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Inter Partes Review
`U.S. Patent No. 6,216,158
`
`Apple Inc. v. Uniloc Luxembourg S. A., Case IPR2018-00361
`Andrew S. Ehmke, Haynes and Boone, LLP
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`1
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`APPL-1044 / IPR2018-00361
`Apple v. Uniloc / Page 1 of 44
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`

`

`The Jini-QS Ground
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`The Riggins Ground
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`2
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`2
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`

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`The Jini-QS Ground
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`The Riggins Ground
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`3
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`3
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`

`

`The ’158 Patent is Directed to Using a Palm-Sized Device with
`Sun’s Jini Platform
`
`APPL-1001, 1:36-37; ’158 Petition at 4-5
`
`APPL-1001, 2:44-49; ’158 Petition at 5
`
`APPL-1001, 3:61-65; ’158 Petition at 6
`
`APPL-1001, 2:44-49; ’158 Petition at 5
`
`APPL-1001, Claim 3; ’158 Reply at 9
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`APPL-1002, p. 148; ’158 Petition at 7-8
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`4
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`4
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`

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`Jini-QS Teaches Using a PalmPilot with Jini
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`APPL-1005 at 29; ’158 Petition at 16
`5
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`5
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`

`

`Jini-QS Teaches Using a PalmPilot with Jini
`
`APPL-1005 at 29; ’158 Petition at 16
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`6
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`6
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`

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`Jini-QS is Prior Art
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`7
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`7
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`

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`Jini-QS is Prior Art for All That it Discloses
`
`Institution Decision at 15
`
`Patent Owner Response at 14
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`8
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`8
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`

`

`Jini-QS Teaches the “Accessing a
`Description” Limitation
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`9
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`9
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`

`

`’158 Patent, Claim 1
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`10
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`10
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`

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`Jini-QS Teaches “Accessing a Description” via Lookup
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`11
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`11
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`APPL-1005 at 29; ’158 Petition at 28
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`

`

`Jini-QS Teaches “Accessing a Description” via Lookup
`
`APPL-1005 at 29; ’158 Petition at 27-28
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`12
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`12
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`

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`Claim 1 Encompasses Using Jini Lookup
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`APPL-1001, 3:27-31; ’158 Petition at 5
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`13
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`13
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`APPL-1001, Claim 3; ’158 Reply at 9
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`

`

`Patent Owner’s Characterization of “Icons” is Wrong
`
`Patent Owner Response
`
`’158 Patent Owner Response at 16
`
`Jini-QS
`
`APPL-1005 at 29; ’158 Petition at 28
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`14
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`14
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`

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`Jini-QS Teaches the “Downloading” Limitation
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`15
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`15
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`

`

`’158 Patent, Claim 1
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`16
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`16
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`

`

`Jini-QS’s Main Figure Teaches that a PalmPilot can
`Download the Proxy Code
`
`APPL-1005 at 29; ’158 Petition at 29
`
`APPL-1005 at 29; ’158 Petition at 29
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1005 at 29; ’158 Petition at 29
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`17
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`17
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`

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`Jini-QS’s Proxy Code Is “Program Code”
`
`Claim 1
`
`Jini-QS
`
`APPL-1005 at 29; ’158 Petition at 29
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`18
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`18
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`

`

`The Jini-QS Ground Renders Obvious the
`“Application that Cannot be Executed”
`Limitation
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`19
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`19
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`

`

`’158 Patent, Claim 1
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`20
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`20
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`

`

`It Would Have Been Obvious to Use Jini-QS’s PalmPilot to
`Control an Application that Cannot Execute on the PalmPilot
`
`• Jini-QS teaches controlling software-based services over the
`network.
`
`APPL-1005 at 29; ’158 Petition at 31
`
`• Jini-QS teaches that PDAs have very low memory.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1005 at 29; ’158 Petition at 31
`21
`
`21
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`

`

`It Would Have Been Obvious to Use Jini-QS’s PalmPilot to
`Control an Application that Cannot Execute on the PalmPilot
`
`• Arnold teaches that it was known that one type of network service is
`an application.
`
`APPL-1006, Fig. 3 (annotated); ’158 Petition at 32
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`22
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`22
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`

`

`It Would Have Been Obvious to Use Jini-QS’s PalmPilot to
`Control an Application that Cannot Execute on the PalmPilot
`• McCandless teaches that is was known to control a remote
`application that was too intensive to run on your PDA.
`
`• POSITAs had already suggested this combination and result.
`
`APPL-1007 at 7; ’158 Petition at 32
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1013 at 4; ’158 Petition at 23
`23
`23
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`

`

`The Jini-QS Ground
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`The Riggins Ground
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`24
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`24
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`

`

`Riggins Teaches the “Accessing a
`Description” Limitation
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`25
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`25
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`

`

`’158 Patent, Claim 1
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`26
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`26
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`

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`Riggins Teaches a “Directory of Services”
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1008, Fig. 3A (annotated); ’158 Petition at 61
`
`27
`
`27
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`

`

`Riggins Teaches “Accessing a Description”
`
`APPL-1008, 5:51-53; ’158 Petition at 60
`
`APPL-1008, 6:28-31; ’158 Petition at 61-62
`
`APPL-1008, Fig. 5; ’158 Petition at 62
`
`APPL-1008, 8:25-31; ’158 Petition at 62
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`28
`
`28
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`

`

`Patent Owner Ignores the Actual Teachings of Riggins
`
`Patent Owner Response
`
`’158 Patent Owner Response at 32 (citing APPL-1008, Fig. 5, 6:52-55)
`
`Riggins
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1008, 8:25-31; ’158 Petition at 62
`
`29
`
`29
`
`

`

`Patent Owner Attempts to Read Limitations from
`Specification into the Claim
`
`’158 Patent Owner Response at 33
`
`’158 Patent Owner Response at 33
`
`’158 Patent Owner Response at 33
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`30
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`30
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`

`

`The Riggins Ground Renders Obvious the
`“Application that Cannot Be Executed” Limitation
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`31
`
`31
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`

`

`’158 Patent, Claim 1
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`32
`
`32
`
`

`

`Riggins and Devarakonda Render Obvious Controlling a
`Remote Application that Cannot be Executed on a PDA
`
`• Riggins teaches controlling an email application from a remote
`computer.
`
`APPL-1008, 7:60-65; ’158 Petition at 67
`
`• Riggins teaches that its remote computer is a network computer.
`
`APPL-1008, 8:22-25; ’158 Petition at 55
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`33
`
`33
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`

`

`Riggins and Devarakonda Render Obvious Controlling a
`Remote Application that Cannot be Executed on a PDA
`
`• Devarakonda teaches that it was known that a network computer
`could be a PDA that relies on services for its basic functions.
`
`APPL-1009, 2:11-13, 2:20-22; ’158 Petition at 67
`
`• Devarakonda also teaches that it was known that network
`computers had limited physical resources.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1009, 1:28-32; ’158 Petition at 67
`
`34
`
`34
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`

`

`Patent Owner’s Arguments
`
`Patent Owner Response at 37
`
`Patent Owner Response at 38
`
`Patent Owner Response at 38
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``
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``
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``
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`35
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`35
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`

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`Devarakonda’s Network Computer (e.g., PDA) includes a
`Web Browser
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`36
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`36
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`APPL-1009, Fig. 1; ’158 Reply at 24
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`

`

`The Record Shows that Web Browsers on PDAs Were
`Well Known
`
``
`
``
`
``
`
``
`
`APPL-1040 at 2; ’158 Reply at 25 (also citing APPL-1041 at 4-9)
`
`APPL-1039 at 7-12; ’158 Reply at 25
`
`APPL-1042 (Honeywell Patent), 5:42-45; ’158 Reply at 25
`
`APPL-1043 (Sun Patent), 3:17-18, 3:24-25; ’158 Reply at 25
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`37
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`37
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`

`

`Additional Slides
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`38
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`38
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`

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`Claim Construction – “Palm Sized Computer”
`
`APPL-1001, 1:13-14, 1:19-20; ’158 Petition at 8-9
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`39
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`39
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`

`

`The ’158 Patent is Predicated on a POSITA’s Knowledge of Jini
`Implementation Details
`
`APPL-1001, Claim 3; ’158 Reply at 9
`
`APPL-1001, 1:49-51 (see also 2:45-53); ’158 Reply at 8
`
`APPL-1001, 6:4-6; ’158 Reply at 9
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1001, 5:16-17; ’158 Reply at 9
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`40
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`40
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`

`

`Patent Owner’s Expert Admits POSITAs Had Prior
`Understanding of Jini Protocols
`
`APPL-1032 (Easttom Dep.), 85:16-86:3; ’158 Reply at 9-10
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`41
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`41
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`

`

`POSITAs had Prior Knowledge of Jini Implementation
`Details
`
`APPL-1005 (Jini-QS) at 29; ’158 Reply at 10
`
`APPL-1034 (JavaWorld, Aug. 1, 1998) at 1; ’158 Reply at 11
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`42
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`42
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`

`

`POSITAs had Prior Knowledge of Jini Implementation
`Details
`
`APPL-1036 at 12; ’158 Reply at 13
`
`APPL-1036 at 12 (Dec. ’98 archive of
`java.sun.com); ’158 Reply at 13
`
`APPL-1034 at 4 (JavaWorld, Aug. ’98); ’158 Reply at 11
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`43
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`43
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`

`

`POSITAs had Prior Knowledge of Jini Implementation
`Details
`
`APPL-1033, ¶ 9 (Lanowitz Decl.); ’158 Reply at 10-11
`
`APPL-1035 (Lanowitz Dep.), 64:3-5, 64:11-19 (citing APPL-
`1010 (“Jini Architecture Overview”); ’158 Reply at 11-12
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`44
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`44
`
`

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