UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE, INC.,
`Petitioners,
`
`v.
`
`UNILOC LUXEMBOURG S.A.,
`Patent Owner.
`
`
`IPR2158-00361
`U.S. PATENT NO. 6,216,158
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`
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`DECLARATION OF WILLIAM C EASTTOM II
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`TABLE OF CONTENTS
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`I.
`
`INTRODUCTION ....................................................................................... 1
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`II.
`
`BACKGROUND AND QUALIFICATIONS .............................................. 2
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`III. LEGAL STANARDS USED IN MY ANALYSIS ....................................... 2
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`A. Obviousness ............................................................................................ 2
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`B. Priority Date ........................................................................................... 4
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`C. Person of Ordinary Skill in the Art.......................................................... 4
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`D. Broadest Reasonable Interpretation ......................................................... 5
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`IV. OVERVIEW OF THE ‘158 PATENT ......................................................... 5
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`V.
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`CLAIM CONSTRUCTION ......................................................................... 6
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`A. palm sized computer ............................................................................... 6
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`B. means for accessing a description of a service” ....................................... 7
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`C. means for downloading the program code ............................................... 7
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`D. means for executing at least a portion of the program code ..................... 7
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`E. means for sending control commands to the service in response to the
`means for executing ................................................................................ 7
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`VI. GENERAL ISSUES .................................................................................... 8
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`A. Jini: Quick Study, COMPUTERWORLD (“Jini-QS”) ............................ 8
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`B. McCandless ............................................................................................ 9
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`C. Motivation to Combine ..........................................................................11
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`VII. GROUND 1 SPECIFIC CLAIMS ...............................................................12
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`

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`A. Claim 1 “accessing a description of the service from a directory of
`services, the description of the service including at least a reference to
`program code for controlling the service” ..............................................12
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`B. Claim 1 “downloading the program code to the palm sized computer” ..14
`
`C. Claim 1 “sending control commands to the service from the palm sized
`computer in response to the executing” ..................................................15
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`D. Claim 8 “A method of controlling a program on a network device from a
`palm sized computer, the computer is not capable of executing the
`program by itself, the network device and computer being coupled in
`communications via a network, the method comprising” .......................16
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`E. Claim 8 “loading the program code” ......................................................18
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`F. Claim 9 “The method of claim 8, wherein loading the program code
`includes loading the program code onto the palm sized computer and the
`issuing the control commands includes the palm sized computer issuing
`the control commands” ..........................................................................18
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`G. Claim 12 “The method of claim 8 wherein loading the program code
`includes loading the program code onto the palm sized computer from
`the directory of services” .......................................................................19
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`H. Claim 20 “means for downloading the program code” ...........................20
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`VIII. GROUND 2 ................................................................................................20
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`A. A method of controlling a service on a network using a palm sized
`computer, the palm sized computer being coupled in communications
`with the network, the method comprising ..............................................23
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`B. accessing a description of the service from a directory of services, the
`description of the service including ........................................................26
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`IX. CONCLUSIONS ........................................................................................27
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`EASTTOM CV .....................................................................................................29
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`A. Education ...............................................................................................29
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`1. University Degrees ........................................................................... 29
`2. Industry Certifications ...................................................................... 30
`3. Hardware and Networking Related Certifications ............................. 30
`4. Operating System Related Certifications........................................... 30
`5. Programming and Web Development Related Certifications ............ 31
`6. Database Related Certifications ........................................................ 31
`7. Security and Forensics Related Certifications ................................... 31
`8. Software Certifications ..................................................................... 32
`9. Licenses ............................................................................................ 32
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`B. Publications ...........................................................................................32
`1. Books 32
`2. Papers, presentations, & articles........................................................ 34
`3. Patents .............................................................................................. 37
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`C. Standards and Certification Creation ......................................................38
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`D. Professional Awards and Memberships .................................................39
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`E. Speaking Engagements ..........................................................................40
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`F. Litigation Support Experience ...............................................................44
`1. Testifying Experience ....................................................................... 51
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`G. Professional Experience .........................................................................54
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`H. Continuing Professional Education ........................................................58
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`I. References to my work ..........................................................................59
`1. Media References ............................................................................. 60
`2. References to publications ................................................................ 61
`3. Universities using my books ............................................................. 68
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`J. Training .................................................................................................70
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`K. Technical Skills .....................................................................................72
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`I, Chuck Easttom, hereby declare as follows:
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`I.
`
`INTRODUCTION
`1. My name is William Charles Easttom II (Chuck Easttom) and I
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`have been retained by Uniloc Luxembourg S.A. (“Uniloc” or the “Patent
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`Owner”) to provide my expert opinions regarding U.S. Patent No. 6,216,158
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`(the ‘158 Patent). In particular, I have been asked to opine on whether a person
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`of ordinary skill in the art (POSITA) at the time the inventions described in
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`the ‘158 patent were conceived would have found all claims, claims 1-2, 6-9,
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`12, 14-15, and 20 (“Challenged Claims”) as unpatentable in light of the cited
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`references and arguments in IPR2158-00361.
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`2.
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`Based on my review of the Petition and its exhibits, and my
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`understanding of the relevant requirements of patent law, and my decades of
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`experience in the field of computer science including communications
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`systems, it is my opinion that the Challenged Claims would not have been
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`obvious in light of the proposed combinations.
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`3.
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`I am being compensated for my time at my standard consulting
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`rate of $300 per hour. I am also being reimbursed for expenses that I incur
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`during the course of this work. Apart from that, I have no financial interest in
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`Uniloc. My compensation is not contingent upon the results of my study or
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`the substance of my opinions.
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`

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`II. BACKGROUND AND QUALIFICATIONS
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`4.
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`In my over 25 years of computer industry experience I have had
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`extensive experience in communications systems, including data networks in
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`general that have messaging capabilities. I hold 42 industry certifications,
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`which include (among others) networking certifications. I have authored 26
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`computer science books, several of which deal with networking topics. I am
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`also the sole named inventor on thirteen patents.
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`5.
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`I also have extensive experience with Java and remote
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`programming with Java. Of my 26 published books, 2 are Java books and one
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`of those is about Enterprise Java Beans, a means for accessing remote
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`programming code via Java.
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`6.
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`A more detailed description of my professional qualifications,
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`including a list of publications, teaching, and professional activities, is
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`contained in my curriculum vitae, a copy of which is attached hereto as
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`Exhibit A.
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`III. LEGAL STANARDS USED IN MY ANALYSIS
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`7.
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`Although I am not an attorney and I do not offer any legal
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`opinions in this proceeding, I have been informed of and relied on certain legal
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`principles in reaching the opinions set forth in this Declaration.
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`A.
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`8.
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`Obviousness
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`I understand that a patent claim is invalid if the differences
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`between the subject matter and the prior art are such that the subject matter as
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`

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`a whole would have been obvious to a POSITA at the time of the alleged
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`invention. I further understand that an obviousness analysis involves a review
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`of the scope and content of the asserted prior art, the differences between the
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`prior art and the claims at issue, the level of ordinary skill in the pertinent art,
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`and objective indicia of non-obviousness such as long-felt need, industry
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`praise for the invention, and skepticism of others in the field.
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`9.
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`I have been informed that if a single limitation of a claim is
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`absent from the cited prior art, the claim cannot be considered obvious.
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`10.
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`I have further been informed that it is improper to combine
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`references where the references teach away from a proposed combination; and
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`that the following factors are among those relevant in considering whether
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`prior art teaches away:
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`• whether a POSITA, upon reading the reference would be led in a
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`direction divergent from the path that was taken by the applicant;
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`• whether the prior art criticizes, discredits, or otherwise discourages
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`investigation into the claimed invention;
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`• whether a proposed combination would produce an inoperative
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`result; and
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`• whether a proposed combination or modification would render the
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`teachings of a reference unsatisfactory for its intended purpose.
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`11.
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`In addition, I have been informed that a proposed combination
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`that changes the basic principles under which the prior art was designed to
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`operate may fail to support a conclusion of obviousness.
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`

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`B.
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`Priority Date
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`12. The 6,622,158 patent issued on Apr. 10, 2001 and the application
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`was filed on Jan.25, 1999. For purposes of this declaration, I have assumed
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`the priority date for the ‘158 patent is Jan.25, 1999.
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`C.
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`Person of Ordinary Skill in the Art
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`13.
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`I understand that a POSITA is a hypothetical person who is
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`presumed to have ordinary skill in the art as of the priority date. I understand
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`that factors that may be considered in determining the level of ordinary skill
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`in the art may include: (a) the type of problems encountered in the art; (b)
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`prior art solutions to those problems; (c) the rapidity with which innovations
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`are made; (d) the sophistication of the technology; and (e) the educational
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`level of active workers in the field.
`14.
`I have been asked to provide my opinion as to the qualifications
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`of the person of ordinary skill in the art to which the ‘158 patent pertains as
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`of April 24, 2000. I understand that Dr. Houh opines that a person of ordinary
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`skill in the art “B.S. degree in Electrical Engineering, Computer Engineering,
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`or Computer Science, or equivalent training, as well as at least three years of
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`technical experience in the field of computer networking.” I agree with Dr.
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`Houh’s opinion of a POSA, except that I would add that more experience
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`could compensate for less education and vice versa. For example, one with a
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`

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`master’s degree might only need 1 to 2 years’ experience, or a person with no
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`degree but over 5 years’ experience in networking would qualify as a POSA.
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`15. Although my qualifications and experience exceed those of the
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`hypothetical person having ordinary skill in the art defined above, my analysis
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`and opinions regarding the ‘158 Patent have been based on the perspective of
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`a person of ordinary skill in the art as of April 10, 2001.
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`D. Broadest Reasonable Interpretation
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`16.
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`I have been informed that, for purposes of this Inter Partes
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`Review (IPR), the terms in the claims of the ‘158 patent are to be given their
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`Broadest Reasonable Interpretation (BRI) in light of the specification and
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`prosecution history of ‘158 Patent as understood by a POSITA on the priority
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`date. I have used this standard throughout my analysis.
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`IV. OVERVIEW OF THE ‘158 PATENT
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`17. The ’158 patent is titled “System and method using a palm sized
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`computer to control network devices.” The ʼ158 patent issued April 10, 2001,
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`from U.S. Patent Application No. 09/237,609 filed January 25, 1999 and
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`originally assigned to 3Com Corporation (3Com).
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`18. The inventors of the ’158 patent observed that at the time,
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`relative to desktop and laptop computers, palm sized computers had limited
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`processing, display and input capabilities. These limitations prevented palm
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`sized computers from running the same applications as desktop or laptop
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`computers. The portability of palm sized computers made the ability to run
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`desktop applications advantageous.
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`19. According to the invention of the ’158 Patent, a program on the
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`palm sized computer is used to access a registry of network services. This
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`registry includes descriptions for various services. Each description includes
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`at least a reference to program code that can be downloaded to the palm sized
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`computer. Executing this program causes the palm sized computer to issue
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`commands directly to the specific network services needed. In some cases,
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`these network services include application services for running desktop
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`applications that the palm sized computer could not execute.
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`V. CLAIM CONSTRUCTION
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`20.
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`I have been asked to provide my opinions regarding the
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`construction of certain terms used in the claims of the ‘158 Patent as would
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`be understood by a POSITA using the BRI.
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`A.
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`palm sized computer
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`21. The petitioner has suggested the following definition: “For the
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`purposes of this proceeding, it is sufficient to specify that a personal digital
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`assistant (PDA) and a 3Com Palm Platform™ computer are examples of a
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`“palm sized computer” in the context of the ’158 Patent.’” It appears the
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`petitioner has offered examples of what a palm sized computer is but has not
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`offered a definition. It is my opinion that this term does not require definition.
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`

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`B. means for accessing a description of a service”
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`22. The petitioner has suggested the following definition: “a palm-
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`sized computer executing the Jini middleware from Sun Microsystems, and
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`equivalents thereof.”
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`23.
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`I disagree. I see nothing in the patent that would limit this claim
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`element to the specific Jini middleware.
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`C. means for downloading the program code
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`24. The petitioner has suggested the following definition: “a palm-
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`sized computer executing the Jini middleware from Sun Microsystems, and
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`equivalents thereof”
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`25.
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`I disagree. I see nothing in the patent that would limit this claim
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`element to the Jini middleware. Furthermore, the petitioners definition does
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`not actually address the ‘downloading’ portion of the claim limitation.
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`D. means for executing at least a portion of the program code
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`26. The petitioner has suggested the following definition: “a palm-
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`sized computer executing a Java Virtual Machine, and equivalents thereof.”
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`27.
`
`I disagree, I see nothing in the patent that would limit this claim
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`element to the Java Virtual Machine.
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`E. means for sending control commands to the service in
`response to the means for executing
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`

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`28. The petitioner has suggested the following definition “a palm-
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`sized computer executing a control protocol capable of issuing control
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`commands or Java’s Remote Method Invocation (RMI) protocol, and
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`equivalents thereof.”
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`29.
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`I disagree, I see nothing in the patent that would limit this claim
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`element to the Java RMI protocol.
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`VI. GENERAL ISSUES
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`30.
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`In reviewing the petition for inter partes review, and the attached
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`exhibits and declarations, several issues stood out as pervasive to the petition
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`and need to be addressed separate from the specific claims. Those issues are
`
`addressed here.
`A.
`Jini: Quick Study, COMPUTERWORLD (“Jini-QS”)
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`31.
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`In Ground 1, in every single instance, the petitioner relies on
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`some combination of the “Jini-QS”. This is inappropriate for several reasons.
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`32. The first being that my understanding while non-enabling prior
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`art may qualify under Section 103, that non-enabling reference only qualifies
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`as prior art for what is disclosed in it. However, “Jini-QS” is a marketing
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`article in a general-purpose magazine. It does not provide any detail on how
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`the elements in the article would actually be done.
`33. Furthermore, the article itself admits that the product it describes
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`is not yet complete “It will be available in the second half of next year. Jini's
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`goal is to enable the creation of simpler, more flexible networks.” A POSA
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`would readily understand that it is quite common for technology to not unfold
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`according to plan. Frequently promised technology either is not completed in
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`time, or does not have all the expected functionality.
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`34. The ComputerWorld article does not constitute prior art. Instead
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`it is a marketing piece describing technology that the author hopes will be
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`available “in the second half of next year.”
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`35. The ComputerWorld article cannot be prior art. It was allegedly
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`published in December of 1998, and the article itself says this technology may
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`be available in the “second half of next year”, which would be at least June of
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`1999. The application for the ‘158 patent was filed on January 25, 1999. Even
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`if one ignores the fact that this article does not describe how to accomplish its
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`goals in sufficient detail, and then ignores the fact that technology often fails
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`to meet expectations, then further assumes that every item in the article is
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`exactly what the petitioner claims it is, and it was all fully functional when the
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`article said it would be, that would still be at least six months after the ‘158
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`patent was filed. This article cannot be considered prior art.
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`B. McCandless
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`36. The
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`petitioner
`
`appears
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`to
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`completely misunderstand
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`McCandless. The section the petitioner cites is from a section "In the pipeline"
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`

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`which discusses various improvements to PDA's that the author believes will
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`come at some point in the future. The author is not describing what PDA’s
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`can do at the time of the writing, or even what is in the immediate future, but
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`rather a wish list for what may eventually happen.
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`37. Citations throughout this section of McCandless demonstrate this
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`(emphasis added) “PDA's will soon come with built-in access to a ubiquitous
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`wireless network". In the paragraph just preceding the one the petitioner cites
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`(emphasis added) "Using this network your PDA will eventually subsume
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`functionality of the remote controls in your home". Then in the paragraph
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`immediately after the one that the petitioner cites (emphasis added) "In due
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`time, your PDA will absorb the other things you now feel compelled to carry
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`in your pockets". Taken in context, a POSA would immediately see that
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`McCandless is not discussing what was available at the time of the writing,
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`but rather things the author hoped would eventually be added to PDA’s.
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`38. Reading all of McCandless it would be a clear to a POSA that
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`the article is not describing any technology that existed at the time of the
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`writing of the article. Rather, the article is the authors speculation about future
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`improvements to PDA’s that he believes may happen someday. It is therefore
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`impossible for a POSA to combine McCandless with any other prior art.
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`

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`C. Motivation to Combine
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`39. The preceding section leads naturally to a dissection of the
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`alleged the motivation to combine. On paragraph 37 of Dr. Houh’s declaration
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`he states “ (f) 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
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`combine prior art reference.” On this issue I am in complete agreement with
`
`Dr. Houh.
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`40. However, throughout Dr. Houh’s declaration, not once does he
`
`explain any motivation to combine. He continually recites “it is my opinion
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`that one of ordinary skill in the art would have been motivated to combine..”
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`but never provides any reason at all why a POSA would be motivated to
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`combine.
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`41. Beyond that issue, since the Jini-QS article a) did not fully
`
`describe how to implement its technology and b) described technology it
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`admitted did not yet exist, it would have been impossible to combine Jini-QS
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`with anything. Jini-QS did not yet exist. There was simply an article that
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`hoped it would be ready “in the second half of next year”, at least six months
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`after the application for the ‘158 patent was filed.
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`

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`VII. GROUND 1 SPECIFIC CLAIMS
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`42.
`
`I have reviewed the claims in light of the proposed combinations
`
`and believe they do not disclose the claimed features.
`A. Claim 1 “accessing a description of the service from a
`directory of services, the description of the service including at
`least a reference to program code for controlling the service”
`
`43. The petitioner states:
`
`“Jini-QS discloses this limitation because it teaches that the Jini
`platform includes a Lookup Service that keeps track of which
`services are available on the network – i.e., “Lookup is the
`equivalent of a network bulletin board for all available services.”
`APPL-1005, p. 29 (left column). Jini-QS illustrates the Lookup
`Service:”
`and
`“Jini-QS further teaches that the user requests (accesses)
`descriptions of the available services via the Lookup Service and
`in response is shown descriptive icons corresponding to the
`services: “[t]he user requests services that are available, and
`icons appear on his screen.” APPL-1005, p. 29 (main figure).
`“Lookup stores pointers to various sources on the network as
`well as code for other services,” and when a user selects a service
`from the list of services, the Lookup “server instantly sends
`proxy code back to the device.” Id. at p. 29(left column; main
`figure).”
`44. Aside from the previously discussed fact that Jini-QS is not prior
`
`art, and in fact did not actually exist, but rather there was an article discussing
`
`what it might do “in the second half of next year”, nothing in Jini-QS teaches
`
`or even suggests “at least a reference to program code for controlling the
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`service”
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`

`

`45. The petitioner appears to claim that the proxy code referenced by
`
`Jini-QS is a “reference to program code”. However, what Jini-QS actually
`
`states is:
`
`Proxy: This is the piece of Java code that moves around from device to
`device acting as the front end for all the Jini-enabled or legacy systems.
`The proxy essentially tells the client how to use the device. For
`example, it may include a graphical user interface that shows the user
`how to work the network projector. In the PC world, the equivalent
`would be the device driver.
`
`
`46. This proxy is first shared code for all the Jini-enabled or legacy
`
`systems. It has information about how the client could use the device, but does
`
`not include “a reference to program code for controlling the service”
`
`47. The petitioner further claims:
`
`Thus, Jini-QS’s teaching registering a new device in the Lookup
`Service and advertising its services by storing a descriptive name or
`icon associated with the service and a pointer to the service’s associated
`proxy code, in view of Arnold’s teaching of registering services with
`the lookup service, which stores in the lookup service an object
`corresponding to the service that facilitates access to the service, render
`obvious the claimed: “registering the service in the directory of services
`by storing the description of the service in the directory of services.”
`
`
`48. Aside from the fact that Jini-QS was merely a description of
`
`technology that might exist “in the second half of next year” and therefore
`
`could not anticipate anything, nor be combined with anything, there are other
`
`errors in the petitioners claim.
`
`

`

`49. The petitioner even states that Jini-QS stored “a descripted name
`
`or icon associated with the service’ and the petitioner does not claim that this
`
`in and of itself is a “a reference to program code for controlling the service”.
`
`Arnold describes in claim 1 “initiating a communications link between a
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`browser stored on a client and a server; receiving selection of a service
`
`identifier from a set of service identifiers; receiving Downloadable code
`
`corresponding to the selected service identifier from the server;”
`
`50. Arnold was not about finding services on a network one could
`
`control, but rather going through a web page, using the client browser, to find
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`out what services a web server offered. Nothing in Arnold teaches, or even
`
`suggests controlling a network device.
`
`B. Claim 1 “downloading the program code to the palm sized
`computer”
`
`51. The petitioner equates the proxy code of Jini-QS with program
`
`code. In the early 2000’s I published a book about Enterprise Java Beans, a
`
`common way of accessing remote programming code in Java. I have a detailed
`
`understanding of remote programming code used in Java. As any POSA
`
`would understand, proxy code is what one uses instead of program code.
`
`Rather than download the actual program code, one downloads a proxy that
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`

`

`allows one to route commands to the actual program code that is remote1. The
`
`following excerpt demonstrates this:
`
`
`
`MSDN https://msdn.microsoft.com/en-us/library/ee809525.aspx
`
`52. As the preceding excerpt describes, when using proxy code, the
`
`programmer is making calls to code that is running on a remote server. This
`
`requires some technical steps to be taken such as serializing and de-serializing
`
`information. More importantly, the code being executed is remote. That code
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`is not on the client.
`
`53. Proxy code is a completely different approach than downloading
`
`the program code. Proxy code is used when, for whatever reason,
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`downloading the program code is infeasible or undesirable.
`
`C. Claim 1 “sending control commands to the service from the
`palm sized computer in response to the executing”
`
`54. The petitioner states “Jini-QS in view of Arnold render obvious
`
`this limitation. First, Jini-QS teaches that in response to and during execution
`
`of the proxy code, a user’s input to the graphical user interface results in
`
`
`1 https://docs.oracle.com/javase/7/docs/technotes/guides/net/proxies.html
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`

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`sending control commands/instructions to the service in order to control the
`
`service: “The proxy essentially tells the client how to use the device. For
`
`example, it may include a graphical user interface[.]” APPL-1005, p. 29 (left
`
`column). Jini-QS further teaches that a service will receive a command or
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`“instruction via that proxy code[.]” Id. at p. 29 (main figure). In the example
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`described in association with item 3 in the main figure, the client controls a
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`print service by issuing a “printing instruction.” APPL-1005, p. 29 (main
`
`figure).”
`
`55. Aside from the fact that Jini-QS was merely a description of
`
`technology that might exist “in the second half of next year” and therefore
`
`could not anticipate anything, nor be combined with anything, there are other
`
`errors in the petitioners claim.
`
`56. The petitioner misunderstands both Jini-QS and the ‘158 patent.
`
`As the petitioner sites, Jini-QS “The proxy essentially tells the client how to
`
`use the device”, however using a device is not the same thing as controlling
`
`the device. The Jini-QS system merely sends information. And as has been
`
`previously discussed, there is no executing program code. This claim
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`limitation is ‘in response to the executing’.
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`D. Claim 8 “A method of controlling a program on a network
`device from a palm sized computer, the computer is not capable of
`executing the program by itself, the network device and computer
`
`

`

`being coupled in communications via a network, the method
`comprising”
`
`57. Aside from the fact that Jini-QS was merely a description of
`
`technology that might exist “in the second half of next year” and therefore
`
`could not anticipate anything, nor be combined with anything, there are other
`
`errors in the petitioners claim.
`
`58. The petitioner claims “Jini-QS in view of Arnold and
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`McCandless render obvious this limitation.” It is immediately obvious that
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`neither Jini-QS nor Anderson ever discuss (emphasis added) “controlling a
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`program on a network device from a palm sized computer, the computer is
`
`not capable of executing the program by itself”
`
`59. The petitioner points to McCandless:
`
`The network relaxes where and how computation occurs. For
`example, applications that are too compute- or space intensive to
`run directly on your PDA will run, instead, on a remote high
`performance computer, but then return the output of the
`computation. When new versions of applications are released,
`your PDA will automatically update.
`
`
`60. The
`
`petitioner
`
`appears
`
`to
`
`completely misunderstand
`
`McCandless. The section the petitioner cites is from a section "In the pipeline"
`
`which discusses various improvements to PDA's that the author believes will
`
`come at some point in the future. The author is not describing what PDA’s
`
`

`

`can do at the time of the writing, or even what is in the immediate future, but
`
`rather a wish list for what may eventually happen.
`
`61. Citations throughout this section of McCandless demonstrate this
`
`(emphasis added) “PDA's will soon come with built-in access to a ubiquitous
`
`wireless network". In the paragraph just preceding the one the petitioner cites
`
`(emphasis added) "Using this network your PDA will eventually subsume
`
`functionality of the remote controls in your home". Then in the paragraph
`
`immediately after the one that the petitioner cites (emphasis added) "In due
`
`time, your PDA will absorb the other things you now feel compelled to carry
`
`in your pockets". Taken in context, a POSA would immediately see that
`
`McCandless is not discussing what was available at the time of the writing,
`
`but rather things the author hoped would eventually be added to PDA’s.
`
`E. Claim 8 “loading the program code”
`
`62. The petitioner again conflates proxy code with program code. As
`
`described previously in this declaration in reference to claim 1, proxy code is
`
`used specifically because, for some reason, program code is either impractical
`
`or undesirable.
`
`F. Claim 9 “The method of claim 8, wherein loading the
`program code includes loading the program code onto the palm
`
`

`

`sized computer and the issuing the control commands includes the
`palm sized computer issuing the control commands”
`
`63. The petitioner states “As discussed in association with [8.2] and
`
`[8.3], Jini-QS and Arnold teach a Jini client, such as a PalmPilot, downloading
`
`and executing the proxy code and issuing commands to services.”
`
`64. The first issue with the petitioners claim is, as has already been
`
`pointed out, Jini-QS is merely at article that briefly discusses technology that
`
`might exist at some future date