Filed on behalf of: E-NUMERATE SOLUTIONS, INC.
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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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`MERRILL COMMUNICATIONS LLC d/b/a MERRILL
`CORPORATION,
`Petitioner
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`
`v.
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` E-NUMERATE SOLUTIONS, INC.,
`Patent Owner
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`
`
`Case IPR2018-01389
`U.S. Patent 9,268,748
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`__________________
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`E-NUMERATE SOLUTIONS, INC’S PATENT OWNER RESPONSE
`PURSUANT TO 37 C.F.R. § 42.120
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`TABLE OF CONTENTS
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`I. INTRODUCTION .......................................................................................................................5
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`II. BACKGROUND ........................................................................................................................7
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`A.
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`B.
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`Prior Art Markup Language Documents ........................................................................7
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`The ‘748 Patent ............................................................................................................39
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`III. DESCRIPTION OF THE PRIOR ART ..................................................................................39
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`A.
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`B.
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`Simpson (Ex. 1005) .....................................................................................................39
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`Goldfarb (Ex. 1006) .....................................................................................................42
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`IV. CLAIM CONSTRUCTION ...................................................................................................45
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`V. PETITIONER FAILED TO DEMONSTRATE THAT THERE IS SUBSTANTIAL
`EVIDENCE THAT ANY OF THE CHALLENGED CLAIMS ARE OBVIOUS ................46
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`A.
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`Grounds 1: Simpson In View Of Goldfarb Does Not Render Claims 1, 11,
`and 19 Obvious ............................................................................................................47
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`1.
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`2.
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`3.
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`4.
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`5.
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`Petitioner Fails To Establish That Either Simpson Or Goldfarb Disclose
`“an application including a network browser on the device for accessing a
`system configured for” as required by claim 1 ......................................................47
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`Petitioner Fails To Establish That Either Simpson Or Goldfarb Disclose
`“calculation rule for validation of a calculation involving data values” as
`required by claim 1 ................................................................................................60
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`Petitioner Fails To Establish That Either Simpson Or Goldfarb Disclose “a
`computer-readable calculation rule for validation of a calculation
`involving data values, and a computer-readable unit rule for validation of a
`unit of data values” as required by claim 1 ............................................................68
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`Petitioner Fails To Establish That Either Simpson Or Goldfarb Disclose
`“code for mapping the one or more of the computer-readable semantic
`tags to the one or more of the original values” as required by claim 11 ................76
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`Petitioner Fails To Establish That Either Simpson Or Goldfarb Disclose
`“outputting at least one computer-readable Extensible Markup Language
`(XML)-compliant data document that is based on at least a portion of the
`at least one object and at least a portion of the mapping” as required by
`claim 11 ..................................................................................................................80
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`B.
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`A POSA Would Not Be Motivated To Modify Simpson In View Of Goldfarb..........83
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`1.
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`2.
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`Simpson Discloses Existing System With Limitations The Claimed
`Invention Overcomes .............................................................................................88
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`The Proposed Modification Would Eliminate Goldfarb’s Stated
`Improvement ..........................................................................................................89
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`3.
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`Petitioner Failed To Address The Inefficiencies Created ......................................91
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`VI. CONCLUSION.......................................................................................................................93
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`PATENT OWNER’S EXHIBIT LIST
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`Exhibit Number Description
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`2001
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`2002
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`Expert Declaration of Dr. Michael J Smith
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`U.S. Patent No. 7,249,328
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`
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`I. INTRODUCTION
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`The Petitioner did not demonstrate that any of the claims of U.S. Patent
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`No. 9,268,748 (“the ‘748 patent”) are obvious because the Petitioner failed to
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`show that a person of ordinary skill in the art (“POSA”) would have been
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`motivated to modify the structure and components of either Simpson or Lyons
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`to achieve the claimed invention or that a POSA “would have had a
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`reasonable expectation of success in doing so.” OSRAM Sylvania, Inc. v. Am
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`Induction Techs., Inc., 701 F.3d 698, 706 (Fed. Cir. 2012). The Board has
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`consistently declined to conclude that a claim is obvious when the Petition fails
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`to identify any objective evidence such as experimental data, tending to
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`establish that two different structures can be combined to achieve the claimed
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`invention with a reasonable expectation of success.1 Here, the Petitioner did
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`not set forth any such objective evidence.2 Rather, the Petitioner’s own expert
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`made hand-waving arguments that the database system of Simpson, which did
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`not support XML, and which required file-specific user-customized
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`1 Epistar, et al. v. Trustees Of Boston University, IPR2013-00298, Decision Not To
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`Institute, Paper No. 18 (P.T.A.B. November 15, 2103).
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`2 See e.g., Petition, pp. 21-23.
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`input_templates or multi-screen Import Wizards to “tag” data with field names
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`so they could be imported into a database system, could be modified to accept
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`XML-formatted markup documents by first running the XML markup
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`documents through an HTML converter (which would remove all markup and
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`structure from said XML markup document). However, such an
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`implementation would eliminate Goldfarb’s stated improvements of “adding
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`more structure to data files and providing a universal file structure that would
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`ease the exchange of data between programs and over the internet”3 by
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`flattening the XML data file of relevant metadata. Further, the Petitioner
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`failed to address the inefficiencies created by flattening the relevant data
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`structure out of the XML file when converting to HTML.
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`For these reasons as explained more fully below, the Petitioner failed to
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`show that there is a substantial evidence to support its position that the claims
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`of the ‘748 patent are obvious over Simpson, Lyon and Goldfarb.
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`Accordingly, the Board should not cancel any of the claims of the ‘748 patent.
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`3 Exhibit 1003, ¶ 78; see also Exhibit 1006, xxxix-xl.
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`II. BACKGROUND
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`A. Prior Art Markup Language Documents4
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`Inventor Russell T. Davis pioneered several inventions related to
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`Reusable Data Markup Language including, but not limited to, the ‘748
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`patent.5 As discussed below, these patents provided numerous advantages over
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`prior art Markup Languages.6
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`In the late 1990’s when numbers were treated the same as letters (text) in
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`software programs, both online and offline, e-Numerate’s key technical
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`advancements allowed numbers to be substantively treated as the numerical
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`values they represent.7 This opened the computer world, both online and
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`4 It should be noted that the following exemplary citations to the specification
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`and/or advantages are for illustrative purposes only, as there may be others
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`and some covered systems/methods may omit one or more of the same. Thus,
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`such exemplary citations should not be deemed limiting to the claim language
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`in any way.
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`5 Exhibit 1001, 1:7-27.
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`6 Id. at 2:66-3:2.
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`7 Exhibit 2002, US 7249328 (parent case to US 9,268,748) 1:48-52.
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`…Continued
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`U.S. Patent No. 9,268,748
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`offline, to vastly improve a user’s ability to identify, manipulate, compare,
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`convert and process numbers in software like never before.8 The technical
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`innovations of the '748 patent9 are embodied in software that improves and
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`enhances the functionalities of computer systems over the prior art.10 The
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`problem that they solve relates to the need for the intelligent identification and
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`processing of numerical information on the Internet.
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`
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`The Problem
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`In the late 1990’s, the Internet was replete with numerical data but (i)
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`there was no way of distinguishing this numerical data from text, (ii) data and
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`analytic routines were not standardized, and (iii) calculations occurred at too
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`low a conceptual level.11
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`8 Id. at 2:42-54.
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`9 Exhibit 1001.
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`10 See, e.g., Exhibit 2001, ¶ 20.
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`11 Exhibit 2002, at 1:48-52.
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`8
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`…Continued
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`U.S. Patent No. 9,268,748
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`The advances of the inventions claimed in the '748 patent12 relate to
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`deficiencies in the prior-art markup languages that existed at the time of the
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`invention.13 These were Hyper Text Markup Language (HTML)14 and
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`Extensible Markup Language (XML).15
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`Internet browsers interpret and display documents formatted in
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`HTML.16 In order to distinguish the text characters to be displayed from the
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`information describing how the text characters are to be formatted,
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`“annotations” that are not visible to the viewer of the displayed document are
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`added to the document.17 The HTML specification describes the use of a
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`markup language to include these non-displayed annotations.18 A markup
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`language is a system for inserting information about the formatting and display
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`12 Exhibit 1001.
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`13 See, e.g., Exhibit 2001, ¶ 22.
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`14 Exhibit 2002, at 1:31-42.
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`15 Id. at 1:65-2:4.
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`16 Id. at 1:43-50.
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`17 Id. at 1:50-52.
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`18 Id. at 1:35-39.
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`of a group of text characters by placing non-displayed “markup” text before
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`and after the group of text characters.19 These markups, commonly known as
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`“tags” in online and other documents in digital format, describe the structure
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`and formatting of digital documents and instruct computer systems on how to
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`display them.20
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`HTML works only with text and images.21 Numbers in HTML
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`documents are read and displayed as text characters.22 There is no HTML tag
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`capable of annotating the context or meaning of numerical data appearing in a
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`markup document for computer systems to interpret these numerical data as
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`numbers representing a particular type of information instead of a simple string
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`of text characters.23 At most, HTML tags can be used only to indicate the
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`display format (e.g., font, size, color, alignment) of numerical data.24 For
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`19 Id. at 1:35-39.
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`20 Id. at 1:39-42.
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`21 Id. at 1:44-46.
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`22 Id. at 1:48-52.
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`23 Id. at 1:55-58.
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`24 Id. at 1:43-48.
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`example, a financial statement showing numbers could be displayed by
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`computer systems running browsers, but HTML cannot be used to annotate a
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`given number as “revenue” or “expense,” or as “dollars” or “Euros,” or as
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`representing “thousands” or “millions,” but rather only as a text character to
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`be displayed in a certain way according to embedded formatting tags.25
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`Consequently, computer systems running web browsers could use HTML tags
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`to display documents containing numbers, but the HTML tags do not enable
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`computer systems to run analytical applications that read, manipulate,
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`combine, compare, transform, or analyze the numbers, load them into a
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`spreadsheet, or display them in a graph directly from multiple online sources.26
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`XML version 1.0 was developed in the mid-to-late 1990s to help
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`overcome some of HTML’s limitations.27 XML, itself, does not include a set of
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`pre-defined tags, but rather is a specification that governs the creation of tags
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`by particular users or groups.28 The XML specification allows developers to
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`25 Id. at 9:59-65.
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`26 Id. at 1:58-64.
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`27 Id. at 1:65-67.
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`28 Id. at 2:1-5.
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`create customized tags that, via a glossary of terms, describe the structure and
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`meaning of online content.29 In other words, XML allows developers to create
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`their own individual markup languages.30 Thus, a user can use XML to create
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`their own markup tags that annotate data characteristics that are meaningful to
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`that particular user.31 But at the time of the inventions of the '748 patent32 no
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`set of XML tags had been promulgated for general use, so any XML tag
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`taxonomy created by one user would not be compatible with the taxonomies
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`created by other users.33 One user’s XML tag taxonomy, whether individuals
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`or groups, is not ordinarily available to any other users or groups of users.34
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`XML’s lack of standardization, and its separation of data from its annotations
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`(metadata), left users with no way to manipulate, combine, compare,
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`transform, or analyze numerical data from singular or multiple online sources
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`29 Id. at 2:7-12.
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`30 Id.
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`31 Id.
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`32 Exhibit 1001.
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`33 Exhibit 2002, at 2:13-17.
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`34 Id.
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`…Continued
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`12
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`using differing custom created XML tag taxonomies.35 The only way to correct
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`the deficiency of XML was to convert unrelated documents by hand.36
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`
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`Various Embodiments Covered by The Claimed Invention
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`In contrast to XML, the Reusable Data Markup Language (“RDML”)
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`represented a significant advance over HTML and XML.37 The patents-at-issue
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`in this case solve these HTML- and XML-related problems with unique tools
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`that allowed users for the first time to easily view, compare, and analyze
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`numerical data on the Internet.38 The Reusable Data Markup Language
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`(“RDML”) and RDML companion innovations pair the metadata directly
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`with the numerical data in machine-readable form so the numerical data could
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`be easily identified and used in different program applications.39 This is a
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`dramatically different approach than previously used, which was to keep
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`35 Id. at 2:42-45.
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`36 Id. at 2:45-49.
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`37 See, e.g., Exhibit 2001, ¶ 20.
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`38 Id. at 8:24-28.
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`39 Id. at 5:53-57.
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`13
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`document metadata and data itself separate from each other.40 Without the
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`pairing of metadata directly with the numerical data as described in the '748
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`patent,41 the capabilities presented in the XBRL standard would not be
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`possible.42 RDML companion innovations also define standards for both data
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`formats and analytic routines43 and enhance analytical calculation power by
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`creating data objects at the line item and document levels.44 This overcomes
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`the limitations of traditional spreadsheets which operate only at the cell (single
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`number) level.45
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`Reusable Data Markup Language provides RDML tags for data
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`characteristics that HTML lack and supplies a set of tags for content and
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`meaning of numbers for general use, which is missing in XML.46
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`40 Id. at 2:1-5.
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`41 Exhibit 1001.
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`42 Id. at page 3; 1:7-27.
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`43 Exhibit 2002, at 10:52.53.
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`44 Id. at 14:7-11.
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`45 Id. at 2:37-41.
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`46 Id. at 9:17-24.
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`…Continued
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`U.S. Patent No. 9,268,748
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`A suite of software applications has been developed to create documents
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`with RDML tag markups, read or parse the RDML documents, display them
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`as graphs or in tree views, combine and compare data from multiple online
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`sources, and manipulate, transform, and analyze numerical data from multiple
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`online sources.47 RDML permits the browsing and manipulation of numbers,
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`and allows the “RDML Data Viewer” to act as a combination Web browser
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`and spreadsheet/analytic application that automatically reads numbers from
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`multiple online sources, understands their meaning, and manipulates them
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`without human intervention.48
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`RDML encodes information about numbers in tags that relate to each
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`number.49 The encoded information is connected with the numbers themselves
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`and the tags move with the numbers when the numbers are ported.50 By
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`47 Id. at 17:20-26.
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`48 Id. at 17:26-33.
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`49 Id. at 4:17-22.
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`50 Id.
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`…Continued
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`U.S. Patent No. 9,268,748
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`associating the numbers with the numbers’ attributes and making it machine-
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`readable, RDML facilitates browsing for and processing numbers.51
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`The RDML Data Viewer is an “Application” in accordance with the
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`XML Specifications.52 The RDML Data Viewer accesses information
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`contained in an XML-formatted document by invoking the XML Processor to
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`obtain individual data elements based on their “extended” tags that have been
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`defined in accordance with the “extensibility” features of XML.53 The RDML
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`Data Viewer automates the process of merging the tagged elements derived
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`from documents written in different formats and languages into a single,
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`standardized data set.54 Where there are conflicts, the RDML Data Viewer
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`automatically resolves the conflicts between the characteristics of the varying
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`documents to create a standard set of tags using the RDML taxonomy.55 The
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`RDML Data Viewer also provides a macro development and management
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`51 Id. at 3:57-67.
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`52 Id. at 8:57-64.
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`53 Id. at 9:17-24.
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`54 Id. at 9:65-67.
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`55 Id. at 11:35-42.
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`scheme that allows users to create reusable custom routines for the
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`manipulation, transformation, and display of RDML-formatted data.56 By
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`defining standards for data characteristics and content-analysis, RDML
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`addresses the problems caused by XML’s use of customized tagging making
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`RDML applicable for general use.57
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`
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`The Impact of The Improvements of the '748 Patent
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`One embodiment covered by the claimed invention includes “pairing the
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`metadata directly with the numerical data in machine-readable form so the
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`numerical data could be easily identified and used in different program
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`applications.”58 This has never been done before.
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`The inventions claimed in the '748 patent59 were invented prior to the
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`creation of the XBRL standard.60 Prior art, as embodied in HTML and XML
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`56 Id. at 9:5-8.
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`57 Id. at 10:31-33.
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`58 Id. at 5:53-57.
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`59 Id.
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`60 Id. at page 3.
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`…Continued
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`U.S. Patent No. 9,268,748
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`at the time of the filing of the '748 patent61 did not provide any metadata (i.e.,
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`information about the attributes or characteristics of a data element) beyond
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`simple display formatting.62 Without these attributes and characteristics, it was
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`not possible for a human or a computer to select, process, combine, or output
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`data elements without resorting to human intervention to find, associate, and
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`take into account how the appropriate attributes and characteristics would
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`affect the selection, processing, combination, and outputting activities.63 For
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`example, financial statements, such as those submitted to the SEC, contain
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`numeric values for typical accounting data items types such as “Assets,”
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`“Balances,” “Cash,” etc.64 To organize the multiple occurrences of these items,
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`accountants would create financial statements such as “Balance Sheets,”
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`“Income Statements,” etc., that typically have formats that hierarchically
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`display and summarize these accounting items in a manner that reflects how
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`the individual organization or organizational unit represents its financial
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`61 Exhibit 1001.
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`62 Exhibit 2002, at 1:39-42.
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`63 Id. at 2:42-49.
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`64 Id. at 9:59-65.
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`18
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`condition.65 Before the introduction of the inventive concepts contained in the
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`'748 patent66 there were no tools that could automatically associate individual
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`accounting data items with the appropriate sections of the organization’s
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`financial statements.67 Typically, the organization would have to rely on its
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`senior financial accountants to manually select, analyze, combine, and format
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`accounting items in a manner that corresponded to that organization’s
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`Financial Statement situation.68 Thus, each iteration of Financial Statement
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`preparation required a large amount of human intervention to create a
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`Financial Statement that faithfully adhered to the “letter” and “intent” of the
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`generally accepted accounting standards due to the lack of a means to capture
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`and utilize the required metadata.69 The '748 patent70 provides these
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`65 Id.
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`66 Exhibit 1001.
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`67 Exhibit 2002, at 5:53-61.
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`68 See, e.g., Exhibit 2001, ¶ 32.
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`69 Id.
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`70 Exhibit 1001.
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`19
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`…Continued
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`U.S. Patent No. 9,268,748
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`capabilities which are not addressed by either HTML or XML.71 The
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`continuing significant efforts by the Financial Accounting Standards Board
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`(FASB) and the XBRL International organization to grow and expand the
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`Extensible Business Reporting Language are a testament to the necessity and
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`value of the inventions contained in the '748 patent.72 The SEC is currently
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`performing cross-financial entity and cross-industry “data mining” activities to
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`better understand financial trends and to better discover improprieties by
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`comparing financial entities.73 These activities would not be possible without
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`the ability of different program applications to utilize the inventions contained
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`in the '748 patent.74
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`One embodiment covered by the claimed invention also seeks to “define
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`standards for both data formats and analytic routines.”75
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`71 See, e.g., Exhibit 2001, ¶ 32.
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`72 Id.
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`73 See, e.g., Exhibit 2001, ¶ 32.
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`74 Id.
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`75 Exhibit 2002, at 10:52.53.
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`20
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`Before the introduction of the inventions contained in the '748 patent76
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`the preparation of financial statements involved the manual selection, analysis,
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`combination and outputting of numerical data items based on the best efforts
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`of the organization’s senior accountants and later accepted as appropriate by
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`Certified Public Accountants.77 Without defined standards for capturing and
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`accessing both numerical data attributes and characteristics, the selection of
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`appropriate data formats and analytic routines could not be performed
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`automatically by either human or machine.78 The '748 patent79 provides a
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`mechanism to capture the metadata required to identify the attributes and
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`characteristics of each numerical data element, and thereby allow the
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`automated selection of the appropriate analytic routines based on the metadata
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`associated with those analytical routines.80 For example, an international
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`organization may operate in several political jurisdictions, each having their
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`76 Exhibit 1001.
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`77 See, e.g., Exhibit 2001, ¶ 34.
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`78 Exhibit 2002, at 10:31-33.
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`79 Exhibit 1001.
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`80 Exhibit 2002, at 13:7-17.
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`21
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`own financial regulations, reporting formats, and analytical processing
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`procedures.81 For the international organization to produce a combined
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`Financial Statement of Condition, the financial statement within each
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`jurisdiction must first be created and then combined into a consolidated
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`financial statement.82 To facilitate this consolidation, senior international
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`accountants would have to manually identify the variations associated with
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`each jurisdiction and determine how these diverse statements of financial
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`condition could be combined.83 One embodiment covered by the claimed
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`invention provides a mechanism to capture the necessary numerical data, item
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`metadata, and analytical processing routine metadata to facilitate the required
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`association of numerical data to routines needed to automatically produce
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`combined financial statements without manual human intervention.
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`81 Id. at 49:38-43.
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`82 Id.
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`83 See, e.g., Exhibit 2001, ¶ 34.
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`22
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`One embodiment covered by the claimed invention involves “enhance
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`analytical calculation power by creating data objects at the line item and
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`document levels.” 84
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`Prior art at the time of the filing of the '748 patent85 only provided for the
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`automated display of structured data using HTML86 or XML.87 While these
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`display structures provided an elementary “visual” representation of the
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`relationship between the data elements, there was no standard way of
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`capturing these relationships in a manner that this information could be stored
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`and accessed by human or automated processes.88 The '748 patent89 provides a
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`mechanism to capture and utilize these types of relationships.90 For example,
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`financial transactions typically might consist of a date, description, multiple
`
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`84 Exhibit 2002, at 14:7-11.
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`85 Exhibit 1001.
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`86 Exhibit 2002, at 1:31-42.
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`87 Id. at 1: 65-2:4.
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`88 Id. at 10:31-33.
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`89 Exhibit 1001.
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`90 Exhibit 2002, at 13:7-17.
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`23
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`account identifiers (e.g., debit, credit, distribution, etc.), and amounts for
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`each.91 In a manual or automated accounting system, these components of a
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`financial transaction would typically be stored together in an information
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`processing system (e.g., “data base”).92 Without the inventions contained in
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`the '748 patent93 there would be no automated way of unambiguously
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`capturing these elements presented in an HTML or XML document due to the
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`lack of the necessary metadata.94
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`One possible embodiment of the Reusable Data Markup Language
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`(RDML) includes “A set of tags to encode attributes and meaning of
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`numbers.”95 RDML encodes information about numbers in tags that relate to
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`each number which is connected with the numbers themselves, and the tags
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`move with the numbers when the numbers are ported.96
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`91 Id. at 9:59-65.
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`92 Id. at 9:59-65.
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`93 Exhibit 1001.
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`94 Exhibit 2002, at 2:42-49.
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`95 Id. at 9:17-24.
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`96 Id. at 4:17-22.
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`24
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`Prior art at the time of the filing of the '748 patent97 did not provide a
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`mechanism to identify numerical data element attributes, characteristics,
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`formats, or relationships.98 For example, an information system would
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`typically store structured data, such as financial transactions, in a “database”
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`system that preserved record or “line item” relationships for a collection of
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`related transactions (i.e., a business document).99 Typically, the metadata
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`describing these record and data element characteristics would be stored in the
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`“schema” subsystem of the database system.100 However, there was no
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`universal mechanism to store and share the metadata describing the structure
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`of the records, the metadata of the individual data elements within each
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`record, the metadata describing the relationship among different records
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`representing a transaction, nor the semantic meaning of the data elements.101
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`For example, an “invoice” might consist of various information about the
`
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`97 Exhibit 1001.
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`98 Exhibit 2002, at 1:55-58.
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`99 Id. at 9:59-65.
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`100 Id. at 11:18-21.
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`101 Id. at 11:22-27.
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`25
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`supplier (e.g., name, address, tax id, etc.), consumer (e.g., name, address, tax
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`id, etc.), and individual invoice line items (e.g., item identifier, description,
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`dimensions, cost, etc.) .102 Without RDML’s encoding of attributes and
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`meaning, each time information from one information system (manual or
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`automated) was to be shared with another information system, a “mapping” of
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`all of these data elements had to be manually created.103 Various embodiments
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`covered by the claimed invention provide for automated sharing of the
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`metadata necessary for information to be shared among information systems
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`without manual intervention.104
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`RDML also includes “A suite of applications that create documents with
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`RDML tag markups, read or parse the RDML documents, display them as
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`graphs or in tree views, combine and compare data from multiple online
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`sources, and manipulate, transform and analyze numerical data from multiple
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`online sources.” 105
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`102 See, e.g., Exhibit 2001, ¶ 38.
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`103 Id. at 2:49-53.
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`104 Exhibit 2002, at 24:44-48.
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`105 Id. at 17:20-26.
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`26
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`…Continued
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`IPR2018-01389
`U.S. Patent No. 9,268,748
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`The '748 patent106 includes the specifications for the implementation of
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`automated information application systems to provide the benefits of various
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`embodiments covered by the claimed invention, and the implementation
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`specifications for the “RDML Data Viewer” describe the mechanisms
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`necessary to provide the benefits of such embodiments.107 Just as the “dial
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`telephone” enhanced the efficiency and ease of use of the telephone system
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`beyond that experienced when human operators were necessary to make a
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`telephone call, the RDML Data