Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`24. The method of claim 22, wherein
`Lempel-Ziv is utilized by the data
`compression engine to compress the
`additional boot data.
`
`Magstar, as evidenced by the example
`citations below, discloses
`“Lempel-Ziv is utilized by the data
`compression engine to compress the
`additional boot data.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, Lempel-Ziv is utilized by the data compression
`engine to compress the additional boot data), Apple contends that one of skill in the art
`would understand the operation of booting a computer system to include the element that
`is missing similar to the manner in which the patentee relied upon such knowledge of
`skill in the art during prosecution. See Sections VI. and VII. of Apple’s Invalidity
`Contentions.
`
`Magstar discloses this limitation:
`
`See Claims 15 and 22 above.
`
`
`
`
`Magstar
`“The method of claim 22, wherein Lempel-Ziv is utilized by the data compression engine to
`compress the additional boot data”
`
`Claim 24
`Page 42 of 53
`
`2001
`
`

`

`Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`25. The method of claim 22, wherein a
`plurality of encoders are utilized by the
`data compression engine to compress the
`additional boot data..
`
`Magstar, as evidenced by the example
`citations below, discloses
`“a plurality of encoders are utilized by the
`data compression engine to compress the
`additional boot data.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, a plurality of encoders are utilized by the data
`compression engine to compress the additional boot data), Apple contends that one of
`skill in the art would understand the operation of booting a computer system to include
`the element that is missing similar to the manner in which the patentee relied upon such
`knowledge of skill in the art during prosecution. See Sections VI. and VII. of Apple’s
`Invalidity Contentions.
`
`Magstar discloses this limitation:
`
`See Claims 16 and 22 above.
`
`
`
`
`Magstar
`“The method of claim 22, wherein a plurality of encoders are utilized by the data compression engine
`to compress the additional boot data.”
`
`Claim 25
`Page 43 of 53
`
`2002
`
`

`

`Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`27.1 a boot device..
`
`Magstar, as evidenced by the example
`citations below, discloses
`“a boot device.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, a boot device), Apple contends that one of skill in
`the art would understand the operation of booting a computer system to include the
`element that is missing similar to the manner in which the patentee relied upon such
`knowledge of skill in the art during prosecution. See Sections VI. and VII. of Apple’s
`Invalidity Contentions.
`
`Magstar discloses this limitation:
`
`See Claim 1 above.
`
`
`
`Magstar
`“a boot device”
`
`
`
`Claim 27.1
`Page 44 of 53
`
`2003
`
`

`

`Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`27.2 a processor..
`
`Magstar, as evidenced by the example
`citations below, discloses
`“a processor.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, a processor), Apple contends that one of skill in the
`art would understand the operation of booting a computer system to include the element
`that is missing similar to the manner in which the patentee relied upon such knowledge
`of skill in the art during prosecution. See Sections VI. and VII. of Apple’s Invalidity
`Contentions.
`
`Magstar discloses this limitation:
`
`See Claim 1.2 above.
`
`
`
`Magstar
`“a processor”
`
`
`
`Claim 27.2
`Page 45 of 53
`
`2004
`
`

`

`Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`27.3 cache memory; and.
`
`Magstar, as evidenced by the example
`citations below, discloses
`“cache memory.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, cache memory), Apple contends that one of skill in
`the art would understand the operation of booting a computer system to include the
`element that is missing similar to the manner in which the patentee relied upon such
`knowledge of skill in the art during prosecution. See Sections VI. and VII. of Apple’s
`Invalidity Contentions.
`
`Magstar discloses this limitation:
`
`See Claims 1.3 and 1.4 above.
`
`
`
`Magstar
`“cache memory”
`
`
`
`Claim 27.3
`Page 46 of 53
`
`2005
`
`

`

`Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`27.4 non-volatile memory for storing
`logic code for use by the processor,..
`
`Magstar, as evidenced by the example
`citations below, discloses
`“non-volatile memory for storing logic
`code for use by the processor.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, non-volatile memory for storing logic code for use
`by the processor), Apple contends that one of skill in the art would understand the
`operation of booting a computer system to include the element that is missing similar to
`the manner in which the patentee relied upon such knowledge of skill in the art during
`prosecution. See Sections VI. and VII. of Apple’s Invalidity Contentions.
`
`Magstar discloses this limitation:
`
`See Claim 1.1 and 1.3 above.
`
`
`
`
`Magstar
`“non-volatile memory for storing logic code for use by the processor,”
`
`Claim 27.4
`Page 47 of 53
`
`2006
`
`

`

`Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`27.5 the logic code being used for:
`maintaining a list associated with boot
`data, wherein the boot data is used in
`booting a first system
`
`Magstar, as evidenced by the example
`citations below, discloses
`“the logic code being used for:
`maintaining a list associated with boot
`data, wherein the boot data is used in
`booting a first system.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, the logic code being used for: maintaining a list
`associated with boot data, wherein the boot data is used in booting a first system;), Apple
`contends that one of skill in the art would understand the operation of booting a computer
`system to include the element that is missing similar to the manner in which the patentee
`relied upon such knowledge of skill in the art during prosecution. See Sections VI. and
`VII. of Apple’s Invalidity Contentions.
`
`Magstar discloses this limitation:
`
`See Claim 1.1 above.
`
`
`
`
`Magstar
`“the logic code being used for: maintaining a list associated with boot data,
`wherein the boot data is used in booting a first system”
`
`Claim 27.5
`Page 48 of 53
`
`2007
`
`

`

`Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`27.6 preloading compressed boot data
`associated to the list into the cache
`memory prior to completion of
`initialization of a central processing unit
`of the first system; and
`
`Magstar, as evidenced by the example
`citations below, discloses
`“preloading compressed boot data
`associated to the list into the cache
`memory prior to completion of
`initialization of a central processing unit
`of the first system.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, preloading compressed boot data associated to the
`list into the cache memory prior to completion of initialization of a central processing
`unit of the first system), Apple contends that one of skill in the art would understand the
`operation of booting a computer system to include the element that is missing similar to
`the manner in which the patentee relied upon such knowledge of skill in the art during
`prosecution. See Sections VI. and VII. of Apple’s Invalidity Contentions.
`
`Magstar discloses this limitation:
`
`See Claim 1.3 above.
`
`
`
`
`Magstar
`“preloading compressed boot data associated to the list into the cache memory prior to
` completion of initialization of a central processing unit of the first system”
`
`Claim 27.6
`Page 49 of 53
`
`2008
`
`

`

`Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`27.7 servicing requests for the compressed
`boot data from the first system after
`completion of initialization of the central
`processing unit; and
`
`Magstar, as evidenced by the example
`citations below, discloses
`“servicing requests for the compressed
`boot data from the first system after
`completion of initialization of the central
`processing unit.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, servicing requests for the compressed boot data from
`the first system after completion of initialization of the central processing unit), Apple
`contends that one of skill in the art would understand the operation of booting a computer
`system to include the element that is missing similar to the manner in which the patentee
`relied upon such knowledge of skill in the art during prosecution. See Sections VI. and
`VII. of Apple’s Invalidity Contentions.
`
`Magstar discloses this limitation:
`
`See Claim 1.4 above.
`
`
`
`
`Magstar
`“servicing requests for the compressed boot data from the first system after completion of
` initialization of the central processing unit”
`
`
`Claim 27.7
`Page 50 of 53
`
`2009
`
`

`

`Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`27.8 a data compression engine for
`decompressing the compressed boot data
`accessed from the cache memory for use
`in responding to the servicing requests
`and for compressing additional boot data
`and storing the additional compressed
`boot data to the boot device
`
`Magstar, as evidenced by the example
`citations below, discloses
`“a data compression engine for
`decompressing the compressed boot data
`accessed from the cache memory for use
`in responding to the servicing requests
`and for compressing additional boot data
`and storing the additional compressed
`boot data to the boot device.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, a data compression engine for decompressing the
`compressed boot data accessed from the cache memory for use in responding to the
`servicing requests and for compressing additional boot data and storing the additional
`compressed boot data to the boot device), Apple contends that one of skill in the art
`would understand the operation of booting a computer system to include the element that
`is missing similar to the manner in which the patentee relied upon such knowledge of
`skill in the art during prosecution. See Sections VI. and VII. of Apple’s Invalidity
`Contentions.
`
`Magstar discloses this limitation:
`
`See Claims 4, 10, and 11 above.
`
`
`
`
`Magstar
`“a data compression engine for decompressing the compressed boot data accessed from the cache memory
`for use in responding to the servicing requests and for compressing additional boot data and storing
` the additional compressed boot data to the boot device”
`
`
`Claim 27.8
`
`Page 51 of 53
`
`2010
`
`

`

`Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`29. The system of claim 27, wherein
`Lempel-Ziv is utilized by the data
`compression engine to compress the
`additional boot data.
`
`Magstar, as evidenced by the example
`citations below, discloses
`“Lempel-Ziv is utilized by the data
`compression engine to compress the
`additional boot data.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, Lempel-Ziv is utilized by the data compression
`engine to compress the additional boot data), Apple contends that one of skill in the art
`would understand the operation of booting a computer system to include the element that
`is missing similar to the manner in which the patentee relied upon such knowledge of
`skill in the art during prosecution. See Sections VI. and VII. of Apple’s Invalidity
`Contentions.
`
`Magstar discloses this limitation:
`
`See Claims 15 and 27 above.
`
`
`Magstar
`“The system of claim 27, wherein Lempel-Ziv is utilized by the data compression engine
`to compress the additional boot data”
`
`
`Claim 29
`Page 52 of 53
`
`2011
`
`

`

`Appendix A33
`Invalidity of U.S. Patent 7,181,608 based on Magstar
`
`
`30. The system of claim 27, wherein a
`plurality of encoders are utilized by the
`data compression engine to compress the
`additional boot data.
`
`Magstar, as evidenced by the example
`citations below, discloses
`“a plurality of encoders are utilized by the
`data compression engine to compress the
`additional boot data.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, a plurality of encoders are utilized by the data
`compression engine to compress the additional boot data), Apple contends that one of
`skill in the art would understand the operation of booting a computer system to include
`the element that is missing similar to the manner in which the patentee relied upon such
`knowledge of skill in the art during prosecution. See Sections VI. and VII. of Apple’s
`Invalidity Contentions.
`
`Magstar discloses this limitation:
`
`See Claims 16 and 27 above.
`
`
`
`
`Magstar
`“The system of claim 27, wherein a plurality of encoders are utilized by the data compression engine
` to compress the additional boot data”
`
`
`Claim 30
`Page 53 of 53
`
`2012
`
`

`

`Appendix A34
`Invalidity of U.S. Patent 7,181,608 based on Mealey
`
`The publication Mealey, B, IBM, An IP.com Prior Art Database Technical Disclosure,
`January, 1992 (“Mealey”) invalidates claims 1-13, 15-16, 19-20, 22, 24-25, 27, and 29-30
`of United States Patent No. 7,181,608 (“the ’608 Patent”) pursuant to 35 U.S.C. § 102
`and/or 35 U.S.C. § 103 either alone or in combination with other prior art references, and/or
`in combination with the knowledge of a person of ordinary skill.
`
`The analysis provided in this chart may in some instances uses Realtime’s proposed (or
`implied) claim constructions, and Apple reserves all rights to challenge these proposed (or
`implied) constructions. To the extent any of the charted prior art should fail to disclose an
`element of any claims of the ’608 Patent, Apple reserves the right to rely upon the
`knowledge of one skilled in the art, or any other disclosed prior art, alone or in combination,
`whether produced by Apple or by Realtime, to show the element and thereby invalidate
`those claims. Citations given in the chart below are merely representative of the respective
`elements and are not meant to be exhaustive.
`
`
`
`
`
`
`
`
`Mealey
`
`
`
`
`
`
`Page 1 of 46
`
`2013
`
`

`

`Appendix A34
`Invalidity of U.S. Patent 7,181,608 based on Mealey
`
`
`1 (Preamble) A method for providing
`accelerated loading of an operating
`system, comprising the steps of:
`
`Mealey, as evidenced by the exemplary
`citations below, discloses “a method for
`providing accelerated loading of an
`operating system, comprising the steps
`of:”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, accelerated loading of an operating system), Apple
`contends that one of skill in the art would understand the operation of booting a computer
`system to include the element that is missing similar to the manner in which the patentee
`relied upon such knowledge of skill in the art during prosecution. See Sections VI. and
`VII. of Apple’s Invalidity Contentions.
`
`Mealey discloses this limitation:
`
`“Disclosed is an approach that reduces resources and time required for
`system initialization. This is accomplished by applying a data compression
`algorithm to the text and data of a boot-image.
`The boot-image is divided into two portions: text and data. The text is
`compressed and bound with a decompression program. It is decompressed
`immediately after being loaded.
`The data portion is a RAM disk file system. The file system is compressed
`at the block level. It is accessed by a pseudo device driver that compresses
`on writes and decompresses on reads. The file system remains compressed
`during system initialization reducing the amount of memory required to
`hold it.
`Applying compression to a boot image can produce a significant time
`savings when booting from a slow device, such as a busy LAN or floppy
`disk. It also reduces the size of the media required to hold the image.
`Finally, it can reduce the amount of memory required to hold the boot
`image until system initialization is complete.”
`
`
`Mealey, 1.
`
`
`
`
`
`
`
`
`
`
`
`
`Mealey
`“A method for providing accelerated loading of an operating system, comprising the steps
`of:”
`
`
`Claim 1 (Preamble)
`Page 2 of 46
`
`2014
`
`

`

`Appendix A34
`Invalidity of U.S. Patent 7,181,608 based on Mealey
`
`
`1.1 maintaining a list of boot data used for
`booting a computer system;
`
`
`Mealey, as evidenced by the example
`citations below, discloses “maintaining a
`list of boot data used for booting a
`computer system;”
`
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, maintaining a list of boot data used for booting a
`computer system), Apple contends that one of skill in the art would understand the
`operation of booting a computer system to include the element that is missing similar to
`the manner in which the patentee relied upon such knowledge of skill in the art during
`prosecution. See Sections VI. and VII. of Apple’s Invalidity Contentions.
`
`Mealey discloses this limitation:
`
`“Disclosed is an approach that reduces resources and time required for
`system initialization. This is accomplished by applying a data compression
`algorithm to the text and data of a boot-image.
`The boot-image is divided into two portions: text and data. The text is
`compressed and bound with a decompression program. It is decompressed
`immediately after being loaded.
`The data portion is a RAM disk file system. The file system is compressed
`at the block level. It is accessed by a pseudo device driver that compresses
`on writes and decompresses on reads. The file system remains compressed
`during system initialization reducing the amount of memory required to
`hold it.
`Applying compression to a boot image can produce a significant time
`savings when booting from a slow device, such as a busy LAN or floppy
`disk. It also reduces the size of the media required to hold the image.
`Finally, it can reduce the amount of memory required to hold the boot
`image until system initialization is complete.”
`
`
`Mealey, 1.
`
`
`
`
`
`Mealey
`“maintaining a list of boot data used for booting a computer system;”
`
`
`
`Claim 1.1
`Page 3 of 46
`
`
`
`2015
`
`

`

`Appendix A34
`Invalidity of U.S. Patent 7,181,608 based on Mealey
`
`
`1.2 initializing a central processing unit of
`the computer system;
`
`
`Mealey, as evidenced by the example
`citations below, discloses “initializing a
`central processing unit of the computer
`system;”
`
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, initializing a central processing unit of the computer
`system), Apple contends that one of skill in the art would understand the operation of
`booting a computer system to include the element that is missing similar to the manner
`in which the patentee relied upon such knowledge of skill in the art during prosecution.
`See Sections VI. and VII. of Apple’s Invalidity Contentions.
`
`Mealey discloses this limitation:
`
`“Disclosed is an approach that reduces resources and time required for
`system initialization. This is accomplished by applying a data compression
`algorithm to the text and data of a boot-image.
`The boot-image is divided into two portions: text and data. The text is
`compressed and bound with a decompression program. It is decompressed
`immediately after being loaded.
`The data portion is a RAM disk file system. The file system is compressed
`at the block level. It is accessed by a pseudo device driver that compresses
`on writes and decompresses on reads. The file system remains compressed
`during system initialization reducing the amount of memory required to
`hold it.
`Applying compression to a boot image can produce a significant time
`savings when booting from a slow device, such as a busy LAN or floppy
`disk. It also reduces the size of the media required to hold the image.
`Finally, it can reduce the amount of memory required to hold the boot
`image until system initialization is complete.”
`
`
`
`Mealey, 1.
`
`
`
`
`Mealey
`“initializing a central processing unit of the computer system;”
`
`
`
`
`
`Claim 1.2
`Page 4 of 46
`
`
`
`2016
`
`

`

`Appendix A34
`Invalidity of U.S. Patent 7,181,608 based on Mealey
`
`
`1.3 preloading the boot data into a cache
`memory prior to completion of
`initialization of the central processing unit
`of the computer system, wherein
`preloading the boot data comprises
`accessing compressed boot data from a
`boot device; and
`
`
`Mealey, as evidenced by the example
`citations below, discloses
`“preloading the boot data into a cache
`memory prior to completion of
`initialization of the central processing unit
`of the computer system, wherein
`preloading the boot data comprises
`accessing compressed boot data from a
`boot device; and”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, preloading the boot data into a cache memory prior
`to completion of initialization of the central processing unit of the computer system,
`wherein preloading the boot data comprises accessing compressed boot data from a boot
`device), Apple contends that one of skill in the art would understand the operation of
`booting a computer system to include the element that is missing similar to the manner
`in which the patentee relied upon such knowledge of skill in the art during prosecution.
`See Sections VI. and VII. of Apple’s Invalidity Contentions.
`
`Mealey discloses this limitation:
`
`“Disclosed is an approach that reduces resources and time required for
`system initialization. This is accomplished by applying a data compression
`algorithm to the text and data of a boot-image.
`The boot-image is divided into two portions: text and data. The text is
`compressed and bound with a decompression program. It is decompressed
`immediately after being loaded.
`The data portion is a RAM disk file system. The file system is compressed
`at the block level. It is accessed by a pseudo device driver that compresses
`on writes and decompresses on reads. The file system remains compressed
`during system initialization reducing the amount of memory required to
`hold it.
`Applying compression to a boot image can produce a significant time
`savings when booting from a slow device, such as a busy LAN or floppy
`disk. It also reduces the size of the media required to hold the image.
`Finally, it can reduce the amount of memory required to hold the boot
`image until system initialization is complete.”
`
`
`
`Mealey, 1.
`
`
`
`
`Claim 1.3
`
`Mealey
`“preloading the boot data into a cache memory prior to completion of initialization of the central processing unit of the computer
`system, wherein preloading the boot data comprises accessing compressed boot data from a boot device; and”
`
`
`
`Page 5 of 46
`
`2017
`
`

`

`Appendix A34
`Invalidity of U.S. Patent 7,181,608 based on Mealey
`
`
`1.4 servicing requests for boot data from
`the computer system using the preloaded
`boot data after completion of the
`initialization of the central processing unit
`of the computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective access
`rate of the cache.
`
`
`Mealey, as evidenced by the example
`citations below, discloses
`“servicing requests for boot data from the
`computer system using the preloaded boot
`data after completion of the initialization
`of the central processing unit of the
`computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective access
`rate of the cache.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, servicing requests for boot data from the computer
`system using the preloaded boot data after completion of the initialization of the central
`processing unit of the computer system, wherein servicing requests comprises accessing
`compressed boot data from the cache and decompressing the compressed boot data at a
`rate that increases the effective access rate of the cache), Apple contends that one of skill
`in the art would understand the operation of booting a computer system to include the
`element that is missing similar to the manner in which the patentee relied upon such
`knowledge of skill in the art during prosecution. See Sections VI. and VII. of Apple’s
`Invalidity Contentions.
`
`Mealey discloses this limitation:
`
`“Disclosed is an approach that reduces resources and time required for
`system initialization. This is accomplished by applying a data compression
`algorithm to the text and data of a boot-image.
`The boot-image is divided into two portions: text and data. The text is
`compressed and bound with a decompression program. It is decompressed
`immediately after being loaded.
`The data portion is a RAM disk file system. The file system is compressed
`at the block level. It is accessed by a pseudo device driver that compresses
`on writes and decompresses on reads. The file system remains compressed
`during system initialization reducing the amount of memory required to
`hold it.
`Applying compression to a boot image can produce a significant time
`savings when booting from a slow device, such as a busy LAN or floppy
`disk. It also reduces the size of the media required to hold the image.
`Finally, it can reduce the amount of memory required to hold the boot
`image until system initialization is complete.”
`
`
`Mealey, 1.
`
`
`
`
`
`Mealey
`“The method of claim 1, wherein the boot data comprises program code associated with one
`of an operating system of the computer system, an application program, and a combination
`thereof.”
`
`
`Claim 2
`
`
`
`Page 6 of 46
`
`2018
`
`

`

`Appendix A34
`Invalidity of U.S. Patent 7,181,608 based on Mealey
`
`
`2. The method of claim 1, wherein the
`Mealey, as evidenced by the example
`citations below, discloses
`boot data comprises program code
`“wherein the boot data comprises program
`associated with one of an operating
`code associated with one of an operating
`system of the computer system, an
`system of the computer system, an
`application program, and a combination
`application program, and a combination
`thereof.
`thereof.”
`
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, boot data that comprises program code associated
`with one of an operating system of the computer system, an application program, and a
`combination thereof), Apple contends that one of skill in the art would understand the
`operation of booting a computer system to include the element that is missing similar to
`the manner in which the patentee relied upon such knowledge of skill in the art during
`prosecution. See Sections VI. and VII. of Apple’s Invalidity Contentions.
`
`Mealey discloses this limitation:
`
`See Claims 1.1, 1.3, and 1.4 above.
`
`See also
`
`“Disclosed is an approach that reduces resources and time required for
`system initialization. This is accomplished by applying a data compression
`algorithm to the text and data of a boot-image.
`The boot-image is divided into two portions: text and data. The text is
`compressed and bound with a decompression program. It is decompressed
`immediately after being loaded.
`The data portion is a RAM disk file system. The file system is compressed
`at the block level. It is accessed by a pseudo device driver that compresses
`on writes and decompresses on reads. The file system remains compressed
`during system initialization reducing the amount of memory required to
`hold it.
`Applying compression to a boot image can produce a significant time
`savings when booting from a slow device, such as a busy LAN or floppy
`disk. It also reduces the size of the media required to hold the image.
`Finally, it can reduce the amount of memory required to hold the boot
`image until system initialization is complete.”
`
`
`Mealey, 1.
`
`
`
`
`
`Mealey
`“The method of claim 1, wherein the boot data comprises program code associated with one
`of an operating system of the computer system, an application program, and a combination
`thereof.”
`
`
`Claim 2
`
`
`
`Page 7 of 46
`
`2019
`
`

`

`Appendix A34
`Invalidity of U.S. Patent 7,181,608 based on Mealey
`
`
`3. The method of claim 1, wherein the
`preloading is performed by a data storage
`controller connected to the boot device.
`
`
`Mealey, as evidenced by the example
`citations below, discloses
`“wherein the preloading is performed by a
`data storage controller connected to the
`boot device.”
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, wherein the preloading is performed by a data storage
`controller connected to the boot device), Apple contends that one of skill in the art would
`understand the operation of booting a computer system to include the element that is
`missing similar to the manner in which the patentee relied upon such knowledge of skill
`in the art during prosecution. See Sections VI. and VII. of Apple’s Invalidity
`Contentions.
`
`Mealey discloses this limitation:
`
`See Claims 1.3, and 1.4 above.
`
`See also
`
`“Disclosed is an approach that reduces resources and time required for
`system initialization. This is accomplished by applying a data compression
`algorithm to the text and data of a boot-image.
`The boot-image is divided into two portions: text and data. The text is
`compressed and bound with a decompression program. It is decompressed
`immediately after being loaded.
`The data portion is a RAM disk file system. The file system is compressed
`at the block level. It is accessed by a pseudo device driver that compresses
`on writes and decompresses on reads. The file system remains compressed
`during system initialization reducing the amount of memory required to
`hold it.
`Applying compression to a boot image can produce a significant time
`savings when booting from a slow device, such as a busy LAN or floppy
`disk. It also reduces the size of the media required to hold the image.
`Finally, it can reduce the amount of memory required to hold the boot
`image until system initialization is complete.”
`
`
`Mealey, 1.
`
`
`
`
`
`Mealey
`“The method of claim 1, wherein the preloading is performed by a data storage controller
`connected to the boot device.”
`
`
`Claim 3
`
`Page 8 of 46
`
`2020
`
`

`

`Appendix A34
`Invalidity of U.S. Patent 7,181,608 based on Mealey
`
`
`4. The method of claim 1, further
`Mealey, as evidenced by the example
`citations below, discloses
`comprising updating the list of boot data.
`“updating the list of boot data.”
`
`To the extent that Realtime contends this reference does not explicitly disclose this
`element of this claim (for example, updating the list of boot data), Apple contends that
`one of skill in the art would understand the operation of booting a computer system to
`include the element that is missing similar to the manner in which the patentee relied
`upon such knowledge of skill in the art during prosecution. See Sections VI. and VII. of
`Apple’s Invalidity Contentions.
`
`Mealey discloses this limitation:
`
`See Claim 1.1 above.
`
`See also
`
`“Disclosed is an approach that reduces resources and time required for
`system initialization. This is accomplished by applying a data compression
`algorithm to the text and data of a boot-image.
`The boot-image is divided into two portions: text and data. The text is
`compressed and bound with a decompression program. It is decompressed
`immediately after being loaded.
`The data portion is a RAM disk file system. The file system is compressed
`at the block level. It is accessed by a pseudo device driver that compresses
`on writes and decompresses on reads. The file system remains com