IPR2017-00914, No. 27 Other Not for motions - Patent Owners Demonstrative Exhibits (P.T.A.B. May. 22, 2018)

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`Paper No. 27
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––––––––––
`
`GOOGLE LLC,
`Petitioner,
`
`v.
`
`BLACKBERRY LTD.,
`Patent Owner.
`
`––––––––––––––––––
`
`Case No. IPR2017-00914
`U.S. Patent No. 8,713,466 B2
`
`––––––––––––––––––
`
`PATENT OWNER’S DEMONSTRATIVE EXHIBITS
`
`

`Patent Owner BlackBerry Ltd.
`Google LLC v. BlackBerry Ltd.
`IPR2017-00913 (U.S. Patent No. 8,402,384)
`IPR2017-00914 (U.S. Patent No. 8,713,466)
`
`May 30, 2018
`
`1
`
`

`Petitioner’s Asserted Grounds
`
`IPR2017-00913 (‘384 patent):
`Claims (* independent)
`1*, 4-7, and 10-13
`2 and 3
`
`8
`
`9
`
`Reference(s) (§ 103)
`Cadiz (Ex. 1005)
`Cadiz (Ex. 1005)
`Ng (Ex. 1006)
`Cadiz (Ex. 1005)
`Matthews (Ex. 1008)
`Cadiz (Ex. 1005)
`Smith (Ex. 1009)
`
`IPR2017-00914 (‘466 patent):
`Reference(s) (§ 103)
`Claims (* independent)
`1*, 4, 6, 12-14*, 17, 22*, and 24 Cadiz (Ex. 1006)
`2, 3, 15, and 23
`Cadiz (Ex. 1006)
`Hawkins (Ex. 1007)
`Cadiz (Ex. 1006)
`Siedlikowski (Ex. 1008)
`Cadiz (Ex. 1006)
`Yamadera (Ex. 1009)
`
`5, 10, 11, 16, 20, 21, and 26
`
`7-9, 18, 19, and 25
`
`2
`
`

`The Parties’ Primary Disputes For Ground 1
`
`Ground 1 (§ 103 – Cadiz):
`
`• (All Claims) The claimed “software application” is not disclosed or rendered
`obvious by Cadiz’s person-centric interface.
`
`• (All Claims) The claimed “expanded dynamic bar” having “a selectable link” that
`“invokes the software application” is not disclosed or rendered obvious by
`Cadiz’s email-centric interface.
`
`• (‘384 patent, Claim 4) The claimed “method of claim 1, wherein the apparatus
`comprises a cellular telephone” is not disclosed or rendered obvious by Cadiz.
`
`• (All Claims) Properly construed, the claimed “a selectable link embedded in the
`additional dynamic preview information” (‘384 patent) and “additional dynamic
`preview information comprising a selectable link” (‘466 patent) are not disclosed
`or rendered obvious by Cadiz’s person-centric interface.
`
`3
`
`

`Representative Claims: ‘384 patent, claim 1
`
`‘384 Patent
`-00913, Ex. 1001
`
`1. A method for controlling an apparatus comprising a display,
`the method comprising:
`displaying a dynamic bar on the display;
`displaying dynamic preview information in the dynamic bar,
`the dynamic preview information being determined from
`information managed by a software application, the
`dynamic preview information being updated to reflect a
`change to the information managed by the software
`application;
`expanding the dynamic bar to display an expanded dynamic
`bar in response to a first input from an input device,
`displaying the expanded dynamic bar comprising:
`d
`displaying additional dynamic preview information
`determined from the information managed by the
`software application, the additional dynamic preview
`information being different from the dynamic preview
`information displayed in the dynamic bar, and
`the additional dynamic preview information being updated
`to reflect the same or different change to the
`information managed by the software application;
`displaying a selectable link embedded in the additional
`dynamic preview information to invoke the software
`application; and
`activating the software application in response to a
`second input invoking the link.
`
`4
`
`

`Representative Claims: ‘466 patent, claim 1
`
`’466 Patent
`-00914, Ex. 1001
`
`1. A method for displaying preview information, the method
`comprising:
`displaying on a display dynamic preview information in a
`dynamic bar, the dynamic preview information being
`determined from information managed by a software
`application, the dynamic preview information being
`updated to reflect a change to the information managed
`by the software application; and
`expanding the dynamic bar to display an expanded dynamic
`bar in response to a first input, displaying the expanded
`d
`dynamic bar comprising:
`displaying additional dynamic preview information
`determined from the information managed by the
`software application, the additional dynamic preview
`information being different from the dynamic preview
`information displayed in they dynamic bar;
`the additional dynamic preview information comprising a
`selectable link which when activated, invokes the
`software application.
`
`5
`
`

`The Petitions’ Reliance on Cadiz’s
`Person-Centric Interface and
`Email-Centric Interface
`
`6
`
`

`The Petitions Allege Cadiz’s Person-Centric And Email-Centric Interfaces
`Independently Render Obvious The Independent Claims
`
`Petition
`-00913, Paper 1
`
`-00913 Pet. at 14, 17;
`see also -00914 Pet. at 6-7.
`
`7
`
`

`The Board: Petitions Allege Cadiz’s Person-Centric And Email-Centric
`Interfaces Independently Render Obvious The Independent Claims
`
`Institution Decision
`-00913, Paper 7
`
`-00913 Inst. Dec. at 16, 21;
`see also -00914 Inst. Dec. at 16-17.
`
`9
`
`

`The Parties’ Primary Disputes For Ground 1
`
`Ground 1 (§ 103 – Cadiz):
`
`• (All Claims) The claimed “software application” is not disclosed or rendered
`obvious by Cadiz’s person-centric interface.
`
`• (All Claims) The claimed “expanded dynamic bar” having “a selectable link” that
`“invokes the software application” is not disclosed or rendered obvious by Cadiz’s
`email-centric interface.
`
`• (‘384 patent, Claim 4) The claimed “method of claim 1, wherein the apparatus
`comprises a cellular telephone” is not disclosed or rendered obvious by Cadiz.
`
`• (All Claims) Properly construed, the claimed “a selectable link embedded in the
`additional dynamic preview information” (‘384 patent) and “additional dynamic
`preview information comprising a selectable link” (‘466 patent) are not disclosed or
`rendered obvious by Cadiz’s person-centric interface.
`
`10
`
`

`Overview Of Cadiz’s Person-Centric Interface
`
`Cadiz
`-00913, Ex. 1005
`
`“[B]y clicking on a face or other image representing a person ticket, a ‘person window’ is automatically opened. As
`described below, the person window is similar to an enhanced tooltip in that it is a window that provides extended
`information and actionable elements relating to the particular contact represented by the person ticket.
`xc
`Consequently, communications access channels and/or status 485 with particular persons or entities via one or more
`of the services in combination with one or more of the information sources may be reviewed or initiated easily, while a
`general communications availability of such people or entities may be understood by a user by simply glancing at the
`peripheral display.”
`
`-00913, Ex. 1005, ¶¶[170]-[171]; -00913 Pet. at 13-14;
`see also -00914 Pet. at 6.
`
`11
`
`

`The Challenged Claims’ Requirements For “Software Application”
`
`‘384 patent:
`1. A method for controlling an apparatus comprising a
`display, the method comprising:
`displaying a dynamic bar on the display;
`displaying dynamic preview information in the dynamic
`bar, the dynamic preview information being determined
`from information managed by a software application,
`the dynamic preview information being updated to
`reflect a change to the information managed by the
`software application;
`expanding the dynamic bar to display an expanded
`dynamic bar in response to a first input from an input
`device, displaying the expanded dynamic bar
`comprising:
`d
`displaying additional dynamic preview information
`determined from the information managed by the
`software application, the additional dynamic preview
`information being different from the dynamic preview
`information displayed in the dynamic bar, and
`the additional dynamic preview information being
`updated to reflect the same or different change to the
`information managed by the software application;
`displaying a selectable link embedded in the additional
`dynamic preview information to invoke the software
`application; and
`activating the software application in response to a
`second input invoking the link.
`
`‘466 patent:
`1. A method for displaying preview information, the
`method comprising:
`displaying on a display dynamic preview
`information in a dynamic bar, the dynamic
`preview information being determined from
`information managed by a software
`application, the dynamic preview information
`being updated to reflect a change to the
`information managed by the software
`application; and
`expanding the dynamic bar to display an
`expanded dynamic bar in response to a first
`input, displaying the expanded dynamic bar
`d
`comprising:
`displaying additional dynamic preview
`information determined from the information
`managed by the software application, the
`additional dynamic preview information
`being different from the dynamic preview
`information displayed in they dynamic bar;
`the additional dynamic preview information
`comprising a selectable link which when
`activated, invokes the software
`application.
`
`12
`
`

`The Parties’ Experts Agree: Cadiz’s Person-Centric Interface Does Not
`Disclose How A Person’s Overall Availability Is Determined
`
`Cadiz
`-00913, Ex. 1005
`
`Petitioner’s Expert:
`Q. Can you tell from looking at Figure 8A by which form of communication Gavin is available?
`
`A. Gavin, in Figure 8A, which form of information? All I can tell from Figure 8A, according to Paragraph 62 of Cadiz, is
`that Gavin is available.
`xc
`Q. But it doesn’t tell you by which form of communication Gavin is available, right?
`
`A.
`
`I do not remember anything in Cadiz that would indicate that, no.
`
`Ex. 2009, 101:18-102:5; -00913 Resp. at 27; see also -00914 Resp. at 29.
`
`14
`
`

`The Parties’ Experts Agree: Cadiz’s Person-Centric Interface Does Not Disclose How A
`Person’s Overall Availability Is Determined
`
`Patent Owner’s Expert:
`“I agree with Dr. Olsen that Cadiz does not
`disclose the source or software application from
`d
`which the sidebar in Figure 8A determines each
`contact’s current availability.”
`-00913, Ex. 2007, ¶58; -00913 Resp. at 27; see also -00914, Ex. 2007, ¶62;
`-00914 Resp. at 28-29.
`
`Petitioner’s Expert:
`“If we are referring to the availability represented in
`his picture, which I believe that is what we were
`discussing, it could come from a variety of sources.
`And I don’t remember a place in Cadiz where he
`specifies where that picture comes from, or that
`information.
`
`***
`What I said was it is undetermined what the source
`of that availability is.
`xc
`It could be from any of those places. It could be
`from a combination of those places. It could be
`some place different. It is not said, to my memory.
`***
`I said to my knowledge, to my memory, I don’t
`remember a place in Cadiz that specifies the source
`of the information referenced in Paragraph 62 of the
`Cadiz patent.”
`
`Ex. 2009, 98:18-99:24, 100:13-25; -00913 Resp. at 27;
`see also -00914 Resp. at 28.
`
`15
`
`

`The “Software Application” That Determines Cadiz’s Overall Availability Is Not the
`Same “Software Application” That Determines Any of Cadiz’s Alleged “Additional
`Dynamic Preview Information”
`Regarding Cadiz’s availability on individual
`Regarding Cadiz’s overall availability, Patent
`communications channels, Petitioner’s Expert testified:
`Owner’s Expert testified (unrebutted):
`
`“Based on Cadiz’s disclosures, however, a POSA
`would have understood that such availability
`information is determined from information managed by
`an ‘availability’ application that integrates information
`d
`from multiple communications channels to determine
`‘availability’ of a person (and hence whether the person
`is depicted facing the user of Cadiz’s system or is
`depicted in profile within the sidebar).”
`
`-00913, Ex. 2007, ¶59; -00913 Resp. at 26-27;
`see also -00914, Ex. 2007, ¶62; -00914 Resp. at 28-29.
`
`d
`
`Ex. 2009, 82:11-85:5; -00913 Resp. at 26; see also -00914 Resp. at 28.
`Patent Owner’s Expert testified:
`“I agree with Dr. Olsen that the person’s availability with
`d
`respect to each communication channel is managed by a
`different software application.”
`-00913, Ex. 2007, ¶60; -00913 Resp. at 26-27; see also -00914, Ex. 2007, ¶62;
`-00914 Resp. at 28-29.
`
`16
`
`

`The “Software Application” That Determines Cadiz’s Overall Availability Is Not the
`Same “Software Application” That Is “Invoke[d]” From the Person Window
`
`Cadiz
`-00913, Ex. 1005
`
`Cadiz (Ex. 1005):
`“This person window includes further information about the person or entity, as well as action buttons for initiating communication via any
`d
`of a number of conventional communications channels, i.e. email, voice mail, instant messaging (IM), cell phone, telephone, mail, etc.”
`-00913, Ex. 1005, ¶183; -00913 Resp. at 31; see also -00914 Resp. at 33.
`
`Patent Owner’s Expert:
`“As Dr. Olsen testified during his deposition (and I agree), a POSA would have understood from Cadiz’s disclosure that each
`d
`communication channel would have its own action button that would initiate an application for that communications channel.”
`
`Petitioner’s Expert:
`Q. And what happens when you click on that action button for the e-mail application in Figure 8B?
`A. According to Paragraph 183, you initiate communication with the conventional communication channels. And in your case, you are
`d
`talking about e-mail. You initiate the communication channels for e-mail.
`
`-00913, Ex. 2007, ¶63; -00913 Resp. at 29; see also -00914, Ex. 2007, ¶65;
`-00914 Resp. at 29.
`
`Ex. 2009, 111:25-112:9; -00913 Resp. at 29; see also -00914 Resp. at 31.
`17
`
`

`Cadiz Does Not Disclose That Its Overall Availability Is “Updated To Reflect
`A Change To The Information Managed By The Software Application”
`Petitioner’s Expert testified:
`Petitioner alleges:
`“For example, a change in availability for
`“If we are referring to the availability represented in
`‘Gavin’ will result in automatically changing the
`his picture, which I believe that is what we were
`image or picture in person item 815 in the
`discussing, it could come from a variety of sources.
`xc
`sidebar of FIG. 8A and automatically changing
`And I don’t remember a place in Cadiz where he
`the availability information displayed in the
`specifies where that picture comes from, or that
`person window 825 of FIG. 8B.”
`information.
`
`-00913 Pet. at 33;
`see also -00914 Pet. at 8, 12.
`
`“It is irrelevant whether Cadiz also describes
`some other application that aggregates Gavin’s
`availability information for purposes of
`displaying an overall availability in item 810.
`d
`The existence of such an application would not
`change the fact that the availability information
`is managed by the same communications
`application(s).”
`
`-00913 Reply at 10;
`see also -00914 Reply at 11-12.
`
`***
`What I said was it is undetermined what the source
`of that availability is.
`xc
`It could be from any of those places. It could be
`from a combination of those places. It could be
`some place different. It is not said, to my memory.
`***
`I said to my knowledge, to my memory, I don’t
`remember a place in Cadiz that specifies the source
`of the information referenced in Paragraph 62 of the
`Cadiz patent.”
`
`Ex. 2009, 98:18-99:24, 100:13-25; -00913 Resp. at 27;
`see also -00914 Resp. at 28.
`Patent Owner’s Expert testified:
`“[T]here is no disclosure in Cadiz of how (or
`whether) the integrated overall availability of Gavin
`xc
`in Figure 8A would be impacted by a change to
`Gavin’s availability by any single communications
`channel, such as MSN Messenger.”
`-00913, Ex. 2007, ¶62; -00913 Resp. at 28-29;
`see also -00914, Ex. 2007, ¶64; -00914 Resp. at 28-29.
`
`19
`
`

`The Parties’ Primary Disputes For Ground 1
`
`Ground 1 (§ 103 – Cadiz):
`
`• (All Claims) The claimed “software application” is not disclosed or rendered obvious
`by Cadiz’s person-centric interface.
`
`• (All Claims) The claimed “expanded dynamic bar” having “a selectable link” that
`“invokes the software application” is not disclosed or rendered obvious by
`Cadiz’s email-centric interface.
`
`• (‘384 patent, Claim 4) The claimed “method of claim 1, wherein the apparatus
`comprises a cellular telephone” is not disclosed or rendered obvious by Cadiz.
`
`• (All Claims) Properly construed, the claimed “a selectable link embedded in the
`additional dynamic preview information” (‘384 patent) and “additional dynamic
`preview information comprising a selectable link” (‘466 patent) are not disclosed or
`rendered obvious by Cadiz’s person-centric interface.
`
`20
`
`

`The Challenged Claims Require “Invok[ing] The Software
`Application” From The “Expanded Dynamic Bar”
`‘384 patent:
`‘466 patent:
`1. A method for controlling an apparatus comprising a
`1. A method for displaying preview information, the
`display, the method comprising:
`method comprising:
`displaying a dynamic bar on the display;
`displaying on a display dynamic preview
`information in a dynamic bar, the dynamic
`displaying dynamic preview information in the dynamic
`preview information being determined from
`bar, the dynamic preview information being determined
`information managed by a software
`from information managed by a software application, the
`application, the dynamic preview information
`dynamic preview information being updated to reflect a
`being updated to reflect a change to the
`change to the information managed by the software
`information managed by the software
`application;
`application; and
`expanding the dynamic bar to display an expanded
`expanding the dynamic bar to display an
`dynamic bar in response to a first input from an input
`expanded dynamic bar in response to a first
`device, displaying the expanded dynamic bar
`input, displaying the expanded dynamic bar
`d
`comprising:
`d
`comprising:
`displaying additional dynamic preview information
`displaying additional dynamic preview
`determined from the information managed by the
`information determined from the information
`software application, the additional dynamic preview
`managed by the software application, the
`information being different from the dynamic preview
`additional dynamic preview information
`information displayed in the dynamic bar, and
`being different from the dynamic preview
`the additional dynamic preview information being
`information displayed in they dynamic bar;
`updated to reflect the same or different change to the
`the additional dynamic preview information
`information managed by the software application;
`comprising a selectable link which when
`displaying a selectable link embedded in the
`activated, invokes the software
`additional dynamic preview information to invoke
`application.
`the software application; and
`activating the software application in response to a
`second input invoking the link.
`
`21
`
`

`Overview of Cadiz’s Email-Centric Interface
`
`Cadiz
`-00913, Ex. 1005
`
`Cadiz (Ex. 1005):
`“For example, assuming an email ticket for watching an email inbox folder, a summary of the number of messages received in the folder is
`preferably displayed in the thumbnail, i.e., the item which is being hosted by the container. Further, clicking on, or hovering a pointing device over
`the email item serves to bring up an email-pop-up window including the contents of the email inbox folder being tracked/watched in accordance
`with the email ticket instructions. As described in further detail below, the user may interact with any message in this window in the same manner
`as if the messages with being accessed or viewed within the users’ email application. In other words, given this example, the user can read the
`message, forward, delete, or reply to the message, or perform any other conventional messaging type action on the message from directly within
`d
`the email pop-up window. This functionality is achieved either by providing an email specific viewer having the desired email functionality, or by
`providing a viewer that instantiates an instance of the users email program for purposes of displaying the tracked/watched inbox folder.”
`
`“Similarly, FIG. 10 represents an email type ticket/item 1010 within another container/sidebar 1000. User selection of the email ticket/item 1000
`serves to expand/open an enhanced tooltip email window 1020 which allows user interaction with received email as from within a typical email
`application.”
`
`Patent Owner’s Expert:
`“The latter implementation means that an instance of the full email software application is invoked.”
`d
`-00913, Ex. 2007, ¶73; -00913 Resp. at 35; see also -00914, Ex. 2007, ¶75; -00914 Resp. at 38.
`22
`
`-00913, Ex. 1005, ¶¶ [0072], [0203]; -00913 Resp. at 35; see also -00914 Resp. at 38.
`
`

`Petitioner Takes Inconsistent Positions To Manufacture A
`Motivation To Modify
`
`Petition:
`
`“It would have been obvious in view of Cadiz and the
`knowledge of a POSA, however, to modify Cadiz’s
`email window 1020 such that the message entry is or
`includes an embedded link that, when selected,
`activates the email software application that manages
`the information used to determine the information
`displayed by the sidebar 1000 and email window 1020
`of FIG. 10. . . . Additionally, a POSA would have
`d
`recognized that modifying the message entry so that it
`is or includes an embedded link that, when selected,
`activates the email software application would have
`provided a better user experience. . . . For example, the
`email software application may provide features that
`are not available in email window 1020, consistent with
`Cadiz’s disclosure that the viewer may provide ‘desired’
`features rather than instantiating the fully-
`functioning email application.”
`
`-00913 Pet. at 43-44;
`see also -00914 Pet. at 29-30.
`
`Petitioner’s Reply:
`
`“In both implementations, email window 1020 provides
`d
`only a subset of possible email functionalities. (Pet.
`44.)”
`
`-00913 Reply at 15;
`see also -00914 Reply at 17 (citing -00914 Pet. 30).
`
`Patent Owner’s Expert:
`“A POSA would not have been motivated to modify Cadiz as
`Dr. Olsen suggests. Cadiz already discloses the option of
`directly (as opposed to taking extra steps going through a
`display of enhanced tooltip email window 1020 provided by the
`email specific viewer) invoking the email application as an
`alternative for displaying the enhanced tooltip email window
`1020 (as opposed to invoking the email application through Dr.
`Olsen’s example of ‘a separately displayed icon’ in email
`window 1020 as provided by the email specific viewer). . . .
`Therefore, a POSA who wanted to provide the user with all of
`the features of a fully-functional email application would have
`d
`simply implemented this second option that Cadiz expressly
`discloses, rather than implementing the modification Dr. Olsen
`suggests. . . . Doing so would provide the user with a better
`user experience than Dr. Olsen’s suggested modification
`because Cadiz’s disclosed implementation would require the
`user to take fewer steps to get to the fully-functional email
`application than Dr. Olsen’s modification would. Therefore,
`absent having claim of the ‘384 patent in front of him/her as a
`template, a POSA, in my view, would not have been motivated
`to implement Dr. Olsen’s proposed modification to Cadiz’s
`email-centric interface.”
`
`-00913, Ex. 2007, ¶76; -00913 Resp. at 36-37; see also -00914, Ex.
`2007, ¶78; -00914 Resp. at 38-39.
`
`23
`
`

`Petitioner’s Proposed Modification Is At Odds With
`Cadiz’s Disclosures
`Petitioner’s Expert:
`
`Petition:
`
`“It would have been obvious in view of Cadiz and the
`knowledge of a POSA, however, to modify Cadiz’s
`email window 1020 such that the message entry is or
`includes an embedded link that, when selected,
`activates the email software application that manages
`the information used to determine the information
`displayed by the sidebar 1000 and email window 1020
`of FIG. 10. . . . Additionally, a POSA would have
`d
`recognized that modifying the message entry so that it
`is or includes an embedded link that, when selected,
`activates the email software application would have
`provided a better user experience. . . . For example, the
`email software application may provide features that
`are not available in email window 1020, consistent with
`Cadiz’s disclosure that the viewer may provide ‘desired’
`features rather than instantiating the fully-functioning
`email application.”
`
`-00913 Pet. at 43-44;
`see also -00914 Pet. at 29-30.
`
`***
`
`d
`
`Ex. 2009, 176:6-177:3; -00913 Resp. at 36; see also -00914 Resp. at 38.
`Patent Owner’s Expert:
`“Further, I agree with Dr. Olsen’s deposition testimony
`that a POSA would have understood that for a user to,
`for example, read a message in email window 1020,
`the user would have to select and open that message.
`. . . Therefore, Dr. Olsen’s proposal to modify Cadiz’s
`d
`email window 1020 so that a message entry is or
`includes an embedded link that, when selected,
`activates the email software application is at odds
`with Cadiz’s system, which as disclosed, must also
`allow a user to select and open the same message
`(e.g., to read it) within the email viewer itself.
`-00913, Ex. 2007, ¶74; -00913 Resp. at 36; see also -00914, Ex. 2007, ¶76;
`-00914 Resp. at 38.
`
`24
`
`

`The Parties’ Primary Disputes For Ground 1
`
`Ground 1 (§ 103 – Cadiz):
`
`• (All Claims) The claimed “software application” is not disclosed or rendered obvious
`by Cadiz’s person-centric interface.
`
`• (All Claims) The claimed “expanded dynamic bar” having “a selectable link” that
`“invokes the software application” is not disclosed or rendered obvious by Cadiz’s
`email-centric interface.
`
`• (‘384 patent, Claim 4) The claimed “method of claim 1, wherein the apparatus
`comprises a cellular telephone” is not disclosed or rendered obvious by Cadiz.
`
`• (All Claims) Properly construed, the claimed “a selectable link embedded in the
`additional dynamic preview information” (‘384 patent) and “additional dynamic
`preview information comprising a selectable link” (‘466 patent) are not disclosed or
`rendered obvious by Cadiz’s person-centric interface.
`
`25
`
`

`‘384 Patent
`-00913, Ex. 1001
`
`‘384 patent, claim 4
`1. A method for controlling an apparatus comprising a display,
`the method comprising:
`displaying a dynamic bar on the display;
`displaying dynamic preview information in the dynamic bar,
`the dynamic preview information being determined from
`information managed by a software application, the
`dynamic preview information being updated to reflect a
`change to the information managed by the software
`application;
`expanding the dynamic bar to display an expanded dynamic
`bar in response to a first input from an input device,
`displaying the expanded dynamic bar comprising:
`displaying additional dynamic preview information
`determined from the information managed by the
`d
`software application, the additional dynamic preview
`information being different from the dynamic preview
`information displayed in the dynamic bar, and
`the additional dynamic preview information being updated
`to reflect the same or different change to the
`information managed by the software application;
`displaying a selectable link embedded in the additional
`dynamic preview information to invoke the software
`application; and
`activating the software application in response to a
`second input invoking the link.
`4. The method of claim 1, wherein the apparatus
`comprises a cellular telephone.
`
`26
`
`

`The Petition’s Analysis For ‘384 Patent, Claim 4
`
`‘384 Petition
`-00913, Paper 1
`
`d
`
`-00913 Pet. at 45-46.
`
`27
`
`

`The Parties’ Experts Agree: Cadiz’s Person-Centric and Email-Centric
`Interfaces Are Microsoft Windows Desktop Implementations
`Petitioner’s Expert:
`Patent Owner’s Expert:
`“For example, an application portion is shown in FIG. 10
`“As an initial matter, a POSA would have
`(annotated below) to the right of the sidebar 1000 and
`understood that none of Figures 8A, 8B, and 10
`above the email window 1020 (e.g., Windows Desktop)
`of Cadiz were cell phone, or even handheld
`(Ex. 1005 at FIG. 10), which resembles the ‘application
`device, implementations. Rather, a POSA
`portion 302’ shown in FIG. 3 of the ‘384 patent. . . . As
`would have known that Figures 8A, 8B, and 10
`d
`shown, the application portion comprises two icons (i.e.,
`were implemented on a Microsoft Windows
`‘Run in Compat . . .’ icon and ‘Readme Notes’ Microsoft
`desktop interface. For example, the desktops
`Word icon).”
`visible in the backgrounds of Figures 9 and 10
`include icons (e.g., Microsoft Word icon for
`“Readme Notes” fi

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