IPR 2016-01083
`U.S. Patent No. 7,827,483
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________
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`Microsoft Corporation,
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`Petitioner,
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`v.
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`Corel Software, LLC
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`Patent Owner
`
`_____________________
`
`Case IPR2016-01083
`Patent 7,827,483
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`_____________________
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`
`
`
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`DECLARATION OF DR. BENJAMIN B. BEDERSON
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`Corel Exhibit 2001
`Microsoft v. Corel
`IPR2016-01083
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`
`U.S. Patent No. 7,827,483
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`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`Microsoft Corporation,
`
`Petitioner,
`
`v.
`
`Corel Software, LLC
`
`Patent Owner
`
`_____________________
`
`Case IPR2016-01083
`Patent 7,827,483
`
`_____________________
`
`
`
`
`
`DECLARATION OF DR. BENJAMIN B. BEDERSON
`
`Corel Exhibit 2001
`Microsoft v. Corel
`IPR2016-01083
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`TABLE OF CONTENTS
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`IPR 2016-01083
`U.S. Patent No. 7,827,483
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`I.
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`II.
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`INTRODUCTION
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`QUALIFICATIONS
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`III. BASIS FOR OPINIONS
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`IV. RELEVANT LEGAL PRINCIPLES
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`V.
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`THE TECHNOLOGY OF THE ’483 PATENT
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`A. General Background
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`1.
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`2.
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`3.
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`Graphical User Interfaces (GUIs)
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`Designing Graphical User Interfaces
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`Direct Manipulation
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`4. Menu Selection
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`5.
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`6.
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`Formatting and Exploration
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`Previewing in the Prior Art
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`B.
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`The ’483 Patent
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`VI. SUMMARY OF PETITIONER’S PRIOR ART REFERENCES
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`A. QuarkXPress Reference Manual (“QuarkXPress”) – MS1005
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`B. Mastering WordPerfect 8 2nd Edition (“WordPerfect”) –
`MS1004
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`C.
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`IBM Technical Disclosure Bulletin Vol. 34 No. 7A (“IBM”) –
`MS1007
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`VII. SUMMARY OF OPINIONS REGARDING DISPUTED CLAIM
`TERMS
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`Claim Term: “Without Confirmation Being Received from the
`User”
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`34
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`iii
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`A.
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`IPR 2016-01083
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`I, Dr. Benjamin B. Bederson, hereby declare as follows:
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`I.
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`INTRODUCTION
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`1.
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`I have been retained by Corel Software, LLC (“Corel”) as an expert
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`with regard to responding to Microsoft’s Petition for Inter Partes Review in
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`IPR2016-1083. In that capacity, I have been asked to provide my opinions
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`regarding the meaning of terms and the disclosure of the intrinsic record in the
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`view of a person of ordinary skill in the art in relation to U.S. Patent Nos.
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`7,827,483 (the ’483 patent). I have also been asked to provide my opinions
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`regarding the disclosure of certain references asserted as prior art by Microsoft in
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`its Petition.
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`2.
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`I make this declaration in support of Patent Owner Corel’s
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`Preliminary Response to Petitioner’s Petition for Inter Partes Review of United
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`States Patent No. 7,827,483. Unless otherwise noted, the statements made herein
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`are based on my personal knowledge, and if called to testify, I could and would
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`testify competently and truthfully with regard to these matters.
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`3.
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`I have prepared this declaration in my capacity as an independent
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`consultant. This declaration was prepared at the behest of Robins Kaplan LLP on
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`behalf of its client and Patent Owner, Corel. The purpose of this declaration is to
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`describe, from the perspective of a person of ordinary skill in the art, the disclosure
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`of the intrinsic record of the ’483 patent, the meaning of terms used within the
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`patent, and the teachings and state of the prior art. I understand this declaration is
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`to be used in the matter of Microsoft Corporation v. Corel Software, LLC, Case
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`IPR2016-1083. I have been asked to review the ’483 patent and related materials
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`and, based upon that review, to provide my expert opinions.
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`4.
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`I am being compensated at my usual consulting rate of $600 per hour
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`for my work related to this dispute. My compensation is in no way dependent on
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`the outcome of this dispute or the testimony or opinions that I give.
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`5. My curriculum vitae and testimony list are attached to this
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`declaration.
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`6. My opinions and conclusions are fully discussed in later sections of
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`this declaration.
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`7.
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`In reaching these opinions and conclusions, I have relied upon my
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`education, my experience and training, my review of the patent and the patent
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`prosecution history, the asserted prior art, other documents cited herein, and my
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`review of the intrinsic and extrinsic evidence.
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`8.
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`I reserve any right that I may have to supplement this declaration if
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`further information becomes available or if I am asked to consider additional
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`information. Furthermore, I reserve any right that I may have to consider and
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`comment on any additional expert statements and testimony of Microsoft’s experts
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`in this matter.
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`II. QUALIFICATIONS
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`IPR 2016-01083
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`9. My technical background covers most aspects of Human-Computer
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`Interaction (“HCI”). Through the duration of my educational and professional
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`career, I have worked extensively in the design and analysis of user interfaces. My
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`curriculum vitae reflects my experience in these areas.
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`10.
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`I have since 1998 been a Professor of Computer Science at the
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`University of Maryland (“UMD”), where I have joint appointments at the Institute
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`for Advanced Computer Studies and the College of Information Studies
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`(Maryland’s “iSchool”). I am also Associate Provost of Learning Initiatives and
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`Executive Director of the Teaching and Learning Transformation Center. I am a
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`member and previous director of the Human-Computer Interaction Lab (“HCIL”),
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`the oldest and one of the best-known Human-Computer Interaction research groups
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`in the country.
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`11.
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`I was from 2006-2014 also co-founder and Chief Scientist of Zumobi,
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`Inc., a Seattle-based startup that is a publisher of content applications and
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`advertising platforms for smartphones. I am also co-founder and co-director of the
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`International Children’s Digital Library (“ICDL”), a web site providing the world’s
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`largest collection of freely available online children’s books from around the world
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`with an interface aimed to make it easy for children and adults to search and read
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`children’s books online. I am also co-founder and Chief Technology Officer of
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`Hazel Analytics, a data analytics company in the area of restaurant food safety
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`inspections.
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`12. Prior to becoming a Professor at UMD, from 1995 to 1997 I was an
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`Assistant Professor in the Computer Science Department at University of New
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`Mexico. From 1992 to 1994 I was a Research Scientist at Bell Communication
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`Research. From 1993 to 1994 I was also a Visiting Research Scientist at New York
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`University (“NYU”). From 1990 to 1992 I was a Research Scientist at Vision
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`Applications, Inc. From 1988 to 1990 I was a Teaching Assistant at NYU.
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`13.
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`In addition, I have since 1993 consulted for numerous companies in
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`the area of user interfaces, including Microsoft, the Palo Alto Research Center,
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`Sony, Lockheed Martin, and NASA Goddard Space Flight Center.
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`14. For more than 25 years, I have studied, designed, and worked in the
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`field of computer science and HCI. My experience includes 25 years of teaching
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`and research, with research interests in HCI and the software and technology
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`underlying today’s computing world. This includes the design and implementation
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`of graphical user interfaces, including authoring environments and layout of
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`graphical objects.
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`15. At UMD, my research is in the area of HCI, which relates to the
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`development and understanding of computing systems to serve users’ needs.
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`Researchers in this field are focused on making universally usable, useful,
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`efficient, and appealing systems to support people in their wide range of activities.
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`My approach is to balance the development of innovative technology with people’s
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`practical needs.
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`16.
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`I hold a B.S., M.S., and Ph.D. in computer science. I also earned an
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`undergraduate minor in electrical engineering. I received the Janet Fabri Memorial
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`Award for Outstanding Doctoral Dissertation for my Ph.D. work in robotics and
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`computer vision.
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`17. My work has been published extensively in more than 140 technical
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`publications, and I have given approximately 100 invited talks, including 7 keynote
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`lectures. I have won a number of awards including the Brian Shackel Award for
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`“outstanding contribution with international impact in the field of HCI” in 2007,
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`and the Social Impact Award in 2010 from Association for Computing
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`Machinery’s (“ACM”) Special Interest Group on Computer Human Interaction
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`(“SIGCHI”). ACM is the primary international professional community of
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`computer scientists, and SIGCHI is the primary international professional HCI
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`community. I have been honored by both professional organizations. I am an
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`“ACM Distinguished Scientist,” which “recognizes those ACM members with at
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`least 15 years of professional experience and 5 years of continuous Professional
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`Membership who have achieved significant accomplishments or have made a
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`significant impact on the computing field.” I am a member of the “CHI Academy,”
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`which is described as follows: “The CHI Academy is an honorary group of
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`individuals who have made substantial contributions to the field of human-
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`computer interaction. These are the principal leaders of the field, whose efforts
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`have shaped the disciplines and/or industry, and led the research and/or innovation
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`in human-computer interaction.” The criteria for election to the CHI Academy are:
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`(1) cumulative contributions to the field; (2) impact on the field through
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`development of new research directions and/or innovations; and (3) influence on
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`the work of others.
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`18.
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`I have designed, programmed and publicly deployed dozens of user-
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`facing software products that have cumulatively had millions of users. My work is
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`cited in significant patents that are central to several major companies’ user
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`interfaces, including Sony and Apple.
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`19.
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`I am the co-inventor of 9 U.S. patents. The patents are generally
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`directed to user interfaces/experience, with one being assigned to Microsoft
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`Corporation (U.S. Patent No. 8,261,211).
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`III. BASIS FOR OPINIONS
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`20.
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`In the course of conducting my analysis I reviewed the ’483 patent
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`and its file history as well as the asserted prior art and other related materials. My
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`opinions express my understanding of the meaning of these materials and the terms
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`used in them. I have also relied on my 30 years of personal experience in the
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`Human-Computer Interaction field.
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`21.
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`It is my understanding that Microsoft contends in its IPR petition that
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`one of ordinary skill in the art concerning the technology described and claimed in
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`the ’483 patent would have the following qualifications: a combination of
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`experience and education in computer science and software design. This typically
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`would consist of a minimum of a bachelor degree in computer science, software
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`engineering, computer engineering, or a related engineering field plus 2-5 years of
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`work, graduate study, and/or research experience in the field of computer science
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`and its subfield of graphic user interface design.
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`22. Applying Microsoft’s definition, I am a person of ordinary skill in the
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`art, and was at the time the original Real Time Preview patent application was filed
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`in 1998. Both then and now my qualifications would exceed the requirements of
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`Microsoft’s definition.
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`23.
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`I reserve any right that I may have to supplement the list of materials
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`relied upon in forming the opinions expressed in this declaration, or that I may use
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`to summarize or support the opinions expressed in this declaration, as necessary in
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`light of any new information or positions that Microsoft is permitted to introduce
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`after the submission of this declaration.
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`24.
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`I further reserve any right that I may have to prepare demonstrative
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`exhibits for use in conjunction with any testimony I may give at any claim
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`construction hearing or tutorial.
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`IV. RELEVANT LEGAL PRINCIPLES
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`25. For the purposes of this Declaration, I have been informed about
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`certain aspects of the law that are relevant to my analysis and opinions. I have
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`applied these legal principles in rendering my opinions below.
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`26.
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`I understand that the ordinary and customary meaning of a claim term
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`is the meaning that the term would have to a person of ordinary skill in the art in
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`question at the time of the effective filing date of the patent application that
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`matured into the patent-at-issue. For the ’483 patent, I understand this is as early
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`as September 12, 1997, and that the initial application leading to the ’483 patent
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`was filed August 28, 1998. I do not believe that the difference between these two
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`dates would change the meaning of terms as used in the art during that period.
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`27.
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`I also understand that in the absence of an express intent on the part of
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`the inventor to give a special meaning to the claim terms, the words are presumed
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`to take on the ordinary and customary meanings attributed to them by a person of
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`ordinary skill in the art.
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`28.
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`I understand that it is the use of the words in the context of the written
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`description, and as customarily used by those skilled in the relevant art, that
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`accurately reflects both the ordinary and the customary meaning of the terms in the
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`claims.
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`29.
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`I understand that the basis for a term’s ordinary and customary
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`meaning may be derived from a variety of sources, including the words of the
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`claims themselves, the remainder of the specification, the prosecution history, and
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`extrinsic evidence concerning relevant scientific principles, the meaning of
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`technical terms, and the state of the art at the time of the invention.
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`30.
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`I have been instructed that dictionary definitions or definitions from
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`technical references can be used to inform or confirm the ordinary and customary
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`meaning of words found in a claim, but that in construing claim terms, the general
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`meanings gleaned from reference sources, such as dictionaries, must always be
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`compared against the use of the terms in the context of the claim itself, and the
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`intrinsic record must always be consulted to identify which of the different
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`possible dictionary meanings is most consistent with the use of the words by the
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`inventor.
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`31.
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`I understand that a patent applicant is entitled to be his or her own
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`lexicographer—providing his or her own meaning to a word or phrase—and may
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`rebut the presumption that claim terms are to be given their plain and ordinary
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`meaning. To do so, the applicant must clearly set forth a definition of the term that
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`is different from its ordinary and customary meaning.
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`32. Where the applicant provides an explicit definition for a term, that
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`definition will control interpretation of the term as it is used in the claim in which
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`it appears. I understand that the specification can also be relied on for more than
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`just explicit lexicography to determine the meaning of a claim term. For example, I
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`understand that the meaning of a particular claim term may also be determined by
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`implication, that is, according to the usage of the term in the context of the
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`specification.
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`33.
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`I understand that for the purposes of considering Microsoft’s Petition
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`for Inter Partes Review, the claims should be given their broadest reasonable
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`construction in light of the specification of the patent. I understand that under the
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`broadest reasonable interpretation standard, claim terms are given their ordinary
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`and customary meaning in view of the specification, as would be understood by
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`one of ordinary skill in the art at the time of the invention.
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`V. THE TECHNOLOGY OF THE ’483 PATENT
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`A. General Background
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`34. The patented invention at issue relates to the field of Graphical User
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`Interfaces (GUIs), and specifically GUIs for productivity applications like
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`document editors.
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`1. Graphical User Interfaces (GUIs)
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`35. When Graphical User Interfaces (GUIs) were developed in the 1970s
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`at the Palo Alto Research Center, perhaps the most significant advance was the
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`concept of What You See Is What You Get (WYSIWYG). Before this time, users
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`primarily interacted with indirect representations of their formatted data and
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`documents. Only when the document was processed and printed would it be
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`possible to see what the document really looked like.
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`36. WYSIWYG, on the other hand, enabled users to see exactly what the
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`document would look like on the screen in its final form—including fonts, colors,
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`layout and pictures. Users could modify their document by interacting directly with
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`it and change formatting through commands that were controlled by various user
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`interface elements around the periphery of the document.
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`2.
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`Designing Graphical User Interfaces
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`37. Designing a good user interface is a difficult and complex process.
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`38. Designing a good user interface is difficult and complex because it
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`requires (i) clearly identifying the user needs, where users generally are not able to
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`clearly articulate those needs, (ii) designing a solution that addresses those needs
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`without harming the rest of the user experience, and then (iii) implementing the
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`solution in a fashion that is reliable and efficient on common user platforms, all
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`while encouraging creativity and exploration.
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`39.
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`Identifying user needs is the first challenge to designing a user
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`interface. The identification of user needs typically begins with designers.
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`Designers, however, are experts and do not always understand the needs of users.
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`Asking users, in turn, typically results in variations of existing solutions, since that
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`is what the users know. Even if a talented expert talks to an articulate user, the user
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`is often not aware of the full range of complexity of their environment or their
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`needs.
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`40. To get past these challenges, designers often use a process called
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`“contextual design.”
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`41. Contextual design involves experts observing users in their natural
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`work environment to see what the actual demands on the users are, including
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`identifying problems the user is facing, and then using that information to guide
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`the development of new design requirements aimed at solving the identified
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`problems. See Ex. 2016 at 5-12.
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`42. Designing a good user interface, however, also involves designing a
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`solution that addresses the identified need without harming the rest of the user
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`experience. This results in a common challenge, which is to design user interfaces
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`that are consistent.
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`43. Similarly, a good user interface must allow beginners to learn through
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`exploration. If a user fears losing part of their document, that will discourage them
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`from exploring the various options available to them.
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`44. When attempting to develop a new user interface, designers are often
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`faced with a situation in which, for many existing tasks, a standard way of doing
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`things that meet a user’s expectation already exists. This is referred to as
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`“consistency,” where the notion of consistency is the first of Shneiderman’s Eight
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`Golden Rules of Interface Design. Ex. 2009 at 7-8.
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`45. For example, if users are accustomed to performing an action in a
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`certain way, i.e., previewing formatting commands, then offering a different way
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`of doing the same operation could disrupt a user’s work flow as they would have to
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`learn a new approach, and then switch approaches depending on which tool they
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`are using. As such, creating new or alternative designs for performing an existing
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`task is in conflict with the first of Shneiderman’s Eight Golden Rules—
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`consistency.
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`46. The need for consistency leads to design tension between the need to
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`support individual users (e.g., customization) while maintaining consistency across
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`all installations of the product (e.g., ability for different users to work within the
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`same interface).
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`47. Another issue is that designers do not want users to inadvertently
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`trigger commands from the user interface. This would risk a perception from the
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`user that the interface was no longer under their control. If such a perception arose,
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`it would be in tension with Shneiderman’s Seventh Golden Rule—supporting
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`internal locus of control. Ex. 2009 at 7-8.
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`48.
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`In the end, perhaps the biggest factor impacting design relates to
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`human cognitive abilities. The challenge is to support simple access to common
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`operations that a user expects, while also providing the richness of a full featured
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`application that a user also expects.
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`49.
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`In addition, a designer must consider the constraints of the
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`environment within which a user must operate. For example, a key challenge in the
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`design of every graphical user interface is that there is limited screen space. Space
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`constraints are further limited in document editing programs, where the bulk of that
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`space must be made available for the document content itself. Thus, interfaces
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`must be very carefully designed to offer the needed controls in as small a space as
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`possible.
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`50. This issue is amplified by “Hick’s Law”, which says that “The time it
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`takes to make a decision increases as the number of alternatives increases.” Ex.
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`2017 at 9. Hick’s Law applies, for example, to menus that allow users to select a
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`font from a long list of fonts.
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`51. Designing around these constraints is not trivial, which has led to the
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`development of a large number of design principles that should be followed to
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`insure that a user interface offers a good experience for a wide range of users. One
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`hundred such design issues are captured in the book “Universal Principles of
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`Design”, including:
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`a. “Affordance” – a user must be able to intuit how something will
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`work simply by looking at it; Id. at 3-4;
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`b. “Errors” – Errors are bound to happen, but designing interfaces
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`that help users understand what wrong and how to recover from
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`them is notoriously difficult; Id. at 5-6;
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`c. “Forgiveness” – Users will always make mistakes, so rather
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`than penalize them, systems should be designed to
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`accommodate the users by making it easy to recover from
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`mistakes, and minimize the impact of them when they occur;
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`Id. at 7-8;
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`d. “Recognition over Recall” – Humans are much better at
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`recognizing things they have seen before than recalling them
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`from memory. Thus, user interfaces are often designed to take
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`advantage of this. Yet, this is in tension with the limited
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`availability of screen size since there rarely is sufficient room to
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`display everything a designer would like to. Id. at 10-11.
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`52. As such, designing a successful user interface, which encourages both
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`creativity and exploration, is accomplished by carefully considering how and in
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`what form a user interacts with the software.
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`53. For document productivity software, two of the more common—and
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`distinct—styles of user interaction interfaces are direct manipulation and menu
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`selection.
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`3.
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`Direct Manipulation
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`54.
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` First developed in the 1970s, “direct manipulation” interfaces
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`displayed content (such as text and graphic objects such as images) on the screen
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`with a two dimensional pointing device controller (such as a mouse) that let users
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`directly interact with the content. One example would be to visually drag an object
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`across the screen (such as some selected text or an image into a trash can).
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`55. The direct manipulation approach had three key interaction
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`characteristics – they were:
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`Rapid – users could quickly (with cycle times typically < 100
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`ms) move an object on the screen
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`IPR 2016-01083
`U.S. Patent No. 7,827,483
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`Incremental – small changes in the input (such as moving the
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`mouse a short distance) would result in small changes on the
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`screen (such as moving an object on the screen a short distance)
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`Reversible – undesirable actions such as dragging an object to
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`an unwanted position could easily be reversed by simply
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`moving the object back to where it was initially.
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`56. These three characteristics were key in “encouraging exploration” Ex.
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`2009 at 5, a key trait of interfaces that enable creativity. By supporting users to
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`rapidly and efficiently make changes to an interface, they could try many
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`variations of a design with low cognitive overhead in manipulating the interface.
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`Instead, mouse controller becomes an extension of the body, and users could focus
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`on the content.
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`4. Menu Selection
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`57. Direct manipulation is in contrast to menu selection interfaces which,
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`by their nature, were indirect. Instead of using the mouse to point the cursor at the
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`document content, the mouse was pointed at a command element such as a button.
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`Clicking on that element would result in a command being applied to the document
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`content. Menu selection interfaces have various advantages, including providing
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`clear options which can decrease learning time and ease decision making.
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`However, as Shneiderman says (p. 72), a menu selection interface “may slow
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`frequent users.” Ex. 2009 at 5.
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`58. The indirect nature of menu selection interfaces, which generally
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`associates a single command with each button, results in a lot of mouse movement
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`and clicking that is rarely fast for users – making them a historically poor choice to
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`support rapid exploration, at least as of the late 1990s.
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`59. Given these different approaches towards interaction design, common
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`ways that each approach was used, and summaries from luminaries such as
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`Shneiderman explaining that the trade-offs between them, a designer typically
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`thought of each kind of interface being particularly appropriate for certain kinds of
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`tasks.
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`60. Direct manipulation was often used for rapid exploration and editing
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`specific document content elements such as words and images, e.g. changing their
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`content, size, and position.
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`61. Menu selection interfaces were often used for more structural and
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`slower configuration and systemic operations, such as changes to an entire
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`document, such as setting the font, color or paragraph spacing.
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`62. Menu selections could also be provided in a dialog box. However,
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`previewing from a dialog box, instead of a menu or toolbar option of the document
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`display window, is more likely to obscure the view of the user’s document.
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`63. While these interface approaches were not exclusively applied to each
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`type of operation, they were used quite consistently across the industry in these
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`typical manners. For example, it does not make sense to enter text with a menu
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`interface. Likewise it does not make sense to change the font of text with a direct
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`manipulation interface.
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`5.
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`Formatting and Exploration
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`64. To aid exploration of formatting changes, GUIs in the 1980s and
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`1990s often included the concept of “undo.” Undo allowed a user to try out a
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`formatting change, and if they didn’t like it, they could select the undo command
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`which would revert the document to the state it was in before the formatting
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`change was executed.
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`65. For example, as explained in the ’483 patent, if the user wished to try
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`a different formatting option, he repeated the same process and compared the new
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`option with the previous one. See MS1001 at 1:32-34.
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`66. At this point, the user could either accept the new formats or execute
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`an “undo” command to change the document back to its original state. MS1001 at
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`5:59-64.
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`67. As such, the user would only find out how the document is changed
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`by executing the command and reversing the change via “undo.” MS1001 at 1:46-
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`54, 1:65-67.
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`68. Throughout this period in the mid 1990’s, I was personally focused on
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`the development of advanced GUIs, first at Bell Communications Research and
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`then at the University of New Mexico as an Assistant Professor. My work included
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`developing a version of GUIs that involved rich animation of graphical objects,
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`navigation by zooming in and out, and editing and layout of graphical content
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`including text. I was aiming to build as rich, detailed and flexible a graphical
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`document authoring system as possible and I was aware of the importance of
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`making it easy for users to explore variations of their documents which is why I
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`implemented an undo feature.
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`69.
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`I was aware of mouse-based hover interaction, and used it to
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`implement dynamic highlighting of links in web pages in a web browser that I
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`implemented. However, despite my desire to support easy exploration of graphical
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`documents, it did not occur to me make it easier to do so by exploratory previews.
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`70.
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`Just as I was exploring variations of WYSIWYG GUIs, many other
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`researchers and companies were as well, but the core concept of directly
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`manipulating the document with an undo command to facilitate exploration
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`remained for 20 years. It was only with the invention disclosed in the ’483 patent
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`that a new approach of supporting easy exploration of document modifications
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`came to light with “real time previews.”
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`71. One of the essential insights of the claimed invention was that rather
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`than confirming a command (typically by clicking a button) and then optionally
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`“undo”ing it if the user didn’t like it, the user could temporarily explore the effect
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`of a command by simply hovering over the command in a menu. If the user liked
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`the effect, the user could confirm the command (again, typically by clicking on the
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`command) to make the change permanent. Otherwise, the user could simply move
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`the mouse away from the command and the document would revert to how it was
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`as if nothing had ever happened.
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`72. The difference between the new approach of testing the waters by
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`hovering over a command to explore a command’s effects—in comparison to the
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`traditional heavy approach of clicking and then undoing—makes a world of
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`difference to the user experience. The invention increases speed and efficiency,
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`which in turn encourage exploration and creativity.
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`6.
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`Previewing in the Prior Art
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`73. The specification of the ’483 patent describes two alternative prior art
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`techniques that were available in the 1990s and involved using small preview
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`fields in modal dialog boxes. MS1001 at 1:37-67.
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`74.
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`In the first technique, a user could apply formatting to a pre-existing
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`exemplary text string, such as “The quick brown fox jumps over the lazy dog,”
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`shown within the small preview field in the dialog box. Id. at 1:46-49. Although
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`the dialog box previewed the font that was considered, it did not show the impact
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`of the font on the particular text of the user’s document. Id. at 1:49-54. Nor did it
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`provide an indication of how the change might impact an entire document. Id.
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`75.
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`In the second technique, a small dialog window was again used, but
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`the sample text being modified came from the user’s actual text. Id. at 1:55-60.
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`76. Neither of these prior art interfaces provided “efficient[] and
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`effective[] previewing the impact of User commands on the entire document by
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`executing User commands as they are identified.” Id. at Abstract; see also id. at
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`3:22-24.
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`77. Prior to the invention, there simply was no user interface that allowed
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`users to preview font commands in a user’s document in real time.
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`78. These shortcomings are not insignificant. For example, different fonts
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`have character sizes and spacing that vary greatly amongst them. Thus, changing to
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`a font with a small character size and tight spacing, as compared to a font with
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`large character size and wide spacing, will result in very different changes to the
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`document.
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`79. Similarly, if the impacted text is in a text box, one font may result in
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`the text greatly exceeding the pre-existing bounds of the text box, whereas another
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`may not fill very much of the text box at all. If the impacted text is one page worth
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