Exhibit A3
`
`U.S. Patent No. 6,269,336 to Ladd (“Ladd”)
`
`U.S. Patent No. 6,269,336 to Ladd (“Ladd”) discloses and/or renders obvious Claims 1, 2, 4, 5, 6, 7, 9, 10, 13, and 14 of U.S. Patent
`No. 7,076,431 alone and/or in combination with other references, as set forth in the chart below. Defendants incorporate in this chart
`all applicable qualifications, clarifications, and other statements made in Defendants’ Invalidity Contentions. This invalidity claim
`chart is based on Defendants’ present understanding of Claims 1, 2, 4, 5, 6, 7, 9, 10, 13, and 14 and Parus’s apparent construction of
`the claims, as set forth in Parus’s Infringement Contentions. Defendants are not adopting Parus’s apparent constructions, nor are
`Defendants admitting the accuracy of any particular construction. Where the chart below states that the reference ‘discloses’ a
`limitation, such disclosure may be express, inherent, or implicit. Moreover, to the extent the Court finds that this reference does not
`disclose certain limitations in the asserted claims, such limitations would have been obvious. By mapping claim language to this
`reference, Defendants do not imply or admit that the claim language satisfies 35 U.S.C. § 112. To the extent any cell lacks citations to
`the charted reference, this should not be taken as an admission that the reference does not disclose the corresponding limitation but
`rather indicates that Defendants do not presently intend to rely on the reference as disclosing the limitation based on Defendants’
`present understanding of the claim limitation.
`
`
`
`U.S. Patent No.
`7,076,431
`[1.pre] A system
`for retrieving
`information from
`pre-selected web
`sites by uttering
`speech
`commands into a
`voice enabled
`device and for
`providing to
`users retrieved
`information in an
`audio form via
`
`Ladd
`To the extent the preamble is limiting, Ladd discloses and/or renders obvious a system for retrieving information
`from pre-selected web sites by uttering speech commands into a voice enabled device and for providing to users
`retrieved information in an audio form via said voice enabled device.
`
`See, e.g.,
`
`“The present invention generally relates to information retrieval, and more particular[ly], to methods and systems
`to allow a user to access information from an information source.” (1:22-25.)
`
`“Referring now to the drawings, and more particularly to FIG. 1, a block diagram of a system 100 is illustrated to
`enable a user to access information. The system 100 generally includes one or more network access apparatus
`102 (one being shown), an electronic network 104, and one or more information Sources or content providers
`106 (one being shown).” (2:19-25.)
`
`sf-4164938
`
`1
`
`Parus Exhibit 2002
`Apple Inc. v. Parus Holdings, Inc.
`IPR2020-00686
`Page 1 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`said voice
`enabled device,
`said system
`comprising:
`
`Ladd
`
`
`“The system 100 enables users to access information from any location in the world via any suitable network
`access device. The users can include, but are not limited to, cellular subscribers, wireline subscribers, paging
`subscribers, satellite subscribers, mobile or portable phone subscribers, trunked radio Subscribers, computer
`network subscribers (i.e., internet subscribers, intranet subscribers, etc.), branch office users, and the like.The
`users can preferably access information from the information source 106 using voice inputs or commands. For
`example, the users can access up-to-date information, such as, news updates, designated city weather, traffic
`conditions, stock quotes, calendar information, user information, address information, and stock market
`indicators. The system also allows the users to perform various transactions (i.e., order flowers, place orders
`from restaurants, place buy and sell stock orders, obtain bank account balances, obtain telephone numbers,
`receive directions to various destinations, etc.).” (2:40-58.)
`
`“As shown in FIG. 1, a user utilizes the network access apparatus 102 of the system 100 to communicate and/or
`connect with the electronic network 104. The electronic network 104 retrieves information from the information
`source 106 based upon speech commands or DTMF tones from the user.” (2:59-64.)
`
`
`
`
`
`
`“The information source 106 can be identified by an electronic address using at least a portion of a URL
`(Uniform Resource Locator), a URN (Uniform Resource Name), an IP (Internet Protocol) address, an electronic
`mail address, a device address (i.e. a pager number), a direct point to point connection, a memory address, etc. It
`is noted that a URL can include: a protocol, a domain name, a path, and a filename. URL protocols include:
`“file:” for accessing a file stored on a local storage medium; "ftp:” for accessing a file from an FTP (file transfer
`
`sf-4164938
`
`2
`
`Parus Exhibit 2002, Page 2 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`Ladd
`protocol) server; “http:” for accessing an HTML (hypertext marking language) document; "gopher:' for accessing
`a Gopher Server, "mailto:” for sending an e-mail message, “news: for linking to a Usenet newsgroup, “telnet: for
`opening a telnet session; and “wais:” for accessing a WAIS server.” (3:8-23.)
`
`“The network access apparatus 102 of the system 100 allows the user to access (i.e., view and/or hear) the
`information retrieved from the information source. The network access apparatus can provided the information to
`the user as machine readable data, human readable data, audio or speech communications, textual information,
`graphical or image data, etc. The network access apparatus can have a variety of forms, including but not limited
`to, a telephone, a mobile phone, an office phone, a home phone, a pay phone, a paging unit, a radio unit, a web
`phone, a personal information manager (PIM), a personal digital assistant (PDA), a general purpose computer, a
`network television, an Internet television, an Internet telephone, a portable wireless device, a WorkStation, or
`any other Suitable communication device.” (3:40-53.)
`
`“The system 200 enables a user to access information from any location in the World via a suitable
`communication device. The system 200 can provide access to yellow pages, directions, traffic, addresses,
`movies, concerts, airline information, weather information, news reports, financial information, flowers, personal
`data, calendar data, address data, gifts, books, etc. The user can also perform a series of transactions without
`having to terminate the original call to the system. For example, the user can access a news update and obtain
`weather information, all without having to dial additional numbers or terminate the original call. The system 200
`also enables application developers to build applications for interactive speech applications using a markup
`language, Such as VoxML voice markup language developed by Motorola, Inc.” (4:64-5:11.)
`
`“In response to audio inputs from the user, the communication node 212 retrieves information from a destination
`or database of one or more of the information sources, such as the content providers 208 and 209 or the markup
`language servers. After the communication node 212 receives the information, the communication node provides
`a response to the user based upon the retrieved information.” (6:17-25.)
`
`
`
`sf-4164938
`
`3
`
`Parus Exhibit 2002, Page 3 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`Ladd
`
`(FIG. 9)
`
`sf-4164938
`
`
`
`4
`
`Parus Exhibit 2002, Page 4 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`Ladd
`
`
`
`(FIG. 2.)
`
`“The response is then sent to the VRU client 232. The VRU client processes the response and reads an audio
`message to the user based upon the response.” (9:19-21.)
`
`To the extent that Parus contends Ladd does not disclose or render obvious this claim element, this claim element
`is obvious in light of a combination of Ladd with the knowledge of ordinary skill in the art or one or more other
`references. See e.g., Exs. A1-A25, preamble; Exs. B1-B18, preamble; Ex. C, preamble; and Defendants’
`Invalidity Contentions.
`
`Ladd discloses and/or renders obvious a computer, said computer operatively connected to the internet.
`
`
`5
`
`[1.a] a computer,
`said computer
`
`sf-4164938
`
`Parus Exhibit 2002, Page 5 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`operatively
`connected to the
`internet;
`
`Ladd
`
`See, e.g.,
`
`“The system 100 generally includes one or more network access apparatus 102 (one being shown), an electronic
`network 104, and one or more information sources or content providers 106 (one being shown). The electronic
`network 104 is connected to the network
`access apparatus 102 via a line 108, and the electronic network 102 is connected to the information source 106
`via a line 110. The lines 108 and 110 can include, but are not limited to, a telephone line or link, an ISDN line, a
`coaxial line, a cable television line, a fiber optic line, a computer network line, a digital subscriber line, or the
`like.” (2:22-33.)
`
`“The information of the information source 106 can be accessed over any suitable communication medium. The
`information source 106 can be identified by an electronic address using at least a portion of a URL (Uniform
`Resource Locator), a URN (Uniform Resource Name), an IP (Internet Protocol) address, an electronic mail
`address, a device address (i.e. a pager number), a direct point to point connection, a memory address, etc. It is
`noted that a URL can include: a protocol, a domain name, a path, and a filename. URL protocols include: “file:”
`for accessing a file stored on a local storage medium; "ftp:” for accessing a file from an FTP (file transfer
`protocol) server; “http:” for accessing an HTML (hypertext marking language) document; "gopher:' for accessing
`a Gopher server, "mailto:” for sending an e-mail message, “news: for linking to a Usenet newsgroup, “telnet: for
`opening a telnet session; and “wais:” for accessing a WAIS server.” (3:7-23.)
`
`“The electronic network 104 can include an open, wide area network such as the Internet, the World Wide Web
`(WWW), and/or an on-line service. The electronic network 104 can also include, but is not limited to, an
`intranet, an extranet, a local area network, a telephone
`network, (i.e., a public switched telephone network), a cellular telephone network, a personal communication
`system (PCS) network, a television network (i.e., a cable television system), a paging network (i.e., a local
`paging network), a regional paging network, a national or a global paging network, an email system, a wireless
`data network (i.e., a satellite data network or a local wireless data network), and/or a telecommunication node.”
`(3:27-39.)
`
`“The network access apparatus 102 may also include a voice or web browser, such as, a Netscape Navigator(R)
`web browser, a Microsoft Internet Explorer(R) web browser, a Mosaic web browser, etc.” (3:58-61.)
`
`sf-4164938
`
`6
`
`Parus Exhibit 2002, Page 6 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`Ladd
`
`
`“Although the communication node 206 is shown as being constructed with various types of independent and
`separate units or devices, the communication node 212 can be implemented by one or more integrated circuits,
`microprocessors, microcontrollers, or computers which may be programmed to execute the operations or
`functions equivalent to those performed by the device or units shown. It will also be recognized that the
`communication node 212 can be carried out in the form of hardware components and circuit designs, software or
`computer programming, or a combination thereof.” (7:7-17.)
`
`“In response to the inputs from the user, the node 212 retrieves information from a destination of one of the
`information sources and provides outputs to the user based upon the information.” (7:52-56.)
`
`
`(FIG. 3.)
`
`
`
`
`
`sf-4164938
`
`7
`
`Parus Exhibit 2002, Page 7 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`[1.b] a voice
`enabled device
`operatively
`connected to said
`computer, said
`voice enabled
`device
`configured to
`receive speech
`commands from
`users;
`
`Ladd
`To the extent that Parus contends Ladd does not disclose or render obvious this claim element, this claim element
`is obvious in light of a combination of Ladd with the knowledge of ordinary skill in the art or one or more other
`references. See e.g., Exs. A1-A25, limitation 1.a; Exs. B1-B18, limitation 1.a; Ex. C, limitation 1.a; and
`Defendants’ Invalidity Contentions.
`
`Ladd discloses and/or renders obvious a voice enabled device operatively connected to said computer, said voice
`enabled device configured to receive speech commands from users.
`
`See, e.g.,
`
`“As shown in FIG. 1, a user utilizes the network access apparatus 102 of the system 100 to communicate and/or
`connect with the electronic network 104. The electronic network 104 retrieves information from the information
`source 106 based upon speech commands or DTMF tones from the user.” (2:59-64.)
`
`“The system may also identify the user by detecting a unique speech pattern from the user (i.e., speaker
`verification) or a PIN entered using voice commands or DTMF tones.” (4:15-18.)
`
`“At block 156, the electronic network waits for an input or command from the user that corresponds to a
`destination of the information source desired by the user. The input can be
`audio commands (i.e., speech) or DTMF tones.” (4:37-40.)
`
`“The electronic network preferably determines an electronic address of the information source (i.e., URL, a
`URN, an IP address, or an electronic mail address) based upon the inputs from the user (i.e., speech or DTMF
`tones).” (4:43-47.)
`
`
`sf-4164938
`
`8
`
`Parus Exhibit 2002, Page 8 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`Ladd
`
`
`
`(FIG. 3.)
`
`“The communication devices can include, but are not limited to, landline or wireline devices (i.e., home phones,
`work phones, computers, facsimile machines, pay phones), wireless devices (i.e., mobile phones, trunked radios,
`hand held devices, PIMs, PDAs, etc.), network access devices (i.e. computers), pagers, etc. The communication
`devices can include a microphone, a speaker, and/or a display.” (5:29-36.)
`
`“Referring now to FIG. 3, an exemplary block diagram of an embodiment of a system 200 to enable a user to
`access information is shown. The system 200 enables a user to access information from any location in the world
`via a suitable communication device. The system 200 can provide access to yellow pages, directions, traffic,
`addresses, movies, concerts, airline information, weather information, new reports, financial information,
`flowers, personal data, calendar data, address data, gifts, books, etc. The user can also perform a series of
`transactions without having to terminate the original call to the system. For example, the user can access a news
`update and obtain weather information, all without having to dial additional numbers or terminate the original
`
`sf-4164938
`
`9
`
`Parus Exhibit 2002, Page 9 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`[1.c] at least one
`speaker-
`independent
`speech
`recognition
`device, said
`speaker-
`independent
`speech
`recognition
`device
`operatively
`connected to said
`computer and to
`said voice
`enabled device;
`
`sf-4164938
`
`Ladd
`call. The system 200 also enables application developers to build applications for interactive speech applications
`using a markup language, such as VoxML™ voice markup language developed by Motorola, Inc.” (4:62-5:11.)
`
`“The VRU client 232 of the communication node 212 is preferably connected to the VRU server 234 and the
`LAN 240. The VRU client 232 processes speech communications, DTMF tones, pages, and messages (i.e.,
`emails) from the user. Upon receiving speech communications from the user, the VRU client 232 routes the
`speech communications to the VRU Server 234.” (8:3-8.)
`
`To the extent that Parus contends Ladd does not disclose or render obvious this claim element, this claim element
`is obvious in light of a combination of Ladd with the knowledge of ordinary skill in the art or one or more other
`references. See e.g., Exs. A1-A25, limitation 1.b; Exs. B1-B18, limitation 1.b; Ex. C, limitation 1.b; and
`Defendants’ Invalidity Contentions.
`
`
`Ladd discloses and/or renders obvious at least one speaker-independent speech recognition device, said speaker-
`independent speech recognition device operatively connected to said computer and to said voice enabled device.
`
`See, e.g.,
`
`“At block 156, the electronic network waits for an input or command from the user that corresponds to a
`destination of the information source desired by the user. The input can be
`audio commands (i.e., speech) or DTMF tones.” (4:37-40.)
`
`“The electronic network preferably determines an electronic address of the information source (i.e., URL, a
`URN, an IP address, or an electronic mail address) based upon the inputs from the user (i.e., speech or DTMF
`tones).” (4:43-47.)
`
`“The node 212 can provide various dialog voice personalities (i.e., a female voice, a male voice, etc.) and can
`implement various grammars (i.e., vocabulary) to detect and respond to the audio inputs from the user. In
`addition, the communication node can automatically select various speech recognition models (i.e., an English
`model, a Spanish model, an English accent model, etc.) based upon a user profile, the user's communication
`
`10
`
`Parus Exhibit 2002, Page 10 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`Ladd
`device, and/or the user's speech patterns. The communication node 212 can also allow the user to select a
`particular speech recognition model.” (6:25-36.)
`
`“As shown in FIG. 3, the communication node 212 preferably includes a telephone switch 230, a voice or audio
`recognition (VRU) client 232, a voice recognition (VRU) server 234, a controller or call control unit 236, an
`Operation and Maintenance Office (OAM) or a billing server unit 238, a local area network (LAN) 240, an
`application server unit 242, a database server unit 244, a gateway server or router firewall server 246, a voice
`over internet protocol (VOIP) unit 248, a voice browser 250, a markup language server 251, and a paging server
`252.” (6:65-7:7.)
`
`
`(FIG. 3.)
`
`“The voice communication processing boards of the VRU client 232 are preferably Dialogic boards, Model No.
`Antares, available from Dialogic Corporation, 1515 Route 10, Parsippany, N.J. 07054. The voice communication
`boards may include a voice recognition engine having a vocabulary for detecting a speech pattern (i.e., a key
`
`
`
`sf-4164938
`
`11
`
`Parus Exhibit 2002, Page 11 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`[1.d] at least one
`speech synthesis
`device, said
`speech synthesis
`
`sf-4164938
`
`Ladd
`word or phrase). The voice recognition engine is preferably a RecServer software package, available from
`Nuance Communications, 138.0 Willow Road, Menlo Park, Calif. 94025.” (8:19-28.)
`
`“The VRU server 234 preferably includes a text-to-speech (TTS) unit 252, an automatic speech recognition
`(ASR) unit 254, and a speech-to-text (STT) unit 256.” (9:1-3.)
`
`“The ASR unit 254 of the VRU server 234 provides speaker independent automatic speech recognition of speech
`inputs or communications from the user. It is contemplated that the ASR unit 254 can include speaker dependent
`speech recognition. The ASR unit 254 processes the speech inputs from the user to determine whether a word or
`a speech pattern matches any of the grammars or vocabulary stored in the database server unit 244 or
`downloaded from the voice browser. When the ASR unit 254 identifies a selected speech pattern of the speech
`inputs, the ASR unit 254 sends an output signal to implement the specific function associated with the
`recognized voice pattern. The ASR unit 254 is preferably a speaker independent speech recognition software
`package, Model No. RecServer, available from Nuance Communications. It is contemplated that the ASR unit
`254 can be any suitable speech recognition unit to detect voice communications from a user. The STT unit 256
`of the VRU server 234 receives speech inputs or communications from the user and converts the speech inputs to
`textual information (i.e., a text message). The textual information can be sent or routed to the communication
`devices 201, 202, 203 and 204, the content providers 208 and 209, the markup language servers, the voice
`browser, and the application server 242. The STT unit 256 is preferably a Naturally Speaking software package,
`available from Dragon Systems, 320 Nevada Street, Newton, Mass. 02160-9803.” (9:27-54.)
`
`To the extent that Parus contends Ladd does not disclose or render obvious this claim element, this claim element
`is obvious in light of a combination of Ladd with the knowledge of ordinary skill in the art or one or more other
`references. See e.g., Exs. A1-A25, limitation 1.c; Exs. B1-B18, limitation 1.c; Ex. C, limitation 1.c; and
`Defendants’ Invalidity Contentions.
`
`
`Ladd discloses and/or renders obvious at least one speech synthesis device, said speech synthesis device
`operatively connected to said computer and to said voice enabled device.
`
`See, e.g.,
`
`12
`
`Parus Exhibit 2002, Page 12 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`device
`operatively
`connected to said
`computer and to
`said voice
`enabled device;
`
`Ladd
`
`
`“At block 160, the electronic network retrieves at least a portion of the information from the destination of the
`information source at block 160. The electronic network processes the information and then provides an output
`to the user based upon the retrieved information at block 162. The output can include a speech communication,
`textual information, and/or graphical information. For example, the electronic network can provide a speech
`communication using speech-to-text technology or human recorded speech.” (4:50-58.)
`
`“The communication devices can include, but are not limited to, landline or wireline devices (i.e., home phones,
`work phones, computers, facsimile machines, pay phones), wireless devices (i.e., mobile phones, trunked radios,
`hand held devices, PIMs, PDAs, etc.), network access devices (i.e. computers), pagers, etc. The communication
`devices can include a microphone, a speaker, and/or a display.” (5:29-36.)
`
`“As shown in FIG. 3, the communication node 212 preferably includes a telephone switch 230, a voice or audio
`recognition (VRU) client 232, a voice recognition (VRU) server 234, a controller or call control unit 236, an
`Operation and Maintenance Office (OAM) or a billing server unit 238, a local area network (LAN) 240, an
`application server unit 242, a database server unit 244, a gateway server or router firewall server 246, a voice
`over internet protocol (VOIP) unit 248, a voice browser 250, a markup language server 251, and a paging server
`252.” (6:65-7:7.)
`
`
`sf-4164938
`
`13
`
`Parus Exhibit 2002, Page 13 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`Ladd
`
`
`
`(FIG. 3.)
`
`“The TTS unit 252 can provide data to the VRU client 232 which reads or plays the data to the user. For
`example, when the user requests information (i.e., news updates, stock information, traffic conditions, etc.), the
`communication node 212 retrieves the desired data (i.e., textual information) from a destination of the one or
`more of the information sources and converts the data via the TTS unit 252 into a response. The response is then
`sent to the VRU client 232. The VRU client processes the response and reads an audio message to the user based
`upon the response. It is contemplated that the VRU server 234 can read the audio message to the user using
`human recorded speech or synthesized speech. The TTS unit 252 is preferably a TTS 2000 software package,
`available from Lernout and Hauspie Speech Product NV, 52 Third Avenue, Burlington, Mass. 01803.” (9:11-
`27.)
`
`To the extent that Parus contends Ladd does not disclose or render obvious this claim element, this claim element
`is obvious in light of a combination of Ladd with the knowledge of ordinary skill in the art or one or more other
`
`sf-4164938
`
`14
`
`Parus Exhibit 2002, Page 14 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`[1.e] at least one
`instruction set for
`identifying said
`information to be
`retrieved, said
`instruction set
`being associated
`with said
`computer, said
`instruction set
`comprising:
`
`Ladd
`references. See e.g., Exs. A1-A25, limitation 1.d; Exs. B1-B18, limitation 1.d; Ex. C, limitation 1.d; and
`Defendants’ Invalidity Contentions.
`
`Ladd discloses and/or renders obvious at least one instruction set for identifying said information to be retrieved,
`said instruction set being associated with said computer, said instruction set comprising.
`
`See, e.g.,
`
`“The information of the information source 106 can be accessed over any suitable communication medium. The
`information source 106 can be identified by an electronic address using at least a portion of a URL (Uniform
`Resource Locator), a URN (Uniform Resource Name), an IP (Internet Protocol) address, an electronic mail
`address, a device address (i.e. a pager number), a direct point to point connection, a memory address, etc. It is
`noted that a URL can include: a protocol, a domain name, a path, and a filename. URL protocols include: “file:”
`for accessing a file stored on a local storage medium; "ftp:” for accessing a file from an FTP (file transfer
`protocol) server; “http:” for accessing an HTML (hypertext marking language) document; "gopher:' for accessing
`a Gopher server, "mailto:” for sending an e-mail message, “news: for linking to a Usenet newsgroup, “telnet: for
`opening a telnet session; and “wais:” for accessing a WAIS server.” (3:7-23.)
`
`“At block 156, the electronic network waits for an input or command from the user that corresponds to a
`destination of the information source desired by the user. The input can be audio commands (i.e., speech) or
`DTMF tones. After the electronic network receives the input from the user, the electronic network establishes a
`connection or a link to the information source at block 158. The electronic network preferably determines an
`electronic address of the information source (i.e., URL, a URN, an IP address, or an electronic mail address)
`based upon the inputs from the user (i.e., speech or DTMF tones). The electronic address can be retrieved from a
`database using a look-up operation based upon at least a portion of the input.” (4:37-49.)
`
`“The VRU client 232 preferably comprises a computer, such as, a Windows NT compatible computer with
`hardware capable of connecting individual telephone lines directly to the switch 230. The VRU client preferably
`includes a microprocessor, random access memory, read-only memory, a T1 or ISDN interface board, and one or
`more voice communication processing board (not shown).” (8:13-19.)
`
`
`sf-4164938
`
`15
`
`Parus Exhibit 2002, Page 15 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`Ladd
`“The VRU server 234 processes the speech communications and compares the speech communications against a
`vocabulary or grammar stored in the database server unit 244 or a memory device. The VRU Server 234
`provides output signals, representing the result of the speech processing, to the LAN 240.” (8:58-63.)
`
`“The application server 242 of the communication node 212 is preferably connected to the LAN 240 and the
`content provider 209. The application server 242 allows the communication node 212 to access information from
`a destination of the information sources, such as the content providers and markup language servers. For
`example, the application server can retrieve information (i.e., weather reports, stock information, traffic reports,
`restaurants, flower shops, banks, etc.) from a destination of the information sources.” (10:58-66.)
`
` “The voice browser 250 of the system 200 is preferably connected to the LAN 240. The voice browser 250
`preferably receives information from the information sources, such as the content provider 209 via the
`application server 242, the markup language servers 251 and 257, the database 244, and the content provider
`208. In response to voice inputs from the user or DTMF tones, the voice browser 250 generates a content request
`(i.e., an electronic address) to navigate to a destination of one or more of the information sources. The content
`request can use at least a portion of a URL, a URN, an IP, a page request, or an electronic email. After the voice
`browser is connected to an information source, the voice browser preferably uses a TCP/IP connect to pass
`requests to the information source. The information source responds to the requests, sending at least a portion of
`the requested information, represented in electronic form, to the voice browser.” (11:25-42.)
`
`“The content providers 208 and 209 can include a server to operate web pages or documents in the form of a
`markup language. The content providers 208 and 209 can also include a database, scripts, and/or markup
`language documents or pages.” (11:56-59.)
`
`
`
`
`sf-4164938
`
`16
`
`Parus Exhibit 2002, Page 16 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`Ladd
`
`
`“The example shown above illustrates the use of the OPTION element to select one of three applications. Note
`that the URLs used in the NEXT attributes are full HTTP URLs, and that unlike the previous example, each
`OPTION element has a unique NEXT attribute.” (28:20-36.)
`
`
`
`
`
`“In the example shown above, the RENAME element is used to account for differences in the variable names
`collected from a grammar and those expected by another script. In particular, a grammar from foo.com is used to
`provide input to an application hosted by fancyquotes.com. Because, in this example, the grammar and script
`
`
`
`sf-4164938
`
`17
`
`Parus Exhibit 2002, Page 17 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`[1.f] a plurality of
`pre-selected web
`site addresses,
`each said web
`site address
`identifying a web
`site containing
`said information
`to be retrieved;
`
`Ladd
`have been developed independently, the RENAME element is used to help connect the grammar and the stock-
`quoting application.” (35:20-33.)
`
`To the extent that Parus contends Ladd does not disclose or render obvious this claim element, this claim element
`is obvious in light of a combination of Ladd with the knowledge of ordinary skill in the art or one or more other
`references. See e.g., Exs. A1-A25, limitation 1.e; Exs. B1-B18, limitation 1.e; Ex. C, limitation 1.e; and
`Defendants’ Invalidity Contentions.
`
`
`Ladd discloses and/or renders obvious a plurality of pre-selected web site addresses, each said web site address
`identifying a web site containing said information to be retrieved.
`
`See, e.g.,
`
`“The information of the information source 106 can be accessed over any suitable communication medium. The
`information source 106 can be identified by an electronic address using at least a portion of a URL (Uniform
`Resource Locator), a URN (Uniform Resource Name), an IP (Internet Protocol) address, an electronic mail
`address, a device address (i.e. a pager number), a direct point to point connection, a memory address, etc. It is
`noted that a URL can include: a protocol, a domain name, a path, and a filename. URL protocols include: “file:”
`for accessing a file stored on a local storage medium; "ftp:” for accessing a file from an FTP (file transfer
`protocol) server; “http:” for accessing an HTML (hypertext marking language) document; "gopher:' for accessing
`a Gopher server, "mailto:” for sending an e-mail message, “news: for linking to a Usenet newsgroup, “telnet: for
`opening a telnet session; and “wais:” for accessing a WAIS server.” (3:7-23.)
`
`“At block 156, the electronic network waits for an input or command from the user that corresponds to a
`destination of the information source desired by the user. The input can be audio commands (i.e., speech) or
`DTMF tones. After the electronic network receives the input from the user, the electronic network establishes a
`connection or a link to the information source at block 158. The electronic network preferably determines an
`electronic address of the information source (i.e., URL, a URN, an IP address, or an electronic mail address)
`based upon the inputs from the user (i.e., speech or DTMF tones). The electronic address can be retrieved from a
`database using a look-up operation based upon at least a portion of the input.” (4:37-49.)
`
`sf-4164938
`
`18
`
`Parus Exhibit 2002, Page 18 of 44
`
`

`

`U.S. Patent No.
`7,076,431
`
`Ladd
`
`
`“The system 200 generally includes one or more communication devices or network access apparatus 201, 202,
`203 and 204 (four being s