Petitioner RPX’s Demonstratives
`November 8, 2016 Oral Argument
`
`RPX Corporation, Petitioner
`v.
`Applications In Internet Time LLC, Patent Owner
`
`IPR2015-01750, Patent 8,484,111
`
`IPR2015-01751, IPR2015-01572, Patent 7,356,482
`
`1
`
`

`
`POR, Paper 63 in IPR2015-01750 and -01752, Paper 65 in IPR2015-01751
`
`2
`
`

`
`(12:
`
`Sllklli £1 IL
`
`Patent
`
`USC063d12:S7|}l
`our |'areut Nu.:
`US 5.341.287 Bl
`Jul. 22, IIIIZ
`(:5) Date of Patent:
`
`.
`
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`An iateyatetl system fur managing changes in regulatory
`mt nun-tngnlflnry requtmmnislm basamucttviii-.su an
`tmaturatoieemmucial I'an'lfl,y.A|1yliealinn cflhis system
`rm-.m-tmnmtmtaL healfla and safely mitrilita, and to fund.
`drag.maane1ir:. and medical treatment anddevioe activities.
`In: discussed u mmptca 'IItc. sysfllni pluvichs nm: or
`male dntahlstu that contain l|'llfllllIll.lDll on operation and
`mquilcnlsnls mutxming an actitrily ur ma nr lcntsinuss:
`receive: information on regulatory and Jinn-regulatory
`dmwastl-at rem uqteralitatu nftlte ragtime: converts um
`change. Inn changer: ln am army fenmz, dan meaning
`and Innlyiéi pmoedurenand pmtemtlon thy prlItlitI3, elec-
`Imnle displny arid-tor dlaui-mlo-1) at tlm pvomslnu and
`analysis reatlts to seleued recipients. without requiring nu
`serviecs of one or more pogrmmurs Ill relttey androi-
`rctlerrnu the nuns cheered by It: charge: and ianplemetas
`receipt or change iahrmaubu ml dissemimrlmt of data
`processing and aaalyaia it-sate lining file rmlitiee arm
`Internet.
`
`What is claimed is:
`tracks a controlled release or
`a fifth database that
`1. Asystem for monitoring processing and disposition of
`discharge of a material to the environment, the fifth
`10 at least one material used in a business at a facility, the
`database including information on discharge of at
`system comprising:
`least one hazardous substance into at least one of the
`a first database that provides product stewardship for at
`air, ihe water, the groundwater and the soil at the
`least one selected material
`that is received, created,
`facility, and information on at least one toxic chemi-
`consumed or produced as awaste product at the facility,
`cal release at the facility;
`the first data base including information on at least one
`it sixth database that provides selected information on
`product produced at the facility, information on eco-
`regulatory requirements for receiving, handling. pro-
`logical and toxicological studies performed at
`the
`cessing or producing hazardous materials. the sixth
`facility,
`information for production of a Materials
`database including information on at least one euvi»
`Safety Data Sheet (MSDS) for at least one material
`ronmental audit conducted at the facility, informa-
`used at
`the facility, and tracking of allegations and
`tion on regulatory lists used at, and on regulatory
`inquiries concerning operations at the facility; and
`issues concerning, the facility. and information on at
`at least one additional database, drawn from the following
`least litigation issue concerning the facility; and
`group of databases:
`a. seventh database that provides selected information
`a second database that allows traclring and prevention
`on management of the facilitst. the seventh database
`of selected incidents involving uninteentled discharge
`including information on at least one of the physical
`of a material at
`the facility, the second database
`structure and the organizational structure at
`the
`including information on response to at least one
`facility.
`information on tracking of at
`least one
`type of emergency at
`the facility, information on
`tracking of at least one incident at the facility. and
`equipment item at the facility, and information on at
`least one pmcnss used at the facility;
`safety irrlorrnation on at least one process used at the
`a tools module that provides software for at least one of 5
`f3°fli1lv'3
`creation of a report on operations at the facility, cre-
`third dfililbasc "131 IJl’0VidBS information 051 and
`tllion of formulas and exprcaions for a. report on
`“3°5'il'°1'i“8 Of P°'3°m1°1 11°31‘-h “Dd 3af°1Y 31 “W
`opefgfigns’ cfggfiofl of at least one image for 3 [gpgfl an
`Eflfllllly, l.l]C lhlfd database lllfilllfllflg lDf0ITI]3llC|l‘l OI]
`operations, archiving of at
`least one record on
`dCl'«D°3|'3Pl1i¢5 Of Pt‘rTS0flflt~’«l Wtlfkiflg 31 1513 facility.
`gP¢rgt_[on3, and 5q;;ufi[y m¢,a,u;;_¢, implgmgntgd at 151.;
`information on personnel training, information on
`safety measures implemented at the facility; injuries
`facility, and that
`implements entry of one or more
`and illnesses experienced by at least one worker at
`changes in regulatory and non-regulatory reqttiremenrs
`the facility, and information on industrial hygiene
`for the business without requiring manual reprogram-
`and occupational medicine studies carried out at the
`(',tJttmt_t7ttint:|ttu;|L5|]Et:t|.t5
`ming of the tools module software; and
`facility;
`rttnusrat
`TM N
`..i ll
`a relational database managctne ut module that linlts each
`"“"5
`a fourth database that provides information on and
`datahase to each other database and to the tools module
`monitoring of hazardous materials and hazardous
`Ex. 1011 in IPR2015-01750; Ex. 1013 in IPR2015-01751; Ex. 1113 in IPR2015-01752
`l'nl!l£5. VEM. FUNDTIDE MD
`so that an information item, once entered, becomes
`Pt1EE.llilJLFEE.lFE.Al3l3EJ BY
`waste, the fourth database including information on
`available to each database and to the tools module.
`ENE LRR Fljtlillllli lt'lIl LETADAIA
`at least one hazardous material used at the facility,
`tracking of at lest one waste material produced at
`the facility, information on at pollution prevention
`measures and on site remediation measures imple-
`mented at the facility;
`
`]NTFZlllAI'EII CHANGE MANAGFMFNT
`UNTI‘
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`US.(. is-1(a) by 0 days.
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`craters arr |llEl'l'|1Fl' Irt LEN3
`IlTE.lI':‘Elll -H ..ttN|J FIlDI'lDBl FElll lIllI:lG.FltlT||]i
`END USER FUNCTIONS
`EDNFEBURATIDN TDUL5 THAI
`El!lltlBl_EE| EN CDNFIGUMTIUN
`ENABLE THE END USEFI FUNCTIONS
`
`3
`
`

`
`14.
`
`(New) A system, comprising:
`
`a server accessible by a browser executed on a client device, the server including a first
`
`portion, a second portion, a third portion, and a fourth portion,
`
`the first portion of the server having information about unique aspects of a particular
`
`application,
`
`the second portion of the server having information about user interface elements and one
`
`or more functions common to various applications,
`
`the various applications including the
`
`particular application,
`
`the third portion of the server being configured to dynamically generate a functionality
`
`and a user interface for the particular application, the functionality and the user interface of the
`
`particular application being based on the information in the first portion of the server and the
`
`information in the second portion of the server, the third portion of the server being configured to
`
`send the functionality and the user interface for the particular application to the browser upon
`
`establishment of the connection between the server and the client,
`Ex. 1012 at 5 in IPR2015-01750 – from 12/098,154
`the fourth portion of the server being configured to automatically detect changes that
`
`affect the information in the first portion of the server and the information in the second portion
`
`of the server.
`
`4
`
`

`
`(New) A system, comprising:
`
`a server accessible by a browser executed on a client device, the server including a first
`
`portion, a second portion, a third portion, and a fourth portion,
`
`the first portion of the server having infonnation about unique aspects of a particular
`
`application,
`
`the second portion of the server having information about user interface elements and one
`
`or more frmctions common to various applications,
`
`the various applications including the
`
`particular application,
`
`the third portion of the server being configured to dynamically generate a functionality
`
`and a user interface for the particular application, the functionality and the user interface of the
`
`particular application being based on the information in the first portion of the server and the
`
`information in the second portion of the server, the third portion of the server being configured to
`
`send the functionality and the user interface for the particular application to the browser upon
`
`establishment of the connection between the server and the client,
`Ex. 1012 at 5 in IPR2015-01750 – from 12/098,154
`the fourth portion of the server being configured to automatically detect changes that
`
`affect the infonnation in the first portion of the server and the infonnation in the second portion
`
`of the server.
`
`13. A system, comprising:
`a server accessible by a browser executed on a client
`device, the server including a first portion, a second
`portion, a third portion, and a fourth portion,
`the first portion of the server having infonnation about
`unique aspects of a particular application,
`the second portion of the server having information about
`user interface elements and one or more fi111Cti0IlS com-
`
`mon to various applications, the various applications
`including the particular application,
`the third portion of the server being configured to dynami-
`cally generate a functionality and a user interface for the
`particular application,
`the functionality and the user
`interface ofthe particular application being based on the
`information in the first portion of the server and the
`information in the second portion ofthe server, the third
`portion of the server being configured to send the func-
`tionality and the user interface for the p
`' ular appli-
`cation to the browser upon establi
`- u - u
`o
`onnection
`Ex. 1001 at 33:19–34:8 in IPR2015-01750
`the fourth portion of the server being con gured to auto-
`matically detect changes that affect the information in
`the first portion of the serverhe information in the
`second portion of the server.
`
`betweenthe serverand the client
`
`5
`
`EX. 1012 at 5 in lPFf2015-01750 — from 12/098,154
`
`EX. 1001 at 33.'19—34.'8 in IPFr’2015-01750
`
`

`
`14.
`
`(New) A system, comprising:
`
`a server accessible by a browser executed on a client device, the server including a first
`
`portion, a second portion, a third portion, and a fourth portion,
`
`the first portion of the server having information about unique aspects of a articular
`
`Examiner Note
`
`If the examiner had not read the application number she never would have realized that
`
`these claims went with this specification. The claims are extremely generic and broad there is no
`
`mention about regulatory changes or anything that the invention talks about in the first 13 pages
`
`of the specification that the invention is trying to solve/ directed at.
`
`Currently the independent claim has 1) “unique aspect” and 2) “user interface element”
`Ex. 1013 at 7-8 in IPR2015-01750
`Ex. 1012 at 5 in IPR2015-01750 – from 12/098,154
`for a particular application. If you talked to any software developer every project they worked
`
`on has at least these two elements and probably 100% of their software projects.
`
`6
`
`

`
`Change Layer
`
`CHANGES ARE IDENTIFIED ON THE INTERNET USING
`
`INTELLIGENT AGENTS AND PROVIDED FOR CONFIGURATION
`
`ENO USEFI FUNCTIONS
`ENABLED BY CONFIGURATION
`
`CONFIGURATION TOOLS THAT
`ENABLE THE END USEG FUNCTIONS
`
`Java Data Management Layer
`
`13
`
`ENO USER FUNCTIONS ARE ENABLED
`FFIOM NIEIADATA DEFINITIONS
`
`TABLES, VIEWS, FUNCDONS AND
`PROCEDURES ARE ACCESSED BY
`Ex. 1001/1101 FIG. 1
`END USER FUNCTIONS VIA METADATA
`
`|
`
`Metadata Layer
`
`CONFIGURATION TOOLS DEFINE
`END USEFI FUNCTTONS IN METROATA
`
`1 5
`
`L
`MEMDATA REFERENCES TABLES,
`vIEw3_ FUNCTIONS ANEI pngcgnungs
`
`FIG. 1
`
`Business Content Layer
`
`17
`
`7
`
`

`
`Change Layer
`
`INTELLIGENT AGENTS AND PROVIOEO FOR CONFIGURATION
`
`END USEFI FUNCTIONS
`ENABLED BY CONFIGURATION
`
`CONFIGURATION TOOLS THAT
`ENABLE THE END USER FUNCTIONS
`
`Java Data Management Layer
`
`13
`
`FFIUM METADATA DEFINITIONS
`
`OGNRGORATTONTOOLS DEFINE
`
`END USER FUNUNDNS IN METADATA
`
`Metadata Layer
`
`15
`
`TABLES, VIEWS, FUNCTIONS AND
`Ex. 1001/1101 FIG. 1
`Am I
`
`’
`
`HQ‘ 1
`
`Ex_ 1001/1101 F/G_ 1
`
`The system operates at four layers, as illustrated in FIG. 1:
`(1) a change management layer 11 that includes one or 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 aflect 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 pro-
`vides andfor defines data about every feature of the user
`Ex. 1001 at 9:38-52 in IPR2015-01750
`interface including, without limitation, tools, worklists, data
`reports, documents, processes,
`formulas,
`entry forms,
`Ex. 1001/1101 at 9:33-48 in IPR2015-01751 and -01752
`images, tables, views, columns, and other structures and func -
`tions, and (4) a business content layer 1 7 that is specific to the
`particular business operations of interest to the user.
`
`8
`
`

`
`Change Layer
`CHANGES ARE IDENTIFIED DN THE INTERNET USING
`INTELLIGENT AGENTS AND PROVIDED FDR CUNFIGURATIDN
`
`I
`
`END USER FUNCTIONS
`ENABLED BY CONFIGURATION
`Elfl
`
`CONFIGURATION TUCILS THAT
`ENABLE THE END USER FUNCTIONS
`F71 ll
`IE7
`
`Java Data Management Layer
`
`Ex. 1001/1101 FIG. 1
`TAEILEG, VIEWS, FUNCTIONS AND
`PROCEDURES ARE ACCESSED BY
`END USER FUNCHONS WA METADMA
`
`EX. 1001/1101 FIG. 1
`
`The system operates at four layers, as illustrated in FIG. 1:
`(1) a change management layer 11 that includes one or more
`-
`n
`-
`-
`-
`I
`I 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 aflect a user’s business;
`(2) a Java data management layer 13, a user interface, built
`using the Java language, that applies metadata attributes to
`
`I that inc
`(1)21 chalige nianageinent layer 1
`8 1,1561‘
`eliange agelils that “crtlist: the 1-‘N-"I.:b""EI11«T.l itlentilij.-' Enid bring Lo ,3: data
`Ex. 1001 at 9:38-52 in IPR2015-01750
`the LI;-N:r";~; EIttI.:TT1itT1T I'Ii3lLI‘.-".E1l]l regttltlttir}-' and l1t]I'l-I'tJ_":.£_L1l‘Ellt}I'_"y'
`Ex. 1001/1101 at 9:33-48 in IPR2015-01751 and -01752
`elianges found U11 the l-VEIJ that n1a}: tiffettl £1
`11 ser’ s bu siness:
`particular business operations of interest to the user.
`
`9
`
`

`
`Change Layer
`
`CHANGES ARE IDENTIFIED DN THE INTERNET USING
`INTELLIGENT AGENTS AND PROVIDED FDR GUNFIGURATIDN
`
`END USER FUNCTIONS
`ENABLED BY CONFIGURATION
`:- —
`
`CDNFIGUFIATIUN TUCILS THAT
`ENABLE THE END USER FUNCTIONS
`-
`
`Java Data Management Layer
`
`I
`
`END USER FUNCTIONS ARE ENABLED
`FHDNI METADATA DEFINITIONS
`
`CDNATIDN TUDLS DEFINE
`END USER FUNCTIONS IN IVIETADATA
`
`Ex. 1001/1101 FIG. 1
`iEUflI:Igg|E¥EDAg\EJ
`END USER FUNCHONS WA METADMA
`
`The system operates at four layers, as illustrated in FIG. 1:
`(1) a change management layer 11 that includes one or 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 aflect 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 andbusiness-Chane related data reulation-based
`
`Ex. 1001 at 9:38-52 in IPR2015-01750
`Ex. 1001/1101 at 9:33-48 in IPR2015-01751 and -01752
`business and btlsitiess-chatige related data (reg1Il:.1Iion-based rmulas’
`dfunc-
`+
`_
`ornon-reg11lal1on-basad)1 ,
`,
`
`10
`
`

`
`Change Layer
`
`CHANGES ARE IDENTIFIED DN THE INTERNET USING
`INTELLIGENT AGENTS AND PROVIDED FDR GUNFIGURATIDN
`
`END USER FUNCTIONS
`ENABLED BY CONFIGURATION
`I
`Elfl
`
`CDNFIGUFIATIUN TUCILS THAT
`ENABLE THE END USER FUNCTIONS
`EDI
`II
`IE7
`
`,an_/I3
`
`Java Data Management Layer
`
`END USER FUNCTIONS ADE ENABLEDI CDNFIBLIFIATIDN TUDLS DEFINE
`
`INMETADMA
`
`‘"15
`
`at
`_
`!
`ll
`I]
`|
`I Al
`PRO II
` "—I
`Metadata Layer
`-
`Ex. 1001/1101 FIG. 1
`iEUflI:Igg|E¥EDAg\EJ
`END USER FUNCHONS WA METADMA
`
`-
`
`F][.}_ 1
`
`EX- 7007/7707 F/G 7
`
`The system operates at four layers, as illustrated in FIG. 1:
`(1) a change management layer 11 that includes one or 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 aflect a user’s business;
`
`(2) a Java data management layer 13, a user interface, built
`using the Java language, that applies metadata attributes to
`(3) a metadata layer 15 that pro- 3t"*'(1'eg“1ali°n'b35ed
`‘\«"1(lBS a11d,-“or delities data about es-‘en-' feature of the user ta layer 15 that pm"
`"
`;
`feature of the user
`interl'aceit1cl11di11g, witl1ouI lir11iIaIion. tools. worltlists. data to013! Workfistsa data
`Ex. 1001 at 9:38-52 in IPR2015-01750
`reports, documents. processes.
`tormltlas, processes’
`formulas,
`eIITry
`terms.
`Ex. 1001/1101 at 9:33-48 in IPR2015-01751 and -01752
`images. tables. Tsiews, colunms, and other structures and ll.1llC- er structures and func-
`tions;
`7 that is specific to the
`C1] ar USIIIBSS 013611?! 10113 O 111 CICSI E0 thfl USCI‘.
`
`11
`
`

`
`Change Layer
`
`CHANGES ARE IDENTIFIED DN THE INTERNET USING
`INTELLIGENT AGENTS AND PROVIDED FDR CUNFIGURATIDN
`
`END USEFI FUNCTIONS
`ENABLED BY CONFIGURATION
`Elfl
`
`CDNFIGUFIATIUN TUCILS THAT
`ENABLE THE END USER FUNCTIONS
`FWI
`II
`IF7
`
`Java Data Management Layer
`
`END USER FUNCTIONS ARE ENABLED
`FHDNI METADATA DEFINITIONS
`
`Metadata Layer
`
`Ex. 1001/1101 FIG. 1
`TAGLEG, VIEWS, FUNCTIONS AND
`PRUCEDUFIES ARE ACCESSED BY
`END USER FUNCHONS WA METADMA
`
`The system operates at four layers, as illustrated in FIG. 1:
`(1) a change management layer 11 that includes one or more
`si
`-
`n
`-
`-
`-
`I
`NIEADATAHEFENES I change agents that cruise the Web and identify and bring to
`—"TT T‘. the user’s attention relevant regulatory and non-regulatory
`Business Content Layer
`changes found on the Web that may aflect a user’s business;
`(2) a Java data management layer 13, a user interface, built
`to
`
`EX. 1001/1101 FIG. 1
`
`(4)21 business t3L“Il1'[t3I1Tl£E1_'jI-’Cl‘ 17 tl
`partietllar bttsiliess UptJl’ElIIUI'lH DI" iTTIercE-II to the Ltser.
`Ex. 1001 at 9:38-52 in IPR2015-01750
`' I" u
`HI
`n|""
`Ex. 1001/1101 at 9:33-48 in IPR2015-01751 and -01752
`images, tables, views, columns, and other structures and func -
`tions; and (4) a business content layer 1 7 that is specific to the
`particular business operations of interest to the user.
`
`12
`
`

`
`CHANGES ARE IDENTIFIED DN THE INTERNET USING
`
`Change Layer
`
`INTELLIGENT AGENTS AND PHDVIDED ma CONFIGURATION
`END USER FUNCTIONS
`BONHGUHAHDN TOOLS THAT
`ENAELED 3y c0N|:tGUF;ATtDN
`ENABLE THE END USEF; ]IUNC'|'|[]NS
`
`CQNHGURAHQN TQQLS DEHNE
`
`15
`
`MEMDATA HEFERENCE5 TABLES,
`VIEWS. FIJNCTIUNS AND PROCEDURE;
`17
`
`Ex. 1001/1101 FIG. 1
`TABLES,V|EWS,FUNCt1DNSAND
`PROCEDURES ARE ACCESSED By
`END USER FtJNCTtDNS VIA METADATA
`
`_
`Busmess C°"t9”t Layer
`
`EX. 1001/1101 FIG. 1
`
`(
`_
`_
`‘
`_
`A 5} ntem tor pnwtdtttga d}t1£II111Caii}' generated apph-
`cation having one or more luncttens and one or nmre user
`interlitce elements; cumprisitlg:
`at server computer:
`
`one or more client contputers connected to tlte server
`CI.‘)lIlplII€l' GU61‘ -'3! COI'l1plll|3I' l1€IW0l'i(2
`it first layer associated with the server CDtt‘t]'!uIC]‘ contain-
`
`ing ittfonttatiott about the unique aspects efa particular
`applicatinn;
`it secund layer associated with the server eumptlter cun-
`,--
`»
`~
`..
`.
`.
`..
`- .: ~
`.
`tanning tntetrm.tt1on abeut the user tntcrhtcc and tunn-
`Item: common to a vartety nt apphcattmts. a particular
`applieatinn being generated based on the data in both
`the that and second |a;.'et'.~::
`a third layer associated with the server computer that
`retrieves the data in the tirst and second layers in order
`In generate the functionality and user interface ele-
`ments of the application: and
`a change ntanagentent layer for autematicallgr detecting
`citattges that atTect an ztpplieatittlt.
`Ex. 1001/1101 at 32:9-34 in IPR2015-01751 and -01752
`each client computer further eentprising a brntvser appli-
`cation being executed by each client computer. wherein
`13
`a user interface and l‘unctinna|ity fer the particular
`application is distributed to the brtwrser application and
`dyttattticaily generated when the client computer cun-
`neets In the server eutttpttter.
`
`

`
`AIT’S SOLE BASIS FOR CHALLENGING THE GROUNDS IS THAT
`
`THE PRIOR ART ALLEGEDLY DOES NOT TEACH
`
`“AUTOMATICALLY DETECTING CHANGES THAT AFFECT AN
`
`APPLICATION”
`
`For each of Grou.nd.s 1-4, the only limitation that the POR and AlT’s
`
`su.pporting expert d.eclarations alleged was not met was “automatically detecting
`
`changes that affect a particu.lar application” in claim 21 and the change
`
`management layer for performing that function in claim 13 . POR at 22-32; Ex.
`
`2032 ‘W51-84; Ex. 2033 W41-64; Ex. 1058 at 118:3-119:6, 127:5-128:8, 143:2-
`
`Petitioner’s Reply to POR, Paper 72 at 4 in IPR2015-01751
`l44:5 (Dr. Jagad.ish conceded that he offered. no opinion that the prior art fails to
`
`meet any other claim limitation)4.
`
`14
`
`Petitioner’s Reply to POR, Paper 72 at 4 in IPR2015-01751
`
`

`
`1. A system for providing a dynamically generated appli-
`cation having one or more functions and one or more user
`interface elements; comprising:
`
`a server computer:
`one or more client computers connected to the server
`computer over a computer network:
`a first layer associated with the server computer contain-
`ing information about the unique aspects of a part
`application:
`a second layer associated with the server mputer con-
`taining information about the user '
`erface and func-
`tions common to a variety of . . lications. a particular
`application being genera = u based on the data in both
`the lirst and second + ers-
`
`a third layer associated with the server computer that
`retrieves the data in the first and second layers in order
`to generate the functionality and user interface ele-
`ments of the application; and
`a c ange management ayer or atttomatrca y etectrng
`chan es that aifect an a lication.
`
`each client computer firrther comprising a browser appl'
`cation being executed by each client computer. who in
`a user interface and functionality for the pa cuiar
`application is distributo:i to the browser appli
`.
`dynamically generated when the client co - uter con-
`nects to the server computer.
`
`‘482 Patent
`
`. 1001), claim 1.
`
`a chair e mana ement la er for atrtomaticall deteetin
`-1 aflim an aPP1i'~‘=tti0n~
`
`27.
`
`In my opinion.
`
`the broadest reasonable interpretation a POSITA
`
`would apply to a “change management layer“ is automatically detecrin
`
`RPX Exhibit 1057
`
`_
`_
`_
`RPX .A|T
`h rrnpact how the applrcatron p1'og1'am should operate. In the context of the ,pR2£,'154m51
`
`‘482 patent. hese “changes" detected by the change ntanagernent layer arise from
`
`changes external to the application promm.
`
`15
`
`

`
`POR, Paper 63 in IPR2015-01750 and -01752, Paper 65 in IPR2015-01751
`
`16
`
`

`
`I-IDSMGRAI-BER JEGADISH, PH.D.
`
`-
`
`I]6f23f2lJ16
`
`Page 1131
`
`I-IOSJLGIIAI-E111 JEGADISH, PlI.D.
`
`— 06/23/2016
`
`Page lD2
`
`Right. What I'm trying to get at with my question is
`
`that what your construction does is construe the
`
`functional words that follow a change management layer
`
`for; right? Those words are automatically detecting
`
`changes that affect an application.
`
`So you're
`
`offering a construction of what that function means;
`
`right?
`
`Yes. And I think what I was trying to say was I'm not
`
`trying to limit myself to some kind of functional
`
`construction.
`
`I'm trying to construe change
`
`management layer and yes, it is true that my
`
`understanding of change management layer is to a large
`
`extent determined by the functions that such a layer
`
`should perform.
`
`Well. when you say such a layer should perform,
`
`the
`
`claim explicitly says what function it performs;
`
`right?
`
`Well. that's the best intrinsic evidence in support of
`
`my understanding.
`
`And you have construed the function in the claim as
`
`meeting your construction? Sorry. That's a terrible
`
`question.
`
`You have construed the words ‘for
`
`of . not the words "change management layer‘; right?
`
`Yeah. And I think that that's what I'm trying to
`
`explain.
`
`I think that to the extent change management
`
`layer is not a term of art, when one attempts to
`
`understand what that could possibly mean in the
`
`context of these claims, one has to look at the claims
`
`and the spec and whatever else one knows that's
`relevant —— or one at that time would have known
`
`that's relevant. and—
`
` That
`is consistent with everything else that we know about
`
`change management layer with respect to what is stated
`
`about it in the spec and elsewhere.
`
`Okay.
`
`So can I point you to Paragraphs 42 and 43 of
`
`your declaration?
`Yes.
`
`So in these paragraphs —— what Dr. Crovella said was I
`
`believe exactly what you just said, which is that when
`
`you construe that clause ‘change management layer‘
`
`performing the function, it should be construed to be
`
`automatically detecting changes that affect an
`
`application"? That is what you offered a construction
`
`a layer that performs the function explicitly recited
`AIT’s Expert, Ex. 1058/1158 at 102:9-13
`in the claim. and Paragraphs 42 and 43- of your
`
`17
`
`1-517-542-0039
`
`DTI CU“-“'3 R‘3P°r'3i"-9 5°]-11'-'-i°"1 ‘ E'°5'3‘I'1
`WW-deposition-com
`
`1-517-542-0039
`
`DTI Court Reporting Solution — Eustczn
`www.c'lepos:i.ticIn.cc|m
`
`

`
`1. A system for providing a dynamically generated appli-
`cation having one or more functions and one or more user
`interface elements; comprising:
`
`a server computer:
`one or more client computers connected to the server
`computer over a computer network:
`a first layer associated with the server computer contain-
`ing information about the unique aspects of a part
`application:
`a second layer associated with the server mputer con-
`taining information about the user '
`erface and func-
`tions common to a variety of . . lications. a particular
`application being genera = u based on the data in both
`the lirst and second + ers-
`
`a third layer associated with the server computer that
`retrieves the data in the first and second layers in order
`to generate the functionality and user interface ele-
`ments of the application; and
`a c ange management ayer or atttomatrca y etectrng
`chan es that aifect an a lication.
`
`each client computer firrther comprising a browser appl'
`cation being executed by each client computer. who in
`a user interface and functionality for the pa cuiar
`application is distributo:i to the browser appli
`.
`dynamically generated when the client co - uter con-
`nects to the server computer.
`
`‘482 Patent
`
`. 1001), claim 1.
`
`a chair e mana ement la er for atrtomaticall deteetin
`-1 aflim an aPP1i'~‘=tti0n~
`
`27.
`
`In my opinion.
`
`the broadest reasonable interpretation a POSITA
`
`would apply to a “change management layer“ is automatically detecrin
`
`RPX Exhibit 1057
`
`_
`_
`_
`RPX .A|T
`h rrnpact how the applrcatron p1'og1'am should operate. In the context of the ,pR2£,'154m51
`
`‘482 patent. hese “changes" detected by the change ntanagernent layer arise from
`
`changes external to the application promm.
`
`18
`
`

`
`automatically delcctin 1
`tat al]'cct an application.
`
`27.
`
`In n1y opinion.
`
`the broadest reasonable inteipretation a POSITA
`
`would apply to a "change nianagement layer" is automatically detectin Rpx Exhibit1g57
`RPX V. AIT
`|PR2015-01750
`
`which impact how the application p1'og1'a1n should operate. In tl1e context of the
`
`Ex. 1057/1157
`
`‘482 patent. hese “‘cha11ges" detected by the change nianagement layer arise fi'on1
`
`Changes external to the application progranl.
`
`Okay.
`
`So I want to Show you another—
`
`and it is the same exhibit but
`
`we've color coded the words I think we've just walked
`
`through and agreed how they correspond to each other.
`
`So I'd like to just quickly walk through this.
`
`So the
`
`green boxes illustrate that the words "automatically
`
`detecting" in the claim appear in the construction
`
`verbatim; right?
`
`Yes.
`
`AIT’s Expert, Ex. 1058/1158 at 94:1-15
`
`Jagaish Dec]. (Ex.2032) at'[ 27.
`
`EX' 1057/1157
`
`19
`
`

`
`lmS JEGRDI, PH.D.
`
`— 06/23/2016
`
`Page B3
`
`imrentor says I can accept user input in whatever form
`
`it may arrive, that use of the form is the word 'form'
`
`in English and not necessarily a web form, which is
`
`what the invention may be about. And I think that one
`
`shouldn't just because one used that word 'form'
`
`somewhere in the plain and ordinary English sense get
`
`confused with respect to the use of the technical term
`
`"form" which means a web form in the context of my
`
`hypothetical invention.
`
`Can we get back to this one; right?
`
`I mean, I believe
`
`you testified earlier the word 'change' is not a
`
`technical term of art,
`
`is it?
`
`3- ' However;
`word "change" and “change management‘ and
`
`the
`
`"automatically detecting change‘ are critical terms in
`the claims and therefore terms that have to be
`
`construed and understood in light of the claims and
`
`the specification.
`
`Right. End this very same inventor used the word
`
`"change" to refer to —— 'changed' to refer to actions
`
`taken by a user, right, with respect to the system?
`
`It's the same inventor; right?
`
`The imrentor used the verb 'changed' in an entirely
`
`different context as something that was used
`AIT’s Expert, Ex. 1058/1158 at 83:13
`explicitly as a user override to the primary
`
`1—61'i"—542—[IlllI39
`
`IJTI Count lleport:i.ng Boluticm — Boston
`|Iww.depoBitioIl.umII
`
`20
`
`

`
`POR at 14, Paper 63 in IPR2015-01750 and -01752, Paper 65 in IPR2015-01751
`
`21
`
`

`
`HDSEGHBHER JEGBDISH, PH.D.
`
`- 06/23/2016
`
`Page 115
`
`HDSHGRAHDR JEGADISH, PH.D.
`
`- U6f23f2D16
`
`Page 116
`
`not changes that require automatic detection, and so
`
`if you read changes to include those things,
`
`then you
`
`end up with an inconsistent reading of the phrase
`
`"automatically detect changes.‘
`Well. let's taI|J( about that. Because I think there's
`
`a difference between saying you end up with an
`
`interpretation that is not limited to the embodiment
`
`and an interpretation that is inconsistent; right?
`
`Yes.
`
`I'm taI|J(_ing about inconsistency.
`
`I'm not —— I
`
`have never tried to limit the claims to the
`
`environment.
`
`agreement. if we interpret it as B,
`
`then he's
`
`inconsistent. and I therefore declare his
`
`interpretation as A or B as overly broad and believe
`
`that the correct interpretation should be A and not A
`or B.
`
`6
`
`Well. let me give you a hypothetical that maybe is
`
`simple.
`
`The specification describes an orange and the
`
`patent drafter calls it a fruit. Okay?
`
`Somebody in
`
`the petitioner's position challenge it and shows a
`
`reference that shows an apple.
`
`Is an apple a fruit?
`
`An apple is a fruit.
`
`So let's talk about that. —
`
`It's not the fruit in the specification?
`
` That is correct-
`
`Calling the —— interpreting the fruit broadly enough
`-
` to cover an apple and an orange is not inconsistent
`
` because —— here's
`sort of the logic. Change can mean A or E.
`If change
`means A. let's say that it covers the embodiments of
`
`the spec.
`
`If change means B, it leads to an
`
`inconsistent interpretation of the spec —— of the ——
`
`The claims —— the claim
`of the claims. Sorry.
`language is inconsistent.
`I'm interpreting change to
`
`mean. A. he wants to interpret it to mean A or B.
`If
`AIT’s Expert, Ex. 1058/1158 at 115:12-17
`he interprets it as A —— if I take his A or B and
`deconstruct it, if we interpret it as A, we're in
`
`with the specification; right?
`No, it is not.
`In fact,
`that is —— that's exactly how
`one should be reading claims.
`
`Okay.
`
`So in our example I think we agreed that change
`
`that happens in some government database is the same
`
`type of change that happens to the internal database.
`What I understand you to be saying is, yeah, but the
`
`type of change that happens to the internal database
`
`is not the type of change that is detected by the
`embodiments in the specification and therefore I'm
`
`1-617-542-0039
`
`DTI Court Reporting Solution — Boston
`mm-.depositiorn.aom
`
`1-617-542-0039
`
`D'I'I Court. Reporting Solutiozn — Boston
`mIw.depoBitim1.omn
`
`22
`
`

`
`US 7.356.432 B2
`9
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