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
`
`

`

`New:
`
`(731
`
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`(21:
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`IIIII
`
`US 6.341.287 Bl
`(In) Patent Nu.:
`United States Patent
`
`
`
`sour-r et IL
`(:5) Date of Patent:
`Jul. 22. no:
`‘wrm is claimed is:
`
`50
`a fiflh database that
`tracks a controlled release or
`l. A system for monitoring processing and disposition of
`
`
` (54! m'rmmrrn CHANGE wnormrm spanner n - mm Struma
`
`
`discharge of a material to the environment, the fifth
`10 at least one material used to a business at a facility. the
`mm“
`5.9mm A ' tom? outlier
`
`room A - 1mm m-uqc
`database including information on discharge of at
`system comprising:
`least one hazardous substance into at least one of the
`(75)
`
`lmurrm. ArithmyT. m.1ntrnmn Bay.
`Elm-“1‘ *‘
`' 5W“ 79"“l
`a first database that provides product stewardship for at
`Astral: lawman. Foal." on; Judith
`flag: g 1 lm m‘m'f‘fl
`air. the water, the groundwater and the soil at the
`F. nip-um. llanMwn nay; lttrhrd
`'
`'
`” "'
`'
`least one selected material
`that is received, treated,
`
`l'nnllllltfl.Slrt lose:W M.
`- we, mm
`facility, and information on at least one toxic chemi—
`Mltehzl. ttl outrun-Jami LL
`‘
`‘
`
`consumed or produced as awaste product at the facility,
`rim-an. Santa Ctlra,‘ man: It.
`“'7‘"! Eon-"Fromm“ “Mt
`cal release at the facility;
`
`the first data base including information on at least one
`Elll‘pflh 5m Mum, all at CA (US)
`MW“ *m'flw Willa
`a sixth database that provides selected information on
`(HUM: mm or Hun—on; Cant Wm in
`product produced at the facility, information on wo-
`
`Assam. Alum-nu: smlne.nuttnm Fmdwml-JLP
`regulatory requirements for receiving, handling. pro—
`logical and toxicological studies performed at
`the
`(57}
`storm
`“'Y- C" ["57
`
`cessing or producing hazardous materials. the sixlh
`facility,
`information for production of a Materials
`5mm“: m Mina. m: mm nflltis
`An impaled system lor managilg changes in regulatory
`pm I: mended or lair-sled null“ 33
`all nmmgnlaloryrequilentnlslrlbuinoaomiviliallnn
`database including information on at. least one envi»
`Safety Data Sheet (MSDS) for at least one material
`
`USI- With) by 0 rura-
`int‘htalrialolcuntneleial [adlfly.A|1ylicalinn oflhis system
`tonnrimnmnnlaL health and safety miviim and to find.
`ronmental audit conducted at the facility, informa-
`used at
`the facility, and tracking of allegations and
`mt. Mr... mm”
`dmLmunetic. and medical moment anddevioe activities.
`
`tion on regulatory lists used at, and on regulatory
`In: discussed or complex 1m system: pluviihs m: or
`inquiries ooocerning operations at the facility; and
`Filed:
`Dec. 18, l!!!
`male dotahlsu that ontllaitl inlorlltalJnlt l'llI openliom and
`issues concerning. the facility. and information on at
`at least one additional database, drawn from the following
`mquilcmeltls mourning an activin ur aims at hotness:
`.. CHI" 11».
`
`receivea information on relulatory and Jinn-regulatory
`least litigation issue concerning the facility; and
`group of databases:
`damn-at Iihafl upsetting D‘llts bliinflfi: mm on
`
`
`a. seventh database that provides selected information
`doom lilo change: it data entry rm. em Mn;
`at second database that allows tracking and prevention
`.
`'
`'
`.
`and Inllyréi prr-oedem.artd mailman (by printing. elec-
`on management of the facility. the seventh database
`
`of Selected incidents involving unintended discharge
`29' 1“ ml’ 1" mar:
`Imnle dfittlly androi- dlwimlon) at dun mesh. and
`including information on at least one of the physical
`of it material at
`the facility, the second database
`Mnmchd
`Imminent“; weakened recipientstwilhwtnqlin'ngttu
`
`sem'w: of one or me grammars ltl relay androi-
`LLi Pm'r‘ DOCUMENTS
`rctmnu the nuns unwed by It: chow; Ind ilnplelnetus
`structure and the organizational structure at
`the
`including information on response to at least one
`receipt or «my. inkrmau‘eu :an dissemination of data
`
`4min - more lnrpinLJ‘r:
`facility.
`information on tracking of at
`least one
`type of emergency at
`the facility, information on
`promising and annysa min lining the facilities arm
`5,IJlS,fiW A ' LII-n; urinals-L
`
`Internal.
`53;qu - Trim sutured
`tracking of at least one incident at the facility. and
`equipment item at the facility, and information on at
`
`5,6MJI2 A - W199? sum mt. .
`
`5,112,9qu -
`trim innit-m-
`
`least one pmcatss used at the facility;
` l Clllm, H Moll-u M
`safety information On at least one process used at the
`
`
`facility;
`a tools module that provides software for at least one of 5
`
`
`third database that providm information on and
`creation of a report on operations at the facility, cre-
`monitoring of personnel health and safely at the
`ation of formulas and expreSions for a report on
`IlTElBElll -H -.th|] HlDr'lDBl Full montnm
`CHM-ES arr Inontnmnttr'l'mrr Lam
`
`
`facility, the third database including information on
`operations, creation of at least one image for a report on
`
`demographics of personnel working at the facility,
`operations, archiving of at
`least one record on
`
`
`
`END USER FUNCTIONS
`EDNFEBURAI'IDN TDDLS THAT
`
`ENIIBLEEI EN CDNFIGWATIUN
`QUAKE THE END USER FUNCTIONS
`information on personnel training, information on
`
`operations, and security measurm implemented at the
`
`
`
`
`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 neo-regtdarery requirements
`
`the facility, and information on industrial hygiene
`
`4F)
`CNFMAHENIWLSIJEHNE
`for the business without requiring manual reprogram-
`and occupational medicine studies carried out at the
`
`FNDLERF
`TIN N
`.b-l‘
`
`
`ming of the tools module software; and
`
`facility;
`"---15
`
`5
`a relational database management module that linlcs each
`
`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'fllltES. VEM. FUND‘IIDE MD
`so that an information item, once entered, becomes
`WWWLFEEPFEW BY
`waste. the fourth database including information on
`
`available to each database and to the tools module.
`
`45
`ENE LHR Fmillllfi lt'tll hElADAlA
`
`
`
`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 [treasures imple-
`
`
`
`mented at the facility;
`
`55
`
`on
`
`65
`
`15
`
`25
`
`30
`
`35
`
`
`
`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 information about unique aspects of a particular
`
`application,
`
`of the server.
`
`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
`
`
`
`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 information about
`unique aspects of a particular application,
`the second portion of the server having information about
`user interface elements and one or more fimctions 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
`- n - I
`e
`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 server-he information in the
`second portion of the server.
`
`betweenthe serverand the client”
`
`5
`
`
`
`EX. 1012 at 5 in lPR2015-01750 — from 12/098,154
`
`EX. 1001 at 33: 19—34.‘8 in lPR2015-01750
`
`

`

`
`
`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 IDENTIRED ON THE INTERNET USING
`
`INTELLIGENT AGENTS AND PROVIDED FOR CONFIGURATION
`
`END USER FUNCTIONS
`ENABLED BY CONFIGURATION
`
`CONFIGURATION TOOLS THAT
`ENABLE THE END USER FUNCTIONS
`
`Java Data Management Layer
`
`13
`
`END USER FUNCTIONS ARE ENABLED
`FROM MEIADATA DEFINITIONS
`
`CDNRGURADON TOOLS DEFINE
`END USER FUNCTIONS IN NETADATA
`
`1 5
`
`Metadata Layer
`
`
`
`TABLES, VIEWS, FUNCRDNS AND
`PROCEDURES ARE ACCESSED BY
`Ex. 1001/1101 FIG. 1
`END USER FUNCUDNS VIA METADATA
`
`.
`
`MHADATA REFERENCES TABLES,
`VIEWS. FUNCTEDNS AND PRDCEDURES
`
`Business Content Layer
`
`17
`
`7
`
`FIG. 1
`
`

`

`INTELLIGENT AGENTS AND PROVIOEO FOR CONFIGURATION
`
`END USER FUNCTIONS
`ENABLED av CONFIGURATION
`I I I I I
`
`CONFIGURATION TOOLS THAT
`ENABLE THE END USEFI FUNCTIONS
`I I I I I
`
`13
`
`Java Data Management Layer
`
`FFIUM MEIADATA DEFINITIONS
`
`ODNRGURATIONTODLG DEFINE
`END USER FUNL'IIIJNS IN METADATA
`
`Metadata Layer
`
`15
`
`
`Ex. 1001/1101 FIG. 1
`TABLES, VIEWS, FUNCTIONS AND
`EgfiégfiggflfflficafigfinATA ‘
`
` Change Layer
`
`
`
` FIG.
`
`
`The system operates at four layers, as illustrated in F1G. 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 afiect a user’s business;
`
`(2) a Java data management layer 13, a user interface, built
`’I
`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 and/or 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.
`
`EX_ 1001/1101 F/G_ 1
`
`8
`
`

`

` Change Layer
`
`CHANGES ARE IDENTIFIED ON THE INTERNET USING
`INTELLIGENT AGENTS AND PROVIDED FOR CONFIGURATION
`
`I
`
`
`CONFIGURATION TUCILS THAT
`END USER FUNCTIONS
`
`
`ENABLE THE END USER FUNCTIONS
`ENABLED BY CONFIGURATION
`FRI
`Elm
`II
`IF?
`
`Java Data Management Layer
`
`
`
`
`
`
`
`
`
`
`
`TABLES, VIEWS, FUNCTIONS AND
`Ex. 1001/1101 FIG. 1
`
`PROCEDURES ARE ACCESSED BY
`METADATA REFERENCES TA
`
`END USER FUNCTIONS VIA METADATA
`VIEWS, FUNCTIONS AND PRI
`
`
`The system operates at four layers, as illustrated in F1G. 1:
`(l) a change management layer 11 that includes one or more
`change agents that “cruise the Web" and identify and bring to 40
`
`the user’s attention relevant regulatory and non-regulatory
`changes found on the Web that may afiect a user’s business;
`
`(2) a Java data management layer 13 a user interface built
`using the Java language that applies metadata attributes to
`
`
`changeagEnts thatcruisctheVtcb andidentily Enidbring to ts data
`
`
`._._
`e USCT
`Ex. 1001 at 9:38-52 in IPR2015-01750
`
`the user s attention relax-ant regulEIttTr} and nan-regulatory
`Ex. 1001/1101 at 9:33-48 in IPR2015-01751 and -01752
`changes found on the Web that may affect a a ser’ s business:
`
`particular business operations of interest to the user.
`
`
`
`
`9
`
`

`

` Change Layer
`
`
`
`CHANGES ARE IDENTIFIED ON THE INTERNET USING
`INTELLIGENT AGENTS AND PROVIDED FOR CONFIGURATION
`
`CONFIGURATION TOOLS THAT
`END USER FUNCTIONS
`ENABLE THE END USER FUNCTIONS
`ENABLED BY CONFIGURATION
`
`
`_- I
`I
`
`
`
`
`
`
`|
`Java Data Management Layer
`
`
`
`END USER FUNCTIONS ARE ENABLED
`' CDNFIRATION TOOLS DEFINE
`END USER FUNCTIONS IN METADATA
` FROM METADATA DEFINITIONS
`
`
`
`
`
`The system operates at four layers, as illustrated in F1G. 1:
`
`
`
`TABLES, VIEWS, FUNCTIONS AND
`
`Ex. 1001/1101 FIG. 1
`(l) a change management layer 11 that includes one or more
`
`PROCEDURES ARE ACCESSED BY
`METADATA REFERENCES TA
`
`
`change agents that “cruise the Web" and identify and bring to 40
`END USER FUNCTIONS VIA METADATA
`
`VIEWS, FUNCTIONS AND PRI
`
`
`the user’s attention relevant regulatory and non-regulatory
`changes found on the Web that may afiect 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. 1001/1101 FIG. 1
`
`
`
`
`(2} a Java data management layer 13, a user interlaee, built
`using the Jasa language, that applies metadata attributes te
`Ex. 1001 at 9:38-52 in IPR2015-01750
`Ex. 1001/1101 at 9:33-48 in IPR2015-01751 and -01752
`business and business-change related data (regulation-based rmmas’
`dfunc- 50
`+
`_
`ornon-regulalien-based)1 ,
`,
`
`10
`
`

`

`
`
`
`
`Change Layer
`
`CHANGES ARE IDENTIFIED ON THE INTERNET USING
`INTELLIGENT AGENTS AND PROVIDED FOR CONFIGURATION
`
`CONFIGURATION TOOLs THAT
`END USER FUNCTIONS
`ENABLE THE END USER FUNCTIONS
`ENABLED BY CONFIGURATION
`
`I
`BIT
`Ed I
`I
`I
`I F—I
`
`Arm/IE
`
`Java Data Management Layer
`
`
`
`
`
`
`
`
`
`
`
`11
`
`END USER FUNCTIONSARE ENABLED !' CONFIGURATIONTOOLS DEFINE
`
`
`
`FRD 1________‘I 4' | IA
`"—-___IINMETADATA
`
`Metadata Layer
`M15
`
`
`
`METADATA REFERENCES TA.
`VIEWS, FUNCTIONS AND RRI
`
`
`
`Business Content Layer
`
`TABLES, VIEWS, FUNCTIONS AND
`Ex. 1001/1101 FIG. 1
`PROCEDURES ARE ACCEDSED BY
`END USER FUNCTIONS VIA METADATA
`
`
`The system operates at four layers, as illustrated in F1G. 1:
`(l) a change management layer 11 that includes one or more
`
`
`change agents that “cruise the Web" and identify and bring to 40
`the user’s attention relevant regulatory and non-regulatory
`
`
`changes found on the Web that may afiect a user’s business;
`
`(2) a Java data management layer 13, a user interface, built
`FIG. 1
`
`
`using the Java language, that applies metadata attributes to
`
`EX. 1001/1101 FIG. 1
`(3) [I metadata layer 15 that pro- nata (regulation-based 4S
`
`
`vides and-”or delines data about even! leature ol' the user ‘ta layer 15 that pm'
`
`"
`t
`feature of the user
`
`interface includinn without limitation. tools. TT-‘Urltlists. data tools worklists data
`Ex. 1001 at 9:38-52 in IPR2015-01750
`
`
`reports documents processes
`formulas processes
`formulas
`entry Torms
`Ex. 1001/1101 at 9:33-48 in IPR2015-01751 and -01752
`images tables. TIeTT scolumnsand other structures andtunc- erstructuresandfunc- so
`
`7 that is specific to the
`
`on ar usmess opera ions 0 1n crest to the user.
`
`
`

`

`
`
`
`
`
`Change Layer
`
`CHANGES ARE IDENTIFIED ON THE INTERNET USING
`INTELLIGENT AGENTS AND PROVIDED FOR CONFIGURATION
`
`END USER FUNCTIONS
`ENABLED BY CONFIGURATION
`Elm
`
`CONFIGURATION TUCILS THAT
`ENABLE THE END USER FUNCTIONS
`WI
`II
`IF?
`
`Java Data Management Layer
`
`END USER FUNCTIONS ADE ENABLED
`FROM METADATA DEFINITIONS
`
`EX. 1001/1101 FIG. 1
`
`‘
`
`
`
`
`
`Metadata Layer
`1
`Thesystemoperatesatfourlayers,asillustratedinF1G.1:
`
`TABLES, VIEWS, FUNCTIONS AND
`Ex. 1001/1101 FIG. 1
`(l) a change management layer 11 that includes one or more
`
`PROCEDURES ARE ACCESSED BY
`IIIIETADATA REFERENCES TA change agents that “cruise the Web" and identify and bring to
`lD PRI
`I
`L
`It
`END USER FUNCTIONS VIA METADATA
`, E, ,7
`——‘-———l- the user’s attention relevant regulatory and non-regulatory
`
`
`changes found on the Web that may afiect a user’s business;
`(2) a Java data management layer 13, a user interface built
`using the Java language that applies metadata attributes to
`(4)21 business content la}cr 1? Thatis specific tottil
`particular business tTpcratiITus tTI interest to 1ch user.
`
`
`
`Ex. 1001 at 9:38-52 in IPR2015-01750
`
`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
`
`

`

`Change Layer
`
`CHANCES ARE IDENTIFIED ON THE INTERNET USING
`INTELLIGENT AGENTS AND PROVIDED FOR CONFIGURATION
`
`END USER FUNCTIONS
`ENABLED BY CONFIGURATION
`
`CONFIGURATION TOOLS THAT
`ENABLE THE END USER FUNCTIONS
`
`CONFIGURATTON TOOLS DEFlNE
`END USEFl FUNCTIONS IN METADATA
`
`1 5
`
`cation having one or more functions and one or more user
`interface elements; comprising:
`a server Computer:
`
` l. A system for providing a dynamically generated appli-
`
`
`one or more client computers connected to the server
`computer over a computer network:
`a first layer associated with the server computer contain-
`ing inlonnation about the unique aspects ol'a particular
`application;
`a second layer associated with the server computer con-
`taining inl‘onnation about the user interface and func-
`tions common to a variety of applications. a particular
`application being generated based on the data in both
`the first and second layers:
`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 inlerfiice ele-
`ments of the application: and
`a change management layer for automatically detecting
`changes that allect an application.
`Ex. 1001/1101 at 32:9-34 in IPR2015-01751 and -01752
`each client computer further comprising a browser appli-
`cation being executed by each client computer. wherein
`13
`a user interface and litnctinnality liar the particular
`application is distributed to the browser application and
`dynamically generated when the client computer con-
`nects to the server computer.
`
`Ex. 1001/1101 FIG. 1
`TABLES, VIEWS, FUNCDUNS AND
`PROCEDURES ARE ACCESSED BY
`END USER FUNCTlDNS VIA METADATA
`
`MEIAOATA REFERENCES TABLES,
`VEEWS. RJNCTIONS AND PROCEDURES
`
`Business Content Layer
`
`17
`
`EX. 1001/1101 FIG. 1
`
`

`

`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 Grounds 1-4, the only limitation that the POR and AIT’s
`
`supporting expert declarations alleged was not met was “automatically detecting
`
`changes that affect a particular application” in claim 21 and the change
`
`management layer for performing that function in claim 13 . POR at 22-32; Ex.
`
`2032 $51-84; Ex. 2033 W4l-64; EX. 1058 at 118:3-119:6_, 127:5-128z8, 143:2-
`
`
`
`Petitioner’s Reply to POR, Paper 72 at 4 in IPR2015-01751
`l44:5 (Dr. Jagadish 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 ofa part
`application:
`
`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 automattca y Ietecttng
`chan- es that allect an a lication.
`
`detectin
`a chart e mana ement la er for automaticall
`.. afloat an application—
`
`27.
`
`In my opinion.
`
`the broadest reasonable interpretation a POSITA
`
`‘482 Patent
`
`. 1001), claim 1.
`
`‘482 patent. hese “changes" detected by the change management layer arise from
`
`changes external to the application program.
`
`each client computer litrther comprising a browser appl'
`cation being executed by each client computer. who: in
`a user interface and functionality for the pa cular
`application is distributed to the browser appli
`.
`dynamically generated when the client on . 'uuter con-
`nects to the server computer.
`
`Jagadish Decl. (Ex. 2032) at 'l 27.
`
`would a
`l
`PP Y
`
`to a “chart e management la er“ is automaticall detectin- chances
`:3:
`~
`y
`y
`‘
`
`RPx Exhibit 1057
`RPX v.AIT
`.
`.
`.
`.
`which nnpact how the application program should operate. In the context of the 1PR2015_01751
`
`
`
`15
`
`

`

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

`

`
`
`
`
`- 06/23/2016HDSMRAHER WISH, PH.D. Page 101
`
`
`
`WEN-Ell}. JEWISH, PILD. Page 102 — 06/23/2016
`
`
`
`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
`
`automatically detecting changes that affect an
`
`application"? That is what you offered a construction
`
`
`
`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
`
`layerII
`
`performing the function, it should be construed to be
`
`m.depositim.com
`
`
`
`
`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
`
`
`1—617—542—0039
`
`DTI Court Reporting Solution: — Boston
`www.depositim.com
`
`1417—5412—0039
`
`DTI Court Reporting Solution — Boston
`
`17
`
`

`

`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 ofa part
`application:
`
`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 automattca y Ietecttng
`chan- es that allect an a lication.
`
`detectin
`a chart e mana ement la er for automaticall
`.. afloat an application—
`
`27.
`
`In my opinion.
`
`the broadest reasonable interpretation a POSITA
`
`‘482 Patent
`
`. 1001), claim 1.
`
`‘482 patent. hese “changes" detected by the change management layer arise from
`
`changes external to the application program.
`
`each client computer litrther comprising a browser appl'
`cation being executed by each client computer. who: in
`a user interface and functionality for the pa cular
`application is distributed to the browser appli
`.
`dynamically generated when the client on . 'uuter con-
`nects to the server computer.
`
`Jagadish Decl. (Ex. 2032) at 'l 27.
`
`would a
`l
`PP Y
`
`to a “chart e management la er“ is automaticall detectin- chances
`:3:
`~
`y
`y
`‘
`
`RPx Exhibit 1057
`RPX v.AIT
`.
`.
`.
`.
`which nnpact how the application program should operate. In the context of the 1PR2015_01751
`
`
`
`18
`
`

`

`aulomaticallv delectin
`
`lat afl'ect an application—
`
`27.
`
`In my opinion.
`
`the broadest reasonable nltelpretation a POSITA
`
`would apply to a "change management layer" is
`
`automatically delectifll- RPX Exhibit 1057
`RPX v. AIT
`|PR2015-01750
`
`which impact how the application program Should operate. In the context of the
`
`“482 patent. hese “changes" detected by the change management layer arise fi'oni
`
`
`
`Okay.
`
`So I want to show you another—
`
`EX. 1057/1157
`
`Jagadish Decl. (Ex. 2032) at'l 27.
`
`Changes external to the application program.
`
`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
`
`
`
`Ex. 1057/1157
`
`19
`
`

`

`
`
`
`
`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 'fo'rm'
`
`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?
`
`1L
`
`the
`
`m-JmmrhmMI-J
`
`to
`
`10
`
`11
`
`12
`
`13
`
`
`
` Page 83
` HDSHERRHER JEGRDIHE, PH.D. — 06/23/2016
`inventor says I can accept user input in whatever form
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`— However.
`
`14
`word "change“ and I‘change management' and
`
`"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. find 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 inventor 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
`
`
`
`D'l'I Court Reporting Scluticm — Boston
`
`
`1—61?—542—0039
`www.dnpositiom.com
`
`
`
`
`
`20
`
`

`

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

`

`
`
`
`
`— 06/23/2016msmnmmn WISH, PILD. Page 115
`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.'l
`Well. let’s talk 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?
`
`I'm not —— I
`I'm taIIJdJIg about inconsistency.
`Yes.
`have never tried to limit the claims to the
`environment .
`
`So laws as about that. —
`
`—hecau=ae ~ 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
`
`
`1—617—542—0039
`
`D'l’I Gaul: Rewrting Solution — Boston
`m.depositiorn.amn
`
`1—617—542—0039
`
`DTI Court Reporting Solution — Boston
`www.deposition.com
`
`
`
`
`
`
`
`- UfifszZUlfiHDSBGRRHDR WISH, PH.D. Page 116
`
`then he's
`agreement. if we interpret it as B,
`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.
`
`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.
`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
`
`with the specification; right?
`
`that is —— that's exactly how
`In fact,
`No. it is not.
`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