synonymous. Patent Owner Response (“POR”) at 27-28.
`
`• Petitioner argues: “select” as used in the claim is synonymous
`with “decide” or “determine …” Petitioner’s Reply (“Reply”) at 7
`(emphasis added)
`• “specification equates the claimed selection with a ‘delivery
`decision’ and makes clear that the decision can be based on
`dynamic information carried with the received message itself,
`or a predefined set of choices ….” Id.
`
`TriPlay, Inc.
`
`8
`
`
`
`Petitioners Cannot Argue For A Construction of “Select” That IS
`Contrary To Its Plain Meaning
`
`• The Petition did not advance a construction of “select.” Rules require that
`“where a party believes that a specific term has meaning other than its plain
`meaning, the party should provide a statement identifying a proposed
`construction of the particular term and where the disclosure supports that
`meaning.” 77 Fed. Reg. 48764.
`
`• TIP Systems, LLC v. Phillips & Brooks/Gladwin, Inc., 529 F.3d 1364, 1373
`(Fed. Cir. 2008)
`
`• “Our precedent is replete with examples of subject matter that is
`included in the specification, but is not claimed”. Id. at 1373 (emphasis
`added).
`
`•
`
`“constru[ing] the claim term to encompass the alternative embodiment
`… would contradict language of the claims.” Id.
`
`TriPlay, Inc.
`
`9
`
`
`
`Coulombe Does Not Disclose A “Media Block Configured to Select”
`
`• The “goal” of Coulombe is to:
`“facilitate message adaptation in
`such a way that incoming messages may be made suitable for the
`recipient’s terminal, user’s preferences . . . .” POR at 2 (citing to
`Coulombe, ¶ 53) (emphasis added).
`
`•
`
`Incoming messages can have: (i) different types of media, (ii) media
`content encoded in different media formats; (iii) media content
`with different characteristics; (iv) different messages formats.
`POR at 3 (citing Coulombe, ¶¶ 7, 86-88 and Dr. Suratia Decl., ¶ 22).
`
`• Coulombe allows user recipients to control how content sent to
`them should be adapted (e.g., a device might support images in
`several formats but
`the user’s preference may explicitly require
`images be converted to just one of those formats). POR at 5 (citing to
`Surati Decl., ¶ 31).
`
`TriPlay, Inc.
`
`10
`
`
`
`Coulombe Does Not Disclose A “Media Block Configured to Select”
`
`• “the Capability Manager resolves the terminal capabilities and user
`preferences using different
`inputs and methods.”
`POR at 5
`(quoting Coulombe, ¶ 5).
`
`• Examples: (i) the body message, (ii) header fields such as a key to Terminal
`Capability Database, and (iii) “SIP options request to the recipient in order
`to learn its capabilities or user preferences.” POR at 5-7 (citing and quoting
`Coulombe, ¶¶ 75-77 & 82).
`
`• “resolve” refers to “the operation of 1) gathering all possible
`capabilities and preference descriptors… 2) Combing the
`capabilities or user preferences obtained by different methods in
`the most appropriate manner to obtain a complete set of capability
`information.” Coulombe, ¶ 59; POR at 6 (emphasis added).
`
`TriPlay, Inc.
`
`11
`
`
`
`Coulombe Does Not Disclose A “Media Block Configured to Select”
`
`• Coulombe “make[s] a determination of what sort of adaptation
`or adaptions are required by comparing the capabilities or
`user preferences of the intended destination terminal 15 with
`the incoming message characteristics (e.g., present resolution,
`format and size of images, size of message, etc.) for each
`component thereof.” POR at 33 (quoting Coulombe, ¶ 118)
`(emphasis added).
`
`• “A POSITA would understand that
`for the
`the support
`destination device’s user preferences alone would mean that
`the messaging system cannot have a predefined set of choices
`since a unique user’s preference cannot be defined in advance.”
`POR at 34 (citing to Surati Decl., ¶ 106) (emphasis added).
`
`TriPlay, Inc.
`
`12
`
`
`
`Claim 6 Limitations
`6. The system of claim 1 configured to receive a message
`“Template”
`having a layout based on a template,
`said template characterized by at least a unique identifier,
`
`“Template
`Identifier”
`
`“Identifier
`Recognition”
`
`wherein the system is further configured to recognize the unique
`identifier of the template, and
`
`“Repeated
`Claim 1”
`
`“Predefined
`Layout”
`
`TriPlay, Inc.
`
`the media block is further configured to select before
`transmitting, at least one message format and a message layout
`for each of the at least one message formats fitting to each of said
`at least one destination device, and then convert the initial layout
`of the message to the selected message layouts,
`said selection and conversion being done in accordance with at
`least one predefined layout corresponding to the recognized
`unique identifier and the displaying capabilities of the destination
`communication device.
`
`13
`
`
`
`Mapping Petition To Claim 6 Limitations
`
`Claim 6
`Limitation
`“Template”
`
`“Template
`Identifier”
`
`“Identifier
`Recognition”
`
`“Predefined
`Layout”
`
`Coulombe
`
`Druyan
`
`Tittel
`
`“template” is “master style sheet”
`file. Pet., pg. 45.
`
`“obvious that Druyan’s process of
`making copies of initial style sheet
`would have included Druyan
`recognizing the style sheet’s
`unique identifier” Pet, pg. 49.
`“the ‘predefined layout
`corresponding to the recognized
`unique identifier’ takes the form of
`the derivative style sheet file” Pet.,
`pg. 50.
`
`Druyan does not disclose.
`Obvious in view of Tittel.
`Pet., pg. 46.
`
`Petitioner does not
`contend that Tittel
`discloses the
`“predefined layout”
`limitation. POR at 39.
`
`TriPlay, Inc.
`
`14
`
`
`
`Druyan Does Not Teach A “Template” Limitation
`
`“Template”
`Limitation
`6. The system
`of claim 1
`configured to
`receive a
`message having
`a layout based
`on a template
`…
`
`Petitioners’ Argument
`
`“Druyan discloses a technique in which a message, in the form of an
`HTML document (such as a web page), can have a layout based on a
`template.” Petition at pg. 45 (emphasis added).
`
`“The ‘template’ in Druyan takes the form of a “master style sheet file,
`which Druyan also refers to as ‘XSLT style sheet file 230’.” Id.
`(emphasis added).
`
`“The styling information in the style sheet file (230) is part of the
`HTML document (240) itself, and it specifies how to display the
`HTLM document.” Id.
`
`TriPlay, Inc.
`
`15
`
`
`
`Druyan Does Not Teach A “Template” Limitation
`
`•
`
`“template” is “any kind of predefined user interface related to content
`and/or layout of transmitted and/or received message.” Pet. at 15.
`
`• XSLT style sheet file 230 is not a template because it is not a “user
`interface.”
`
`• XLST master style sheet file 230 is a set of XSLT style rules to apply to an
`XML file. Without the XML input file, the XSLT master sheet file does not
`provide an output at all. POR at pg. 36 (Surati Decl., ¶ 112).
`
`TriPlay, Inc.
`
`16
`
`
`
`Construction Of “Predefined Layout”
`
`Patent Owner’s Construction
`“a layout that is defined prior to
`the receipt of message for
`delivery to a destination
`communication device” POR at
`29.
`
`Petitioner’s Construction
`“a layout that is created or defined prior
`to being used” Reply at 15.
`
`• A construction that permits a “predefined” layout to be generated at any time
`prior to use renders the word “predefined” superfluous. POR at 29.
`
`•
`
`‘475 patent discloses that layouts are selected based upon predefined rules and
`parameters based upon “look up tables.” POR at 29 (‘475 patent, 21:1-12).
`
`• That
`the
`the claim requires “selection” further informs a POSITA that
`predefined layout must exist before the incoming message is received. POR
`at 30 (Dr. Surati Decl., ¶ 92.)
`
`TriPlay, Inc.
`
`17
`
`
`
`Specification does not alter plain meaning of “Predefined Layout”
`
`• Petition did not contend “Predefined Layout” should have
`construction other than ordinary meaning. BUT if considered,
`Specification does not alter plain meaning:
`
`template-based messaging the delivery
`for
`Accordingly,
`instructions with regard to layout of the message are based on
`predefined layout of message matching to template unique
`identifiers and capabilities of destination device. The layout
`may be further predefined in accordance with the information
`to be obtained with regard to certain filled field, format of
`selected media items, etc.” 21:1-8 (emphasis added).
`
`TriPlay, Inc.
`
`18
`
`
`
`Druyan Does Not Teach A “Predefined Layout”
`
`“Predefined Layout” Limitation Argument based on Petitioners’ Construction
`“said selection and conversion
`The “derivative style sheet file is a “predefined”
`being done in accordance with at
`layout because it was created prior to its use in
`least one predefined layout
`generating an appropriate display ….” Pet. at pg. 51.
`corresponding to the recognized
`unique identifier …”
`• Disclosure of “prior to its use” is irrelevant; “predefined layout” requires creation prior
`to the incoming message being received.
`
`•
`
`In Druyan, derivative style sheets created after incoming message received.
`
`•
`
`“In Step 610, in response to receive a request to restyle the web page, first
`derivative style sheet file 310 describing the first presentation style document 340
`is generated.” POR at 37-38 (quoting Druyan, 5:43-46 and citing Dr. Surati Decl.,
`¶ 113.
`
`• A POSITA would understand, in the context of Druyan invention, request to
`restyle the web page would be at the time of request for a web page. Surati Dep.
`at 100:3-25.
`
`TriPlay, Inc.
`
`19
`
`
`
`Dr. Surati’s Testimony: Request To Restyle The Web Page
`
`Pg. 100
`
`TriPlay, Inc.
`
`20
`
`
`
`Druyan Does Not Teach A “Predefined Layout”
`
`Argument based on Patent Owner’s Construction
`
`“Predefined
`Layout” Limitation
`“Additionally, it would have been obvious to one of ordinary
`“said selection and
`conversion being
`skill in the art that the derivative style sheets files could have
`• Druyan discAdditional sentences in passage do not create a disclaimer. The
`done in accordance
`been created at any time prior to the receipt of the initial
`full passage (21:1-12) reads:
`with at least one
`message.” Pet. at 51.
`predefined layout
`corresponding to the
`recognized unique
`identifier …”
`
`•
`
`•
`
`“This is clear from disclosure of Druyan, which explains that
`‘[t]he process of deriving a derivative (also known as a
`‘child[‘]) style sheet from a master style sheet may be
`implemented manually or may be automated by a computer
`program.’” Id. at 51-52.
`
`• No need in Druyan to create the derivative style sheets in advance because
`elements for segmenting are already known. Inefficient and inconsistent
`with general practice to generate the derivative style sheets in advance of a
`user’s need. POR at 38; Surati Dep. at 76:18-22 (“all possible content …
`to look good across all devices).
`
`TriPlay, Inc.
`
`21
`
`
`
`Petitioners’ Reply Argument Regarding Manually Created Style
`Sheets Should Be Rejected
`
`• Petitioners: “Druyan specifically discloses that a derivative style sheet
`may be created “manually,” which as the patent owner’s expert
`acknowledged, would occur before the receipt of a request for the web
`page.” Reply at 16-17.
`
`• Dr. Surati responded to a hypothetical question and provided an
`answer in the context of a high volume web site. See Surati Dep. at
`72:1-73:11
`
`• “The process of deriving a derivative … style sheet from a master
`style sheet may be implemented manually or may be automated by a
`computer program ….” Druyan, Ex. 1004 at 3:37-39
`
`TriPlay, Inc.
`
`22
`
`
`
`Dr. Surati Testimony Regarding “Manually” Created Derivative
`Style Sheets
`
`TriPlay, Inc.
`
`23
`
`
`
`The Board Should Reject Petitioners’ Reply Argument Re Assuming
`Knowledge Of Capability Of Destination Devices
`
`• Petitioners: “If the system knows the capabilities of the destination device
`and the type of content it will receive, as the patent owner acknowledged, it
`could pre-create the derivative style sheet.” Reply at 17.
`
`•
`
`“So, for example, the Druyan patent talks about basically taking a table and
`splitting up across a bunch of different views … these derivative style sheets
`depend on what content has come in. So, you would have to create these
`style sheets for all possible content that would come in, and then since
`you don’t know what client device would be requesting it, you’d have to
`create style sheets that look good across all the devices.…” Surati Dep.
`76:10-24.
`
`• No need in Druyan to create the derivative style sheets in advance because
`elements for segmenting are already known. Inefficient and inconsistent
`with general practice to generate the derivative style sheets in advance of a
`user’s need. POR at 38
`
`TriPlay, Inc.
`
`24
`
`
`
`fundamentally different
`
`Coulombe and Druyan are
`systems
`• Coulombe: flexible messaging system (POR at 39-40).
`• Message content is unrestricted; not known in advance
`• Ad-hoc delivery decisions based on user preferences and device capabilities
`• Supports instant messaging: capabilities updated every time a user registers
`•
`“SIP Options request” to determine device capabilities if not known
`
`• Druyan: web solution for displaying text content on small devices (POR 40-41).
`• Content for delivery is known in advance
`• Structured delivery: XML document as input to XSLT processing engine
`• Master style sheet file specifies programming for html output for full screen
`• Derivative styles sheets utilized for dividing up elements onto multiple pages
`
`TriPlay, Inc.
`
`25
`
`
`
`Petitioners Offer No Motivation To Combine Coulombe
`and Druyan
`• The lack of technological obstacle to combining references does not, in
`and of itself, support a finding of obviousness. In re Omeprazole Patent
`Litigation, 536 F.3d 1361 (Fed. Cir. 2008) (POR at 31).
`
`• Obviousness requires “some articulated reasoning with some rationale
`underpinnings to support the legal conclusion of obviousness.” In re
`Kahn, 441 F.3d 977, 988 (Fed. Cir. 2006) (POR at 31).
`
`• “If the proposed modification or combination of the prior art would
`change the principle of operation of the prior art invention being
`modified, then the teachings of the references are not sufficient to render
`the claims prima facie obvious.” MPEP § 2143.01(VI) (2015) (citing In
`re Ratti, 270 F.2d 810, 813 (CCPA 1959)) (POR at 32).
`
`TriPlay, Inc.
`
`26
`
`
`
`Petitioners Offer No Motivation To Combine Coulombe
`and Druyan
`Purported Motivation
`
`“Druyan and Coulombe are
`analogous references in the
`same
`field of
`converting
`messages (such as HTML
`documents) into a form that
`can be displayed on smaller
`devices with reduced screen
`sizes.” Pet. at 48.
`
`Purported Motivation Does Not Support
`Combination
`• Even if analogous, Petitioners still fail to
`explain how Druyan’s XSLT style sheet
`teachings provide advantages over
`Coulombe’s method of adaption.
`
`• Coulombe teaching: “methods to adapt Web
`pages to different end users … can’t be
`applied directly to all applications” and
`Petitioner’s expert is incorrect to discount
`teaching. POR at 9-10 (emphasis added).
`
`• Druyan converting XML to HTML. POR at
`44.
`
`TriPlay, Inc.
`
`27
`
`
`
`Petitioner Offers No Motivation To Combine Coulombe
`and Druyan
`Purported Motivation
`
`Coulombe
`fact,
`“In
`specifically discloses the
`ability to convert
`input
`formats using XHTML, a
`format that encapsulates
`HTML within XML.”
`Pet. at 48-49.
`
`Purported Motivation Does Not Support
`Combination
`• Coulombe does not teach or suggest
`that XHMTL is anything but one of
`many formats handled by messaging
`system. POR at 11.
`• A POSITA would recognize that
`XHTML in messaging is far more
`limited and would not be compatible
`with Druyan. POR 12.
`
`TriPlay, Inc.
`
`28
`
`
`
`Petitioners Offer No Motivation To Combine Coulombe
`and Druyan
`Purported Motivation
`
`“One of ordinary skill in the art
`would
`have
`found
`no
`technological obstacle to, and no
`teaching away from, adapting the
`style sheet teachings of Druyan
`and Tittel to the SIP messaging
`system of Coulombe.”
`Pet. at
`49.
`
`Purported Motivation Does Not Support
`Combination
`• Technical obstacle is not sufficient. In re
`Omeprazole Patent Litigation, 536 F.3d 1361 (Fed.
`Cir. 2008) (POR at 31).
`• Coulombe teaching: “methods to adapt Web pages
`to different end users … can’t be applied directly to
`all applications” and Petitioners’ expert is incorrect
`to discount teaching. POR at 9-10.
`• Reply incorrectly contends Patent Owner’s
`argument is “based on the false assumption that
`HTML and style sheets are relevant only to web
`browsing.” Reply at 19.
`
`TriPlay, Inc.
`
`29
`
`
`
`Combining Coulombe And Druyan Would Hinder Coulombe’s Basic
`Principle Of Operation
`• Coulombe’s flexible system requires ad-hoc decision process for delivery decisions. A
`POSITA would find no advantages to using Druyan’s derivative style sheets.
`
`• Druyan’s advantages: only where delivery decisions can be reasonably restricted to
`obtain processing benefits. POR at 53.
`
`• Restricting message content and delivery flexibility is contrary to Coulombe;
`combining with Druyan hinders basic principle of operation. POR at 46.
`
`• Druyan would require incoming messaging restrictions. POR at 47-48.
`
`• Flawed premise: “one of ordinary skill in the art would understand that XSLT style
`sheet file 230 may be incorporated into an HTML file via link tag.” Klausner Decl.,
`¶ 106. XHTML (with full structure XML) required. POR at 47.
`
`• Druyan’s derivative style sheets would hinder Coulombe delivery decision. POR at
`49-50. A negative regardless of when the derivative style sheets are created but worse
`if defined in advance, as argued for purposes of disclosing a delivery decision based
`on a predefined layout. POR at 50.
`
`TriPlay, Inc.
`
`30
`
`
`
`Motivation Of “Consistent Formatting Of The Input Data”
`Is Not A Basis To Combine
`Purported Motivation
`Purported Motivation Does Not Support
`Combination
`• Consistent formatting of the input
`data appears to be referring to the
`use of structured XML. Structured
`XML is inconsistent with
`Coulombe. POR at 47-48
`• Motivation appears to be referring
`to motivation of message sender.
`
`the
`of
`sender
`the
`“Because
`message is the creator of both the
`content and the accompanying
`style sheet template, style sheets
`would offer to the message sender
`precisely
`the
`same
`set
`of
`advantages
`as
`to
`a website
`For example, with
`designer.
`respect to Druyan, a person of
`ordinary skill
`in the art would
`have understood the advantage of
`using a style sheet
`in light of
`consistent formatting of the input
`data.” Reply at 21 (italics and
`bold added; underline in original).
`
`TriPlay, Inc.
`
`31
`
`
`
`Alleged Reply Motivation That Druyan Not Limited To
`XSLT And Java Code Can Include CSS
`Purported Motivation Purported Motivation Does Not Support Combination
`• Petition relied on Druyan’s disclosure of an XSLT
`“Druyan techniques ‘can
`be implemented in a
`master style sheet and XSLT derivative style sheets
`variety of programming
`for template and predefined layout limitation. Pet. at 45
`languages,’ …. One of
`and 50-51.
`ordinary skill in the art
`• Druyan’s derivative style sheets require removing
`would have understood
`that Druyan’s ‘.jsp style
`elements from the master style sheet. POR at 21
`sheet files’ used in the
`(citing to Druyan, 2:52-54 and Fig. 4)
`JSP technique can
`• CSS style sheets cannot remove elements. POR at 15
`include code written in
`(citing to Dr. Surati Decl., ¶ 53.
`CSS.” Reply at 23.
`• Dr. Surati did not testify that CSS can perform the same
`function as XSLT. Asked nothing other than whether it
`can perform inputs and outputs. Surati Dep. 81:22-
`82:20.
`
`TriPlay, Inc.
`
`32
`
`
`
`Dr. Surati Testimony Re CSS Versus XSLT
`
`TriPlay, Inc.
`
`33
`
`
`
`Motivation That XSLT Versus CSS Is A Design Choice Is
`Not A Basis To Combine
`Purported Motivation
`
`“…a person of ordinary skill in the art
`would have found Druyan’s style sheets
`applicable in any context where a
`master style sheet and derivative style
`sheets could be used to create different
`HTML inputs based on a certain input
`(e.g., content of the message). The
`particular implementation of the input
`and style sheets, whether it uses
`XML/XSLT or HTML/CSS, is merely
`a routine design choice that has no
`bearing on whether a person of ordinary
`skill in the art would have combined
`Druyan with Coulombe.” Reply at 23-
`24 (emphasis added).
`
`Purported Motivation Does Not Support
`Combination
`• Petition relied on Druyan’s
`disclosure of an XSLT master style
`sheet and XSLT derivative style
`sheets for template and predefined
`layout limitation. Pet. at 45 and 50-
`51.
`• Druyan’s derivative style sheets
`require removing elements. POR at
`21 (citing to Druyan, 2:52-54 and
`Fig. 4)
`• CSS cannot alter the elements of the
`input document. POR at 15 (citing to
`Dr. Surati Decl., ¶ 53).
`
`TriPlay, Inc.
`
`34
`
`
`
`Petitioners’ CSS Style Sheet Reply Arguments Do Not
`Support Obviousness As To Claim 6
`Petitioners’ Arguments
`Reply Arguments Do Not Support Obviousness
`
`“Presentation nature of CSS style
`sheets is irrelevant.” Reply at 24.
`“The use of CSS to implement the
`layout adaption described in
`Coulombe for Certain HTML
`messages – specifically, those
`having an initial layout based on a
`style sheet template – would not
`hinder or impair the system’s ability
`to receive other types of messages
`(e.g., messages in formats other
`than HTML), or adapt the layout of
`these messages using techniques
`other than CSS. “ Reply at 25.
`
`• Petitioner does not contend that Tittel
`discloses the “predefined layout” limitation.
`POR at 39.
`• Petitioner cited to Druyan’s derivative style
`sheets for the “predefined layout” limitation.
`Pet. at 51.
`• The presentation nature of CSS is irrelevant
`because message designer is not content
`creator; no motivation to combine consistent
`look and feel capability to a messaging
`system. POR at 54-55.
`• Petitioners’ contention – “would not hinder or
`impair” is not a motivation.
`
`TriPlay, Inc.
`
`35
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
