IPR2015-01898, Paper No. 38
`IPR2015-01899, Paper No. 38
`January 11, 2017
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`trials@uspto.gov
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`571-272-7822
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`CORE WIRELESS LICENSING S.A.R.L.,
`Patent Owner.
`____________
`
`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Patent 8,713,476 B2)
`____________
`
`Held: December 14, 2016
`____________
`
`
`
`
`
`BEFORE: JAMESON LEE, DAVID C. McKONE, and KEVIN
`W. CHERRY, Administrative Patent Judges.
`
`The above-entitled matter came on for hearing on Wednesday,
`December 14, 2016, commencing at 1:30 p.m., at the U.S. Patent
`and Trademark Office, 600 Dulany Street, Alexandria, Virginia.
`
`
`
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`IPR2015-01899, Paper No. 38
`January 11, 2017
`
`trials@uspto.gov
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`571-272-7822
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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`CORE WIRELESS LICENSING S.A.R.L.,
`Patent Owner.
`____________
`
`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Patent 8,713,476 B2)
`____________
`
`Held: December 14, 2016
`____________
`
`
`
`
`
`BEFORE: JAMESON LEE, DAVID C. McKONE, and KEVIN
`W. CHERRY, Administrative Patent Judges.
`
`The above-entitled matter came on for hearing on Wednesday,
`December 14, 2016, commencing at 1:30 p.m., at the U.S. Patent
`and Trademark Office, 600 Dulany Street, Alexandria, Virginia.
`
`
`
`
`
`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Paten 8,713,476 B2)
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`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
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`J. STEVEN BAUGHMAN, ESQUIRE
`MEGAN F. RAYMOND, ESQUIRE
`
`Ropes & Gray, LLP
`
`2099 Pennsylvania Avenue, N.W.
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`Washington, D.C. 20006-6807
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`
`
`ON BEHALF OF PATENT OWNER:
`
`WAYNE HELGE, ESQUIRE
`WALTER D. DAVIS, Jr., ESQUIRE
`Davidson, Berquist, Jackson & Gowdey, LLP
`8300 Greensboro Drive
`Suite 500
`McLean, Virginia 22102
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`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Paten 8,713,476 B2)
`P R O C E E D I N G S
`- - - - -
`JUDGE CHERRY: Good afternoon. This is the
`hearing in IPRs 2015-1898 and 1899, Apple Inc versus Core
`Wireless Licensing S.A.R.L. Counsel, will you please make your
`appearances.
`MR. BAUGHMAN: Your Honor, Steve Baughman and
`Megan Raymond from Ropes & Gray for petitioner, Apple Inc.
`We have a representative from Apple, Cyndi Wheeler.
`MR. HELGE: Good afternoon, Your Honor. Wayne
`Helge for the patent owner. I have with me my partner, Walter
`Davis, and we have representatives, Mr. Burt and Mr. Anderson
`from the patent owner as well.
`JUDGE CHERRY: Thank you. In addition to myself
`and Judge Lee, we also have Judge McKone remote in the
`Midwest office in Detroit. So when you speak, please speak into
`the microphone so that Judge McKone can hear what you are
`saying. And also, please when you are going through your
`demonstratives, please refer to the slide number so that Judge
`McKone can follow along.
`Mr. Baughman, you are the petitioner. Would you like
`to begin.
`MR. BAUGHMAN: Thanks, Your Honor. Judge
`McKone, please feel free to remind me if I stray away from the
`podium. I apologize in advance.
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`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Paten 8,713,476 B2)
`Good afternoon, may it please the Board, at the outset
`we would like to reserve 20 minutes of our time for rebuttal, if we
`may.
`
`Turning to petitioner's slide 4, particularly given the
`time we have today, petitioner is going to rely on the positions
`and evidence we have offered the Board in briefing to support our
`arguments that the '020 and '476 patents at issue here and in
`particular the challenged claims are invalid as obvious over the
`permutations of prior art we've laid out on slide 4. As Your
`Honors can see, we have a number of demonstratives available in
`this case on particular topics, if they should arise, along with a
`table of abbreviations showing the source of that information and
`a table of contents. But we certainly don't plan to address all of
`that today. Instead, what we would propose to do is address in
`this opening discussion three topics along with any questions the
`Board may have.
`Turning to slide 5, this afternoon I'll first briefly address
`several points on claim construction of terms that respectfully the
`patent owner distorts in an attempt to read in a raft of extra
`limitations that are not supported by the record here and attempt
`to navigate around the prior art. Actually, for a number of them,
`patent owner does not even try to link the constructions to an
`issue in these trials.
`Second, I will touch on a few of patent owner's primary
`arguments about Schnarel, that's Exhibit 1004, which alone or in
`combination renders all the claims obvious.
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`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Paten 8,713,476 B2)
`And then third, my colleague, Ms. Raymond, is going to
`address the Nason reference, our second primary prior art
`reference.
`Before we jump into that, I would like to offer to
`observations of the kind of evidence the Board has before it and
`the kind of evidence it does not. First, we would note that patent
`owner has pivoted a bit from some of the arguments raised in the
`preliminary response. So as stated in the Board's scheduling
`order, that's paper 8 at 3 and 1898, patent owner has waived any
`arguments that don't appear in that patent owner response.
`And the second point we would ask the Board to
`consider as you listen to today's arguments is the nature of what
`patent owner is urging here. We are starting off with the very
`short disclosures of the '020 and '476 patents at issue. They are
`about four and a half columns, give or take, before the claims.
`And they are simply about GUIs, graphical user interfaces, and
`trying to improve navigation among menus, which were already
`known.
`
`So patent owner's attempt to lard up claim construction
`and distinguish the prior art here all go to a level of
`implementation detail that is simply absent from the '020 and '476
`patents. So as we hear patent owner today arguing about
`software sitting on top of an operating system or trying to
`delineate between applications and what is or isn't in some
`abstracted application layer model, it's helpful to bear in mind
`that those things never appear as requirements of the patents.
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`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Paten 8,713,476 B2)
`JUDGE CHERRY: I wonder what your thoughts were
`under broadest reasonable interpretation as to how we should
`apply the concept that claims should be read so that they are
`enabled. Or do you have any opinion about whether we should
`take into the potential enablement or nonenablement of the claims
`in considering the claim constructions?
`MR. BAUGHMAN: It might be a little difficult to
`address that in the abstract, Judge Cherry.
`JUDGE CHERRY: Like application.
`MR. BAUGHMAN: Sure. And we'll definitely address
`that. One thing to note at the outset is the canons of construction
`about preserving validity, I think, are Phillips canons. Not BRI
`canons. So while I think the specification can help inform what
`the claims are meant to be, I think if there's a problem with them
`that isn't addressed by the specification, that's not something we
`can solve in a way that's narrowing them to construe and preserve
`validity. Does that respond to Your Honor's question?
`JUDGE CHERRY: I guess my one question was,
`should we take into account that we cannot consider
`unpatentability on 112 grounds in how we construe the claims?
`MR. BAUGHMAN: I guess what I would respond with
`is we are not arguing 112, Your Honor. I think however you
`construe the claims would be our view. They are disclosed or
`rendered obvious by the prior art. But along the lines of
`application, I think it's actually helpful if we take a look at patent
`owner's response, it's paper 18 and pages 16 to 17. I think that's
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`pages 21 to 22 if you are looking at the PDF pages. If we look at
`the bottom line there, we see that one of the things that patent
`owner is arguing about application is that it has to be arranged in
`an application layer. Now, the phrase "application layer" might
`suggest to someone of skill in the art something about the OSI
`model. But we have no idea what it is because this is literally the
`only place in the briefing that the phrase "application layer"
`appears. It doesn't show up in Mr. Denning's declaration. And
`certainly the words of the patent never say "application layer."
`The only place the patent talks about layers is in the context of
`hierarchical menus of functions and data layering through those
`menus.
`
`So I think this is an example of a place where the
`invitation from patent owner to add new things to the claims is
`not supported by the spec. And we would actually use that as a
`way of pointing out what the correct claim construction is, Your
`Honor.
`
`Maybe we can turn to that first substantive topic of
`construction. I will address application first and then try to touch
`on function and data. Turning to our slide 10, patent owner has
`put in a construction for application, but we actually have a
`construction here on the left that we began with plain and
`ordinary meaning. And then Dr. Myers, our expert, testified that
`this is what the plain and ordinary meaning would be if you were
`to try to write it out.
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`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Paten 8,713,476 B2)
`On this slide we address one of the requirements that
`patent owner tries to add in to application involving operating
`system. Respectfully, all the art here has operating system. So I
`think we are going to move on beyond that. I don't think it's an
`issue that actually matters under the Vivid case to this trial.
`Turning to slide 11, one of the things that Dr. Myers
`testified about is that an application can be a program or a group
`of programs that is serving a function. And I think one of the
`things we are seeing is sort of a negative implication of what they
`are arguing application is. They argue it must be some single
`piece of code. It's not exactly clear what they mean, but we think
`that's absolutely not what either the specification or the plain
`meaning would be.
`JUDGE CHERRY: So you think the message center of
`Schnarel would count as an application under Dr. Myers'
`definition?
`MR. BAUGHMAN: Absolutely, Your Honor. That's
`because if you take a look at it, the purpose of the message center
`is served by the center and the viewers acting together, the
`viewers, whether you regard them as plug-ins or com objects.
`Turning to our slide 20, it is the very function of the message
`center application to provide integrated access to the messages.
`We know slide 22, I think it is, that Schnarel expressly teaches us
`that functionality, the top yellow highlight there, that
`functionality is provided by viewers inside Schnarel. Turning
`back to slide 20, sorry about the jumping around, Schnarel
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`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Paten 8,713,476 B2)
`teaches that when you press its buttons for functions or data, that
`causes the message center application to launch together with the
`associated viewers. So it's not like they are separate and they
`launch at different times.
`If you take a look at each of these examples, first we
`have the active call logger button, that causes the message
`application to launch and a call log viewer to be displayed. The
`second example, we have the active fax button. The message
`application is launched and a viewer is displayed. And the third
`example, when the user selects an icon and the new message is
`icon list, a procedure associated with that icon launches the
`message center application program and displays the appropriate
`message viewer. So however you regard the viewers, and we can
`come back to this in more detail, they certainly are part of an
`application, the message center application working together to
`provide access to functions and data.
`And if we look back at slide 11, just in terms of raw
`claim construction, the '020 and '476, as I think Your Honors
`have probably noted, doesn't spend a lot of time telling you what
`an application is, but it gives examples. And here it's grouping
`functions together. If you look in the EG, the parenthetical in the
`second box on slide 11, message center application, they are
`talking about functions. Message center, contacts, address book
`application, calendar application, telephone application, those are
`functions, and they are providing access with pieces of software
`to those functions.
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`And again, the extrinsic evidence we have here, the
`dictionary and the Mac OS Bible show that as of that time people
`of ordinary skill understood applications to be software providing
`a particular group of tasks. And application in particular, the
`Random House definition, a group of programs, would qualify.
`Touching briefly on function -- Your Honor, I'm happy
`to come back and I'll talk about Schnarel in more detail that's
`useful in application, but just in terms of claim construction, any
`questions on application?
`JUDGE CHERRY: No. I mean, I think maybe on
`Schnarel or however you pronounce it, maybe go back to that and
`then maybe focus on the reach directly given the limited time.
`MR. BAUGHMAN: Yes, Your Honor. Will do. I'll
`just briefly touch on function and data and then move out of
`claim construction. Function, again, we have what we think is
`the plain and ordinary meaning supported by -- turning to slide
`12. Sorry. Supported by the specification. Patent owner is
`adding a negative limitation here. They are trying to argue
`around the art by saying a function can't be essentially opening
`application and displaying a window. But if you look at the
`specifications, they absolutely don't say that. They don't exclude
`that kind of function. Instead the spec talks about commands as
`functional groups. So the commands and operation idea we had
`captured in our plain and ordinary meaning is certainly the
`correct one.
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`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Paten 8,713,476 B2)
`And to the contrary, if you look at the two bottom
`quotes on slide 12, they talk about functions. You select a
`function causing the user to be presented with a screen in which
`the data or function of interest is prominent. And the same for
`the bottom quote, displaying the relevant screen offering the
`relevant functionality. So certainly displaying pertinent data and
`available functions can be a function in terms of the '020 and
`'476. And respectfully, they are running away from the actual
`disclosure of this in the spec.
`Turning to slide 13, just to give a couple of examples,
`patent owner concedes that entering a chat room or entering pin
`are both functions. Dr. Myers confirmed both of those involve
`opening a window and viewing a screen. Like in a chat room, it's
`going to show you the ongoing conversation and it may offer you
`the opportunity to join it. A person of skill would certainly have
`understood a function includes displaying relevant information in
`the window of an application.
`Turning to slide 14, furthermore, patent owner has
`admitted that functions can include displaying a certain view.
`During prosecution, the patent owner and the examiner were
`discussing the Arcuri reference. We have an excerpt of that
`shown in the figure on the right, Figure 2 of Arcuri, which the
`patent owner conceded shows a menu offering a limited list of
`common functions. Those common functions are views of a
`word processing document. So again, this negative limitation
`they are arguing is unsupported. We have at the bottom of the
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`Case IPR2015-01898 (Patent 8,434,020 B2)
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`screen here on 14 another example of extrinsic evidence
`confirming our understanding of the plain and ordinary meaning
`of function as being an operation or a command.
`And finally, turning to data, slide 15, please, the claim
`term is actually data associated with an application. We have laid
`out on the screen what the specification supports is the meaning
`there. Patent owner has turned data stored in to data stored by,
`essentially trying to claim the storing, which it has not done.
`I think what is helpful here is to take a look at patent
`owner's response at page 20 and Denning declaration, Exhibit
`2003, paragraph 35. If you look at those, you'll find that there's
`zero citation to the patent. This is just an assertion they make
`with attorney argument and nothing more.
`If you actually look at the specification, which we have
`quoted in the second and third quote blocks there under the table,
`you'll see that it talks about the claimed application summary
`window and the limited list of data stored in the application. And
`then it talks about the embodiment that patent owner points to,
`which describes that as an app snapshot with data associated with
`the application. So it's mapping data associated with the
`application to data stored in the application. And of course you
`can't be storing the data in between bits of code. So this is
`certainly what the patent means. It doesn't say anything about
`stored by. And it certainly doesn't talk about storing in a memory
`location specifically allocated. If you take a look at the quote at
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`Case IPR2015-01898 (Patent 8,434,020 B2)
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`the bottom, in fact, the patent talks about simply storing in a
`device.
`
`Unless there are other claim construction questions,
`Judge Cherry, I'll turn back to Schnarel for a second and
`functions and applications. If we look at slide 18 and blow up, if
`we could, the abstract on the right, so Schnarel, just like the '020
`and '476, is about a GUI, graphical user interface or a web phone
`or other telephony device providing data information and access
`to functions.
`If we turn to slide 17, in the upper left there, we have
`highlighted our mapping of one of Schnarel's panes to the
`different limitations of the claim. We have a summary window in
`red, the limited list of data with the green icons, the limited list of
`functions, the buttons highlighted in purple. The example we
`have here is Caller Log, if you can read it.
`To the right we actually have another example from
`Figure 4 of fax. And I wanted to note that those two different
`images of fax change depending on whether a fax is present in
`Schnarel. So it changes from gray text to black. And all of these
`icons that you see with the green arrow and above only appear if
`there is a message. That's what the bottom block of text on slide
`17 confirms. Otherwise you get a "no new messages" message.
`As the upper quote block there under Schnarel talks
`about, in response to selecting an active fax button or an active
`logger button, you might get prompted for an ID and password
`depending on whether those were activated. And then it causes a
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`Case IPR2015-01898 (Patent 8,434,020 B2)
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`message center application to launch and appropriate call viewer
`to be displayed.
`Turning back to slide 18, we have here the embodiment
`in the lower left from the '020 and the '476 and that image from
`Schnarel along with the claim language. Walking through the
`limitations, we have an application summary window in red. You
`can see that highlighted in the pane in Schnarel and in the
`example in the '020. Each of them has a limited list, at least one
`function. That's the blue material. Each of those can be selected
`to launch. Turning to the '476, we have a limited list of data.
`That's the green items. And each of those, again, is selectable to
`launch.
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`And we talked a little bit earlier, Judge Cherry, in
`response to your questions, about the point on slide 19. Patent
`owner is essentially arguing that the message viewers are separate
`for separate plug-ins and then can't be part of the application.
`Again, the quote we have on the bottom of 19, Schnarel expressly
`confirms that message center application is the parent of the
`message summary pane, that red box we highlighted on the prior
`slide.
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`Turning to slide 21, we talked earlier about how each of
`those viewers launches with the application of which it is a plug-
`in or part. Figure 7 again shows the message viewers are part of
`the message center application. You can see that in the portion
`highlighted in the lower right of the slide, that portion of Figure
`7. If you actually look at the description accompanying it, which
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`is in the upper left of the slide, it lists application program shown
`in Figure 7. It lists the message center, but none of the viewers.
`And Dr. Myers confirmed this.
`Finally, turning to slide 22, as we talked about before,
`it's providing the functionality with these viewers to remove the
`viewers from the message center would really gut the application.
`It wouldn't be performing the functions it's meant for. That's how
`it does the functions. So as Dr. Myers testified, certainly even if
`you treat those as individually reachable applications or plug-ins,
`they together are a group of programs performing this function.
`We have evidence of the understanding of plug-in at the time as
`essentially providing additional functions for a main application.
`Turning to slide 23, in the alternative, Dr. Myers did
`address this argument. If you were to treat all these as separate, it
`certainly would have been obvious to put all these into a single
`program if that were required, although he doesn't think it was.
`And turning now to slide 24, moving away from
`applications to functions, as we understand patent owner's
`argument, they are arguing Schnarel doesn't disclose functions
`because it's displaying views of information. Dr. Myers testified
`that's not correct.
`If you turn to slide 25, while patent owner is trying to
`analogize this to sort of a semantic argument about an address
`book function, we are pointing out that one of the admitted
`functions of the entering a pin number in the '020 and '076 is
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`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Paten 8,713,476 B2)
`quite analogous to Schnarel's functions of identifying and
`entering a password, as Dr. Myers confirmed.
`Turning to slide 26, again, the viewer is providing the
`functionality for displaying and managing messages. That center
`quote on slide 26, Schnarel is pointing out these are all tasks.
`And Schnarel puts reviewing a message on the same footing as
`composing a message in those terms. The beginning of this
`sentence talks about tasks. And Dr. Myers pointed out that
`managing messages is something that's offered from this viewing
`screen. If you turn to Figure 5 of Schnarel, which is on page 6 of
`Exhibit 1004, as Dr. Myers pointed out, you not only have an
`example of a log here, but you have an example of what
`additional functionality the user is being offered when that log
`appears, including the ability to move in that button on the lower
`right.
`
`So unless there are further questions about Schnarel and
`functions and applications, I think I'll reserve the rest of that time
`until we respond to patent owner. And I'll pass the podium to my
`colleague to talk about Nason.
`JUDGE CHERRY: Reach directly.
`MR. BAUGHMAN: I'm sorry, Your Honor. We've
`addressed reach directly in a number of ways. Turning to slide
`28, I apologize, Judge Cherry, first of all, we've pointed out how
`Schnarel by itself would render obvious reaching that summary
`pane, that window we were pointing in to in red from a main
`menu. As Dr. Myers testified, it would have been beneficial to do
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`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Paten 8,713,476 B2)
`that. It would have advantageously avoided cluttering the display
`with information while still giving easy access especially in the
`context of a small screen device like a phone. We have
`Schnarel's own teachings about pop-ups and resizing and
`customizing. So given all that, as Dr. Myers testified, if you can
`see the cite there, in his declaration, paragraphs 58 to 59, he gives
`the rationale for this and points out that you would still be able to
`quickly discover and access new messages even if you had to go
`through that first step. If you compare it to the normal accessing
`of messages outside of that shortcut menu that Schnarel teaches,
`you would still have to go through fewer steps to go down one
`from the main menu and access the summary window than you
`would to have to go through the messages button and click
`through and make all the choices that would get you to the same
`place.
`
`JUDGE CHERRY: So the modification of Schnarel by
`itself would be putting a button on the menu bar?
`MR. BAUGHMAN: I think we've disclosed two ways
`of doing this, as either a button or a pop-up, both of which are
`disclosed in Schnarel itself and both of which certainly were
`within the skill of one of ordinary skill in the art at the time. We
`have Dr. Myers testifying about that skill. I think the Board
`acknowledged it at institution as well that certainly, as is plain
`from the patent itself and from patent owner's own response,
`hierarchical menus with shortcuts were already known.
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`Case IPR2015-01898 (Patent 8,434,020 B2)
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`Navigating among them was known. So it's all about where you
`put particular content on the menu.
`JUDGE LEE: I have a question. If it were a matter of a
`pop-up, how would you trigger the pop-up? Would you just put
`the cursor there for a moment and then it will appear or you have
`to click on something, then the pop-up menu?
`MR. BAUGHMAN: I think those are both options that
`are compatible with and consistent with the input mechanism as
`shown in Schnarel. I believe there's both keyboard and mouse
`and probably some additional input devices that are shown in
`Schnarel. In the background art references we've given there are
`a number of disclosures that Dr. Myers cites in this connection as
`showing different ways you could do that input. So certainly an
`affirmative clicking would be one way to reach directly. I believe
`one of the embodiments in the '020 talks about having it pop up
`when you hover or linger. But I think there's really no patentable
`difference between parking over something or clicking on it. And
`certainly both are obvious.
`JUDGE McKONE: Are you asking us to combine
`Schnarel with this background art? Is that really what your
`position is or is it -- because that's not the stated combination. As
`far as Schnarel alone, it wouldn't be -- you haven't stated a
`position that it's combining with background art.
`MR. BAUGHMAN: Judge McKone, thank you for the
`opportunity to address that. As the Board noted in institution,
`what we were attempting to do when we referred to the
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`background art was to show the level of skill of one of ordinary
`skill, the knowledge that was already the baseline from which a
`person of skill would be reading Schnarel. So for the Schnarel
`alone combination, the stand-alone 103, we would argue that
`from reading Schnarel and knowing what a person of skill would
`know, which can be evidenced by other documents, and Dr.
`Myers' testimony itself conveys this and collects documents
`giving evidence for his opinion, that combination, that
`modification would have been obvious from Schnarel standing
`alone.
`
`We also have affirmatively added, as Your Honors are
`aware, Aberg is a combination there because Aberg affirmatively
`teaches locating this kind of dynamic menu, this pop-upable
`menu at different levels of the hierarchy, including coming off the
`main menu.
`JUDGE LEE: Is there some point where it stops being
`direct? Do you have to do too many steps in order to reach
`something?
`MR. BAUGHMAN: Reach directly, Your Honor? You
`know, we didn't have to sort of discover the outer boundaries of
`this claim term in order to apply it to the art here. So under Vivid
`we weren't offering a construction of that. So I think for both the
`Nason combinations and Schnarel, we don't need to know
`whether there can be intervening steps. I think we've
`acknowledged in our paper that in litigation we've argued that
`there should be only one user step required. So we would meet
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`that, I guess, arguably narrower construction, but we don't think
`it's necessary to construe here.
`With that, if it's okay, I might pass and reserve the rest
`of our time.
`MS. RAYMOND: Good afternoon, Your Honors. May
`it please the Board, if we could turn to slide 49, we would like to
`start talking about just generally what Nason is about before I get
`into the particular arguments. Nason is about a menu system that
`uses bars with cartridges. These bars may be used individually,
`as shown in the top of this slide with the America Online
`cartridge, Figure 10 of Nason, or there can be multiple bars that
`are displayed at the same time. An example of this is Figure 9
`where the bars are stacked one on top of each other.
`Turning to slide 50, here we have a little bit more detail
`about the bars themselves and examples of the GUIs that are
`described in Nason. The bars are composed of one or more
`buttons or cartridges, and pressing a button allows a user to
`perform an action. So for instance, selecting a button can launch
`an application associated with the button. And one of the buttons
`that's pressable here is button 50. It shows up as 58 or 46 of
`Figure 2. Again, these bars of cartridges also may contain a
`ticker such as ticker 52 where it says text. And that can be
`clicked on to launch an application or URL.
`Turning to slide 51, we see here these cartridges may be
`made to rotate using rotator buttons such as button 44 shown in
`Figure 2 of Nason. What happens when you press the rotator
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`Case IPR2015-01898 (Patent 8,434,020 B2)
`Case IPR2015-01899 (Paten 8,713,476 B2)
`button is that everything to the right of that rotator button pivots.
`So in that way you can get from the main menu to an application
`summary window by clicking button 44.
`Turning to slide 52, and here I'll talk a little bit about
`our mapping. But first maybe we'll start with the abstract. We
`see here Nason broadly describes that the bars provide access to
`functions, and we see that here. And at the bottom, we also see
`that these buttons can initiate an application.
`So if we go back out to the whole slide, we see here
`some mapping. The red which has to do with the application
`summary window shown both in the '020
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