UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
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`VILOX TECHNOLOGIES LLC.
`Patent Owner
`
`____________________
`
`Case IPR2018-00044
`Patent No. 7,302,423
`____________________
`
`DECLARATION OF WESLEY W. CHU, PH.D.
`July 9, 2018
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`TABLE OF CONTENTS
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`INTRODUCTION ......................................................................................................... 4
`I.
`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE ...................................... 4
`III. LEVEL OF ORDINARY SKILL IN THE ART AND RELEVANT LEGAL
`STANDARDS ................................................................................................................. 11
`IV. U.S. PATENT 7,302,423 (THE ’423 PATENT), EXHIBIT 1001 .............................. 14
`A. Specification and Prosecution History ......................................................... 15
`1. Specification .................................................................................................... 15
`2. Prosecution History ........................................................................................ 17
`V. CLAIM CONSTRUCTION ........................................................................................ 20
`A. Determining a Database Schema for a Database ......................................... 21
`B. Determining a Number of Characters in Each Entry of the Selected
`Database Field ....................................................................................................... 23
`C. Performing a Truncation ................................................................................. 25
`D. Displaying a Portion of Each Entry in the Selected Database Field,
`wherein a Number of Characters Displayed in Each Portion is Less Than or
`Equal to the Specified Amount of Characters .................................................... 26
`E. Each Entry from the Selected Data Field is Displayed on a Terminal ........ 27
`VI. REFERENCES RELIED ON BY THE PETITIONER .............................................. 28
`A. U.S. Patent 5,701,453 to Maloney (Maloney, Exhibit 1006) .......................... 28
`1. Maloney Does Not Disclose Determining a Database Schema .................. 28
`2. Maloney Discloses and Requires an Explicit Naming Convention ............ 34
`B. Excel 2000 Bible and Excel (Exhibit 1009) ................................................... 39
`C. U.S. Patent 7,168,039 to Bertram (Bertram, Exhibit 1007) ........................... 55
`D. U.S. Patent 6,300,947 TO Kanevsky (Kanevsky, Exhibit 1008) ................... 70
`VII. NONE OF PETITIONER’S ASSERTED CHALLENGES ESTABLISH
`OBVIOUSNESS ............................................................................................................. 76
`A. Claim 1 is Not Obvious over Maloney in view of Bertram ........................... 77
`1. Maloney in View of Bertram Does Not Disclose or Suggest All Claim 1
`Limitations ........................................................................................................... 77
`2. There Can Be No Motivation to Combine Maloney and Bertram ................ 83
`B. Claim 2 is Not Obvious over Maloney in View of Bertram ........................... 87
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`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`C. Claim 1 Is Not Obvious over Excel in View of Bertram ................................ 89
`1. Excel in View of Bertram Does Not Disclose or Suggest All Claim 1
`Limitations ........................................................................................................... 89
`2. There Can Be No Motivation to Combine Excel and Bertram ..................... 91
`D. Claim 3 is Not Obvious over Maloney in View of Bertram ........................ 100
`1. Maloney in View of Bertram Does Not Disclose or Suggest All Claim 3
`Limitations ......................................................................................................... 101
`2. There Can Be No Motivation to Combine Maloney and Bertram Because
`Any Combination of Maloney and Bertram Would Render Critical Features of
`Maloney Inoperative ......................................................................................... 102
`E. Claim 3 is Not Obvious over Excel in View of Bertram .............................. 106
`1. Excel in View of Bertram Does Not Disclose or Suggest All Claim 3
`Limitations ......................................................................................................... 106
`2. There Can Be No Motivation to Combine Excel and Bertram ................... 106
`F. Claim 6 is not obvious over Maloney in View of Bertram and Kanevsky . 114
`1. The Combination of Maloney, Bertram, and Kanevsky Does Not Disclose
`or Suggest the Claim 6 Limitations ................................................................. 114
`2. There Can Be No Motivation to Combine Maloney, Bertram, and Kanevsky
` 115
`G. Claim 6 is Not Obvious over Excel in View of Bertram and Kanevsky .... 117
`1. There Can Be No Motivation to Combine Excel, Bertram, and Kanevsky
` 117
`VIII. CLAIMS 1, 3, AND 6, AS AMENDED, ARE VALID ........................................... 123
`A. CLAIM 1/24 ..................................................................................................... 123
`B. CLAIM 3/25 ..................................................................................................... 124
`C. CLAIM 6/26 ..................................................................................................... 125
`IX. CONCLUSION ...................................................................................................... 126
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`INTRODUCTION
`
`I have prepared this Declaration at the request of Vilox Technologies, LLC stating
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`I.
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`1.
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`my opinions as an independent expert regarding issues raised in the matter of Petition
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`IPR2018-00044 (“Petition”) and the April 19, 2018 Decision on Institution of Inter Partes
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`Review (“Decision”).
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`2.
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`I am being compensated for this work, and my compensation is not dependent
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`on the outcome of this matter.
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`3.
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`In preparation for this Declaration, I studied Exhibits 1001 – 1010 provided by
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`Petitioner as well as the Petition. I also studied the Decision; Exhibit 2003, Declaration
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`of Dr. Joseph L. De Bellis; Exhibit 2014, Excel III (excerpt tof Excel 2000 Bible); Exhibit
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`2015, Deposition Transcript of Dr. Philip Greenspun; and Exhibits 2019 (Webster’s New
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`Collegiate Dictionary), 2018 (IEEE Dictionary of Electrical and Electronics Terms), and
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`Exhibit 2020, (Microsoft Press Computer Dictionary).
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`4.
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`In preparing this Declaration, I relied, in addition to the above Papers and other
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`documents, on my knowledge and experience gained through 56 years as an engineer,
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`professor, and consultant.
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`II.
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`5.
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`QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
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`My Curriculum Vitae is provided as Exhibit 2002. Following is a summary of my
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`education and relevant experience.
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`6.
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`I am Emeritus Distinguished Professor at the University of California, Los
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`Angeles. I received a Bachelor of Science degree in electrical engineering from the
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`University of Michigan in 1960 and a Master of Science degree in electrical engineering
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`from the University of Michigan in 1961. I received a Ph.D. in electrical engineering
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`Case IPR2018-00044
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`Declaration of Wesley W. Chu, Ph.D.
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`from Stanford University in 1966.
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`7.
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`From 1961 to 1962, I worked at General Electric (now Honeywell) in Phoenix,
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`Arizona with a focus on electrical switching circuits for computers. From 1964 to 1966, I
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`worked on the design of large-scale computers at IBM in San Jose, California. From
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`1966 to 1969, I worked at Bell Laboratories in Holmdel, New Jersey with a focus on
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`computer communications and distributed databases.
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`8.
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`I joined the faculty of the of California, Los Angles in 1969 in the Computer
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`Science Department. I served as Department Chair from 1988 to 1991, as
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`Distinguished Professor since 1998, and as Emeritus Distinguished Professor since
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`2009.
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`9.
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`From 1982 to 2005, I worked as a consultant for several large computer
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`companies:
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`• 1982 - 1984, Western Union Corporation, Upper Saddle River, New Jersey,
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`Executive Consultant to VP Engineering and Member of the Technical Review
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`Board with duties that included:
`o Evaluating and planning for the Western Union Packet Switched Network,
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`Easylink, and other value-added services.
`o Developing transition plans for network modernization, integration with
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`existing networks and for future network growth.
`o Critiquing on going and proposed enhancement plans and compare with
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`other viable alternatives for effectiveness.
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`• 1983 – 1986, Titan Systems Inc., Inglewood California, Consultant, with duties
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`that included developing, evaluating and validating the SENTRY Distributed Data
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`Base System.
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`• 1985 – 1988, Unisys SDC Corp., Huntsville, Alabama, Consultant, with duties
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`that included designing and developing a real time distributed database system
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`for missile defense applications.
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`• 1995 – 2005, Xerox Corporation, El Segundo, California, Consultant, fault
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`tolerant computing, with duties that included designing and developing word
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`processing systems.
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`10. Early in my career, my research focus was on computer communication and
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`networks, distributed databases, memory management, real-time distributed processing
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`systems, and statistical multiplexing - the latter contributing to the development of ATM
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`networks. My pioneering work in file allocation and directory design for distributed
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`databases aided the design and development of domain name servers for the web and
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`current cloud computing systems. I was named an IEEE Fellow for my contributions in
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`these areas.
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`11. Over the past two decades, my research interests evolved to include intelligent
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`(knowledge-based) information systems and knowledge acquisition for large information
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`systems. Using my methodology for relaxing query constraints, I led the development
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`of CoBase, a cooperative database system for structured data, and KMed, a
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`knowledge-based multimedia medical image system.
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`12. Under the KMed project, I developed a Medical Digital Library that provides
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`approximate content-matching and navigation; the library will serve as a cornerstone for
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`future paperless hospitals. More recently, I worked on inference techniques for data
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`security and privacy protection (ISP) and social network-based recommender system
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`(SNRS).
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`13.
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`Together with my students, I received numerous best paper awards at
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`conferences and workshops, and also a certificate of merit for work on the Medical
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`Digital Library system. I am the recipient of the IEEE Computer Society's Technical
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`Achievement Award for contributions to intelligent information systems.
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`14.
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`I am the author or coauthor of more than 150 articles, an editor of three
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`textbooks on information technology, and the co-editor of a reference book on data
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`mining.
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`15.
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`I have received the following U.S. Patents:
`
`“System and Methods for Evaluating Inferences for Unknown Attributes in a
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`Social Network,” U.S. Patent Number 8,160,993 April 17, 2012, Lead inventor,
`
`Wesley W. Chu.
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`“System and Method for Retrieving Scenario Specific Documents,” U.S. Patent
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`Number 7, 548,910, June 2009, Lead inventor, Wesley W. Chu.
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`“Database Event Detection and Notification System Using Type Abstraction
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`Hierarchy (TAH),” U.S. Patent Number 6,247,146, July 2002.
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`“Database System with Query Relaxation Using Type Abstraction Hierarchy
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`(TAH) as Query Condition Relaxation Structure,” U.S. Patent Number 6,427,146,
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`September 1999.
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`•
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`•
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`•
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`•
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`“Multiplexed MOS Multi-Accessed Memory System” (co-invented with D. Hibbits),
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`U.S Patent Number 4,415,991, November 1983.
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`“Multi-access Memory Module for Data Processing System” (co-invented with P.
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`Korff), U.S. Patent Number 4,109,719, August 1978.
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`“Statistical Multiplexing Systems for Computer Communications,” U.S. Patent
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`Number 4,093,823, June 1978.
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`“Statistical Multiplexing Systems for Computer Communications,” U.S. Patent
`
`
`
`•
`
`•
`
`•
`
`•
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`Number 4,082,922, April 1978.
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`16.
`
`I have received the following special recognitions:
`
`•
`
`•
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`Invited by United Nations (1984) and World Bank (1987) as a member of
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`scientific delegates to consult and lecture on Computer Communications and
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`Networks, and Distributed Data Bases in People's Republic of China.
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`IEEE Computer Society Distinguished Visitors Program to give invited lectures to
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`selected universities, 1990-1994.
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`• Selected by National Science Council as a delegate scientist to visit Taiwan and
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`give invited lecture series (1992).
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`• External program review committee for the Department of Information and
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`Computer Science for UC Irvine, June 1996.
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`• KMeD as a feature article on Cutting Edge Technology related to content-based
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`medical image retrieval in the Los Angeles Times, Business Section, August 4,
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`1997.
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`• National Science Foundation research proposal review panel member, 1998-
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`
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`2008.
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`17.
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`I have provided the following professional services:
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`• ACM SIGCOMM chairman from 1973 to 1976.
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`• Associate editor for IEEE Transactions on Computers for Computer Networking
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`and Distributed Processing System (1978 to 1982) and received a meritorious
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`award for his service to IEEE.
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`• Workshop co-chair of the IEEE First International Workshop on Systems
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`Management (1993) and received a Certificate of Appreciation award for his
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`service.
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`• Technical program chairs for SIGCOMM (1975), VLDB (1986), Information
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`Knowledge Sharing (2003), and ER (2004), general conference chair of ER
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`(1997). Technical program chair (knowledge management track) of the 2009
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`International conference on information and knowledge management (CIKM09).
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`• Guest editor and associate editor for several journals related to intelligent
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`information systems.
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`18.
`
`I served as an expert witness in the following matters:
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`• 2009 – 2012
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`U.S. Department of Justice, Case name: FedEx Corporation v. United States,
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`case number: 2:08-cv-02423, filed in the U.S. District Court for the Western
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`District of Tennessee.
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`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`I was retained by the U.S. Government to evaluate the software projects by U.S.
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`corporations to determine if they qualified for research credits under the legal
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`standards of Internal Revenue Code (I.R.C.) section 41(d).
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`Services included:
`o Review information on the software products and prepare report in detail
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`opine on whether, as a matter of computer science, each project met the
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`requirement of the statute and regulations.
`o Review the reports of the plaintiff's experts and identify any issues with
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`their analysis, methodology and/or conclusions.
`o Write expert witness report.
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`Prepare to testify at deposition.
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`The case was settled before trail.
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`• 2012—2014
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`Microsoft Corp and Google Inc. v. GeoTag Inc. (D. Del, Case No 11-cv-175).
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`Defended Microsoft Corp. and Google against GeoTag Inc.
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`Provided expert opinion that U.S. Patent No. 5,930,474 (J.A. 89-133) is invalid as
`
`well as GeoTag's counterclaims that alleged that Google infringed the '474
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`patent. See Microsoft Corp. v. GeoTag, Inc., No. 11-175-RGA, 2014 WL
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`4312167 (D.Del. Aug. 29, 2014.
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`I was deposed by GeoTag attorney and defended Google and Microsoft based
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`on my published research work on Co-Base and Co-GIS resulting in the non-
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`infringement of the ‘474 patent.
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`• 2013
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`Oracle Corporation v. Parent of Clouding; Case IPR 2013-00073 (JL), Patent
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`
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`6,738,799.
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`Participated in Inter Partes Review.
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`Expert consultant for Clouding in patent litigation. Tasks included analysis,
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`conclusion, and preparation report of declaration.
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`• 2014-2015
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`GeoTag Inc. v. Classified Ventures LLC, U.S. District Court for Northern District
`
`of Illinois, cv-00633.
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`Expert consultant for Apple Inc. in patent litigation.
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`Based on our research on Natural Language Processing, the case was settled
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`without going to trial.
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`III.
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`LEVEL OF ORDINARY SKILL IN THE ART AND RELEVANT LEGAL
`STANDARDS
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`19.
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`I understand that the level of ordinary skill may be reflected by the prior art of
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`record, and that a person having ordinary skill in the art (“PHOSITA”) to which the
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`claimed subject matter pertains would have had the capability of understanding the
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`scientific and engineering principles applicable to the pertinent art. I understand that
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`one of ordinary skill in the art has ordinary creativity, but is not an automaton.
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`20.
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`I understand there are multiple factors relevant to determining the level of
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`ordinary skill in the pertinent art, including: (1) the levels of education and experience of
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`persons working in the field at the time of the invention; (2) the sophistication of the
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`technology; (3) the types of problems encountered in the field; and (4) the prior art
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`solutions to those problems.
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`Declaration of Wesley W. Chu, Ph.D.
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`I am familiar with all the subject matter of Exhibit 1001, the ’423 Patent. I am
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`21.
`
`also aware of the state of the art at the time the application resulting in the ’423 Patent
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`was filed. I have been informed that while, based on filing applications with the U.S.
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`Patent Office, the priority date for the ’423 Patent may be as early as February 25,
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`2000, in fact, the inventions disclosed in the ’423 Patent were conceived at least as
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`early as mid-May 1999. I have reviewed the inventor’s declaration (Exhibit 2003,
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`Declaration of Dr. Joseph L. De Bellis) on this subject, and believe the facts stated in
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`the Declaration do support mid-May 1999 as the date of conception of the claimed
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`inventions. Based on the inventions disclosed in the ’423 Patent, and my experience
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`with software engineers at that time, I believe that a PHOSITA would have been
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`someone who had, at the conception date, at least a bachelor’s degree in Computer
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`Science or an equivalent field (or equivalent industry experience) and at least one year
`
`of experience designing, implementing, and using database management systems. I
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`believe that I possessed at least such experience and knowledge at the mid-May 1999
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`conception date of the ’423 Patent, and that I am qualified to opine on the ’423 Patent.
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`22.
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`For purposes of this Declaration, in general, and unless otherwise noted, my
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`statements and opinions, such as
`
`those regarding my experience and
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`the
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`understanding of a PHOSITA generally (and specifically related to the references I
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`consulted herein), reflect the knowledge that existed in the field before the priority date
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`of the ’423 Patent.
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`23.
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`I have been asked to provide my opinions regarding whether claims 1-9 and 13
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`of the ’423 Patent would have been nonobvious to a PHOSITA at the time of invention,
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`in light of the prior art.
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`I am not an attorney. In preparing and expressing my opinions and considering
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`24.
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`the subject matter of the ’423 Patent, I relied on certain legal principles that counsel has
`
`explained to me.
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`25.
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`I have been informed and understand that under 35 U.S.C. § 103, a patent may
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`be invalid for obviousness if the differences between the subject matter sought to be
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`patented and the prior art are such that the subject matter as a whole would have been
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`obvious, at the time the invention was made, to a person having ordinary skill in the art
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`to which said subject matter pertains. I understand that although it is well settled that
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`the ultimate determination of obviousness is a question of law, it is also well understood
`
`that there are factual issues underlying the ultimate obviousness decision. I understand
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`that the obviousness analysis is based on four underlying factual inquiries:  (1) the
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`scope and content of the prior art;  (2) the differences between the claims and the prior
`
`art;  (3) the level of ordinary skill in the pertinent art;  and (4) secondary considerations,
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`if any, of nonobviousness.
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`26.
`
`I understand that because inventions often involve a combination of known
`
`elements that in hindsight seems preordained, to prevent hindsight invalidation of patent
`
`claims, the law requires some “teaching, suggestion or motivation” to combine cited
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`references. I understand that motivation to combine references may be found in the
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`cited references themselves, in the knowledge of a PHOSITA at the time of invention,
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`and in the nature of the problem to be solved.
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`27.
`
`I understand that the Supreme Court has recognized other rationales for
`
`combining references or modifying a reference to show obviousness of claimed subject
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`matter. Some of these other rationales are: (a) combining prior art elements according
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`to known methods to yield predictable results; (b) simple substitution of one known
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`element for another to obtain predictable results; (c) use of a known technique to
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`improve a similar device (method, or product) in the same way; (d) applying a known
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`technique to a known device (method, or product) ready for improvement to yield
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`predictable results; (e) choosing from a finite number of identified, predictable solutions,
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`with a reasonable expectation of success.
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`28.
`
`I understand that obviousness does not require physical combination/bodily
`
`incorporation, but rather consideration of what the combined teachings would have
`
`suggested to a PHOSITA at the time of the invention.
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`29.
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`I further understand that an asserted motivation to combine references can be
`
`overcome based on a showing that those references together “teach away” from their
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`combination. I understand that if the references taken in combination would produce a
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`“seemingly inoperable device,” such references teach away from the combination and
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`thus cannot serve as a basis for obviousness.
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`30.
`
`I understand that within the framework of an obviousness analysis, it is
`
`impermissible to pick and choose from any one reference only so much of it as will
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`support a given position to the exclusion of other parts necessary to the full appreciation
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`of what such reference fairly would have suggested to a PHOSITA. Thus, a reference
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`must be considered in its entirety, including those portions of the reference that argue
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`against obviousness.
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`IV.
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`31.
`
`U.S. PATENT 7,302,423 (THE ’423 PATENT), EXHIBIT 1001
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`The following discusses aspects of the ’423 Patent and its prosecution history
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`that are relevant to the claims subject to the Petition.
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`A.
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`Specification and Prosecution History
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`1.
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`Specification
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`32.
`
`The ’423 Patent, Exhibit 1001, discloses a dynamic search engine and
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`corresponding dynamic search methods. The search engine may be applied to
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`databases for which prior knowledge of database schemas is not available to the search
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`engine. That is, the search engine determines the database schema. See Exhibit
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`1001, ’423 Patent, 6:32 - 33; 7:3 - 5.
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`33.
`
`In response to a query, the search engine returns search results. In an
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`embodiment, the search results may be returned in a tabular form that consists of a
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`column with multiple rows. Id., Figure 4. Each search result may be termed an “entry”
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`in the column. Id., 7:19 - 33. An entry may consist of text composed of a number of
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`characters (for example, numbers, numerals, symbols, spaces and icons). See, e.g.,
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`id., Fig. 30; 17:14 - 15. Thus, entries are not limited to text.
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`34.
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`The search engine may return so many entries that the search results cannot be
`
`displayed within the limited real estate of a display screen or on a single page. To
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`contend with such a possibility, the search engine may perform operations on the
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`returned search results. One such operation involves truncation. The specification
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`provides numerous examples of truncation in the embodiments. See id., 7:19 - 16:40
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`and Figures 4, 10 – 16, 18 – 24, 27 – 38, 40 -49, and 52.
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`35. One example of truncation involves determining a number of characters in each
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`entry in a database field, and if, for a specific entry, the number of characters exceeds a
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`specified limit, deleting a character from the entry. The process of determining and
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`deleting executes in an iterative fashion until all entries may be represented on the
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`display screen or page. See id.
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`36.
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`The following drawing (Figure 11) from the ’423 Patent shows truncation by
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`determining a number of characters in each entry in a database field.
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`37.
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`The list of available data fields shows categories by which a search for books
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`may be narrowed. One available data field is “Titles,” which, as can be seen, was
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`selected by the user. A search for books by title produces so many results that the titles
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`are truncated so that only the first character (1 – 9 and A – Z) of the title is displayed.
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`This first interim result list is generated by successive, or iterative truncation, as
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`disclosed for example in Exhibit 1001, ’423 Patent, 8:22 – 9:6. An example of the actual
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`truncation process used to generate the interim result lists of Figure 11 is provided in
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`Exhibit 1001, ’423 Patent, at 12:33 – 65. Figure 11 shows three sequential interim
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`result lists. Using the interim result lists, the user selects, in sequence, “C,” “Ce,” and
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`finally, “Cells.” “Cells” is in the last sequential interim result list. Thus, each of the three
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`sequential interim result lists produce entries that may be searched further – that is, for
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`example, entry “Ce,” which is a truncation of titles that start with words having the first
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`characters “Ce” (e.g., “Cells”) can be further searched to produce the column I have
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`labeled as interim result list (actually the last sequential interim result list). As can be
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`seen in Figure 11, the user selects “Cells” in the interim result list, and a final search
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`result is displayed with the full titles of each of three books that are available from the
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`Web site.
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`38.
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`The above description and Figure 11 itself show truncation by determining a
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`number of characters in a data field entry and then iteratively reducing the number of
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`characters until a displayable result list is produced. Note the entry “Cell an” in the
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`column I labeled interim result list. The entry “Cell an” consists of seven characters and
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`conveys much information to a user. For example, the user knows there is a book with
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`the title “Cell an****,” where the asterisks mean additional characters have been
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`removed from the title. A user might presume the “an” is a truncation of “and.”
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`2.
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`Prosecution History
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`39. Claims 1 - 9 and 13 were examined extensively by the Office including with
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`respect to Maloney. See Exhibit 1002, patent application 09/935,565 file history. In a
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`September 4, 2007 response to an office action, claim 3 was amended to incorporate
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`limitations recited in a dependent claim that the patent examiner found allowable over
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`the combination of Maloney and Chew et al., U.S. Patent 6,593,849. In particular, claim
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`3 was amended to recite the iterative truncation steps now present in claim 3, as shown
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`below in paragraph 41. The office action stated claim 1 was allowable as examined,
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`and no amendments were made to claim 1. Exhibit 1002, pgs. 27 – 37.
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`40. Claim 1 as recited in the September 4, 2007 Response reads:
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`A computer-implemented method for displaying data comprising:
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`determining a database schema for a database;
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`providing a list of database fields, wherein the list includes a
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`descriptor indicating a data category;
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`receiving a search selection for a database field on the provided list
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`of database fields;
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`determining a number of characters included in each entry in the
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`selected database field; and
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`if the number of characters included in each entry exceeds a
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`specified amount of characters, displaying a portion of each entry in the
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`selected database field, wherein a number of characters displayed in each
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`portion is less than or equal to the specified amount of characters; and
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`if the number of characters included in each entry does not exceed
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`the specified amount, displaying each entry in its entirety.
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`See id.; see also Exhibit 1001, ’423 Patent, claim 1.
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`In the Decision, pages 16-19, the PTAB concluded that the last two limitations of claim 1
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`are conditional and mutually exclusive and that only one of the two limitations needs to
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`be considered to show invalidity. In my opinion, a PHOSITA reading claim 1 would
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`understand that the claim is directed to displaying data in all of a number of entries.
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`Since claim 1 is directed to displaying data in all of a number of entries, a PHOSITA
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`would have understood that the method necessarily encompassed determining a
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`number of characters in every entry. When the number of characters in every entry is
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`determined, some entries will have a number of characters exceeding a character limit
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`and other entries will have a number of character equal to or less than the limit. Hence,
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`a PHOSITA would have understood that the logical and correct interpretation of claim 1
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`is that both of claim 1’s last two limitations must be executed and the PTAB’s conclusion
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`that the last two limitations are conditional and mutually exclusive would lead to a claim
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`that does not meet the intent “to display data.”
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`41. Claim 3 as recited in the September 4, 2007 Response reads:
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`A computer-implemented method
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`for
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`formatting data
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`for display,
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`comprising:
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`generating a list of data fields;
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`receiving a first data field selection from the list of data fields;
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`determining a first quantity indicative of a number of characters in
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`each entry of the selected data field;
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`if the first quantity exceeds a specified limit, reducing a
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`number of characters to be displayed for each entry from the selected
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`data field, comprising:
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`performing a
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`truncation
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`that reduces
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`the number of
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`characters to be displayed from the selected data filed [sic],
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`comparing the reduced number of characters to the specified limit, and
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`if the reduced n