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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`––––––––––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`––––––––––––––––––
`
`VALVE CORPORATION,
`Petitioner,
`
`v.
`
`PALTALK HOLDINGS, INC.,
`Patent Owner.
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`––––––––––––––––––
`
`Case Nos. IPR2018-01241, -01242
`U.S. Patent No. 5,822,523
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`Case Nos. IPR2018-01238, -01243
`U.S. Patent No. 6,226,686
`
`––––––––––––––––––
`
`DECLARATION OF DR. STEVE R. WHITE
`REGARDING U.S. PATENT NOS. 5,822,523 AND 6,226,686
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`Petitioner Valve, Ex. 1007, p. Cover
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`IPR2018-1238, -1241, -1242, -1243
`U.S. Patent Nos. 5,822,523 and 6,226,686
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`Declaration of Dr. Steve R. White
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`I do hereby declare and state, that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true; and further that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment, under Section 1001 of Title 18 of the United States Code.
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`Dated: June 12, 2018
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`Dr. Steve R. White:
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`Petitioner Valve, Ex. 1007, p. i
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`IPR2018-1238, -1241, -1242, -1243
`U.S. Patent Nos. 5,822,523 and 6,226,686
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`Declaration of Dr. Steve R. White
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`TABLE OF CONTENTS
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`Exhibit List .............................................................................................................. vii
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`I.
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`INTRODUCTION ........................................................................................... 1
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`A.
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`B.
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`C.
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`D.
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`Engagement ........................................................................................... 1
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`Background and Qualifications ............................................................. 1
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`Compensation ........................................................................................ 2
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`Information Considered ......................................................................... 3
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`II.
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`LEGAL STANDARDS FOR PATENTABILITY .......................................... 3
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`A. Obviousness ........................................................................................... 5
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`III. U.S. PATENT NOS. 5,822,523 and 6,226,686 ............................................. 11
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`A. Overview of the ’523 and ’686 Patents (PalTalk Patents) .................. 11
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`B.
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`C.
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`D.
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`E.
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`Technical Descriptions of the PalTalk Patents. ................................... 11
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`Prosecution History of the PalTalk Patents ......................................... 14
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`Level of Ordinary Skill in the Art ....................................................... 14
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`Construction of Terms Used in the ’523 and ’686 Patents ................. 16
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`“aggregating/aggregated” (All Independent Claims)................ 16
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`“a shared, interactive application” (Claims 686.1, 686.3, 686.7,
`and 686.18) ................................................................................ 17
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`“group messaging server” (Claims 523.1 and 686.12) ............. 17
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`“wherein/whereby said aggregated/server message keeps the
`shared interactive application operating consistently” (Claims
`686.1, 686.3, 686.5, and 686.18) ............................................... 18
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`IV. OVERVIEW OF THE PRIOR ART ............................................................. 19
`Petitioner Valve, Ex. 1007, p. ii
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`IPR2018-1238, -1241, -1242, -1243
`U.S. Patent Nos. 5,822,523 and 6,226,686
`A.
`International Publication No. WO 94/11814 to Aldred et al.:
`Collaborative Working in a Network (“Aldred”) (Ex. 1009).............. 19
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`Declaration of Dr. Steve R. White
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`Collaborative Working Environment ........................................ 19
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`Network Architecture ................................................................ 21
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`Sharing Sets ............................................................................... 24
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`Central Serialisation Point ........................................................ 27
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`B.
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`RFC 1692: Transport Multiplexing Protocol (TMux)......................... 33
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`C. U.S. Patent No. 5,466,200 to Ulrich et al. (Ex. 1012) ......................... 37
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`D. U.S. Patent No. 5,307,413 to Denzer (Ex. 1014) ................................ 43
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`E.
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`RFC 1459: Internet Relay Chat Protocol (Ex. 1025) .......................... 44
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`V. ANALYSIS OF THE CHALLENGED CLAIMS......................................... 45
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`A.
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`Independent Claims ............................................................................. 46
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`Preambles (All Independent Claims) ........................................ 46
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`Messaging Functions (Claims 523.1, 686.1, 686.3, and
`686.12) ......................................................................................58
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`1.
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`2.
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`Claims 523.1 and 686.12 ................................................ 58
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`Claims 686.1 and 686.3 .................................................. 63
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`Sending / Receiving (All Independent Claims) ........................ 68
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`Payload and Identifying Portions (All Independent Claims) .... 70
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`Aggregating (All Independent Claims) ..................................... 77
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`Forming (Claims 523.1, 686.1, 686.12, and 686.18) ................ 85
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`Transmitting (All Independent Claims) .................................... 86
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`Wherein Clause (Claims 686.1, 686.3. 686.7, and 686.18) ...... 87
`Petitioner Valve, Ex. 1007, p. iii
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`B. Networking Dependent Claims ........................................................... 90
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`Declaration of Dr. Steve R. White
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`The Internet (Claims 686.2, 686.4, 686.8, 686.13, and
`686.19) ......................................................................................90
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`Internet and Session Layer Protocol (Claims 523.6 and
`686.14) ......................................................................................92
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`Group Messaging Protocol (Claims 523.9-10, 686.20-21,
`686.39-40, and 686.56-57) ........................................................ 95
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`Upper-Level Protocol + TCP/IP (Claims 523.32, 686.28,
`686.47, and 686.64) ................................................................... 97
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`Upper-Level Protocol Only Group Messaging (Claims 523.33,
`686.29, 686.48, and 686.65) ...................................................... 98
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`Consistent Operating State (Claims 523.21, 523.22, and
`523.24) ....................................................................................102
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`Claim 523.18 ........................................................................... 103
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`Claim 523.19 ........................................................................... 104
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`Claim 523.20 ........................................................................... 104
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`Claim 523.25 ........................................................................... 105
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`Claim 523.26 ........................................................................... 105
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`Claim 523.31 ........................................................................... 106
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`C. Aggregation and Packet Dependent Claims ...................................... 107
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`Claims 686.9 and 686.15 ......................................................... 107
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`Claim 523.2 ............................................................................. 108
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`Petitioner Valve, Ex. 1007, p. iv
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`Claims 686.10, 686.16, and 523.3 ........................................... 108
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`Claims 686.11 and 686.17 ....................................................... 110
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`Claims 523.44-46 .................................................................... 111
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`Claims 523.7 and 523.8 ........................................................... 112
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`Claims 523.43, 686.36, and 686.55 ......................................... 113
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`Claim 523.47 ........................................................................... 116
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`Claim 523.16 ........................................................................... 117
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`Claim 523.17 ........................................................................... 118
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`D. Ulrich Combination ........................................................................... 118
`
`Close Proximity in 3D Space of a Computer Game (Claims
`523.12, 686.23, 686.42, and 686.59)....................................... 118
`
`Activities of Players in a Computer Game (Claims 523.13-14,
`and 686.24-25, 686.43-44, and 686.60-61). ............................ 133
`
`Dynamic Group Membership (Claims 523.15, 686.26, 686.45,
`and 686.62) .............................................................................. 134
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`Specified Team (Claims 523.27 and 523.28) .......................... 135
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`Game (Claims 523.23, 686.27, 686.46, and 686.63) .............. 141
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`Echo Suppression (Claims 523.11, 686.22, 686.41, and
`686.58) ....................................................................................142
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`Claim 523.29 ........................................................................... 145
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`Claim 523.30 ........................................................................... 146
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`E.
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`Group Functions ................................................................................ 148
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`Create Group (Claims 523.4 and 523.34) ............................... 148
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`Petitioner Valve, Ex. 1007, p. v
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`IPR2018-1238, -1241, -1242, -1243
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`Declaration of Dr. Steve R. White
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`Message to Join/Connect (Claims 523.5, 523.35, 523.41,
`686.34, 686.53, and 686.18) .................................................... 149
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`Closing Message Group (Claims 523.37, 686.30, 686.49, and
`686.66) ....................................................................................152
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`Leaving or Disconnecting (Claims 523.36, 523.42, 686.35, and
`686.54) ....................................................................................153
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`F.
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`RFC 1459 Combination..................................................................... 154
`
`Query Message Groups (Claims 523.38, 686.31, 686.50, and
`686.67) ....................................................................................154
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`Query Members (Claims 523.39, 686.32, 686.51, and
`686.68) ....................................................................................161
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`Query Attributes (Claims 523.40, 686.33, 686.52, and
`686.69) ....................................................................................162
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`Petitioner Valve, Ex. 1007, p. vi
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`IPR2018-1238, -1241, -1242, -1243
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`EXHIBIT LIST
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`No.
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`Exhibit Description
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`1001 U.S. Patent No. 5,822,523
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`1002 U.S. Patent No. 6,226,686
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`1003 Prosecution File History (523 Patent)
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`1004 Prosecution File History (686 Patent)
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`1005 Reexamination File History (523 Patent)
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`1006 Reexamination File History (686 Patent)
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`1007 Declaration of Dr. Steve R. White
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`1008 Curriculum Vitae of Dr. Steve R. White
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`1009
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`International Publication No. WO 94/11814 (Aldred)
`
`1010 Transport Multiplexing Protocol (TMux), RFC 1692 (Aug. 1994)
`
`1011
`
`Internet Protocol, RFC 791 (Sept. 1981)
`
`1012 U.S. Patent No. 5,466,200 (Ulrich)
`
`1013 U.S. Patent No. 5206,934 (Naef)
`
`1014 U.S. Patent No. 5,307,413 (Denzer)
`
`1015
`
`IBM Dictionaryof Computing (1994)
`
`1016 Complaint, PalT alk Holdings, Inc. v. Riot Games, Inc., C.A. No. 1:16-
`cv-01240-SLR (Dec. 16, 2016)
`
`1017
`
`John D. Day et al., The OSI Reference Model, 71-12 Proceedings of the
`IEEE 1334 (1983)
`
`1018 Protocol Standard for a NetBIOS Service on a TCP/UDP Transport:
`Concepts and Methods, RFC 1001 (Mar. 1987)
`
`1019 Martin W. Sachs et al., LAN and 10/ Convergence: A Survey of the
`Issues, IEEE Computer (1994)
`
`1020 Enrico Y. P. Hsu et al., Management Gaming on a Computer Mediated
`Conferencing System: A Case of Collaborative Learning through
`Computer Conference, IEEE (1991)
`
`1021 The Internet Standards Process - Revision 2, RFC 1602 (Mar. 1994)
`
`Petitioner Valve, Ex. 1007, p. vii
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`IPR2018-1238, -1241, -1242, -1243
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`Declaration of Dr. Steve R. White
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`1022
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`Internet Official Protocol Standards, RFC 1720 (Nov. 1994)
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`1023 U.S. Patent No. 5,502,726 (Fischer)
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`1024 U.S. Patent No. 5,566,337 (Szymanski)
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`1025
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`Internet Relay Chat Protocol, RFC 1459 (May 1993)
`
`1026 Declaration of Dave Crocker
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`1027 CV of Dave Crocker
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`1028 The Internet Standards Process, RFC 1310 (Mar. 1992)
`
`1029 The Internet Standards Process – Revision 3, RFC 2026 (Oct. 1996)
`
`1030 U.S. Patent No. 5,558,339 (Perlman)
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`1031 U.S. Patent No. 5,041,963 (Ebersole)
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`1032 PR 4-3 Joint Claim Construction Statement, PalTalk Holdings, Inc., v.
`Sony Comp. Entertainment Am. Inc., Case No. 2:09-cv-274-DF, Dkt. No.
`209 (E.D. Tex. Oct. 25, 2010)
`
`1033 Claim Construction Order, PalTalk Holdings, Inc., v. Microsoft Corp.,
`Case No. 2:06-cv-367-DF (E.D. Tex.)
`
`1034 Song et al., A Distributed Simulation System for Team Decisionmaking,
`IEEE (1994)
`
`1035 Weaver et al., Networked Simulations: New Paradigms for Team
`Performance Research, 27(1), BEHAV. RES. METHODS, INSTRUMENTS, &
`COMPUTERS, 12-24 (1995)
`
`Petitioner Valve, Ex. 1007, p. viii
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`IPR2018-1238, -1241, -1242, -1243
`U.S. Patent Nos. 5,822,523 and 6,226,686
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`Declaration of Dr. Steve R. White
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`I.
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`INTRODUCTION
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`A.
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`Engagement
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`1.
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`I, Dr. Steve R. White, make this declaration. All statements herein
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`made of my own knowledge are true, and all statements herein made based on
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`information and belief are believed to be true. I am over 21 and otherwise
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`competent to make this declaration. Although I am being compensated for my time
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`in preparing this declaration, the opinions herein are my own.
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`2.
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`I have been retained by counsel for Petitioner as an expert witness in
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`the above-captioned proceedings. I have been asked to provide my opinion about
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`the state of the art of the technology described in U.S. Patent Nos. 5,822,523
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`(“’523 Patent”) (Ex. 1001) and 6,226,686 (“’686 patent”) (Ex. 1002) and on the
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`patentability of these patents.
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`B.
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`3.
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`Background and Qualifications
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`Exhibit 1008 is my curriculum vitae. I earned a Bachelor of Arts
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`degree in Physics from the University of California, Santa Barbara, California, and
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`a Ph.D. in Theoretical Condensed Matter Physics from the University of
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`California, San Diego, California.
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`4.
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`I am an expert in the field of computer science and, in particular,
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`distributed computing systems. A distributed system is a system in which
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`components located on networked computers communicate and coordinate their
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`Petitioner Valve, Ex. 1007, p. 1
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`Declaration of Dr. Steve R. White
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`actions by passing messages. Throughout this declaration, I will refer to the field of
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`distributed systems as the relevant field or the relevant art. In formulating my
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`opinions, I have relied upon my training, knowledge, and experience in the
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`relevant art. My current curriculum vitae provide a comprehensive description of
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`my academic and employment history and my publications for the previous 35
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`years.
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`5.
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`As an expert in the field of distributed systems since prior to 1995, I
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`am qualified to provide an opinion as to what a person of ordinary skill in the art
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`would have understood, known, or concluded as of 1995.
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`6.
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`I have been working as a researcher, a university lecturer, and a
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`private consultant in the area of distributed systems for over thirty years. My areas
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`of expertise include distributed systems communications and systems management.
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`C. Compensation
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`7.
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`I am being compensated at a rate of $650 per hour for my study and
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`testimony in this matter. I am also being reimbursed for reasonable and customary
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`expenses associated with my work and testimony in this investigation. My
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`compensation is not contingent on the outcome of this matter or the specifics of my
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`testimony.
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`Petitioner Valve, Ex. 1007, p. 2
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`Declaration of Dr. Steve R. White
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`D.
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`Information Considered
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`8. My opinions are based on my years of education, research and
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`experience, as well as my investigation and study of relevant materials. In forming
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`my opinions, I have considered the materials I identify in this report and those
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`listed in my report’s Exhibit List.
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`9.
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`I may rely upon these materials and/or additional materials to respond
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`to arguments raised by the Patent Owner. I may also consider additional documents
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`and information in forming any necessary opinions — including documents that
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`may not yet have been provided to me.
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`10. My analysis of the materials produced in this investigation is ongoing
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`and I will continue to review any new material as it is provided. This report
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`represents only those opinions I have formed to date. I reserve the right to revise,
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`supplement, and/or amend my opinions stated herein based on new information
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`II. LEGAL STANDARDS FOR PATENTABILITY
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`11.
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`In expressing my opinions and considering the subject matter of the
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`claims of the ’523 and ’686 patents, I am relying upon certain basic legal principles
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`that have been explained to me.
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`12. First, I understand that for an invention claimed in a patent to be
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`found patentable, it must be, among other things, new and not obvious from what
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`was known before the invention was made.
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`Petitioner Valve, Ex. 1007, p. 3
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`Declaration of Dr. Steve R. White
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`13.
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`I understand the information that is used to evaluate whether an
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`invention is new and not obvious is generally referred to as “prior art” and
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`generally includes patents and printed publications (e.g., books, journal
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`publications, articles on websites, product manuals, etc.).
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`14.
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`I understand that in this proceeding Petitioners have the burden of
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`proving that the claims of the ’523 and ’686 patents are obvious from the prior art
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`by a preponderance of the evidence. I understand that “a preponderance of the
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`evidence” is evidence sufficient to show that a fact is more likely true than it is not.
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`15.
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`I understand that in this proceeding, the claims must be given their
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`broadest reasonable interpretation consistent with the specification. The claims
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`after being construed in this manner are then to be compared to the information in
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`the prior art.
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`16.
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`I understand that in this proceeding, the information that may be
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`evaluated is limited to patents and printed publications. My analysis below
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`compares the claims to patents and printed publications that are prior art to the
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`claims.
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`17.
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`I understand that there are two ways in which prior art may render a
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`patent claim unpatentable. First, the prior art can be shown to “anticipate” the
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`claim. Second, the prior art can be shown to have made the claim “obvious” to a
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`Petitioner Valve, Ex. 1007, p. 4
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`person of ordinary skill in the art. My understanding of the “obviousness” standard
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`is set forth below.
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`A. Obviousness
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`18.
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`I understand that a claimed invention is not patentable if it would have
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`been obvious to a person of ordinary skill in the field of the invention at the time
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`the invention was made.
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`19.
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`I understand that the obviousness standard is defined in the patent
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`statute (35 U.S.C. § 103) as follows:
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`A patent may not be obtained though the invention is not
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`identically disclosed or described as set forth in section 102, if the
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`differences between the subject matter sought to be patented and the
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`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
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`ordinary skill in the art to which said subject matter pertains.
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`Patentability shall not be negated by the manner in which the
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`invention was made.
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`20.
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`I understand that the following standards govern the determination of
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`whether a claim in a patent is obvious. I have applied these standards in my
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`evaluation of whether the asserted claims of the ’523 and ’686 patents would have
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`been considered obvious in 1995.
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`21.
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`I understand that to find a claim in a patent obvious, one must make
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`certain findings regarding the claimed invention and the prior art. Specifically, I
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`Petitioner Valve, Ex. 1007, p. 5
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`understand that the obviousness question requires consideration of four factors
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`(although not necessarily in the following order):
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` The scope and content of the prior art;
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` The differences between the prior art and the claims at issue;
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` The knowledge of a person of ordinary skill in the pertinent art;
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`and
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` Whatever objective factors indicating obviousness or non-
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`obviousness may be present in any particular case.
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`22.
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`In addition, I understand that the obviousness inquiry should not be
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`done in hindsight, but must be done using the perspective of a person of ordinary
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`skill in the relevant art as of the effective filing date of the patent claim.
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`23.
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`I understand the objective factors indicating obviousness or non-
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`obviousness may include: commercial success of products covered by the patent
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`claims; a long-felt need for the invention; failed attempts by others to make the
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`invention; copying of the invention by others in the field; unexpected results
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`achieved by the invention; praise of the invention by those in the field; the taking
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`of licenses under the patent by others; expressions of surprise by experts and those
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`skilled in the art at the making of the invention; and the patentee proceeded
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`contrary to the accepted wisdom of the prior art. I also understand that any of this
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`evidence must be specifically connected to the invention rather than being
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`Petitioner Valve, Ex. 1007, p. 6
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`associated with the prior art or with marketing or other efforts to promote an
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`invention. I am not presently aware of any evidence of “objective factors”
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`suggesting the claimed methods are not obvious, and reserve my right to address
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`any such evidence if it is identified in the future.
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`24.
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`I understand the combination of familiar elements according to known
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`methods is likely to be obvious when it does no more than yield predictable results.
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`I also understand that an example of a solution in one field of endeavor may make
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`that solution obvious in another related field. I also understand that market
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`demands or design considerations may prompt variations of a prior art system or
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`process, either in the same field or a different one, and that these variations will
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`ordinarily be considered obvious variations of what has been described in the prior
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`art.
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`25.
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`I also understand that if a person of ordinary skill can implement a
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`predictable variation, that variation would have been considered obvious. I
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`understand that for similar reasons, if a technique has been used to improve one
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`device, and a person of ordinary skill in the art would recognize that it would
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`improve similar devices in the same way, using that technique to improve the other
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`device would have been obvious unless its actual application yields unexpected
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`results or challenges in implementation.
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`Petitioner Valve, Ex. 1007, p. 7
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`IPR2018-1238, -1241, -1242, -1243
`U.S. Patent Nos. 5,822,523 and 6,226,686
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`Declaration of Dr. Steve R. White
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`26.
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`I understand that the obviousness analysis need not seek out precise
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`teachings directed to the specific subject matter of the challenged claim, but
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`instead can take account of the “ordinary innovation” and experimentation that
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`does no more than yield predictable results, which are inferences and creative steps
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`that a person of ordinary skill in the art would employ.
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`27.
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`I understand that sometimes it will be necessary to look to interrelated
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`teachings of multiple patents; the effects of demands known to the design
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`community or present in the marketplace; and the background knowledge
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`possessed by a person having ordinary skill in the art. I understand that all these
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`issues may be considered to determine whether there was an apparent reason to
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`combine the known elements in the fashion claimed by the patent at issue.
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`28.
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`I understand that the obviousness analysis cannot be confined by a
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`formalistic conception of the words “teaching, suggestion, and motivation.” I
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`understand that in 2007, the Supreme Court issued its decision in KSR Int'l Co. v.
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`Teleflex, Inc., 550 U.S. 398 (2007), where the Court rejected the previous
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`requirement of a “teaching, suggestion, or motivation to combine” known elements
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`of prior art for purposes of an obviousness analysis as a precondition for finding
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`obviousness. It is my understanding that KSR confirms that any motivation that
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`would have been known to a person of skill in the art, including common sense, or
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`Petitioner Valve, Ex. 1007, p. 8
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`IPR2018-1238, -1241, -1242, -1243
`U.S. Patent Nos. 5,822,523 and 6,226,686
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`Declaration of Dr. Steve R. White
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`derived from the nature of the problem to be solved, is sufficient to explain why
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`references would have been combined.
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`29.
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`I understand that a person of ordinary skill attempting to solve a
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`problem will not be led only to those elements of prior art designed to solve the
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`same problem. I understand that under the KSR standard, steps suggested by
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`common sense are important and should be considered. Common sense teaches
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`that familiar items may have obvious uses beyond the particular application being
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`described in a reference, that if something can be done once it is obvious to do it
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`multiple times, and in many cases a person of ordinary skill will be able to fit the
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`teachings of multiple patents together like pieces of a puzzle. As such, the prior art
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`considered can be directed to any need or problem known in the field of endeavor
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`as of the priority date of the ’523 and ’686 patents and can provide a reason for
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`combining the elements of the prior art in the manner claimed. In other words, the
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`prior art does not need to be directed towards solving the same problem that is
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`addressed in the patent. Further, the individual prior art references themselves need
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`not all be directed towards solving the same problem.
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`30.
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`I understand that an invention that might be considered an obvious
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`variation or modification of the prior art may be considered non-obvious if one or
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`more prior art references discourages or lead away from the line of inquiry
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`disclosed in the reference(s). A reference does not “teach away” from an invention
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`Petitioner Valve, Ex. 1007, p. 9
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`IPR2018-1238, -1241, -1242, -1243
`U.S. Patent Nos. 5,822,523 and 6,226,686
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`Declaration of Dr. Steve R. White
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`simply because the reference suggests that another embodiment of the invention is
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`better or preferred. My understanding of the doctrine of teaching away requires a
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`clear indication that the combination should not be attempted (e.g., because it
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`would not work or explicit statements saying the combination should not be made).
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`31.
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`I understand that a person of ordinary skill is also a person of ordinary
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`creativity.
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`32.
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`I further understand that in many fields, it may be that there is little
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`discussion of obvious techniques or combination, and it often may be the case that
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`market demand, rather than scientific literature or knowledge, will drive design
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`trends. When there is such a design need or market pressure to solve a problem and
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`there are a finite number of identified, predictable solutions, a person of ordinary
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`skill has good reason to pursue the known options within their technical grasp. If
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`this leads to the anticipated success, it is likely the product not of innovation but of
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`ordinary skill and common sense. In that instance the fact that a combination was
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`obvious to try might show that it was obvious. The fact that a particular
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`combination of prior art elements was “obvious to try” may indicate that the
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`combination was obvious even if no one attempted the combination. If the
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`combination was obvious to try (regardless of whether it was actually tried) or
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`leads to anticipated success, then it is likely the result of ordinary skill and
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`common sense rather than innovation.
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`Petitioner Valve, Ex. 1007, p. 10
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`IPR2018-1238, -1241, -1242, -1243
`U.S. Patent Nos. 5,822,523 and 6,226,686
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`Declaration of Dr. Steve R. White
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`III. U.S. PATENT NOS. 5,822,523 and 6,226,686
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`A. Overview of the ’523 and ’686 Patents (PalTalk Patents)
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`33. The ’523 patent is entitled “Server-group messaging system for
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`interactive applications.” It was filed on February 1, 1996, and issued on October
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`13, 1998.
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`34. The ’686 patent is entitled “Server-group messaging system for
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`interactive applications.” It was filed on September 28, 1999 and issued on May 1,
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`2001. The ’686 patent is a continuation of U.S. Patent No. 6,018,766, which is
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`itself a continuation of the ’523 patent.
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`35. Both the ’523 and ’686 patents share substantially the same
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`specification and drawings. In many cases, they also share substantially the same
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`claim limitations. Where I am aware of any distinctions between the two patents, I
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`have considered it and described it below. I have referred to these patents
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`collectively as the “PalTalk Patents.”
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`B.
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`Technical Descriptions of the PalTalk Patents
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`36. The PalTalk Patents are in the technical field of networking for
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`shared, interactive applications. Ex. 1001 (523 Patent), 1:52-57, 8:22-26; Ex. 1002
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`(686 Patent), 1:56-61, 8:26-30. The patents describe methods for routing messages
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`in a shared, interactive application over a wide area network, such as the Internet.
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`Petitioner Valve, Ex. 1007, p. 11
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`IPR2018-1238, -1241, -1242, -1243
`U.S. Patent Nos. 5,822,523 and 6,226,686
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`Declaration of Dr. Steve R. White
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`Ex. 1001 (523 Patent), 12:38-42, 26:28-29; Ex. 1002 (686 Patent), 12:38-42,
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`26:28-29.
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`37. The claims of the PalTalk Patents are generally directed to methods
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`for deploying interactive applications over a network containing host computers
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`and group messaging servers. The purported invention described in the PalTalk
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`Patents relates to networked collaborative (i.e., multi-person) computer
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`applications. See, e.g., Ex. 1001 (523 Patent), 1:14-23, 1:58–2:33, 2:47–3:22, 10:1-
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`19; Ex. 1002 (686 Patent), 1:19-27, 1:62-2:37, 2:51-3:26, 10:6-23.
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`38. The PalTalk Patents explain, for example, that in networked
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`collaborative environments each user will need to have the same application
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`environment present on his or her computer screen. For each user to see the same
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`application environment the application “state,” or status, must be consistent
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`between all of the users’ computers. The computers achieve this consistency by
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`continuously communicating with one another. Ex. 1001 (523 Patent), 1:66–2:4;
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`Ex. 1002 (686 Patent), 2:3-8. The messages between computers in a multi-person
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`game could contain, for example, player positions and velocity information, as
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`well as information about player actions that may affect other players in the game.
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`Ex. 1001 (523 Patent), 2:8–12; Ex. 1002 (686 Patent), 2:12-16.
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`39. The inventions described in the PalTalk Patents attempt to address
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`issues related to interactive network applications by introducing what is called a
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`Petitioner Valve, Ex. 1007, p. 12
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`IPR2018-1238, -1241, -1242, -1243
`U.S. Patent Nos. 5,822,523 and 6,226,686
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`Declaration of Dr. Steve R. White
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`“group messaging server.” Ex. 1001 (523 Patent), Abstract; Ex. 1002 (686 Patent),
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`Abstract. The users’ computers in the system are referred to as “host computers.”
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`Figure 5 of the PalTalk Patents, below, shows an embodiment of a network
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`implemented pursuant to the concepts described in the PalTalk Patents. Item 62 is
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`the gr