Microsoft Corporation,
`Petitioner
`v.
`Bradium Technologies LLC,
`Patent Owner
`
`IPR2016-00448 for U.S. Patent No. 7,908,343
`IPR2016-00449 for U.S. Patent No. 8,924,506
`
`
`
`April 18, 2017
`
`
`1
`
`Exhibit 2086
`Bradium Technologies LLC - patent owner
`Microsoft Corporation - petitioner
`IPR2016-00448
`
`
`Petitioner
`v.
`Bradium Technologies LLC,
`Patent Owner
`
`IPR2016-00448 for U.S. Patent No. 7,908,343
`IPR2016-00449 for U.S. Patent No. 8,924,506
`
`
`
`April 18, 2017
`
`
`1
`
`Exhibit 2086
`Bradium Technologies LLC - patent owner
`Microsoft Corporation - petitioner
`IPR2016-00448
`
`
`
`One Ground: Reddy and Hornbacker
`
`IPR2016-00448 Institution Decision, Paper 9, pp. 44-45;
`IPR2016-00449 Institution Decision, Paper 9, p. 44.
`
`2
`
`
`
`Reddy, Hornbacker Do Not Teach or Suggest
`
`1. Prioritization of requests for image parcels; (343 patent,
`claims 15–16)
`
`2. Use of a prioritization value for data parcel requests; (343
`patent, claims 10–11)
`
`3. Processor selection of data parcels for progressive
`resolution enhancement; (343 patent, claim 13; 506
`patent, claims 8, 15)
`
`4. Queuing data parcels based on importance; (506 patent,
`claims 6, 13, 20)
`
`5. Efficient data structure; (343 patent, claims 1, 13; 506
`patent claims 7, 14, 21)
`
`IPR2016-00448, Paper 21, pp. 21–43.
`3
`
`
`
`Reddy Does Not Teach or Suggest
`
`1. Limited bandwidth communications channel; (343 patent,
`claim 13; 506 patent, claims 8, 15)
`
`2. Limited communication bandwidth computer device; (343
`patent, claim 1; 506 patent, claims 1, 3–5, 10–12, 15, 17–
`19)
`
`
`
`IPR2016-00448, Paper 21, pp. 21–43.
`4
`
`
`
`Prioritization of Requests
`for Image Parcels
`
`5
`
`
`
`Prioritization of requests for image parcels; (343 patent,
`claims 15–16)
`
`IPR2016-00448, Ex. 1001, 13:16–14:6.
`6
`
`
`
`Prioritization Value
`
`Prioritization Value
`
`7
`
`
`
`Use of a prioritization value for data parcel requests; (343
`patent, claims 10–11)
`
`IPR2016-00448, Ex. 1001, 12:22–33.
`
`8
`
`
`
`Selection of Data Parcels for
`Progressive Resolution Enhancement
`
`9
`
`
`
`Selection of data parcels for progressive resolution
`enhancement; (343 pat., cl. 13; 506 pat., cl. 8, 15)
`
`Claim 13 of the 343 patent, and claims 8 and 15 of the 506 patent,
`require that the processor be operative to select a defined data parcel to
`provide for progressive resolution enhancement
`
`
`E.g., 343 Pat., excerpt of claim 13:
`
`IPR2016-00448, Paper 21 (Public Corrected PO Response) at pp. 26–27; IPR2016-00448, Ex. 1001, 12:49–56.
`
`10
`
`
`
`Selection of data parcels for progressive resolution
`enhancement; (343 pat., cl. 13; 506 pat., cl. 8, 15)
`
`343 Pat., excerpt of claim 13:
`
`IPR2016-00448, Ex. 1001, 12:49–56.
`11
`
`
`
`Selection of data parcels for progressive resolution
`enhancement; (343 pat., cl. 13; 506 pat., cl. 8, 15)
`
`506 Pat., excerpt of claim 8:
`
`506 Pat., excerpt of claim 15:
`
`IPR2016-00448, Ex. 1002, 13:37–44, 14:38–44.
`12
`
`
`
`Reddy (Ex. 1004)
`
`Claim 13 requires that the processor, as opposed to the user’s,
`action perform a selection.
`Reddy requires that the user “fly” close to a particular area
`before the system will request a higher-resolution tile of the
`area.
`
`IPR2016-00448, Ex. 2003 (Agouris Decl.) at ¶¶84–85 (p. 31 (exhibit stamp p. 35)).
`
`13
`
`
`
`Queuing Data Parcels Based on an
`Importance of the Update Data
`Parcel as Determined by the Remote
`Computer
`
`14
`
`
`
`Queuing data parcels based on importance; (506 patent,
`claims 6, 13, 20)
`
`IPR2016-00448, Ex. 1002, 13:14–18, 14:15–18, 15:16–20.
`15
`
`
`
`Efficient Data Structure
`
`16
`
`
`
`Efficient data structure; (343 patent, claims 1, 13; 506
`patent claims 7, 14, 21)
`
`•
`
`•
`
`343 Patent: image parcels are stored on a remote
`computer “in a file of defined configuration such that a
`data parcel can be located by specification of a KD, X, Y
`value that represents the data set resolution index D and
`corresponding image array coordinate.”
`
`TerraVision II: Terrain is defined via a customized set of
`“arbitrary polygons in 3D space,” not a grid.
`
`• VRML is essentially a set of nodes or objects that have
`characteristics and are linked to one another.
`
`
`
`IPR2016-00448, Paper 21, pp. 36–38.
`17
`
`
`
`Efficient data structure; (343 patent, claims 1, 13; 506
`patent claims 7, 14, 21)
`343 Patent, claim 1:
`
`IPR2016-00448, Ex. 1002, 12:40–52, 13:19–24.
`18
`
`
`
`Efficient data structure; (343 patent, claims 1, 13; 506
`patent claims 7, 14, 21)
`506 Patent, excerpt of independent claim 1 and its dependent claim 7:
`
`IPR2016-00448, Ex. 1002, 12:40–52, 13:19–24.
`19
`
`
`
`The Board’s Claim Construction: “Data Parcel”
`
`IPR2016-00448, Paper 9, p. 11; see IPR2016-00449, Paper 9, pp. 10-11.
`
`20
`
`
`
`Proposed Claim Construction: “Image Parcel”
`
`IPR2016-00448, Paper 21 (Public Corrected PO Response), p. 9; see IPR2016-00449, Paper 17 (Public PO Response), pp. 9-10.
`
`21
`
`
`
`Limited Bandwidth Communications
`Channel
`
`22
`
`
`
`Proposed Claim Construction: “Limited Bandwidth
`Communications Channel”
`
`IPR2016-00448, Paper 21 (Public Corrected PO Response), p. 9; see IPR2016-00449, Paper 17 (Public PO Response), p. 10.
`
`23
`
`
`
`“Limited Bandwidth Communications Channel”
`343 patent, claim 13
`
`IPR2016-00448, Ex. 1001, 12:38–13:10.
`
`24
`
`
`
`“Limited Bandwidth Communications Channel”
`506 patent, claim 8
`
`IPR2016-00448, Ex. 1002, 13:25–60.
`
`25
`
`
`
`“Limited Bandwidth Communications Channel”
`
`“[t]he disclosure is related to network based, image distribution systems
`and, in particular, to a system and methods for efficiently selecting and
`distributing image parcels through narrowband or otherwise limited
`bandwidth communications channel to support presentation of high-
`resolution images subject to dynamic viewing frustums.” (Ex. 1001, 1:25–
`30)
`
`“limited bandwidth conditions may exist due to either the direct
`technological constraints dictated by the use of a low bandwidth data
`channel or indirect constraints imposed on relatively high-bandwidth
`channels by high concurrent user loads.” (Ex. 1001, 3:9–14)
`
`“Another problem is that small clients are generally constrained to
`generally to [sic] very limited network bandwidths, particularly when
`operating under wireless conditions.” (Ex. 1001, 3:6–9)
`
`
`
`IPR2016-00448, Paper 21 (Public Corrected PO Response) at pp. 9–11.
`
`26
`
`
`
`“Limited Bandwidth Communications Channel”:
`Dr. Michalson’s Interpretation is “all channels”
`
`Cross examination of Dr. Michalson, page 54, lines 8–16.
`
`
`
`IPR2016-00448, Ex. 2078, 53:21–55:8 at 54:8–16, Paper 44, p. 10.
`
`27
`
`
`
`“Limited Bandwidth Communications Channel”:
`Dr. Michalson’s Interpretation is “all channels”
`
`
`
`Cross examination of Dr. Michalson, page 58, lines 4–19.
`
`IPR2016-00448, Ex. 2078, 58:4–19, Paper 44, pp. 10–11.
`
`28
`
`
`
`Reddy (Ex. 1004)
`
`Reddy discloses a laptop as being able to view VRML data with
`a standard VRML browser, not with TerraVision II. See also Ex.
`2066, pp. 4–5 (contrasting TerraVision running on fast graphics
`workstation with accessing the data via a standard browser
`with a laptop).
`
`IPR2016-00449, Paper 18 at pp. 24–28; Ex. 2003 at ¶¶51, 65, 69–70, 75–76.
`29
`
`
`
`Visualization System
`for SRI’s Digital Earth
`Proposal
`Exhibit 2066
`
`30
`
`
`
`SRI Digital Earth (Ex. 2066)
`SRI Digital Earth (Ex. 2066)
`
`Despite these pnmts, it is clear that "i.-'F._"'-rIL intrbduc as an attractive scalability feature tn eur prap-asal. If the
`rescnurees are available, then a user can use Terra‘a'isicun rtuming an a fast graphics warhstatinn tb rpuclrly and
`intuitiver navigate arcumd the Digital Earth. Altemati‘sel}: these same data can be accessed hunt a laptnp
`
`machine with a standard 1u.."l:'l.‘_l'eIL hrewser. This level ef Cflpflbllll'jr' may be of particular use ta military
`persnnnel performing missian planning and battle damage assessment, nr ta emergency teams ccerdinating a
`natural disaster relief efibrt. I-rr simimarire- the suppcurt bf VEML adds the fallewmg benefits In this pr-crpbsal:
`
`EX. 2066 at pp. 4—5.
`
`Enc burages the use bf ecmniercial riff-Lhe-shelf scftarare.
`Enables the Digital Earth tn be automatically brbwsable with numercuus third-part5: applieatiens, thus
`not tjr'ing it re a single apphcacibn.
`L'ses ETD-ii brawsers that are freely and widele available, sci a large JlLIEIllJ-EI ef users will have access
`tn the features bf the Digital Earth.
`Suppnrts multiple dehs-‘erj: platf-arms- including lawer—end platfcums such as Macs and PC s- sn that the
`Digital Earth is net reserved for peeple whcn have access tn high end graphics werl-zstaticrns.
`Intraduces scalability, in terms if perfccmance as well as available feauires, hardware supp-art. and st:
`farth.
`
`Ex. 2066 at pp. 4–5.
`31
`
`
`
`Limited Bandwidth Computer Device
`
`32
`
`
`
`Proposed Claim Construction: “Limited Bandwidth
`Computer Device”
`
`IPR2016-00448, Paper 21 (Public Corrected PO Response), p. 12; see IPR2016-00449, Paper 17 (Public PO Response), p. 13, Ex. 1001, 5:31–34.
`
`33
`
`
`
`“Limited Communication Bandwidth Computer Device”
`
`“A mobile computing device such as mobile phone, smart phone, and
`or personal digital assistant (PDA) is a characteristic small client. Embedded,
`low-cost kiosk and or automobile navigation systems are other typical
`examples.” (Ex. 1001, 2:51–55)
`
`“Cellular connected PDAs and webphones are examples of small
`clients that are frequently constrained by limited bandwidth conditions.”
`(Ex. 1001, 3:14–16)
`
`“The client software system is very small and easily downloaded to
`conventional computer systems or embedded in conventional dedicated
`function devices, including portable devices, such as PDAs and webphones.”
`(Ex. 1001, 4:6–9)
`
`“For small clients 20, the available memory for the parcel data store 46 is
`generally quite restricted.” (Ex. 1001, 8:7–8)
`
`
`IPR2016-00448, Paper 21 (Public Corrected PO Response) at pp. 12–14.
`
`34
`
`
`
`“Limited Bandwidth Computer Device”
`343 patent, claim 1
`
`IPR2016-00448, Ex. 1001, 11:24–61.
`
`35
`
`
`
`“Limited Bandwidth Computer Device”
`506 patent, claim 1
`
`IPR2016-00448, Ex. 1002, 12:29–60.
`
`36
`
`
`
`Microsoft
`Technical Report
`
`Exhibit 1030
`
`37
`
`
`
`Exhibit 1030: Microsoft Technical Report
`
`Microsoft report is hearsay
`
`It may be used by Bradium as an admission against Microsoft.
`FED. R. EVID. 801(d)(2) (opposing party’s statement, offered
`against an opposing party).
`
`
`
`IPR2016-00448, Paper 47, pp. 11–12.
`38
`
`
`
`Exhibit 1030: Microsoft Technical Report
`
`• The map tile client-server solution described in Exhibit 1030
`“had not been attempted before” and that “many people felt
`it was impossible without using an object-oriented or object-
`relational system.”
`
`• Exhibit 1030 provides specifically that its user interface is
`designed to function adequately over low-speed (28.8 kbps)
`connections.
`
`
`
`IPR2016-00448, Paper 44 at Observations 3, 4 (pp.2–3); Paper 47, p. 11 n.5.
`39
`
`
`
`Exhibit 1003
`
`Hornbacker
`
`Hornbacker
`
`Exhibit 1003
`
`40
`
`
`
`Hornbacker (Ex. 1003)
`
`•
`
`•
`
`The Hornbacker server creates tiles on demand in response
`to each user request, a computationally-intensive and
`inefficient process.
`
`View tiles are not generated in advance. Hornbacker
`creates custom tiles based on specific requests for a
`particular view (e.g., at the rotation angle and scale
`requested).
`
`• Hornbacker does not describe the client system.
`Hornbacker touts the avoidance of client-side applications
`as a benefit.
`
`•
`
`The client-side features described in Hornbacker are
`implemented via HTML.
`
`IPR2016-00448, Paper 21, pp. 19–21.
`41
`
`
`
`Objective Indicia of
`Non-Obviousness
`
`42
`
`
`
`Secondary Considerations
`
`•
`
`Long-felt but unresolved need for the invention
`
`• Praise for the invention
`
`• Commercial success of the invention
`
`IPR2016-00448, Paper 21, pp. 52-60; Ex. 2004 (Levanon Decl.); Ex. 2072 (Public version of Levanon Decl.).
`
`43
`
`
`
`Motion to Exclude
`
`Motion to Exclude
`
`44
`
`
`
`Patent Owner’s Motion to Exclude
`
`• Ex. 1017 (Lavi Declaration)
`
`• Mr. Lavi was not produced for deposition in the
`United States.
`
`• Ex. 1030 (Microsoft Technical Article)
`
`• Hearsay use of a May 2000 version of the
`publication
`
`• Microsoft must have had access to the “June
`1999” version but has not come forward with
`that version.
`
`IPR2016-00448, Paper 47 at pp. 2-7; Paper 59 at p. 5.
`45
`
`
`
`46
`
`
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