American Multi-Cinema, Inc., et al. (Petitioners)
`v.
`Fall Line Patents, LLC (Patent Owner)
`IPR2019-00610
`
`Before Michelle N. Wormmeester, Sheila F. McShane, John R. Kenny
`Administrative Patent Judges
`
`1
`
`AMC 1022
`AMERICAN MULTI-CINEMA v. Fall Line Patents
`IPR2019-00610
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`v.
`Fall Line Patents, LLC (Patent Owner)
`IPR2019-00610
`
`Before Michelle N. Wormmeester, Sheila F. McShane, John R. Kenny
`Administrative Patent Judges
`
`1
`
`AMC 1022
`AMERICAN MULTI-CINEMA v. Fall Line Patents
`IPR2019-00610
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`
`
`Crucial Distinction:
`Java is an Example
`Object-Oriented Programming Language
`
`Patent Owner’s arguments also overlook the fact that the Petition does
`not rely solely on Java—indeed, Java is not referenced as prior art upon
`which Petitioners rely. . . . The Petition refers to Java only as an
`example of what a POSITA would have known to be an object-
`oriented programming language, and such a programming language
`would have allowed a POSITA to practice the claimed tokenizing.
`
`Petitioners’ Reply, Paper 19 at 6.
`
`“Computer program code for carrying out operations of the present
`invention can be written in an object-oriented programming language
`such as Java., Smalltalk or C++.”
`
`Petitioners’ Reply, Paper 19 at 6 (quoting Barbosa, 12:45-47.
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`
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`Crucial Distinction:
`Java is an Example
`Object-Oriented Programming Language
`
`Patent Owner’s arguments also overlook the fact that the Petition does
`not rely solely on Java—indeed, Java is not referenced as prior art upon
`which Petitioners rely. . . . The Petition refers to Java only as an
`example of what a POSITA would have known to be an object-
`oriented programming language, and such a programming language
`would have allowed a POSITA to practice the claimed tokenizing.
`
`Petitioners’ Reply, Paper 19 at 6.
`
`Bandera explains that “JAVA® is a portable and architecturally
`neutral language,” and “JAVA® source code is compiled into a
`machine-independent format that can be run on any machine with a
`JAVA® runtime system known as the JAVA® Virtual Machine (JVM).”
`
`Roman Declaration, Ex. 1005 at par. 171, quoting Bandera,
`Ex. 1004 at 40-44.
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`Patent Owner’s Lack of Objections
`
`Patent Owner did not file any objections to Petitioners’
`evidence in this proceeding
`
`(1) Objection. Any objection to evidence submitted
`during a preliminary proceeding must be filed within
`ten business days of the institution of the trial. Once
`a trial has been instituted, any objection must be
`filed within five business days of service of
`evidence to which the objection is directed. The
`objection must identify the grounds for the objection
`with sufficient particularity to allow correction in the
`form of supplemental evidence.
`
`37 C.F.R. § 42.64
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`Prior Art References
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`Prior Art References – Barbosa
`
`
`Barbosa relates to systems for conducting field assessments utilizing handheld Barbosa relates to systems for conducting field assessments utilizing handheld
`
`data management devices[].data management devices[].
`
`Institution Decision, Paper 14 at 19.
`
`Barbosa, Ex.1002 at FIG. 7.
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`Prior Art References – Hancock
`
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`Hancock discloses an internet based geographic location referencing system. [] Hancock discloses an internet based geographic location referencing system. []
`
`The disclosed system provides informational services to users based on their The disclosed system provides informational services to users based on their
`
`geographic location.geographic location.
`
`Institution Decision, Paper 17 at 47.
`
`Hancock, Ex. 1003 at FIG. 13.
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`Prior Art References – Bandera
`
`
`Bandera’s system selects an advertising object to be displayed within a web Bandera’s system selects an advertising object to be displayed within a web
`
`page based on the geographic location of the user or the time of day.page based on the geographic location of the user or the time of day.
`Institution Decision, Paper 19 at 39.
`
`Systems, methods and computer program Systems, methods and computer program
`
`products are provided for selecting an products are provided for selecting an
`
`advertising object to be displayed within a advertising object to be displayed within a
`
`Web page requested by a user based on Web page requested by a user based on
`
`the geographic location of the user and/or the geographic location of the user and/or
`
`on the time of day. Systems, methods and on the time of day. Systems, methods and
`
`computer program products are provided for computer program products are provided for
`
`validating an offer within an advertising object validating an offer within an advertising object
`
`of a Web page displayed within a Web client of a Web page displayed within a Web client
`
`in communication with a Web server. in communication with a Web server.
`
`Systems, methods and computer program Systems, methods and computer program
`
`products are also provided for changing products are also provided for changing
`
`content within an object displayed within a content within an object displayed within a
`
`Web page based on changes in geographic Web page based on changes in geographic
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`location of a user.location of a user.
`
`Bandera, Ex. 1004 at Abstract.
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`Prior Art References – Falls
`
`
`Falls provides a system and method for facilitating disconnected mobile Falls provides a system and method for facilitating disconnected mobile
`
`computing.computing.
`
`Institution Decision, Paper 17 at 41.
`
`A method and apparatus are disclosed for A method and apparatus are disclosed for
`
`synchronizing transactions in a synchronizing transactions in a
`
`disconnectable network. Each transaction disconnectable network. Each transaction
`
`includes operations that were performed on includes operations that were performed on
`
`a database replica on one computer while a database replica on one computer while
`
`that computer was disconnectedthat computer was disconnected
`
`from another computer and hence from that from another computer and hence from that
`
`other computer's replica. Transaction other computer's replica. Transaction
`
`synchronization, which occurs after the synchronization, which occurs after the
`
`computers are reconnected, transfers computers are reconnected, transfers
`
`information from each computer to the other information from each computer to the other
`
`computer and applies updates to both computer and applies updates to both
`
`replicas as appropriate. Transaction logs and replicas as appropriate. Transaction logs and
`
`clash handling tools may be used with the clash handling tools may be used with the
`
`invention.invention.
`
`Falls, Ex. 1017 at Abstract.
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`
`Grounds 1, 2
`Claims 1 and 19-22 are obvious over
`Barbosa, Barbosa + Bandera
`35 U.S.C. § 103
`
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`Patent Owner’s Arguments
`
`Barbosa does not contemplate Java for handheld devices
`
`Java in 2002 could not be both device-independent and
`used to acquire GPS information from an external source
`
`Java applets were not available in J2ME
`
`The combination of Barbosa and Bandera is inoperable
`
`The art does not describe “specific Java code” for the
`“tokenized” questionnaire
`
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`Patent Owner: Barbosa Does Not
`Contemplate Java for Handheld Devices
`
`Barbosa, Ex. 1002 at FIG 6.
`
`FIG. 6 an illustration of a basic operational environment for
`the handheld device and methods of the present invention;
`Barbosa, Ex. 1002 at 4:58-60.
`
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`Patent Owner: Barbosa Does Not
`Contemplate Java for Handheld Devices
`
`Assessors equipped with handheld devices are
`assigned/deployed to specific positions . . . The template may
`operate in combination with programs resident in the handheld
`computer or may be accompanied by a computer program
`transmitted from the se[r]ver (e.g., in the form of a JAVA applet).
`
`Barbosa, Ex. 1002 at
`11:63-12:18.
`
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`Patent Owner: Barbosa Does Not
`Contemplate Java for Handheld Devices
`
`Referring to FIG. 6 a JAVA® applet 40 running within a mobile Web
`client 21 is configured to communicate with a 65 GPS 22 so as to
`determine when the user moves with the mobile Web client from one
`GPS region to another.
`
`Bandera, Ex. 1004 at 8:63-66.
`
`In fact, Java was originally written for use with handheld devices
`and was run on handheld devices as early as 1992.
`
`Petitioners’ Reply, Paper 19 at 7 (citing 1992 Green Project
`demonstration video).
`.
`
`I note that Java was originally written for use with handheld devices
`and was run on handheld devices as early as 1992, approximately ten
`years before the priority date of the ‘748 Patent.
`
`Roman Reply Declaration, Ex. 1018 at ¶ 12.
`
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`
`
`Patent Owner: 2002 Java Could Not Be
`Device-Independent and Obtain GPS Information
`
`Referring to FIG. 6 a JAVA® applet 40 running within a mobile Web
`client 21 is configured to communicate with a 65 GPS 22 so as to
`determine when the user moves with the mobile Web client from one
`GPS region to another.
`
`Bandera, Ex. 1004 at 8:63-66.
`
`Patent Owner’s argument is illogical and would
`render the purported invention inoperable
`
`However, it is well known that invoking a native function — even in the
`full version of standard Java as it existed in 2000 — would preclude
`device independence:
`
`Patent Owner Response, Paper 16 at 13.
`
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`
`
`Patent Owner: 2002 Java Could Not Be
`Device-Independent and Obtain GPS Information
`
`Second, an operating instruction system ("OIS") is provided on each
`supported device. The OIS is separate from the native operating
`system and overlays it. This is the component that allows the
`questionnaire and its tokens to be device independent and run
`unchanged on each supported device:
`Patent Owner Response, Paper 16 at 6.
`
`The OIS is not claimed in the challenged claims
`
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`Patent Owner: 2002 Java Could Not Be
`Device-Independent and Obtain GPS Information
`
`The OIS is not claimed in the challenged claims—
`in fact, the only claim covering the OIS was
`cancelled during prosecution
`
`’748 Patent File History, Ex. 1007 at 185.
`
`’748 Patent File History, Ex. 1007 at 255.
`17
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`
`
`Patent Owner: Java Applets
`Were Not Available in 2002 J2ME
`
`Although the prior art that can be considered in
`inter partes reviews is limited to patents and
`printed publications, it does not follow that we
`ignore the skilled artisan’s knowledge when
`determining whether it would have been obvious
`to modify the prior art.
`Koninklijke Philips N.V. v. Google LLC,
`Case No. 2019-1177 (Fed. Cir. Jan. 30, 2020)
`
`JSR-179 is a Java Application Programming Interface that “produces
`information about the present geographic location of the terminal to Java
`Applications. Work on JSR-179 began at least as early as March 2002. This
`API was designed for J2ME, and allowed for determination of the device’s
`location “using any possible location methods, for example, satellite methods
`like GPS . . . .” Thus, a POSITA would have recognized at the time of
`Barbosa that there was no fundamental impediment to applets receiving
`GPS data [].
`
`Petitioners’ Reply, Paper 19 at 8 (citations omitted).
`
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`
`Patent Owner: Java Applets
`Were Not Available in 2002 J2ME
`
`Although the prior art that can be considered in
`inter partes reviews is limited to patents and
`printed publications, it does not follow that we
`ignore the skilled artisan’s knowledge when
`determining whether it would have been obvious
`to modify the prior art.
`Koninklijke Philips N.V. v. Google LLC,
`Case No. 2019-1177 (Fed. Cir. Jan. 30, 2020)
`
`Referring to FIG. 6 a JAVA® applet 40 running within a mobile Web
`client 21 is configured to communicate with a 65 GPS 22 so as to
`determine when the user moves with the mobile Web client from one
`GPS region to another.
`
`Bandera, Ex. 1004 at 8:63-66
`[Bandera was filed in January 1999 and issued in December 2001]
`
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`Patent Owner: Barbosa + Bandera Is Inoperable
`
`[The] test for obviousness is not whether the
`features of a secondary reference may be bodily
`incorporated into the structure of the primary
`reference.... Rather, the test is what the combined
`teachings of those references would have
`suggested to those of ordinary skill in the art.
`In re Keller,
`642 F.2d 413, 425 (CCPA 1981).
`
`It is “not necessary that the inventions of the references be physically
`combinable to render obvious the invention under review.” In re Sneed, 710
`F.2d 1544, 1550 (Fed. Cir. 1983). “Rather, the test for obviousness
`is what the combined teachings of the references would have suggested to
`those having ordinary skill in the art.” Mouttet, 686 F.3d at 1332-33.
`
`Petitioners’ Reply, Paper 19 at 11-12.
`
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`
`
`Patent Owner: No Disclosure of “Specific Java Code” For the
`Tokenized Questionnaire
`
`For the reasons provided in our ’043 Institution Decision, we construe
`“token” as “a distinguishable unit of a program, such as an index, an
`instruction, or a command that can represent something else such as
`a question, answer, or operation.”
`
`Institution Decision, Paper 14 at 16.
`
`One of the preferred embodiments of the invention is as a set of
`instructions in a code module . . .
`
`Barbosa, Ex. 1002, 5:67-6:2.
`
`Barbosa discloses “templates (e.g., task/punch lists) and/or
`programs,” and a “program” that “asks questions” and can “prompt
`the user for input of data.”
`
`Barbosa, Ex. 1002, 6:60-61, 7:27-28, 9:54-56.
`
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`
`
`Grounds 4, 5
`Claims 1, 2, 5, and 19-22 are obvious over
`Hancock, Hancock + Bandera
`35 U.S.C. § 103
`
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`Patent Owner’s Arguments
`
`Hancock does not disclose a device-independent language
`
`Bandera does not disclose a tokenized questionnaire
`
`Combining Hancock and Bandera would produce a device-
`dependent program on a desktop computer
`
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`
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`Patent Owner: Hancock Does Not Disclose Device-Independent
`Programming
`
`A finding of obviousness, however, cannot be
`overcome by attacking references individually
`where the rejection is based upon the teachings
`of a combination of references.
`
`Bradium Techs. LLC v. Iancu,
`923 F. 3d 1032, 1050 (Fed. Cir. 2019).
`
`Referring to FIG. 6 a JAVA® applet 40 running within a mobile Web
`client 21 is configured to communicate with a 65 GPS 22 . . .
`
`Bandera, Ex. 1004 at 8:63-66.
`
`Java is one of a limited number of programming languages that a
`POSITA would have considered for implementing an application for a
`mobile device such as the Go2 Application. . . . well within the technical
`grasp of a POSITA . . . predictable results . . . obvious design choice.
`Roman Declaration, Ex. 1005 at ¶ 132.
`
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`
`
`Patent Owner: Bandera Does Not Disclose a Tokenized
`Questionnaire
`
`A finding of obviousness, however, cannot be
`overcome by attacking references individually
`where the rejection is based upon the teachings
`of a combination of references.
`
`Bradium Techs. LLC v. Iancu,
`923 F. 3d 1032, 1050 (Fed. Cir. 2019).
`
`[T]he menu . . . allows users to specify one or more features associated
`with the selected category. Feature selections narrow or drill-down the
`subsequent database search.
`
`Hancock, Ex. 1004 at 28:66-29:10.
`
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`
`
`Patent Owner: Bandera Does Not Disclose a Tokenized
`Questionnaire
`
`Hancock, Ex. 1004 at Fig. 17
`(annotated).
`
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`
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`Patent Owner: Combining Hancock and Bandera would produce a
`device-dependent program on a desktop computer
`
`Portable-computing device 1302 comprises a client computer
`1404.
`
`Hancock, Ex. 1004 at 25:9-10.
`
`[A]n application program is installed on the client computer system. The
`application program prompts the user . . .
`
`Hancock, Ex. 1004 at 3:15-20.
`
`Referring to FIG. 6 a JAVA® applet 40 running within a mobile Web
`client 21 is configured to communicate with a 65 GPS 22 . . .
`
`Bandera, Ex. 1004 at 8:63-66.
`
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`
`
`Ground 3
`Claim 7 is obvious over Barbosa in view of Falls - 35
`U.S.C. § 103
`
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`
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`Claim 7 of ’748 Patent
`
`’748 patent, claim 7
`A method for collecting survey
`data from a user and making
`responses available via the
`Internet, comprising: (a) [ ]; (b)
`automatically transferring said
`designed questionnaire to at
`least one loosely networked
`computer having a GPS
`integral thereto; (c) [ ]; (d) [ ];
`(e) automatically transferring
`via the loose network any
`responses so collected in real
`time to a central computer;
`and, (f) making available via
`the Internet any responses
`transferred to said central
`computer in step (e).
`
`Barbosa discloses and renders
`obvious:
`“automatically transferring said
`•
`designed questionnaire to at least one
`loosely networked computer . . . [Step
`(b)];”
`
`•
`
`“automatically transferring via the loose
`network any responses so collected in
`real time to a central computer [Step
`(e)];” and
`
`•
`
`“making available via the Internet any
`responses transferred to said central
`computer . . . [Step (f)].”
`
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`Barbosa’s Disclosure of “Automatically Transferring”
`
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`Barbosa’s Disclosure of “Automatically Transferring”
`
`Referring to FIG. 11, a flow chart outlining a
`method relating to inventory
`tracking/ordering is described.
`Field technicians may utilize a handheld devices
`to ensure that the proper inventory will be
`provided prior to embarking on a daily service
`schedule. The assessor may start an inventory
`program 1101, identify a service schedule 1102,
`and synchronize the schedule 1103 with an
`inventory manager. The inventory manager
`assesses the schedule requirements and provides
`the technician with an inventory availability
`status 1104.
`The technician may coordinate inventory
`needs with the company automatically using
`this method so that no more inventory than is
`needed is taken to the field.”
`
`Barbosa, Ex. 1002 at 11:29 – 40; Fig. 11.
`
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`
`Barbosa’s Disclosure of “Automatically Transferring”
`
`Referring to FIG. 9, a flow chart a method
`relating to project management is described.
`. . . In accordance with the present invention,
`a program managed by a central
`computer/server may track every aspect of a
`project and provide worker with tasks via a
`template. A worker's handheld device (or
`device assigned to the worker for the
`shift) may be synchronized 901 with a
`server to receive an updated template
`containing tasks for the worker at the
`beginning of every work shift. . . .
`The worker reports 903 on the status of
`tasks at the end of the workday via
`synchronization with a server through
`wired and/or wireless means as described
`at the beginning of the disclosure.
`
`Barbosa, Ex. 1002 at 10:32- 53; Fig. 9.
`
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`Barbosa’s Disclosure of “Automatically Transferring”
`
`The investigator may complete a
`checklist by entering data relating to
`the investigation 1203. The checklist
`and/or data may be stored at the
`handheld 1204 for future
`reference, may be transmitted
`1205 to a server for analysis
`(verification), and/or
`synchronized with computer for
`use in furtherance of an
`investigation.
`The ability to manage data from
`several investigators on large-scaled
`cases may be enhanced through the
`present invention, wherein
`comprehensive data form different
`sources may be analyzed, updated and
`reformatted for representation and
`distribution to plural case workers.
`
`Barbosa, Ex. 1002 at 11:50-60; Fig. 12.
`
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`“Automatically Transferring” Was Obvious
`
`It “would have been obvious to transfer the updated inventory questions to
`the remote device ‘automatically’ in light of this disclosure of Barbosa so as
`to ensure efficiency in the communications, i.e., “so that no more inventory
`than is needed is taken to the field.”
`
`“A POSITA would appreciate that the disclosed synchronization process for
`transferring the updated template to be an automatic process; such
`automatic communications ensures that workers are provided the
`appropriate “daily input” and to ensure “that [completed tasks] are not
`repeated (wasting time) and that unfinished task[s] are addressed . . .”
`
`“Further, it would have been obvious to transfer the updated or template
`questionnaire automatically to the workers at the beginning of every work
`shift to efficiently track the desired workflow as a project progresses, as
`Barbosa teaches.”
`
`Roman Reply Declaration, Ex. 1018 at paras. 25 – 27.
`
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`
`
`Barbosa Discloses Making Responses Available “Via
`the Internet”
`
`35
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`
`
`Barbosa’s Disclosure of Making Responses Available
`“Via the Internet”
`Relative to the Internet, a Web
`Browser is a client program that
`requests services (the sending of Web
`pages or files) from a Web server . . .
`in another computer somewhere on
`the Internet.
`
`During program execution, the user
`may access remote resources (e.g.,
`information, data, assistance) via
`wireless communication
`systems 51 and networks 55.
`Information may be obtained from a
`server 58 located at the user's
`enterprise, or from other
`network 55 resources available to the
`user (e.g., Web pages
`provided/obtained over the Internet).
`
`Barbosa, Ex. 1002 at 7:15-19; 7:51-54; Fig. 6.
`
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`
`
`Barbosa’s Disclosure of Making Responses Available
`“Via the Internet”
`
`The worker reports 903 on the status of tasks at the end of the workday
`via synchronization with a server through wired and/or wireless means
`as described at the beginning of the disclosure. An updated template
`is created by the server 904 for a subsequent worker based on the
`project's updated status, needs and prior worker input. Unfinished
`
`An updated template is created by the server 904 for a subsequent An updated template is created by the server 904 for a subsequent
`business recorded by a prior worker and new tasks may be prepared
`
`worker based on the project's updated status, needs and prior worker worker based on the project's updated status, needs and prior worker
`within a template 905 for provision to the subsequent device/worker.
`
`input. Unfinished business recorded by a prior worker and new tasks may input. Unfinished business recorded by a prior worker and new tasks may
`
`be prepared within a template 905 for provision to the subsequent be prepared within a template 905 for provision to the subsequent
`
`device/worker.device/worker.
`The ability to manage data from several investigators on large-scaled
`cases may be enhanced through the present invention, wherein
`comprehensive data from different sources may be analyzed,
`updated and reformatted for representation and distribution to
`plural case workers.
`
`Barbosa, Ex. 1002 at 10:48-56, 11:55-59.
`
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`
`Making Responses Available “Via the Internet” Was
`Obvious
`
`“[U]sing the Internet in the claimed manner would have been obvious to
`a POSITA at the time of the alleged invention in light of the express
`teachings of Barbosa.”
`
`It “would also have been obvious to a POSITA at the time of the alleged
`invention to use the Internet—which even at that time was the largest
`and most ubiquitous network in the world—to send responses from other
`users, e.g., in multi-user environments. This use of the Internet to
`disseminate a user’s responses would facilitate the real-time coordination of
`resources, as discussed throughout Barbosa.”
`
`Roman Reply Declaration, Ex. 1018 at paras. 28, 31, 32.
`
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`
`
`Ground 6
`Claim 7 is obvious over Hancock in view of Falls - 35
`U.S.C. § 103
`
`39
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`’748 patent, claim 7
`
`A method for collecting
`survey data from a user
`and making responses
`available via the
`Internet, comprising: (a)
`[ ]; (b) automatically
`transferring said
`designed questionnaire
`to at least one loosely
`networked computer
`having a GPS integral
`thereto; (c) [ ]; (d) [ ]; (e)
`[ ], (f) making available
`via the Internet any
`responses transferred
`to said central computer
`in step (e).
`
`Claim 7 of ’748 Patent
`
`Hancock discloses and renders
`obvious:
`“automatically transferring said designed
`•
`questionnaire to at least one loosely networked
`computer . . . [Step (b)];”
`
`“making available via the Internet any
`•
`responses transferred to said central computer
`. . . [Step (f)].”
`
`40
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Hancock’s Disclosure of “Automatically Transferring”
`
`41
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Hancock’s Disclosure of “Automatically Transferring”
`
`“FIGS. 13-22 are used to describe a preferred embodiment of an
`automatic location system using the geographical referencing system
`described above.”
`
`“The server is enhanced in accordance with the present invention by
`
`An updated template is created by the server 904 for a subsequent An updated template is created by the server 904 for a subsequent
`automatically determining the location of the client. In one
`
`worker based on the project's updated status, needs and prior worker worker based on the project's updated status, needs and prior worker
`embodiment, the client automatically advises the server of its current
`
`input. Unfinished business recorded by a prior worker and new tasks may input. Unfinished business recorded by a prior worker and new tasks may
`location via a transmission of an electronic data packet or “handshake”
`
`be prepared within a template 905 for provision to the subsequent be prepared within a template 905 for provision to the subsequent
`upon connection. The server uses this information to perform a
`
`device/worker.device/worker.
`database query to retrieve information that is customized for the
`particular location.”
`
`Current location data can be automatically provided by a variety of
`ways.
`
`Hancock, Ex. 1003 at 23:30-34, 3:9-15, and 3:56-58.
`
`42
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Hancock’s Disclosure of “Automatically Transferring”
`
`Currently, services offered on the Internet do not cater to mobile users.
`In fact, it is often cumbersome to interact with current Internet services
`using portable devices due to the interactive nature of on-line sessions
`that generally require substantial user input. This can raise safety
`concerns, for example, in automotive Internet access devices. What is
`needed therefore, is a system and method that provides Internet
`
`An updated template is created by the server 904 for a subsequent An updated template is created by the server 904 for a subsequent
`services to mobile users with reduced user input requirements.
`
`worker based on the project's updated status, needs and prior worker worker based on the project's updated status, needs and prior worker
`
`input. Unfinished business recorded by a prior worker and new tasks may input. Unfinished business recorded by a prior worker and new tasks may
`“[T]he client is automatically presented with a map of the current
`
`be prepared within a template 905 for provision to the subsequent be prepared within a template 905 for provision to the subsequent
`geographical area. This is accomplished automatically, without
`
`device/worker.device/worker.
`additional manual input from the user. This aspect of the present
`invention is especially useful in a mobile environment, such as an
`automobile, where data entry is not only cumbersome, but also
`dangerous.
`
`Hancock, Ex. 1003 at 1:31-39, 3:39-45.
`
`43
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`“Automatically Transferring” Was Obvious
`
`“[A]utomatic transferring would have been obvious based on Hancock’s
`teachings. As noted, Hancock describes each of its preferred embodiments of
`Figs. 13-22 as an “automatic location system.” In addition to its express
`discussion of an “automatic” system, Hancock makes clear that reducing user
`interaction with its system is a key consideration of its invention, given the
`mobile nature of the client devices. For example, it would have been obvious to
`modify the method of Figure 18 to remove any user prompts before questions
`are transferred so as to avoid “dangerous” user interaction.”
`
`“Because automatically transferring questionnaire information would reduce a
`user’s need to interface with Hancock’s software, a POSITA would appreciate
`that the claimed automatic transfer is at least obvious in light of the
`teachings of Hancock as such an automated transfer would enable
`tailored, location-based information with minimal user interaction.”
`
`Roman Reply Declaration, Ex. 1018 at para. 37 (internal citations omitted).
`
`44
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Hancock Discloses Making Responses Available “Via
`the Internet”
`
`45
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Prior Art References – Hancock
`
`Hancock, Ex. 1003.
`
`46
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Hancock’s Disclosure of Making Responses Available
`“Via the Internet”
`
`Hancock, Ex. 1003 at Fig 13.
`47
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Hancock Discloses Making Responses Available “Via
`the Internet”
`
`Hancock, Ex. 1003 at Fig 19.
`48
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Making Responses Available “Via the Internet” Was
`Obvious
`
`It “would have been obvious based on the teaching of Hancock to make
`the responses received by the central server available via the Internet.
`Hancock states that the “Internet 1318 is used in a preferred embodiment of the
`present invention due to its wide use and availability.” Hancock further
`states, “An advantage of the present invention is that users can benefit from the
`virtually unlimited storage capacity and real-time updates of the Internet 1318.
`Because the Internet 1318 is used in a distributed fashion to provide users with
`customized location related information, the information provided to users can
`be as detailed as desired.”
`
`Consistent with Hancock’s touting of the Internet for its wide use and
`distributed nature, it would have been obvious to a POSITA to make
`responses received by the central server available via Internet so as to
`permit other devices on the Internet (like the disclosed enhanced servers) to
`provide additional, detailed information responsive to a user’s query.
`
`Roman Reply Declaration, Ex. 1018 at para. 41 (internal citations omitted).
`
`49
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
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