Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Plaintiff Express Mobile accuses Defendant Google LLC (“Google”) of making, using, offering for sale, and/or selling in the United
`States and/or importing into the United States the Google Docs platform, including docs.google.com and the Google Docs mobile app
`available for Apple iOS devices (including iPads, iPhones, and iPod Touch) on Apple’s App Store, Android devices (including phones
`and tablets) on the Google Play Store, and related software and servers that afford users access to a system for generating code to
`provide content on a display of a device (collectively, the “Accused Instrumentalities”). The term “Accused Instrumentalities”
`includes the associated computer software and data, associated hardware, and processes and methods related thereto. Google directly
`infringes U.S. Patent No. 9,471,287 (the “’287 Patent”) by making, using, offering for sale, selling in and/or importing into the United
`States the Accused Instrumentalities, which meet each and every limitation of the claims as shown in the charts below. Google may
`have infringed and continues to infringe the ’287 Patent through other software and systems utilizing the same or reasonably similar
`functionality, including other versions of the Accused Instrumentalities. Google has infringed, and continues to infringe, at least the
`claims of the ’287 Patent listed below in the United States by performing and/or directing its users to perform one or more steps of the
`claims and/or conditioning the use of the Accused Instrumentalities and/or receipt of a benefit upon a user’s performance of one or
`more steps, and establishing the manner or timing of that performance. Google conditions the use of its service upon the performance
`of one or more steps of the claimed method of the ’287 Patent by requiring a user to navigate its system in an infringing manner, and
`profits from such an arrangement by charging the certain users a fee for subscribing to the service. Google also conditions the receipt
`of a benefit by a user, i.e., the user benefits by being able to access the system and design a Google Docs document, by requiring the
`user to navigate its system in an infringing manner. Google establishes the manner or timing of a user’s performance of one or more
`steps because the Google software limits how the user can interact with the document creation system. The acts of Google’s service
`providers, such as those that provide infrastructure, hosting, and/or tracking services are also attributable to Google, at least because
`Google receives the services of these service providers by agreement. An analysis of the contracts between these parties will be
`necessary to fully and accurately describe the reasons their acts are attributable to Google and, accordingly, Plaintiff reserves the right
`to supplement these infringement contentions once such information is made available to Plaintiff.
`
`Google markets Google Docs both individually and as a product through Google Workspace (formerly known as G Suite), which
`includes Google Docs as a service for a monthly per user fee. Plaintiff accuses both Google Docs in an individual capacity and
`Google Docs as part of Google Workspace, as well as any other offerings or versions of the Google Docs platform or system.
`
`Google induces infringement of the ’287 Patent by providing to third parties including users, customers, agents and others the
`Accused Instrumentalities to utilize in an infringing manner, as charted below, and intends to cause infringement by such third parties
`as Google instructs and/or controls and directs third parties to use the Accused Instrumentalities in an infringing manner, including
`without limitation by instructing the users to operate Google products, such as those located at docs.google.com. Google also
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`GOOGLE EXHIBIT 1045
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`provides support services for the Accused Instrumentalities, including providing instructions, guides, online materials and technical
`support.
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`Google contributes to infringement of the ’287 Patent by providing its document creation service and/or software to its subscribers,
`which comprises the claimed system and steps, as charted below. Google knows portions of the Accused Instrumentalities to be
`especially made or especially adapted for use in infringement of the ’287 Patent, and not to be staple articles, and not to be
`commodities of commerce suitable for substantial noninfringing use.
`
`The asserted claims include elements that are implemented, at least in part, by proprietary and specialized firmware and/or software in
`the Accused Instrumentalities. The precise designs, processes, and algorithms used in them are held secret, at least in part, and are not
`publicly available in their entirety. An analysis of Google’s documentation and/or source code may be necessary to fully and
`accurately describe all infringing features and functionality of the Accused Instrumentalities and, accordingly, Plaintiffs reserve the
`right to supplement these contentions once such information is made available to Plaintiffs. Furthermore, Plaintiffs reserve the right to
`revise these contentions, including as discovery in the case progresses, in view of any non-infringement arguments Google may make
`(e.g., to allege infringement under the doctrine of equivalents), in view of the Court's final claim construction in this action and in
`connection with the provision of expert reports.
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`Claim
`1. A system for generating code
`to provide content on a display of
`a device, said system comprising:
`
`Accused Instrumentalities
`The Accused Instrumentalities comprise a system for generating code to provide content on a display of a
`device.
`
`As shown below, the Google Docs system provides dynamically generated and editable content
`comprising user-designed documents through an authoring tool and environment.
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Accused Instrumentalities
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
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`computer memory storing a
`registry of:
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`Accused Instrumentalities
`Source: Screenshots from the Google Docs creation tool at docs.google.com
`Live as of October 20, 2020
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`The Accused Instrumentalities store the content and settings adjustments in a database consisting of
`computer memory storing a registry as shown below. A user can save and return to a given document,
`and all of their settings are reflected and preserved, both in the editor and in the preview. A user can
`also save sets of specific user selectable settings (such as “Styles”) for use across multiple documents, as
`shown below.
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
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`Accused Instrumentalities
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`Source: Screenshots from the Google Docs creation tool at docs.google.com
`Live as of October 20, 2020
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
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`a) symbolic names required for
`evoking one or more web
`components each related to a set
`of inputs and outputs of a web
`service obtainable over a
`network, where the symbolic
`names are character strings that
`do not contain either a persistent
`address or pointer to an output
`value accessible to the web
`service, where each symbolic
`name has an associated data
`format class type corresponding
`to a subclass of User Interface
`(UI) objects that support the data
`format type of the symbolic
`name, and where each symbolic
`name has a preferred UI object,
`and
`
`Accused Instrumentalities
`
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`The Accused Instrumentalities include symbolic names required for evoking one or more web
`components each related to a set of inputs and outputs of a web service obtainable over a network,
`where the symbolic names are character strings that do not contain either a persistent address or pointer
`to an output value accessible to the web service, where each symbolic name has an associated data
`format class type corresponding to a subclass of User Interface (UI) objects that support the data format
`type of the symbolic name, and has a preferred UI object.
`
`The Accused Instrumentalities’ creation tool allows a user to select from a variety of different web
`components (such as styles applied to an entire document or portions thereof, or a document itself), and
`each document has its own set of unique user selectable settings. For example, as shown below, a user
`can customize the “default styles” available when editing a document. These default styles are saved to
`the Google database and reflected in the styles pane for any document across any device used by the
`user, giving that symbolic name, such as a parameter name, to that preferred UI object. Also, as shown
`below, a user can customize sections of the document using these styles. The inputs and outputs of the
`web service are shown (for example, input being the individual modifications that make up a style to be
`saved, and the output being the preview of that style saved in the default styles bar and the modifications
`to be applied to any text given that style). These defined UI objects are selected by a user of the
`authoring tool as they edit the content of the document or the default styles. The symbolic names for
`these styles are character strings not containing either a persistent address or pointer to an output value
`accessible to the web service, and each symbolic name has an associated data format class type
`corresponding to a subclass of UI objects.
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Accused Instrumentalities
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
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`Accused Instrumentalities
`An analysis of source code may be necessary to fully and accurately describe functionality of the
`Accused Instrumentality with respect to this limitation and, accordingly, Plaintiff reserves the right to
`supplement these infringement contentions once such information is made available to Plaintiff.
`
`Source: Screenshots from the Google Docs creation tool at docs.google.com
`Live as of October 20, 2020
`b) an address of the web service; The Accused Instrumentalities store an address of the web service. As described above, the computer
`memory stores both the Doc itself and a persistent address of the web service that relates to that
`document saved by a user. As shown below, a user accessing saved Docs does so by referencing that
`persistent address (shown below after the saved Doc is selected).
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
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`Accused Instrumentalities
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`Source: Screenshots from the Google Docs creation tool at docs.google.com
`Live as of October 20, 2020
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
`an authoring tool configured to:
`define a UI object for
`presentation on the display,
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`Accused Instrumentalities
`The Accused Instrumentalities comprise an authoring tool configured to define a UI object for
`presentation on the display as shown below. A user can configure individual UI objects, including for
`example each individual document as well as a style of a section of the document and selectable styles of
`text to be displayed by the corresponding UI objects in the editing display.
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
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`where said defined UI object
`corresponds to a web component
`included in said registry selected
`from a group consisting of an
`input of the web service and an
`output of the web service, where
`each defined UI object is either:
`
`
`
`selected by a user of the
`1)
`authoring tool; or
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`Accused Instrumentalities
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`An analysis of source code may be necessary to fully and accurately describe functionality of the
`Accused Instrumentalities with respect to this limitation and, accordingly, Plaintiff reserves the right to
`supplement these infringement contentions once such information is made available to Plaintiff.
`
`Source: Screenshots from the Google Docs creation tool at docs.google.com
`Live as of October 20, 2020
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`The Accused Instrumentalities include said defined UI object corresponding to the web component
`included in said registry selected from the group consisting of an input of the web service and an output
`of the web service, access said computer memory to select the symbolic name corresponding to the web
`component of the defined UI object, where the defined UI objects are selected by a user of the authoring
`tool or automatically selected by the system as the preferred UI object corresponding to the symbolic
`name of the web component selected by the user of the authoring tool, associate the selected symbolic
`name with the defined UI object, produce an Application including the selected symbolic name of the
`defined UI object where said Application is a device-independent code.
`
`See above. As shown, the defined UI object, such as the section of text or other content in the
`document, or the editable default styles shown in the customizable styles bar in the editor, correspond to
`a web component that is stored in Google’s databases consisting of computer memory. The group
`includes inputs and outputs of the web service as shown (for example, input being the individual
`modifications that make up a style to be saved, and the output being the preview of that style saved in
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
`automatically selected by
`2)
`the system as the preferred UI
`object corresponding to the
`symbolic name of the web
`component selected by the user of
`the authoring tool,
`
`Accused Instrumentalities
`the default styles bar and the modifications to be applied to any text given that style, or in the case of a
`document, the input being the content and modifications that make up the body of the document, and the
`output being the display of that document according to the user selectable settings such as font, text
`weight, size, etc.). These defined UI objects are selected by a user of the authoring tool as they edit the
`content of the document or the default styles.
`
`
`
`
`
`access said computer memory to
`select the symbolic name
`corresponding to the web
`component of the defined UI
`object,
`
`
`
`associate the selected symbolic
`name with the defined UI object,
`
`where the selected symbolic
`name is only available to UI
`objects that support the defined
`data format associated with that
`symbolic name, and produce an
`Application including the selected
`symbolic name of the defined UI
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
`object, where said Application is
`a device-independent code; and
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`Accused Instrumentalities
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`
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`Claim
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`Accused Instrumentalities
`The authoring tool in the Accused Instrumentalities is configured to access said computer memory to
`select the symbolic name corresponding to the web component of the defined UI object.
`
`When the Accused Instrumentalities’ authoring tool creates or modifies a UI object, like a document or a
`style in a Docs document, it is associated with a symbolic name, such as a parameter name, unique to
`that type of UI object in the authoring tool. The Google Docs system accesses the computer memory to
`select the symbolic name, and associates this symbolic name with the defined UI object so that it can be
`referenced by the Google Docs environment at a later time. This data is committed to the database by
`the authoring tool as described below.
`
`The authoring tool in Google Docs is configured to produce an application consisting of a web page
`view from the Google Docs database. That application is provided, for example, in the form of software
`files and associated data for the web page view(s) that are stored in the Google database.
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
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`Accused Instrumentalities
`
`
`When a browser is used to access the Accused Instrumentalities, it uses a player which interacts with the
`application and data stored on the Accused Instrumentalities’ server. The player is, for example,
`software provided to the device in connection with the application. The player accesses and renders the
`data to generate the web page viewed by the user. The player operates with the virtual machine (for
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
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`a Player, where said
`Player is a device-
`dependent code, wherein,
`when the Application and
`the Player are provided to
`
`Accused Instrumentalities
`example, Google Chrome uses the V8 virtual machine) and the information stored in the database in
`order to generate and display at least a portion of one or more web pages. The player includes code that
`is device-platform-dependent in order to allow the environment to work across a variety of devices such
`as personal computers (including laptops and desktops), tablets, browsers, and mobile phones.
`
`An analysis of source code may be necessary to fully and accurately describe functionality of the
`Accused Instrumentalities with respect to this limitation and, accordingly, Plaintiff reserves the right to
`supplement these infringement contentions once such information is made available to Plaintiff.
`
`To the extent that Google contends that its Player does not include “device dependent code,” this
`limitation is nevertheless met through the doctrine of equivalents because any differences between
`Google’s Player code and the claimed Player are insubstantial. Google’s Player code performs
`substantially the same function of ensuring that the Application runs correctly on different device
`platforms. For example, by avoiding executing incompatible code or by invoking compatible code
`depending on the browser, Google’s Player code ensures a web page display correctly in different
`browsers. Google’s Player code performs in substantially the same way by using code within the Player
`that checks for certain device-specific characteristics such as browser type and version. This is
`substantially the same way as using code on a server to query the user device for certain device-specific
`characteristics and send the corresponding compatible code to the device. Google’s Player code achieves
`substantially the same result of a successful execution of the Application. As a result of various browser-
`detection and conditional logical execution code in Google’s Player, Google’s web pages are displayed
`correctly across various browsers.
`
`Source: Screenshots from the Google Docs creation tool at docs.google.com
`Live as of October 20, 2020
`
`The Accused Instrumentalities comprise a Player, where said Player is a device-dependent code, wherein,
`when the Application and the Player are provided to the device and executed on the device, and when a
`user of the device provides one or more input values associated with an input symbolic name to an input
`of the defined UI object, and when the device provides the user provided one or more input values and
`corresponding input symbolic name to the web service, utilize the input symbolic name and the user
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`
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`Accused Instrumentalities
`provided one or more input values for generating one or more output values having an associated output
`symbolic name. The Player then receives the output symbolic name and corresponding one or more
`output values and provides instructions for a display of the device to present an output value in the
`defined UI object.
`
`As described above and shown below, when a browser accesses the Accused Instrumentalities or views a
`document generated by Google Docs, the application is provided to the device in the form of software
`files and other assets. The player code operates with the virtual machine to interpret this software and
`execute it locally.
`
`
`Claim
`the device and executed
`on the device, and when
`the user of the device
`provides one or more
`input values associated
`with an input symbolic
`name to an input of the
`defined UI object,
`
`1) the device provides the
`user provided one or
`more input values and
`corresponding input
`symbolic name to the
`web service,
`
`2) the web service utilizes
`the input symbolic name
`and the user provided one
`or more input values for
`generating one or more
`output values having an
`associated output
`symbolic name,
`
`3) said Player receives the output
`symbolic name and
`corresponding one or more output
`values and provides instructions
`for the display of the device to
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`
`Claim
`present an output value in the
`defined UI object.
`
`Accused Instrumentalities
`
`
`The Accused Instrumentalities, as shown above and discussed throughout, includes UI objects (in the
`form of individual Docs created and modified by a user, as well as customizable default styles that can
`be applied to the entirety or portions of a document) that are configured to receive input and generate
`visual output.
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`Claim
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`Accused Instrumentalities
`
`
`Interaction by the user with the Google Docs environment allows the application to store any input
`values with the Google database. The web service also uses that same data to generate and display
`output values associated with these inputs when displaying data from the database to the user.
`
`For example, shown below, the user provides an input value to customize a particular default style,
`which consists of a variety of possible settings including font weight, color, size, position, etc. The web
`service receives that input value and input symbolic name, such as a parameter name, from the device,
`and generates an output value (in the form of the style preview in the styles pane, as well as output in the
`form of the resulting settings applied to text when the style is selected) associated with an output
`symbolic name, such as a parameter name.
`
`As another example, when another user, or co-author, views the Doc on another device, Google Docs
`utilizes the input symbolic name and user provided one or more input values received from the prior user
`for generating one or more output values having an associated output symbolic name.
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`Claim
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`Accused Instrumentalities
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`Accused Instrumentalities
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`
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`Claim
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`Accused Instrumentalities
`
`
`The player code on the device operates with the virtual machine to execute the software instructions
`provided with Google Docs in order to receive the output symbolic name and output value. The
`
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Claim
`
`2. The system of claim 1, where
`said registry includes definitions
`of input and output related to said
`web service.
`
`
`Accused Instrumentalities
`instructions also provide for the display of this output value in the UI object in order to display the
`appropriate data to the user. This output value is presented in the UI object for display on the device to
`the user.
`
`An analysis of source code may be necessary to fully and accurately describe functionality of the
`Accused Instrumentalities with respect to this limitation and, accordingly, Plaintiff reserves the right to
`supplement these infringement contentions once such information is made available to Plaintiff.
`
`Source: Screenshots from the Google Docs creation tool at docs.google.com
`Live as of October 20, 2020
`
`The Accused Instrumentalities comprise the system of claim 1, where said system stores information in a
`registry, and wherein the registry includes definitions of input and output related to said web service.
`
`The displayed content consists at least in part of web components stored in Google’s databases
`consisting of computer memory storing a registry. The registry also includes input and output related to
`the web service as shown (for example, input being the individual modifications that make up a style to
`be saved, and the output being the preview of that style saved in the default styles bar and the
`modifications to be applied to any text given that style). This input and output is defined in the database
`and loaded when Google Docs webpages are accessed.
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`Claim
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`Accused Instrumentalities
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`Claim
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`Accused Instrumentalities
`
`An analysis of source code may be necessary to fully and accurately describe functionality of the
`Accused Instrumentality with respect to this limitation and, accordingly, Plaintiff reserves the right to
`supplement these infringement contentions once such information is made available to Plaintiff.
`
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`
`
`Accused Instrumentalities
`
`
`Source: Screenshots from the Google Docs creation tool at docs.google.com
`Live as of October 20, 2020
`
`The Accused Instrumentalities comprise the system of claim 1, where said web component is an output of
`a web service. As shown below, the Google Docs authoring tool allows the evocation of a web
`component consisting of an image. That web component is associated with, like other web components, a
`variety of user selectable settings as shown below.
`
`
`Claim
`
`7. The system of claim 1, where
`said web component is an output
`of a web service, is the text
`provided by one or more
`simultaneous chat sessions, is the
`video of a video chat session, is a
`video, an image, a slideshow, an
`RSS display, or an advertisement.
`
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`Exhibit D-1 (Infringement Contentions for U.S. Patent No. 9,471,287 v. Google Docs)
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`
`
`Claim
`
`
`
`Accused Instrumentalities
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`
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`
`
`Claim
`
`11. The system of claim 1, where
`said code is provided over said
`network.
`
`
`Accused Instrumentalities
`An analysis of source code may