UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
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`
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`
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`PLAID TECHNOLOGIES, INC.
`Petitioner
`
`v.
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`YODLEE, INC.
`Patent Owner
`_________________________
`
`Case No. IPR2015-______
`Patent 6,317,783
`_________________________
`
`PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 6,317,783
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
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`

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`
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`Petition for Inter Partes Review of US Patent No. 6,317,783
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`
`TABLE OF CONTENTS
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`TABLE OF AUTHORITIES .................................................................................. I
`EXHIBIT LIST ....................................................................................................... II
`I.
`INTRODUCTION AND RELIEF REQUESTED ...................................... 1
`II. GROUNDS FOR STANDING ...................................................................... 1
`III. MANDATORY NOTICES ........................................................................... 1
`IV. BACKGROUND ............................................................................................ 2
`A.
`DESCRIPTION OF THE ’783 PATENT ......................................................... 2
`B.
`PROSECUTION HISTORY .......................................................................... 4
`C.
`STATE OF THE ART ................................................................................. 7
`
`V.
`
`A.
`B.
`
`PROPOSED GROUNDS OF UNPATENTABILITY ................................ 8
`SUMMARY OF GROUNDS OF REJECTION .................................................. 9
`PRIOR ART OFFERED FOR THE PRESENT UNPATENTABILITY
`CHALLENGES .......................................................................................... 9
`
`VI. CLAIM CONSTRUCTION ........................................................................ 10
`A.
`PROPOSED CLAIM CONSTRUCTIONS ..................................................... 11
`“non-public” (Claims 1, 18, 20) ......................................................... 11
`“intermediary web site” (Claims 14, 33) ............................................ 12
`
`1.
`2.
`
`A.
`
`VII. THE PRIOR ART RENDERS OBVIOUS CLAIMS 1–36 OF THE ’783
`PATENT ....................................................................................................... 13
`GROUND 1: CLAIMS 1, 3–20, AND 22–36 ARE RENDERED OBVIOUS BY
`SUGIARTO IN VIEW OF BRANDT. ........................................................... 13
`Sugiarto ............................................................................................... 14
`Brandt .................................................................................................. 17
`The Proposed Combination of Sugiarto and Brandt .......................... 20
`
`1.
`2.
`3.
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`
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`4.
`5.
`6.
`7.
`8.
`9.
`10.
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`B.
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`Petition for Inter Partes Review of US Patent No. 6,317,783
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`Sugiarto and Brandt render Independent Claim 1 Obvious. .............. 27
`Dependent Claim 3. ............................................................................. 41
`Dependent Claims 4 and 5. ................................................................. 42
`Dependent Claims 6–12 and 14–17 .................................................... 44
`Dependent Claim 13 ............................................................................ 49
`Independent Claim 18 and Dependent Claim 19. ............................... 50
`Independent claim 20 and Dependent Claims 22–36 ......................... 51
`GROUND 2: CLAIMS 2 AND 21 ARE RENDERED OBVIOUS BY SUGIARTO
`IN VIEW OF BRANDT IN FURTHER VIEW OF CHOW. ................................ 56
`
`VIII. CONCLUSION ............................................................................................ 60
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`Petition for Inter Partes Review of US Patent No. 6,317,783
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`TABLE OF AUTHORITIES
`
`Cases
`In re American Academy of Science Tech Center, 367 F.3d 1359, 1364, 1369 (Fed.
`Cir. 2004) ....................................................................................................... 10
`
`In re Cuozzo Speed Techs., LLC., 793 F.3d 1268, 1278–79 (Fed. Cir. 2015) ......... 10
`
`InTouch Techs., Inc. v. VGO Commc’n, Inc., 751 F.3d 1327, 1347 (Fed. Cir. 2014)
` ....................................................................................................................... 14
`
`Statutes
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`35 U.S.C. § 102(e) .............................................................................................. 9, 10
`
`35 U.S.C. § 103 .......................................................................................................... 9
`
`Rules
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`37 C.F.R. § 42.10(b) .................................................................................................. 2
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`37 C.F.R. § 42.100(b) .............................................................................................. 10
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`Petition for Inter Partes Review of US Patent No. 6,317,783
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`EXHIBIT LIST
`
`
`Exhibit Number
`1001
`1002
`
`1003
`1004
`1005
`1006
`1007
`
`1008
`1009
`1010
`1011
`1012
`1013
`
`Document
`U.S. Patent No. 6,317,783 (“the ’783 Patent”)
`Summons Returned as Executed, Yodlee, Inc. v. Plaid Techs.
`Inc., Case No. 14-cv-01445 (D. Del. filed Dec. 1, 2014)
`File History of the ’783 Patent
`U.S. Patent No. 6,278,449 to Sugiarto (“Sugiarto”)
`U.S. Patent No. 5,892,905 to Brandt et al. (“Brandt”)
`U.S. Patent No. 6,029,175 to Chow et al. (“Chow”)
`Claim Construction Briefing in Yodlee, Inc. v. Plaid Techs.
`Inc., Case No. 14-cv-01445 (D. Del. 2014)
`Declaration of Dr. Todd Mowry (“Mowry Decl.”)
`U.S. Patent No. 6,401,118 to Jason B. Thomas
`U.S. Patent No. 6,006,333 to Jakob Nielsen
`Screenshots regarding ESPN Insider
`U.S. Patent No. 6,041,362 to Mears et al.
`U.S. Patent No. 6,243,816 to Fang et al.
`
`ii
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`Petition for Inter Partes Review of US Patent No. 6,317,783
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`I.
`
`INTRODUCTION AND RELIEF REQUESTED
`
`Plaid Technologies, Inc. (“Petitioner”) hereby petitions for institution of
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`inter partes review of U.S. Patent No. 6,317,783 (“the ’783 Patent”) (Ex. 1001).
`
`The ’783 Patent issued on November 13, 2001, and is presently assigned to
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`Yodlee, Inc. (“Patent Owner”). Petitioner respectfully requests cancellation of
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`claims 1–36 of the ’783 Patent based on the grounds of unpatentability detailed
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`herein. The prior art and other evidence offered with this Petition establishes that
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`all elements in the challenged claims of the ’783 Patent were well known as of the
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`earliest alleged priority date, and that the claimed methods and systems recited in
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`the ’783 Patent are obvious.
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`II. GROUNDS FOR STANDING
`Petitioner certifies that the ’783 Patent is available for review under
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`35 U.S.C. § 311(c) and that it is not estopped from requesting an inter partes
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`review challenging claims 1–36 on the grounds identified in this Petition.
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`III. MANDATORY NOTICES
`Real Party in Interest: Petitioner Plaid Technologies, Inc. is the real party-in-
`
`interest for this Petition.
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`Related Matters: Petitioner has been charged with infringement of the ’783
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`Patent in the parallel litigation styled Yodlee, Inc. v. Plaid Techs. Inc., Case No.
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`14-cv-01445 (D. Del.), filed December 1, 2014 (“Co-Pending District Court
`
`Action”). Petitioner was served with the complaint in that litigation on December
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`1
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`Petition for Inter Partes Review of US Patent No. 6,317,783
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`2, 2014. Ex. 1002. A petition for Inter Partes Review of another asserted patent,
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`U.S. Patent No. 6,199,077, is to be filed contemporaneously with this petition.
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`Designation of Counsel: Petitioner designates the following Lead and Back-
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`up Counsel. Concurrently filed with this Petition is a Power of Attorney per 37
`
`C.F.R. § 42.10(b). Service via hand-delivery may be made at the postal mailing
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`address below. Petitioner consents to electronic service by e-mail.
`
`Lead Counsel
`Brian Buroker (Reg. No. 39,125)
`Gibson, Dunn & Crutcher LLP
`1050 Connecticut Avenue, N.W.
`Washington, D.C. 20036-5306
`202.955.8541
`bburoker@gibsondunn.com
`
`IV. BACKGROUND
`
`A. Description of the ’783 Patent
`
`Back-Up Counsel
`Omar Amin (Reg. No. 60,885)
`Gibson, Dunn & Crutcher LLP
`1050 Connecticut Avenue, N.W.
`Washington, D.C. 20036-5306
`202.887.3710
`oamin@gibsondunn.com
`
`The ’783 Patent relates to “an apparatus and process for automated
`
`aggregation and delivery of electronic personal information or data (PI).” ’783
`
`Patent, Ex. 1001, 1:23–26. Fig. 2, reproduced below, provides a visual of the basic
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`elements/components used to implement the alleged invention. The specification
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`discloses a system for delivering personal information (PI) that may include “a
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`user store including end user data, a provider store including information provider
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`data, a personal information store including personal information and a processor
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`that communicates with these data stores.” Id., 3:20–24. The processor
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`“retrieve[s] personal information for the selected end user from the connected
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`information providers.” Id., 3:28–31.
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`
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`Ex. 1001, Fig. 2. As seen in Fig. 2, according to the ’783 Patent, the end user 210
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`accesses a client computer 220 that connects to the Internet 230 to access a PI
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`engine 240 running on a PI host 290. Id., 4:29–34. The PI engine 240, shown in
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`more detail in Fig. 3 above, examines stored PI 280 and refreshes it by directly
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`reacquiring the PI from the particular information provider’s Web site 250 running
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`on the provider’s computer system 260. Id., 4:34–38. The PI Engine includes a
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`“PI access/transact component,” which “supports the update, acquisition and
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`transaction functionality of the PI engine.” Id., 9:30–32. “For each piece of PI
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`requiring access or update,” the PI access/transact component “looks up the access
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`procedure and information needed for the particular PI in the Provider store” as
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`Petition for Inter Partes Review of US Patent No. 6,317,783
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`well as “verification and access data,” which is found in the user store. Id., 9:38–
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`41. “A simulated Web client could perform access or transaction processes
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`automatically supplying access and verification data as necessary.” Id., 9:59–61.
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`The PI engine 240 further stores the aggregated PI in its store 280 and delivers the
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`PI to a selected destination, for example across the Internet 230 to the client
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`computer 220 which displays the information to the end user 210 using the client
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`software 270. Id., 4:39–46. At bottom, the ’783 Patent is directed toward
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`retrieving and storing personal information from multiple sources.
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`B. Prosecution History
`The ’783 Patent issued from U.S. Application No. 09/428,511 (“the ’511
`
`Application”), which was filed on October 27, 1999 with claims 1–28. ’783 Patent
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`File History, Ex. 1003, 32. The ’511 Application claimed the benefit of
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`Provisional Application Nos. 60/105,917 and 60/134,395, filed October 28, 1998
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`and May 17, 1999, respectively. Id., 35. In October 2000, the PTO issued an
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`Office Action in the ’511 Application, rejecting all of pending claims 1–28. Id.,
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`184. Specifically, claims 1–28 were rejected under nonstatutory, obviousness-type
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`double patenting over then-pending Application No. 09/427,602 (“the ’602
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`Application”) and under 35 U.S.C. § 103(a) as being obvious over U.S. Patent No.
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`5,995,965 to Experton (“Experton”), in view of U.S. Patent No. 5,862,325 to Reed
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`et al., (“Reed”). Id., 149–53.
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`The Applicant filed a Reply to the Office Action, which included a Terminal
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`Disclaimer over the ’602 Application to overcome the double patenting rejection,
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`and added claims 29–36. Id., 168. The Reply also included amendments to then-
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`pending independent claims 1, 14, and 27 to overcome the obviousness rejection.
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`For example, the Applicant amended independent claim 14 (which was
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`renumbered as claim 1 in the ’783 Patent) as follows:
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`14. (Once amended) A method for delivering non-public
`personal information relating to an end user via a computer network to
`[at least one] an end user from at least one of a plurality of
`information providers securely storing the personal information, the
`method comprising the steps of:
`
`(a) the processor connecting with at least one information
`provider;
`(b) for a selected end user, the processor retrieving
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`personal information for the selected end user from the connected at
`least one information provider based on end user data associated with
`the selected end user and information provider data associated with
`the connected one or more information providers, the end user data
`including
`information
`identifying
`the plurality of
`information
`providers securely storing the personal information relating to the end
`user the provider data Including a protocol for instructing the
`processor how to access the securely stored personal information via
`the network. the information accessible to the processor using the
`protocol also being accessible by the end user via the network
`independently of the system for delivering personal information; and
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`retrieved personal
`the
`the processor storing
`(c)
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`information in a personal information store for access by the selected
`end user.
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`Id., 165. The Applicant amended then-pending independent claims 1 and 27 in a
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`similar manner. Id., 164–66. In its Remarks, the Applicant argued that, as
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`amended, then-pending claims 1, 14, and 27 were patentable over Experton and
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`Reed because, “[i]n Applicant’s invention, the information providers are those that
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`an end user could alternatively choose to access in a conventional manner, i.e.,
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`independently of using the inventive system. . . . Neither Experton nor Reed
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`addresses the issue of making access to multiple ones of such personal information
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`providers more convenient by obviating a user contacting each provider
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`individually.” Id., 169 (italics removed). Thereafter, the Examiner allowed the
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`’511 Application, concluding that prior art of record did not disclose or render
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`obvious “an end user data including identifying the plurality of information
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`providers securely storing the personal information relating to the end user, the
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`provider data including a protocol for instructing the processor how to access
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`the securely stored personal information.” Id., 175 (bolding in the original). But
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`as described below, the concept that the Examiner found to be novel and non-
`
`obvious—automatic authentication and gathering—was well-known by the priority
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`date of the ’783 Patent.
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`C. State of the Art
`With the proliferation of content on the World Wide Web (“Web” or
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`“WWW”) in the early-to-mid 1990s, software solutions that allowed for automatic
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`aggregation of data on the Web had become well known to those of ordinary skill
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`in the art by the priority date of the ’783 Patent. U.S. Patent No. 6,278,449 to
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`Sugiarto (“Sugiarto”) (Ex. 1004) describes an apparatus which “collect[s]
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`information from various web pages from the worldwide web internet, configure[s]
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`this various information in accordance with a predefined user configuration file,
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`defined by a particular user, and transmit[s] the configured various information to a
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`highly portable internet access device.” Sugiarto, Ex. 1004, 2:10–17. Sugiarto
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`teaches a system that provides a user with a customized Web page that includes
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`data sourced from one or more Web sites of the user’s choosing, e.g., CNN, ESPN,
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`and/or Nasdaq. Id., 4:36–53.
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`Those of ordinary skill in the art further recognized that much of the
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`personal information available on the WWW is only accessible after the user has
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`been authenticated, e.g., by providing his or her credentials (username and
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`password). To automate this process, skilled artisans developed software agents,
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`also termed Internet gateways or simulated web clients, which simulated the user
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`providing his or her credentials. For example, U.S. Patent No. 5,892,905 to Brandt
`
`et al. (“Brandt”) (Ex. 1005) describes “the capability to easily access many
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`different application programs over the WWW via a standardized [graphical user
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`interface].” Brandt, Ex 1005, 3:57–60. In Brandt, an Internet gateway accesses a
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`user library to obtain authentication data needed to access software applications for
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`the user. Id., 12:15–17. The Internet gateway then logs the user onto a requested
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`service using normal security procedures. Id., 12:28–28.
`
`Skilled artisans also recognized that in the Web’s client-server model, end
`
`users often could not find out if server information changed. To address this
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`problem within the existing client-server architecture, U.S. Patent No. 6,029,175 to
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`Chow et al. (“Chow”) (Ex. 1006) describes a software agent, termed a “Revision
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`Manager,” to monitors content at a server. Chow, Ex. 1006, 3:60–64. The
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`Revision Manager accepts user input indicating the user’s interest in monitoring a
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`document. Id., 5:32–34. In response, the Revision Manager “spontaneously
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`monitors the server to notice if the document has been modified.” Id., 6:2–4.
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`V.
`
`PROPOSED GROUNDS OF UNPATENTABILITY
`
`The present Petition relies on prior art references that have not been
`
`considered by the Patent Office in the file history of the ’783 Patent and details
`
`how the challenged claims are obvious in view of the prior art.1 These references
`
`1 None of these references were cited by the Examiner during prosecution of the
`
`’783 Patent. The Applicant cited Chow to the USPTO, but the Examiner did not
`
`rely on Chow in a rejection.
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`evidence the well-known combination of known elements to teach all of the
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`limitations recited by the claims of the ’783 Patent.
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`A. Summary of Grounds of Rejection
`The following chart demonstrates the grounds of rejection and the prior art
`
`references applied against the challenged claims.
`
`Ground 1:
`
`Ground 2:
`
`§103 in view of Sugiarto
`combined with Brandt
`§ 103 in view of Sugiarto
`combined with Brandt in
`further view of Chow
`
`Renders Claims 1, 3–20, and 22–
`36 obvious under §103(a)
`Renders Claims 2 and 21 obvious
`under §103(a)
`
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`With the present grounds of obviousness and the evidence submitted herein,
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`Petitioner has established a reasonable likelihood that it will prevail in establishing
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`unpatentability of claims 1–36 and requests institution of inter partes review and
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`cancellation of these claims.
`
`B. Prior Art Offered for the Present Unpatentability Challenges
`The present Petition states obviousness grounds under 35 U.S.C. § 103 using
`
`the following patents:
`
`• U.S. Patent No. 6,287,449 to Sugiarto et al. (“Sugiarto”) (Ex. 1004) was filed
`
`on September 3, 1998; this reference is prior art at least under pre-AIA 35
`
`U.S.C. § 102(e) (the ’783 Patent’s earliest claimed priority date is October 28,
`
`1998).
`
`• U.S. Patent No. 5,892,905 to Brandt et al. (“Brandt”) (Ex. 1005) was filed on
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`December 23, 1996; this reference is prior art at least under pre-AIA 35 U.S.C.
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`§ 102(e).
`
`• U.S. Patent No. 6,029,175 to Chow et al. (“Chow”) (Ex. 1006) was filed on
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`June 6, 1996; this reference is prior art at least under pre-AIA 35 U.S.C. §
`
`102(e).
`
`VI. CLAIM CONSTRUCTION
`Under 37 C.F.R. § 42.100(b), a claim in inter partes review is given the
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`“broadest reasonable construction” in light of the specification. In re Cuozzo
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`Speed Techs., LLC., 793 F.3d 1268, 1278–79 (Fed. Cir. 2015). Because the
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`standard for claim construction at the Patent Office is different (i.e., broader) from
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`that used in a U.S. district court litigation, see In re American Academy of Science
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`Tech Center, 367 F.3d 1359, 1364, 1369 (Fed. Cir. 2004), Petitioner expressly
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`reserves the right to argue a different claim construction in the district court
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`proceeding for any term of the ’783 Patent, as appropriate.
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`Petitioner requests that the Board give all claim terms not specifically
`
`construed herein their broadest reasonable construction. Nonetheless, Patent
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`Owner and Petitioner have submitted claim construction briefing in the Co-
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`Pending District Court Action.2 See Petitioner’s Opening Claim Construction Br.
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`2 The Court has not yet entered an order construing the claims in the Co-Pending
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`District Court Action.
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`(“Claim Construction Br.”) (Ex. 1007) (providing a listing of constructions
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`proposed by Petitioner and Patent Owner). Petitioner contends that many of these
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`terms do not require specific construction in this proceeding; nevertheless, out of
`
`an abundance of caution, Petitioner explains below how the proposed grounds
`
`render the claims obvious under either Patent Owner’s or Petitioner’s proposed
`
`construction from the Co-Pending District Court Action.
`
`A. Proposed Claim Constructions
`1.
`“non-public” (Claims 1, 18, 20)
`
`The term “non-public” only appears in the claims of the ’783 Patent, not in
`
`the written description. During prosecution of the ’511 Application, however,
`
`when the Applicant added this term to the claims, the Applicant explained
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`“personal information” (which the term “non-public” modifies) as follows:
`
`The essence of personal information is that it is not accessible to the
`general public, i.e., other end users; rather, each information provider
`protects personal information relating to a specific end user against
`access by persons other than that end user or one acting under the
`authority of that end user. The information providers have Web sites
`or other electronic means by which end users can access their personal
`information in the conventional manner, i.e., independently of the
`invention, such as by logging onto a Web site, entering a user name
`and password and following any further instructions for retrieving the
`information.
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`’783 File History, Ex. 1002, 168 (emphases added). The Applicant thus made
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`clear that under the broadest reasonable interpretation, the “non-public”
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`information recited in the ’783 Patent claims covers information secured by Web
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`sites that require user log on (e.g., with a user name and password).
`
`2.
`
`“intermediary web site” (Claims 14, 33)
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`The ’783 Patent describes storing retrieved personal information in a
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`personal information (PI) store 280. ’783 Patent, Ex. 1001, 4:57–60. PI delivery
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`component is responsible for formatting and delivering the PI to the end user. ’783
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`Patent, Ex 1001, 11:66–67; Ex. 1008. The PI may be delivered from PI store 280
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`to one or more “destinations,” e.g., facsimile, telephone, pager, Web browser, or
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`email (see claim 6–8). ’783 Patent, Ex. 1001, 12:2–3. For example, when the
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`destination is a Web browser, the PI may be formatted as an HTML page. ’783
`
`Patent, Ex. 1001, 12:8–11. The delivered page may be dynamically formatted
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`using, e.g., a dynamic HTML generation system. ’783 Patent, Ex. 1001, 12:19–31.
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`The dynamic generation of the web page may be based on factors received from,
`
`e.g., information providers, distributors, the end user, the PI delivery component,
`
`or any combination thereof. ’783 Patent, Ex. 1001, 12:32–36.
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`The PI may also be accessed via “an intermediary web site” (see claim 14).
`
`’783 Patent, Ex. 1001, 12:12–13. The ’783 Patent mainly describes intermediary
`
`websites as being themselves information providers. See ’783 Patent, Ex. 1001,
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`12:17–21. Thus, these Web sites are “intermediaries” between the end user and the
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`personal information engine, i.e., the Web sites are served by Web servers are not
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`running on the end user’s computer or on the computer running the personal
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`information engine. The ’783 Patent, however, expressly states that “the
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`intermediary” is not required to be an information provider. ’783 Patent, Ex. 1001,
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`12:25–28. Thus, Petitioner submits that the broadest reasonable construction of
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`“intermediary web site,” in view of the ’783 Patent, is a Web site that is served by
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`a Web server running on a computer that is not the end user’s computer and is not
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`the “processor.” Ex. 1008, Mowry Decl., ¶ 59.
`
`VII. THE PRIOR ART RENDERS OBVIOUS CLAIMS 1–36 OF THE ’783
`PATENT
`
`The discussion and claim charts below identify each challenged claim and
`
`where the prior art teaches or suggests each portion of the claim, as well as where
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`each portion of the claim is further analyzed in the Declaration of Dr. Todd
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`Mowry, Ex. 1008, and why a person of ordinary skill would be motivated to
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`modify the base reference as outlined in the obviousness combination.
`
`A. Ground 1: Claims 1, 3–20, and 22–36 are Rendered Obvious by
`Sugiarto in view of Brandt.
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`As explained below, one of ordinary skill in the art would have been
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`motivated to combine Sugiarto and Brandt in a manner that teaches all of the
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`limitations of claims 1, 3–20, and 22–36 and would have had a reasonable
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`expectation of doing so. Accordingly, Sugiarto and Brandt render claims 1, 3–20,
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`and 22–36 obvious. InTouch Techs., Inc. v. VGO Commc’n, Inc., 751 F.3d 1327,
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`1347 (Fed. Cir. 2014).
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`1.
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`Sugiarto
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`Sugiarto describes an apparatus that “collect[s] information from various
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`web pages from the worldwide web internet, configure[s] this various information
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`in accordance with a predefined user configuration file, defined by a particular
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`user, and transmit[s] the configured various information to a highly portable
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`internet access device.” Sugiarto, Ex. 1004, 2:10–17. An annotated version of Fig.
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`1 of Sugiarto is provided below. The annotations in blue illustrate Petitioner’s
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`proposed modification of Sugiarto in view of Brandt, and the annotations in red
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`illustrate Petitioner’s mapping of the ’783 claims onto the proposed combination.
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`“End user”
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`Application Gateway
`“Processor”
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`“Wide-area
`computer network”
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`Provider
`Store
`Personal Info.
`Store
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`“User store”
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`Secure
`Content
`Provider
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`Secure
`Content
`Provider
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`“Information
`providers”
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`
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`As shown in Fig. 1 of Sugiarto, the system includes a user access device 6, a
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`system server 2, a database server 8, a network 4, and a desktop computer system
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`9. Sugiarto, Ex 1004, 3:13–24. Network 4 may be the Internet or, in particular,
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`the “world-wide-web aspect of the internet.” Sugiarto, Ex. 1004, 3:47–52. As
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`shown above, desktop computer 9 is coupled to system server 2 through network 4.
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`See also Sugiarto, Ex. 1004, 3:22–24.
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`Software modules 14–20 run on system server 2. Sugiarto, Ex. 1004, 3:58–
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`60. Software module 20 is an HTTP daemon, which “runs in the background” and
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`facilitates “access to HTTP facilities.” Sugiarto, Ex. 1004, 3:62–65. Modules 14,
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`16, and 18 are content gathering modules that service requests for information
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`from an end user. Sugiarto, Ex. 1004, 3:65–66. For example, modules 14, 16, and
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`18 may be implemented as a web browser that navigates to web pages. Sugiarto,
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`Ex. 1004, 8:58–61. When system server 2 receives a request for content, HTTP
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`daemon module 20 invokes one or more of modules 14, 16, and 18 to honor the
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`request. Sugiarto, Ex. 1004, 3:65–4:2. For example, modules 14, 16, and 18 may
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`retrieve data from respective websites over network 4, such as websites maintained
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`by CNN, ESPN, or NASDAQ. Sugiarto, Ex. 1004, 4:18–24.
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`Database server 8 stores configuration files of the end user. Sugiarto, Ex.
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`1004, 3:41–44. Each of the configuration files “specifies what information the
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`user would like to retrieve and how the retrieved information is to be formatted.”
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`Sugiarto, Ex. 1004, 4:18–20.
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`A user initiates a request for a personalized webpage by making a specific
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`type of HTTP request (e.g., the request may be HTTP://access.domain/pir, with
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`“pir” standing for “personal information request”). Sugiarto, Ex. 1004, 8:34–36,
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`8:40–43. Sugiarto explicitly states that this request can come from user access
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`device 6 or desktop computer 9. Sugiarto, Ex. 1004, 8:34–36. “Depending on the
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`information contained in the user’s configuration file, the uploaded module opens
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`the appropriate HTTP connection, fetches the appropriate web pages from the
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`internet, and selects the appropriate predefined portions therefrom, and formats
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`them into a single page in a predefined user format in accordance with the
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`configuration file that is viewable on display screen 10 of handset 6.” Sugiarto,
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`Ex. 1004, 8:61–9:1. Fig. 7 of Sugiarto, provided below, shows an example of such
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`single page, i.e., a personalized web page. As shown below, the personalized web
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`page displays information retrieved from the CNN (portion 742), ESPN (portion
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`744), and NASDAQ (portion 746) websites. Sugiarto, Ex. 1004, 4:36–53.
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`2.
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`Brandt
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`
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`Brandt describes a system that “provides the capability to easily access many
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`different application programs over the WWW via a standardized GUI.” Brandt,
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`Ex. 1005, 3:56–60. Fig. 3 of Brandt, provided below, shows “a block diagram of a
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`system . . . that allows access to a software application of the World-Wide Web
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`from a standard web browser.” Brandt, Ex. 1005, 4:30–33. As shown below, the
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`system includes a client workstation 210, a web server computer system 220, and
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`computer systems 330 and 340. The connections between client workstation 210,
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`server workstation 220, and computer systems 330 and 340 may be via the
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`Internet. Brandt, Ex. 1005, 22:11–16. As seen in Fig. 3, below, an end user uses
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`web browser 212, running on client workstation 210, to interact with web server
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`application 222, running on web server computer system 220, by transmitting a
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`Uniform Resource Locator (URL) or HTML page over connection 216 using the
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`Hypertext Transfer Protocol (HTTP). Brandt, Ex. 1005, 6:35–39.
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`
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`Moreover, Internet/Application Gateway 332 (“Application Gateway 332”)
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`provides for access to software applications 342. See Brandt, Ex. 1005, 9:22–26.
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`As further shown in Fig. 6 of Brandt, provided below, Application Gateway 332
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`facilitates user access by automatically authenticating the user for access to a
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`specific software application 342. The automatic authentication process begins
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`with an end user requesting access to a software application via Web browser 212
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`(step 621). Brandt, Ex. 1005, 11:51–55. In doing so, the end user provides a
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`userID, password, and key to Web server application 222, which controls access to
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`application gateway 332. Brandt, Ex. 1005, 11:55–63. Web server application 222
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`authenticates the user (step 623) and passes the user’s userID, password, key, and
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`request content to application gateway 332 (step 625). Brandt, Ex. 1005, 11:65–
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`12:3. Application Gateway 332 compares the received userID and key to userIDs
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`and keys stored in user library 620, which “stores the user information for a
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`plurality of software applications that are to be accessed through gateway 332”
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`(step 627). Brandt, Ex. 1005, 12:5–7. Application Gateway 332 retrieves
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`authentication data for the specific software application 324 from which the user
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`requested information (step 629). Brandt, Ex. 1005, 12:15–19. Application
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`Gateway 332 uses the retrieved authentication information to log into software
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`application 342 on the user’s behalf just as the user would log in if he or she was
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`attempting to log in to the software application