U.S. Patent No. 7,356,482
`Inter Parte- Review
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`Patent Owner’s Response
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`Case Nos. IPR2015-01750
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`IPR2015-01751
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`IPR2015-01752
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`RPX CORPORATION
`Petitioner
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`v.
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`APPLICATIONS IN INTERNET TIME LLC,
`Patent Owner
`____________________
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`US Patent No. 7,356,482
`Issue Date: July 9, 2013
`Title: Integrated Change Management Unit
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`US Patent No. 8,484,111
`Issue Date: July 9, 2013
`Title: Integrated Change Management Unit
`____________________
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`Inter Parte Review Nos. 2015-01750; 2015-01751; 2015-01752
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`________________________________________________________________
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`PATENT OWNER’S RESPONSE TO THE PETITIONS1
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`                                                            
`1 This is a single Response addressed to all three cases and, therefore, the identical
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`document is being filed in each case.
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`U.S. Patent No. 7,356,482
`Inter Parte- Review
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`Patent Owner’s Response
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`TABLE OF CONTENTS
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`Introduction ...................................................................................................... 1
`I.
`II. Background and Summary of Argument .......................................................... 4
`A.
`Related Matters ...................................................................................... 4
`B. Grounds Upon Which Trial was Instituted ........................................... 4
`C.
`The Integrated Change Management Unit ............................................ 6
`III. RPX is a Proxy for Real Party in Interest Salesforce.com, Inc. ....................... 8
`IV. Claim Construction ........................................................................................... 8
`A.
`Plain and Ordinary Meaning Standard .................................................. 9
`B.
`Level of Skill of a POSITA ................................................................. 10
`C.
`Construction of Specific Terms ........................................................... 11
`D.
`The “automatically detecting” step ..................................................... 20
`E.
`“The fourth portion” or “the fourth portion of the server”
`element ................................................................................................ 20
`The “intelligent agent” element ........................................................... 21
`F.
`V. The Petition Fails to Show that Any Claim is Invalid .................................... 22
`A.
`Popp does not include a “change management layer”,
`“automatically detect “changes” or include a “fourth portion”
`and therefore cannot anticipate any claims of the ‘482 patent or
`the ‘111 patent ..................................................................................... 22
`B. Kovacevic does not disclose a “change management layer”,
`“automatically detecting a change” or the “fourth portion” and
`therefore cannot anticipate any claims of the ‘482 patent or the
`‘111 patent ........................................................................................... 25
`Balderrama does not disclose a “change management layer”,
`“automatically detecting a change” or a “fourth portion” and
`therefore cannot render any claims of the ‘482 patent or the
`‘111 patent obvious ............................................................................. 28
`VI. Conclusion ...................................................................................................... 32
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`C.
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`U.S. Patent No. 7,356,482
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`Patent Owner’s Response
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`CASES
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`In re Cuozzo Speed Technologies, LLC, 778 F. 3d 1271
` (Fed. Cir. 2015) ............................................................................................ 8, 9, 10
`In re Man Mach. Interface Techs. LLC, 2016 U.S. App. LEXIS 6992 (Fed. Cir.
`Apr. 19, 2016) .....................................................................................................2, 9
`In re NTP, Inc., 654 F.3d 1279 (Fed. Cir. 2011) ....................................................... 9
`Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) ........................................... 9
`Verdegaal Bros. v. Union Oil Co. of California, 814 F.2d 628
` (Fed. Cir. 1987) ..................................................................................................... 22
`Wellman, Inc. v. Eastman Chem. Co., 642 F.3d 1355 (Fed. Cir. 2011) .................... 2
`STATUTES
`35 U.S.C. § 103(a) .................................................................................................5, 6
`35 U.S.C. 102 .............................................................................................. 4, 5, 6, 22
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`U.S. Patent No. 7,356,482
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`Patent Owner’s Response
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`I.
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`Introduction
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`Patent Owner Applications in Internet Time, LLC hereby files this combined
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`Response in three related cases. Two of the cases are directed to Patent No.
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`7,356,482 (the ‘482 patent), and one is directed to its child, Patent No. 8,484, 111
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`(the ‘111 patent).2 Because of the close relationship between the patents and the
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`relevant issues, for efficiency and consistency Patent Owner presents a single
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`Response which addresses all three cases.3
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`Patent Owner respectfully asks that the Board change its petition-stage
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`decisions in these three and confirm patentability. At the petition stage, the only
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`evidence of how a person of ordinary skill in the art would interpret the cited art
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`was the Petitioner’s expert. Patent Owner now submits the opinions of two,
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`independent experts. These two experts agree that Petitioner’s expert clearly erred
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`2 Because the ‘111 patent is a continuation of the ‘482 patent, they have
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`substantially identical specifications and drawings. Citations to the specification
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`are to the ‘482 patent and documents in IPR2015-01751 unless otherwise expressly
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`indicated.
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`3 Rather than file three Responses of up to 60 pages each – a total of 180 pages, this
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`single Response is less than 60 pages. 
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`U.S. Patent No. 7,356,482
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`in several determinative ways. Patent Owner’s experts also provide useful and
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`compelling evidence on how the claims must be interpreted.
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`The Board declined to construe any claim terms even though both Patent
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`Owner and Petitioner RPX (“RPX”) proposed claim constructions. Petitioner, on
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`its part, proposed and relied upon an overly-broad construction of the term “change
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`management layer” in the ‘482 patent and “fourth portion” in the ‘111 patent, and
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`the associated term “change.” Because construction of these terms is necessary to
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`“resolve the controversy” they should be construed. Wellman, Inc. v. Eastman
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`Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011).
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`The lack of construction of these terms led to the Board’s determination that
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`claims 1, 7, 8, 10–12, 19–21, 27–32, 39, and 40 of the ‘482 patent and claims 13-
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`18 of the ‘111 patent are invalid. The Board relied upon a non-construction
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`(IPR2015-01751, Ex. 62 at 19) which, by applying the art cited by the Petitioner,
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`depended upon Petitioner’s flawed proposed construction. Most basically,
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`Petitioner’s construction, relied upon by the Board, divorces the claims from the
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`meaning imputed to them by the specification. In In re Man Mach. Interface
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`Techs. LLC, 2016 U.S. App. LEXIS 6992 (Fed. Cir. Apr. 19, 2016), the court held
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`that the broadest reasonable interpretation must be reasonable in light of the claims
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`and the specification.”
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`Patent Owner respectfully submits that the Board must construe the terms
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`“change management layer,” “fourth portion” and “changes” as the Federal Circuit
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`requires – in light of the specification and from the perspective of one of ordinary
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`skill in the art. In a proper construction, the “change management layer” and the
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`“fourth portion” “detect changes which impact how the application program should
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`operate”. The associated “changes” “arise from changes external to the application
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`program.” Two experts representing both academia and industry agree here on that
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`construction, and the Board should adopt these experts’ views.
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`Each of the references relied upon by the Petitioner and in turn applied by
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`the Board discloses user interface interactions with an application – typically
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`inputting of data into a web form. Petitioner argued that these user interface
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`interactions satisfy the “change management layer” and “fourth portion” limitation
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`in the claims. Yet, at least to a person of ordinary skill in the art, these are clearly
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`not the “changes” that the “change management layer” or the “fourth portion”4
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`detect. Therefore, none of the cited references can anticipate or render obvious the
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`claims of the ‘482 patent or the ’111 patent.
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`4 The “change management layer” appears in claim 1 of the ‘482 patent. The
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`“fourth portion of the server” appears in claim 13 of the ‘111 patent.
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`Patent Owner respectfully requests entry of a Final Decision confirming the
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`patentability of the claims of the ‘482 patent, and the ‘111 patent.
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`II. Background and Summary of Argument
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`A. Related Matters
`Petitioner identified the related matters in its Petition that was filed on
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`August 17, 2015, which include Applications in Internet Time, LLC v.
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`Salesforce.com, Inc., No. 3:13-cv-00628, which is currently pending in the United
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`States District Court for the District of Nevada.
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`B. Grounds Upon Which Trial was Instituted
`After summarizing in this section the grounds upon which trial was
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`instituted, the grounds are addressed in detail below.
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`1. ‘482 patent, 1751 case
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`In the Decision on Institution of Inter Partes Review dated February 25,
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`2016 in IPR2015-01751 (“the ‘482 Decision”), the Board instituted the current trial
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`for U.S. Patent No. 7,356,482 (the “’482 patent”) on the following grounds (Dkt.
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`51):
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`Ground 1: Claims 1, 7, 8, 10–13, 18–21, 27–33, and 38–40 as anticipated
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`under 35 U.S.C. § 102(e) by Popp;
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`Ground 2: Claims 13–17 and 33–37 as obvious under 35 U.S.C. § 103(a) in
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`view of Popp and Anand;
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`Ground 3: Claims 1, 8, 10, 19–21, 28, 30, 39, and 40 as anticipated under 35
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`U.S.C. § 102(b) by Kovacevic; and
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`Ground 4: Claims 1, 7, 8, 10–12, 19–21, 27–32, 39, and 40 as obvious under
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`35 U.S.C. § 103(a) in view of Balderrama and Java Complete.
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`2. ‘482 patent, 1752 case
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`In the Decision on Institution of Inter Partes Review dated February 25,
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`2016 in IPR2015-01752, the Board instituted the current trial on the following
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`grounds (Dkt. 51):
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`Ground 1: Claim 22 as anticipated under 35 U.S.C. § 102(e) by Popp;
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`Ground 2: Claims 3-6 and 23-26 as obvious under 35 U.S.C. § 103(a) in
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`view of Popp and Codd;
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`Ground 3: Claim 22 as obvious under 35 U.S.C. § 103(a) in view of
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`Baldarrama and Java Complete;
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`Ground 4: Claims 3-6 and 23-26 as obvious under 35 U.S.C. § 103(a) in
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`view of Balderrama, Java Complete, and Codd.
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`Ground 5: Claims 3-6 and 23-26 as obvious under 35 U.S.C. § 103(a) in
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`view of Kovacevic and Codd.
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`3. ‘111 patent, 1750 case
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`In the Decision on Institution of Inter Partes Review dated February 25,
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`2016 in IPR2015-01750 (the “’111 Decision”), the Board instituted the current trial
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`for U.S. Patent No. 8,484,111 (the “’111 patent”) on the following grounds (Dkt.
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`51):
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`Ground 1: Claims 13-18 as anticipated under 35 U.S.C. § 102(e) by Popp;
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`Ground 2: Claims 13-18 as anticipated under 35 U.S.C. § 102(b) by
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`Kovacevic;
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`Ground 3: Claims 13-18 as obvious under 35 U.S.C. § 103(a) in view of
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`Baldarrama and Java Complete;
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`C. The Integrated Change Management Unit
`The ‘482 patent discloses an integrated change management unit that
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`identifies changes in the regulatory and non-regulatory environment for business
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`activities and updates or suggests updates to an application in response to those
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`identified changes because they affect the application. Examples of regulatory
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`changes include changes in environmental, health and safety laws (‘482 patent, col.
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`1, lines 4-6). Examples of regulated activities include environmental health and
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`safety, agricultural activities, and treatment and disposal of nuclear materials, to
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`name a few.
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`The ‘482 patent provides an example in the hazardous substance industry
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`and explains that since 1969, there has been an increase in new laws directed to
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`regulating hazardous substances. In addition, some states have even passed their
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`own state regulations directed to hazardous substances. (col. 2, lines 12-24). With
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`the increasing pace of new regulations being passed, there is a need for a system
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`that can integrate these new laws into existing platforms without requiring users to
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`re-program the system.
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`Due
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`to
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`these constantly changing regulations
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`in various business
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`environments, the ‘482 patent explains that many attempts had been made to
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`handle these regulatory requirements. Most of these solutions rely upon manually
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`updating software through employing programmers to alter existing software and
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`databases in response to external changes. The ‘482 patent explains that previous
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`systems failed to provide a “closed loop” approach that identifies changes using
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`intelligent network agents, recommends modifications to the business content, and
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`automatically makes or suggests modifications in the system without the use of
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`programmers and/or programming. (col. 7, lines 47-67).
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`The system disclosed in the ‘482 patent was designed to address that very
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`issue – namely to enable an application to detect changes that affect it and to
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`automatically adapt the system to the changes detected. In order to achieve this, the
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`‘482 patent discloses a multilayer application system that detects the changes in the
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`regulatory and non-regulatory laws that arise in various commercial and industrial
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`activities.
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`III. RPX is a Proxy for Real Party in Interest Salesforce.com, Inc.
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`In its decision instituting these three trials, the Board stated that there was
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`insufficient evidence to find that the real party in interest is Salesforce.com, Inc.
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`Patent Owner disagrees with the Board’s view of the law and the facts, and in
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`particular believes that the Board misconstrued the law. As explained previously,
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`the AIA was intended to prevent defendants from getting “a second bite at the
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`apple.” Yet, the Board is doing just that by allowing Petitioner to act indirectly for
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`Salesforce. In its decision, the Board set an improperly high burden of proof for the
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`patent owner, and also improperly shifted the burden of proof to the patent owner.
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`As explained in Patent Owner’s Preliminary Response, Salesforce is the real party
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`in interest and Petitioner is acting as its proxy. Because Salesforce is time limited,
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`so is Petitioner and patentability should be confirmed on this basis.
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`IV. Claim Construction
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`Claims in an IPR are currently interpreted according to their broadest
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`reasonable interpretation. In re Cuozzo Speed Technologies, LLC, 778 F. 3d 1271
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`(Fed. Cir. 2015). The current standard for claim construction by the Board is the
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`broadest reasonable interpretation viewed in light of the specification and the
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`record evidence.” In re NTP, Inc., 654 F.3d 1279, 1288 (Fed. Cir. 2011).
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`“Reasonable” breadth is taken from the perspective of one of ordinary skill in the
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`art at the time of filing the priority application. Phillips v. AWH Corp., 415 F.3d
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`1303, 1316 (Fed. Cir. 2005). Further, reasonableness is limited to reasonableness
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`in view of the specification. In re Man Mach. Interface Techs. LLC, 2016 U.S.
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`App. LEXIS 6992 (Fed. Cir. Apr. 19, 2016). Patent Owner therefore presents its
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`arguments below as currently legally required — under the broadest reasonable
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`interpretation of the claims in light of the specification taken from the perspective
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`of one of ordinary skill in the art at the time of filing the priority application
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`Plain and Ordinary Meaning Standard
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`A.
`The application of the broadest reasonable interpretation standard to IPR
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`proceedings is presently being challenged in the U.S. Supreme Court in Cuozzo
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`Speed Technologies, LLC v. Lee (2016). The patent owner in Cuozzo argues that
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`the plain and ordinary meaning standard typically used in district court litigation
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`should apply, and Patent Owner agrees. Most relevant here, claims are construed in
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`a district court with a view to maintaining validity because the patent owner is
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`unable to amend. See, e.g. Phillips v. AWH Corp., 415 F.3d 1303, 1327 (Fed. Cir.
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`2005) (describing the statutory presumption of patent validity). As made plain in
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`the Cuozzo briefing and oral argument, although the IPR process allows a patent
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`owner to move to amend, there is no automatic right to amend, and de facto the
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`patent owner is unable to amend.
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`B.
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`Level of Skill of a POSITA
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`Patent Owner does not dispute Petitioner’s definition of the person of
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`ordinary skill in the art (“POSITA”). See Petition, p. 5-6 (“at least a B.S. in
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`Computer Science or the equivalent, along with at least two years of computer
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`programming experience in developing applications for client-server systems”), in
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`the relevant time period of 1998.
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`Patent Owner provides expert declarations from two experts on the issue of
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`claim construction. The first expert, Dr. H. V. Jagadish, is currently a professor of
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`Electrical Engineering and Computer Science at the University of Michigan. He is
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`qualified to testify as to claim construction because at the relevant time period,
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`namely 1998, Dr. Jagadish was an engineer at AT&T. In his role at AT&T, he
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`directed and led a team of engineers in the database department that comprised of
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`engineers who were considered POSITAs. He also brings an academic’s
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`perspective.
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`The second expert, Mr. James Flynn, is a computer science industry
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`professional, and has held senior management technical roles at a variety of
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`technical companies. By 1998, Mr. Flynn had worked as a technical executive in
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`three different technical companies, and was the Co-founder of @Work
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`Technologies located in New York. As co-founder, Mr. Flynn had an opportunity
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`to directly manage engineers who were POSITAs in 1998. The opinions of two
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`different experts, one currently in academia, and one an industry professional, are
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`provided to clarify what a POSITA would have understood in the relevant time
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`period, namely 1998.
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`The views of Petitioner’s expert, Dr. Crovella, merit far less weight than Dr.
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`Jagadish or Mr. Flynn. In 1998, Dr. Crovella was working primarily in academia,
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`not in industry. Dr. Crovella therefore was already considerably more than
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`ordinary, and was surrounded by graduate students, themselves not ordinary. [cite
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`to Jag] Thus, Dr. Crovella’s testimony about a POSITA is at best speculative. [cite
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`to supreme court case about experts]
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`C. Construction of Specific Terms
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`1. “Application” or “application program”
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`The appropriate definition of “application” or “application program” is “a
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`higher level program for use by an end-user to perform specific kind of work that
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`is useful to the end-user; its work is not related to the computer itself, and therefore
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`is not a utility.” (Ex. 2032, ¶ 23) While an application program can perform
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`specific tasks, its purpose is broader – performing useful work. (Id.).
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`This definition comports with Petitioner’s own dictionary definitions:
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` Webster’s: “A program that enables you to do something useful with
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`the computer, such as writing or accounting (as opposed to utilities,
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`programs that help you maintain the computer).” Ex. 1009, p. 30.
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`Webster’s explains that an application program “transforms the
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`computer into a tool for performing a specific kind of work, such as
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`word processing, financial analysis (with an electronic spreadsheet),
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`or desktop publishing.” Ex. 2023, p. 418.
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` Barron’s: “a computer program that performs useful work not related
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`to
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`the computer
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`itself. Examples
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`include word processors,
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`spreadsheets, accounting systems, and engineering programs.
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`Contrast UTILITY; OPERATING SYSTEM.” Ex. 1010, p. 22.
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`In contrast, Petitioner proposed a definition which is unreasonably broad
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`(Ex. 2032, ¶ 24; Ex. 2033, ¶ 23), and limited in almost no regard whatsoever.
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`Petitioner’s expert even admits that under Petitioner’s proposed definition even a
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`single web page (e.g., taken apart from the rest of the web site), seemingly with no
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`other operability whatsoever that is not “directed to maintaining the computer
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`itself” is an “application.” (Crovella Deposition at page 50, lines 15-22).
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`2. “Change management layer”
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`A “change management layer” automatically detects changes external to an
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`application program which impact how the application program should operate.
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`This term appears in claim 1 of the ‘482 patent in the limitation, “a change
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`management layer for automatically detecting changes that affect an application.”
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`Claim 1 states (emphasis added):
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`1. A system for providing a dynamically generated application
`having one or more functions and one or more user interface
`elements; comprising:
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`
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`a server computer;
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`one or more client computers connected to the server
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`computer over a computer network;
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`the server computer
`layer associated with
`a first
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`containing information about the unique aspects of a particular
`application;
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`a second layer associated with the server computer
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`containing information about the user interface and functions
`common to a variety of applications, a particular application
`being generated based on the data in both the first and second
`layers;
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`a third layer associated with the server computer that
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`retrieves the data in the first and second layers in order to
`generate the functionality and user interface elements of the
`application; and
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`U.S. Patent No. 7,356,482
`Inter Parte- Review
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`Patent Owner’s Response
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`for automatically
`layer
`a change management
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`detecting changes that affect an application,
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`each client computer further comprising a browser
`application being executed by each client computer, wherein a
`user interface and functionality for the particular application is
`distributed
`to
`the browser application and dynamically
`generated when the client computer connects to the server
`computer.
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`the Board
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`implicitly and Petitioner explicitly define “change
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`Both
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`management layer” to read on detecting changes internal to an application
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`program. Yet, detecting changes internal to an application program is precisely
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`what the claimed “third layer” does. A POSITA clearly would recognize this.
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`(see, e.g. Ex. 2032, ¶¶ 34-36)
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`The term “change management layer” is not a term of art. However, the term
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`“change management layer” when interpreted in view of the specification would
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`readily be understood to a person of ordinary skill in the art to mean “a layer that
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`automatically detects changes external to the application program which impact
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`how the application program should operate.” (Ex. 2032, ¶ 27; Ex. 2033, ¶ 27) The
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`‘482 patent includes an extensive description of the change management layer,
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`sometimes referred to as the “change layer:” In particular, the ‘482 patent states
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`(col. 9, lines 33-38):
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`The system operates at four layers, as illustrated in FIG.
`1: (1) a change management layer 11 that includes one or
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`more change agents that "cruise the Web" and identify and
`bring to the user's attention relevant regulatory and non-
`regulatory changes found on the Web that may affect a
`user's business; (2) a Java data management layer 13, a user
`interface, built using the Java language, that applies metadata
`attributes
`to business and business-change related data
`(regulation-based or non-regulation-based); (3) a metadata layer
`15 that provides and/or defines data about every feature of the
`user interface including, without limitation, tools, worklists,
`data entry forms, reports, documents, processes, formulas,
`images, tables, views, columns, and other structures and
`functions; and (4) a business content layer 17 that is specific to
`the particular business operations of interest to the user.
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`Figure 1 of the ‘482 patent shows a change layer that is separate from the
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`three other layers of the system:
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`U.S. Patent No. 7,356,482
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`As seen in the figure, the system comprises four separate layers: 1) the
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`change management layer (the “Change Layer”); 2) the Java Data Management
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`layer; 3) the Metadata layer, and 4) the Business Content Layer. The specification
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`explains that the “change layer primarily involves an intranet or the Internet and
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`uses one or more intelligent agents (IA’s) that continually search on the Web for
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`relevant changes in a selected business area. The changes may be regulatory and/or
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`non-regulatory, and each IA is defined by rules and constraints that focus on the
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`selected business area. When an IA discovers a relevant change, the IA obtains all
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`available information concerning this change and delivers this information to the
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`Java data management layer.” (col. 16, lines 17-34) (Ex. 2032, ¶¶ 32-34; Ex. 2033,
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`¶¶ 33-34).
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`Directly under the Change layer in figure 1, it states, “Changes are identified
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`on the Internet using Intelligent Agents and provided for configuration”. The ‘482
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`patent then explains that an intelligent agent is a “specialized program that makes
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`decisions and performs tasks based on predefined rules and objectives. An IA can
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`be used to identify changes in laws, statutes, ordinances, regulations and related
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`issues, changes in technical requirements, to provide feedback, and to perform
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`Change Configuration tasks.” (col. 19, line 66-col. 20, line 6). All of these
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`“changes” shown in the ‘482 patent are all “external to the application program.”
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`Importantly, the associated changes cause “creation and change” of “intelligent
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`manual routines, such as intelligent agents, screens, fields, reports, documents, and
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`logic” “without requiring programming skills”. (col. 10, lines 3-14).
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`Finally, it would be nonsensical for application-internal “changes” to be the
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`“changes that affect the application”. These types of changes have taken place
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`since the first application was compiled. (see, e.g. Ex. 2032, ¶¶ 44, 68) The
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`specification includes an example that highlights that the definition proposed by
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`the Patent Owner for the “change management layer” and the associated “change”
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`are the broadest reasonable interpretation when read in light of the specification.
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`The ‘482 patent explains that regulations and technical requirements are constantly
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`changing, and that these changes are posted in various media, including paper,
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`microfiche and electronic media. The example in the ‘482 patent states (col. 10,
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`lines 21-60) (emphasis added):
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`Assume that a federal regulation, governing disposal of
`hazardous waste in landfills, is amended so that the regulation
`now requires analysis, reporting and record keeping of landfill
`samples. Part of the change language addresses what landfill
`sample information must be collected, including landfill type,
`landfill cell, parameter(s) sampled, identification of chain-of-
`custody, and laboratory results. The change is posted in the
`Federal Register and becomes promptly available as a hard
`copy (paper) and electronically, on the Internet.
`The invention begins tracking change using one or more
`intelligent agents ("IA's"). An "intelligent agent"
`is a
`specialized program that resides on a network, or at a server as
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`an applet, and can make decisions and perform tasks based on
`pre-defined rules. Preferably, two or more IA's used by a
`business will have sufficiently different assignments that at
`most modest overlap occurs between the IA's. An IA function is
`part of the Logic Menu, which is discussed subsequently.
`A change made to landfill waste regulations is identified
`by an IA on the Internet, and the relevant change information
`is routed to a selected metadata table in the invention. The
`change
`information
`includes one or more of
`five
`recommendations: (1) create a new WorkList; (2) change one or
`more data entry forms; (3) create one or more new reports; (4)
`create a new process; and (5) add one or more new document
`images. Configuration Users can choose to automatically
`configure the preceding recommendation based on a set of
`default
`conditions, or
`can manually
`implement
`the
`configuration using a configuration toolkit.
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`The term “change management layer” would be understood to one of
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`ordinary skill in the art as “a layer that automatically detects changes which
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`impact how the application program should operate.” (Ex. 2032, ¶ 27; Ex.
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`2033, ¶ 26) The associated “changes” “arise from changes external to the
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`application program.” (Ex. 2032, ¶ 27; Ex. 2033, ¶¶ 27-28) Even Petitioner’s
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`expert, Dr. Crovella, deposition testimony suggests that this is an appropriate
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`definition (Ex. 2031, p.52, line 18-p. 53, line 25, emphasis added):
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` 18 Q. The first -- the lines I indicated: 33
` 19 through 38, "The system operates at four layers, as
` 20 illustrated in Figure 1: a change management layer
` 21 11 that incl