UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
`UBISOFT, INC. AND SQUARE ENIX, INC.,
`Petitioners,
`
`v.
`
`UNILOC USA, INC. AND UNILOC LUXEMBOURG S.A.,
`Patent Owners.
`
`____________
`
`Case No. IPR2017-01814
`U.S. Patent No. 6,324,578
` ____________
`
`DECLARATION OF DR. VIJAY K. MADISETTI, PH.D.
`
`1
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`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
`UBISOFT, INC. AND SQUARE ENIX, INC.,
`Petitioners,
`
`v.
`
`UNILOC USA, INC. AND UNILOC LUXEMBOURG S.A.,
`Patent Owners.
`
`____________
`
`Case No. IPR2017-01814
`U.S. Patent No. 6,324,578
` ____________
`
`DECLARATION OF DR. VIJAY K. MADISETTI, PH.D.
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`I, Vijay K. Madisetti, hereby declare the following:
`I.
`BACKGROUND AND EDUCATION
`1. My name is Vijay Madisetti, and I am a Professor of Electrical and
`
`Computer Engineering at Georgia Institute of Technology (“Georgia Tech”) in
`
`Atlanta, GA.
`
`2.
`
`I received a Bachelor of Technology in electronics and Electrical
`
`Communications Engineering from the Indian Institute of Technology (IIT) in 1984.
`
`I received my Ph.D. in Electrical Engineering and Computer Sciences (EECS) from
`
`the University of California, Berkeley in 1989. I am currently a tenured full Professor
`
`at Georgia Institute of Technology, and I have been on the faculty of Georgia
`
`Institute of Technology since 1989. I have authored or co-authored over 100
`
`reference articles in the area of electrical engineering. I have also authored, co-
`
`authored, or edited several books in the areas of electrical engineering, signal
`
`processing, image and video processing, computer engineering, and embedded
`
`systems,
`
`including Modeling, Analysis, Simulation of Computer and
`
`Telecommunications Systems (1994), VLSI Digital Signal Processors (1995) and
`
`The Digital Signal Processing Handbook (First & Second Editions) (1998, 2012),
`
`and VHDL: Electronics Systems Design Methodologies (2000). Although I discuss
`
`my expert qualifications in more detail below, I also attach as [Appendix A] a recent
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`and complete curriculum vitae, which details my educational and professional
`
`background and includes a listing of most of my publications.
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`3.
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`I have been active in the area of computer and information security and
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`protection in the networked environment since late 1980s, starting with my work on
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`“GAFFES: A Design of A Globally Distributed File System” (EECS Technical
`
`Report, UCB/CSD-87-361, June 1987) which described early work on security,
`
`authentication and replication in the network context. I have also published papers
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`in the area of coding theory for secure storage, communications and noise immunity
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`in the context of storage networks (See, e.g., “Constrained Multritrack RLL Codes
`
`for the Storage Channel”, IEEE Transactions on Magnetics, Vol. 31, Issue 3, 1995).
`
`I have also developed algorithms for detection of erroneous (or false) information
`
`that can be introduced and propagated into computer networks, and developed a
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`preemptive algorithm called WOLF that has been efficient in limiting the
`
`propagation by rolling back the effects of incorrect messages within a network. (See
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`WOLF: A Rollback Algorithm for Optimistic Distributed Simulation Systems,
`
`1988).
`
`4.
`
`I have been involved in research and technology in the area of signal
`
`processing, event-driven programming, embedded systems, and distributed
`
`computer and information systems since the late 1980s, and my work in this area has
`
`focused on secure and efficient distribution of information over networks,
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`synchronization of updates across a distributed network, and multiprocessing
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`systems and tools.
`
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`5.
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`In 1987, at UC Berkeley, I worked on implementing a globally
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`distributed file system, called GAFFES, to facilitate information sharing in a global
`
`network of workstations. GAFFES provided four services to handle naming,
`
`replication and caching, security and authentication, and file access primitives.
`
`GAFFES outlined features of access in terms of users and their roles, and in terms
`
`of beliefs and policies. Every file in GAFFES has at least one role, and the owner of
`
`a role determines the roles that may use that role to operations on software files.
`
`6.
`
`In the past twenty years, I have also authored several peer-reviewed
`
`papers in the areas of computer software and design, and these include:
`
`• V. Madisetti, et al, “Synchronization mechanisms for distributed
`event-driven computation”, ACM Transactions on Modeling and
`Computer Simulation, Vol 2, No. 1, January 1992
`• V. Madisetti, et al, “The Georgia tech Digital Signal Multiprocessor”,
`IEEE Transactions on Signal Processing, Vol 41, No. 7, July 1993
`• V. Madisetti et al, “Rapid Prototyping on the Georgia Tech Digital
`Signal Multiprocessor”, IEEE Transactions on Signal Processing, Vol
`42, March 1994.
`• V. Madisetti et al, “Computer Simulation of Application-Specific
`Signal Processing Systems”, International Journal in Computer
`Simulation, Vol. 4, No. 4, Nov 1994
`• V. Madisetti, “Reengineering legacy embedded systems”, IEEE
`Design & Test of Computers, Vol 16, Vol 2, 1999
`• V. Madisetti et al, “Virtual Prototyping of Embedded Microcontroller-
`based DSP Systems”, IEEE Micro, Vol 15, Issue 5, 1995
`• V. Madisetti, et al, “Incorporating Cost Modeling in Embedded-
`System Design”, IEEE Design & Test of Computers, Vol 14, Issue 3,
`1997
`• V. Madisetti, et al, “Conceptual Prototyping of Scalable Embedded
`DSP Systems”, IEEE Design & Test of Computers, Vol 13, Issue 3,
`1996.
`
`
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`• V. Madisetti, “Electronic System, Platform & Package Codesign,”
`IEEE Design & Test of Computers, Vol 23, Issue 3, June 2006.
`• V. Madisetti, et al, “A Dynamic Resource Management and
`Scheduling Environment for Embedded Multimedia and
`Communications Platforms”, IEEE Embedded Systems Letters, Vol 3,
`Issue 1, 2011.
`
`I have over 100 peer-reviewed publications issued from the early 1980s
`
`7.
`
`to the present on topics related to computer engineering, signal processing, event-
`
`driven programming, and digital system design.
`
`8.
`
`I am a Fellow of the Institute of Electrical and Electronics Engineering
`
`(“IEEE”), which signifies the highest professional standing in my research and
`
`educational community.
`
`9.
`
`In sum, I have over 25 years of experience in research and development
`
`in the areas of signal processing, event-driven programming, computer engineering
`
`and electrical engineering as a professor, researcher and consultant.
`
`10.
`
`I have been retained by Petitioners and am submitting this declaration
`
`to offer my independent expert opinion concerning certain issues raised in the
`
`Petition for Inter Partes Review (“Petition”). I am being compensated at the rate of
`
`$450 per hour, as well as being reimbursed for fees and expenses reasonably incurred
`
`with this engagement. My compensation is not based on the substance of the
`
`opinions rendered here. As part of my work in connection with this matter, I have
`
`studied U.S. Patent No. 6,324,578 (“the ‘578 patent”), including the respective
`
`written descriptions, figures and claims, in addition to the ‘578 patent prosecution
`
`
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`history. Moreover, I have reviewed the Petition for the ‘578 patent and I have also
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`carefully considered the following references discussed in the Petition, in addition
`
`to all of the materials cited herein:
`
`•
`
`•
`
`•
`
`U.S. Patent No. 5,832,505 to Kasso, et al. (“Kasso”), entitled
`“Computer System for Managing and Configuring Application
`Properties and Enabling System Administrator to Override Certain
`User-Set or Host Properties,” filed April 2, 1997 and issued November
`3, 1998 [EX1002]
`
`JavaStation™ Software Environment for Developers (JSE 1.0.2)
`(“JavaStation”) published in 1997 by Sun Microsystems Inc., Mountain
`View [EX1003]
`
`U.S. Patent No. 5,734,831 to Sanders (“Sanders”), entitled “System for
`Configuring and Remotely Administering a Unix Computer over a
`Network,” filed April 26, 1996 and issued March 31, 1998 [EX1004]
`
`11. This declaration is based on my personal knowledge and my review of
`
`the materials referenced in this Declaration.
`
`12. My opinions are based on my education, research, and experience from
`
`the pertinent timeframe.
`
`II. LEGAL FRAMEWORK
`13.
`I have been informed by counsel and understand that the first step in an
`
`unpatentability analysis involves construing the claims, as necessary, to determine
`
`their scope. And, second, the construed claim language is then compared to the
`
`
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`disclosure of the prior art. In proceedings before the United States Patent and
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`Trademark Office, I have been informed that the claims of an unexpired patent are
`
`to be given their broadest reasonable interpretation in light of the specification from
`
`the perspective of a person of ordinary skill in the art at the time of the invention. I
`
`have been informed that the ‘578 patent is unexpired.
`
`14.
`
`In comparing the claims of the ‘578 patent to the prior art, I have
`
`carefully considered the ‘578 patent and its prosecution history based upon my
`
`experience and knowledge in the relevant field. In my opinion, the broadest
`
`reasonable interpretation of the claim terms of the ‘578 patent is generally consistent
`
`with the ordinary and customary meaning of those terms, as one skilled in the
`
`relevant field would understand them at the time of the invention. For purposes of
`
`this proceeding, I have applied the claim constructions set forth in the claim
`
`construction section of the IPR Petition that this declaration accompanies when
`
`analyzing the prior art and the claims. For those terms that have not expressly been
`
`construed, I have applied the meaning of the claim terms of the ‘578 patent that is
`
`generally consistent with the terms’ ordinary and customary meaning, as a person of
`
`ordinary skill in the art would have understood them at the time of the invention.
`
`15.
`
`I have been informed by counsel that there are two ways in which a
`
`prior art patent or printed publication can be used to invalidate a patent. First, the
`
`prior art can be shown to “anticipate” the claim. Second, the prior art can be shown
`
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`to “render obvious” the claim. My understanding of the two legal standards is set
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`forth below.
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`16.
`
`I have been informed by counsel that, in general, for a patent claim to
`
`be invalid as “anticipated” by the prior art, each and every feature of the claim must
`
`be found, expressly or inherently, in a single prior art reference or product arranged
`
`as in the claim. Claim limitations that are not expressly found in a prior art reference
`
`are inherent if the prior art necessarily functions in accordance with, or includes, the
`
`claim limitations.
`
`17.
`
`I have also been informed by counsel that an inventor is not entitled to
`
`a patent if his or her invention would have been obvious to a person of ordinary skill
`
`in the field of the invention at the time the invention was made. I understand that a
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`patent claim is not patentable under 35 U.S.C. § 103 if the differences between the
`
`patent claim and the prior art are such that the claimed subject matter as a whole
`
`would have been obvious at the time the claimed invention was made to a person
`
`having ordinary skill in the art to which the subject matter pertains. Obviousness,
`
`as I understand it, is based on the scope and content of the prior art, the differences
`
`between the prior art and the claim, the level of ordinary skill in the art, and, to the
`
`extent that they exist and have an appropriate nexus to the claimed invention (as
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`opposed to prior art features), secondary indicia of non-obviousness.
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`18.
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`I have been informed that whether there are any relevant differences
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`between the prior art and the claimed invention is to be analyzed from the view of a
`
`person of ordinary skill in the art at the time of the invention, in this case December
`
`14, 1998. As such, my opinions below as to a person of ordinary skill in the art are
`
`as of the time of the invention, even if not expressly stated as such; for example,
`
`even if stated in the present tense.
`
`19.
`
`I have been informed that for a reference to be proper for use in an
`
`obviousness ground of unpatentability, the reference must be “analogous art” to the
`
`claimed invention. Under the correct analysis, any need or problem known in the
`
`field of endeavor at the time of the invention and addressed by the patent can provide
`
`a reason for combining the elements in the manner claimed. This does not require
`
`that the reference be from the same field of endeavor as the claimed invention,
`
`because I have been informed that when a work is available in one field of endeavor,
`
`design incentives and other market forces can prompt variations of it, either in the
`
`same field or a different one. Rather, a reference is analogous art to the claimed
`
`invention if: (1) the reference is from the same field of endeavor as the claimed
`
`invention (even if it addresses a different problem); or (2) the reference is reasonably
`
`pertinent to the problem faced by the inventor (even if it is not in the same field of
`
`endeavor as the claimed invention). In order for a reference to be “reasonably
`
`pertinent” to the problem, it must logically have commended itself to an inventor's
`
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`attention in considering his problem. In determining whether a reference is
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`reasonably pertinent, a relevant consideration is the problem faced by the inventor,
`
`as reflected either explicitly or implicitly, in the specification. I believe the
`
`references that my opinions in this proceeding are based upon are well within the
`
`range of references a person of ordinary skill in the art would consult to address the
`
`type of problems described in the ’578 Patent, as described further below.
`
`20.
`
`In analyzing the relevance of the differences between the claimed
`
`invention and the prior art, I have been informed that I must consider the impact, if
`
`any, of such differences on the obviousness or non-obviousness of the invention as
`
`a whole, not merely some portion of it. The person of ordinary skill faced with a
`
`problem is able to apply his or her experience and ability to solve the problem and
`
`also look to any available prior art to help solve the problem.
`
`21. An invention is obvious if a person of ordinary skill in the art, facing
`
`the wide range of needs created by developments in the field, would have seen an
`
`obvious benefit to the solutions tried by the applicant. When there is a design need
`
`or market pressure to solve a problem and there are a finite number of identified,
`
`predictable solutions, it would be obvious to a person of ordinary skill to try the
`
`known options. If a technique has been used to improve one device, and a person of
`
`ordinary skill in the art would recognize that it would improve similar devices in the
`
`same way, using the technique would have been obvious.
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`22.
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`It is my understanding that a precise teaching in the prior art directed to
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`the subject matter of the claimed invention is not needed and that one may take into
`
`account the inferences and creative steps that a person of ordinary skill in the art
`
`would have employed in reviewing the prior art at the time of the invention. For
`
`example, if the claimed invention combined elements known in the prior art and the
`
`combination yielded results that were predictable to a person of ordinary skill in the
`
`art at the time of the invention, then this evidence would make it more likely that the
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`claim was obvious. On the other hand, if the combination of known elements yielded
`
`unexpected or unpredictable results, or if the prior art teaches away from combining
`
`the known elements, then this evidence would make it more likely that the claim that
`
`successfully combined those elements was not obvious.
`
`23.
`
`I understand that hindsight must not be used when comparing the prior
`
`art to the invention for obviousness.
`
`24.
`
`It is my understanding that obviousness may also be shown by
`
`demonstrating that it would have been obvious to modify what is taught in a single
`
`piece of prior art to create the subject matter of the patent claim. Obviousness may
`
`be shown by showing that it would have been obvious to combine the teachings of
`
`more than one item of prior art. In determining whether a piece of prior art could
`
`have been combined with other prior art or combined with or modified in view of
`
`
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`other information within the knowledge of one of ordinary skill in the art, the
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`following are examples of approaches and rationales that may be considered:
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`Combining prior art elements according to known methods to yield
`predictable results;
`
`Simple substitution of one known element for another to obtain
`predictable results;
`
`Use of a known technique to improve similar devices (methods, or
`products) in the same way;
`
`Applying a known technique to a known device (method, or product)
`ready for improvement to yield predictable results;
`
`Applying a technique or approach that would have been "obvious to
`try" (choosing from a finite number of identified, predictable solutions,
`with a reasonable expectation of success);
`
`Known work in one field of endeavor may prompt variations of it for
`use in either the same field or a different one based on design incentives
`or other market forces if the variations would have been predictable to
`one of ordinary skill in the art; or
`
`Some teaching, suggestion, or motivation in the prior art that would
`have led one of ordinary skill to modify the prior art reference or to
`combine prior art reference teachings to arrive at the claimed invention.
`
`25.
`
`I understand that the rationale for modifying a reference and/or
`
`combining references may come from sources such as explicit statements in the prior
`
`art, or the knowledge of one of ordinary skill in the art, including any need or
`
`problem known in the field at the time, even if different from the specific need or
`
`problem addressed by the inventor of the patent claim.
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`26. Finally, I understand that for two structures to be “equivalent” under
`
`§112, ¶6, they must perform the identical function, in substantially the same way,
`
`with substantially the same result.
`
`III. LEVEL OF A PERSON HAVING ORDINARY SKILL IN THE ART
`27.
`I have been asked to provide my opinion regarding the qualifications of
`
`a person having ordinary skill in the art (“POSITA” or “skilled artisan”) with respect
`
`to the ‘578 Patent. I understand that the POSITA is a hypothetical person who is
`
`presumed to have known the relevant art at the time of the invention, which I
`
`understand here to be sometime at or around the December 14, 1998 filing date of
`
`the ‘578 Patent. I understand that factors that may be considered in determining the
`
`level of ordinary skill in the art may include: (a) the type of problems encountered
`
`in the art; (b) prior art solutions to those problems; (c) the rapidity with which
`
`innovations are made; (d) the sophistication of the technology; and (e) the
`
`educational level of active workers in the field.
`
`28.
`
`In my opinion, the POSITA relevant to the ‘578 Patent would have at
`
`least an undergraduate degree, in computer science, computer engineering, or a
`
`related field or an equivalent number of years of working experience. In addition, a
`
`POSITA would have at least one to two years of experience in networking
`
`environments, including at least some experience with management of application
`
`programs in a network environment.
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`29. As demonstrated by my experience above, I more than meet the
`
`definition of one of ordinary skill in the art. In addition, throughout the 1990s and
`
`2000s, I worked with numerous people of ordinary skill in the field in question.
`
`IV. OVERVIEW OF THE ‘578 PATENT
`30. The ‘578 Patent generally relates to “management of configurable
`
`application programs on a network.” See ‘578 Patent at Title. Specifically, the ‘578
`
`Patent discloses a server providing an “application launcher” program executing an
`
`application program and a “configuration manager” program to obtain preferences
`
`from an administrator. ‘578 Patent at Abstract. An application program having a
`
`plurality of configurable preferences and a plurality of authorized users is installed
`
`on a server coupled to a network. ‘578 Patent at 4:25-27. A user set of the plurality
`
`of configurable preferences associated with one of the plurality of authorized users
`
`executing the application launcher program is obtained and an administrator set of
`
`the plurality of configurable preferences is obtained from an administrator. ‘578
`
`Patent at 4:29-34. The application program is executed using the obtained user set
`
`and administrator set of the plurality of configurable preferences responsive to a
`
`request from one of the plurality of authorized users. ‘578 Patent at 4:34-38. This
`
`process is generally depicted in Figures 3 and 4 of the ‘578 Patent:
`
`
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`V. OVERVIEW OF THE ‘578 PATENT FILE HISTORY
`31. The application leading to the ‘578 Patent was filed on December 14,
`
`
`
`1998 with 25 claims. EX1007, ‘578 Patent File History at pp. 34-42. The PTO
`
`initially indicated the claims were subject to a restriction requirement. ‘578 Patent
`
`File History at p. 81 (March 6, 2001 Telephone Interview Summary). In response,
`
`Applicants elected claims 1-18 and 23-24, cancelled claims 19-22 and 25, and added
`
`
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`new claims 26-51. ‘578 Patent File History at p. 67 (March 7, 2001 Amendment).
`
`The Examiner issued a Notice of Allowability on March 9, 2001. ‘578 Patent File
`
`History at 74-76. On June 21, 2001, Applicants filed an RCE and IDS listing a
`
`number of prior art references. ‘578 Patent File History at pp. 84-88. Another Notice
`
`of Allowance was issued on June 28, 2001. ‘578 Patent File History at pp. 90-93.
`
`The ‘578 Patent issued on November 27, 2001.
`
`VI. BACKGROUND ON THE STATE OF THE RELEVANT ART
`32.
`It was well-known in the early to mid-1990s to centrally manage
`
`application program use according to administrator and user preferences. Access to
`
`the applications was often gained through a client installed on the user (application
`
`launcher in the terminology of the ‘578 Patent) after the user was authorized.
`
`Although only one exemplary system is generally described in this Section, many
`
`were known and in use prior to December 1998, including those described in the
`
`Petition and further discussed below. As part of commercialization efforts on a
`
`startup I launched in the mid 1990s, I developed licensing, installation and
`
`configuration software for software products that we developed, including control
`
`and configuration of demo licenses for software products over networks. The
`
`products included simulation models, IT and workstation management tools, and
`
`reverse engineering software tools.
`
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`33. U.S. Patent No. 5,692,129 (“the ‘129 Patent”), filed on July 7, 1995,
`
`titled “Managing Application Programs in a Computer Network by Using a Database
`
`of Application Objects” issued on November 25, 1997. EX1014. The ‘129 Patent
`
`discloses the concept of managing application programs in a computer network.
`
`Sonderegger at 2:47-64. Sonderegger discloses application management routines
`
`through which an administrator can create a new application object and define the
`
`attributes for the object, such as defining and adding a file path. Sonderegger at
`
`11:3-18, 13:32-45. Application objects and associated attributes are stored in the
`
`Novell NetWare Directory Services database. Sonderegger at 6:53-7:20. The
`
`administrator can further define the application program icons that will display on a
`
`user’s application launcher upon logging into the system. Sonderegger at 7:11-20,
`
`11:53-62, Fig. 8.
`
`34. Sonderegger further discloses configurable preferences for an
`
`application launcher, including the application launcher’s window size, position,
`
`icon refresh, and whether the user is allowed to resize the launcher’s window.
`
`Sonderegger at 12:51-65. As shown in Figure 8, a user can change the value of
`
`selected attributes of application objects displayed in the application launcher.
`
`Sonderegger at 18:29-37, Fig. 8.
`
`
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`35. As described above, centrally managing the use and preferences of
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`application programs was well known in the art by the mid to late 1990s.
`
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`VII. KASSO IN VIEW OF JAVASTATION
`36.
`I was asked to consider whether, at the time of the alleged invention, it
`
`would have been obvious to combine Kasso and JavaStation.
`
`37. As an initial matter, I note that the ‘578 Patent is directed to “network
`
`management in general and in particular to application program management on a
`
`computer network.” ‘578 Patent at 1:22-24. Kasso and JavaStation also relate to
`
`the field of management of application programs in a computer network and,
`
`therefore, are in the same field of endeavor. Kasso at 1:8-11, Abstract; JavaStation
`
`at pp. 27-29. Not only that, but like the ‘578 Patent, Kasso and JavaStation each
`
`address the problem of providing configurable preferences for an application
`
`program, including allowing a mix of user and administrator defined configurable
`
`preferences to be associated with a specific application program . Kasso at 1:8-2:56,
`
`16:7-15; JavaStation at pp. 40-41, 60-61; ‘578 Patent at 2:11-34, 3:40-45. Kasso,
`
`JavaStation, and the ‘578 also address the problem of controlling access for mobile
`
`users. Kasso at 1:33-46, 16:16-29; JavaStation at pp. 40-41, 60-61; ‘578 Patent at
`
`2:35-3:23. For at least these reasons, Kasso and JavaStation are analogous to each
`
`other and to the ‘578 Patent.
`
`38. Kasso, assigned to Sun Microsystems, Inc., discloses a method,
`
`apparatus, and computer program product for managing and configuring program
`
`properties of an application program. Kasso at Abstract. Kasso describes use of the
`
`
`
`19
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`IPR2017-01839
`Ubisoft, et al. EX1005 Page 19
`
`
`
`disclosed system in connection with the JavaOS operating system and HotJava
`
`Views software, both from Sun Microsystems, Inc. Kasso at 4:54-57 (“A JavaOS
`
`boot server (JBS) 206 is also coupled to the local area network. The JBS 206
`
`provides or distributes an operating system program, such as the JavaOS operating
`
`system available from Sun Microsystems, Inc.”).
`
`
`
`Fig. 5 (depicting HotJava Views interface).
`
`39.
`
`In particular, Kasso discloses that application programs are managed
`
`through the use of loading configuration files and property lists maintained at a
`
`server, such as an HTTP server and remote file server, and applying precedence rules
`
`
`
`20
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`IPR2017-01839
`Ubisoft, et al. EX1005 Page 20
`
`
`
`to resolve conflicts among properties. Kasso at 2:45-67, 6:20-30. Kasso further
`
`discloses providing property lists, where “properties” “refers broadly to application
`
`program attributes, parameters, preferences, and environmental variables, e.g., any
`
`aspect of an application program that an end user may configure or adjust.” Kasso
`
`at 6:44-47. Exemplary “properties” include “display fonts, the identity and location
`
`of external resources such as printers, servers, and other input/output devices,
`
`methods of alerting a user such as through an alarm or bell, window location and
`
`size, and language used by an application.” Kasso at 6:47-52.
`
`40. Kasso discloses that application programs, implemented as Java
`
`applets, are “stored in association with an HTML page on the HTTP server 208.
`
`Selector displays a main screen 402, shown in Fig. [5]. Each application program
`
`240 is represented in the main screen by an icon 404, 406 in the application icon
`
`pane 410 of the Selector main screen.” Kasso at 5:60-66. Each application icon
`
`represents one application program, such as an e-mail program. Kasso at 5:66-6:4.
`
`The disclosed property lists allow a user and administrator to define or write specific
`
`property list values that are compared with previously loaded default properties and
`
`will override the previously loaded property values as defined according to rules of
`
`precedence, where a system administrator can define final property lists that always
`
`override any conflicting values from user-defined property lists. Kasso at 7:3-8,
`
`7:10-22, 7:28-57.
`
`
`
`21
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`IPR2017-01839
`Ubisoft, et al. EX1005 Page 21
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`
`
`41. Kasso further discloses that an administrator may manage and
`
`configure application properties, such as assigning users to groups, and apply
`
`application properties to the group. Kasso at 9:44-10:12, Table 2, 10:64-11:39,
`
`Tables 4, 5, 13:3-15. The “final” application-specific properties, settable only by an
`
`administrator, in addition to the default application-specific properties are stored on
`
`the HTTP server 208, while the user-specific properties are stored on a remote file
`
`server 232 in a home director exclusively assigned to a particular user. Kasso at
`
`6:20-30, 6:53-7:2. Kasso discloses that the property list files are “loaded both when
`
`Selector initializes and each time any other NC application starts, is loaded, or is
`
`invoked. When Selector initializes and the property list files are loaded, Selector
`
`builds a merged property list in the memory of the host that is executing Selector.”
`
`Kasso at 14:7-13. The “merged property list” can be stored “in the RAM memory
`
`of the network computer on which Selector is running (such as NC 200), or in files
`
`on a mass storage device of a server such as the HTTP server 208 or JBS 206, or in
`
`the RAM memory of the server.” Kasso at 7:18-22.
`
`42. Additionally, Kasso discloses a system for multiple users, where an
`
`individual user may set certain preferences that are applied when his or her own
`
`applications execute, for example, “one user may prefer to use the typeface Helvetica
`
`as the default font for a certain application program, whereas another user prefers a
`
`different font.” Kasso at 1:22-25. Kasso discloses preferences for groups of users
`
`
`
`22
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`IPR2017-01839
`Ubisoft, et al. EX1005 Page 22
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`
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`such as an “engineering” group and a “default” group. Kasso at 9:44-55. Kasso
`
`further discloses property lists set individually by users within a group of users,
`
`where “the user could specify a particular type-font for their email application that
`
`would follow the user from one host to the next, but would be different from all the
`
`other users in the receptionist group.” Kasso at 16:27-30.
`
`43.
`
`JavaStation provides a detailed description of the HotJava Views
`
`software and specifically describes the design and implementation of JavaStation
`
`Software Environment 1.0.2 (JSE 1.0.2). It discloses many aspects of JSE 1.0.2, but
`
`specifically discloses the “tools” of JSE 1.0.2, including system administration
`
`programs, such as Views Manager, and how to shift a network from desktop to
`
`webtop computing.
`
`“JavaStation Software Environment 1.0.2 for Developers (JSE 1.0.2)
`describes the JSE software and gives instructions on how to install it. It
`describes how to set up the JavaStation network using the JavaStation™
`Manager and Views Manager administrative tools. It also describes how to
`configure JavaStation clients and the HotJava™ Views™ software. This book
`is intended for experienced UNIX system administrators.
`JavaStation at vii, Preface.
`
`“The JavaStation Software Environment for Developers (JSE 1.0.2) provides
`the tools to shift your network from desktop to webtop computing. A webtop
`is your computer workspace redefined for a Java environment. In this new
`paradigm, a user’s account (programs, files, and data) resides on the network,
`
`
`
`23
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`IPR2017-01839
`Ubisoft, et al. EX1005 Page 23
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`
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`and can be accessed from any JavaStation client. Java applets supply
`everything to the webtop from the network.”
`JavaStation at 9.
`
`44. The View
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