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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`GOOGLE LLC,
`Petitioner
`
`v.
`
`EXPRESS MOBILE, INC.,
`Patent Owner
`
`____________________
`
`Patent No. 9,471,287
`____________________
`
`DECLARATION OF SANDEEP CHATTERJEE, PH.D.
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`
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`
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`Page 1 of 157
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`GOOGLE EXHIBIT 1002
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`

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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`
`
`TABLE OF CONTENTS
`
`
`INTRODUCTION .......................................................................................... 5
`I.
`BACKGROUND AND QUALIFICATIONS ................................................ 6
`II.
`SUMMARY OF OPINIONS ........................................................................ 10
`III.
`IV. PERSON OF ORDINARY SKILL IN THE ART ....................................... 13
`V.
`TECHNICAL BACKGROUND .................................................................. 14
`A. Websites ............................................................................................. 14
`B. Web Services ...................................................................................... 16
`C.
`Graphical User Interface .................................................................... 19
`D.
`Code Portability .................................................................................. 23
`VI. OVERVIEW OF THE ’287 PATENT ......................................................... 28
`VII. CLAIM CONSTRUCTION ......................................................................... 32
`VIII. OVERVIEW OF THE PRIOR ART ............................................................ 34
`A. Huang ................................................................................................. 34
`B.
`Angelov ............................................................................................... 44
`IX. THE PRIOR ART DISCLOSES OR SUGGESTS ALL OF THE
`FEATURES OF CLAIMS 1, 2, 7, and 11 OF THE ’287 PATENT ............ 48
`A. Huang and Angelov Disclose or Suggest the Features of Claims
`1, 2, 7, and 11 ..................................................................................... 48
`1.
`Claim 1 ..................................................................................... 48
`i)
`[1.pre] “A system for generating code to
`provide content on a display of a device, said
`system comprising:” .................................................... 48
`
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`i
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`[1.a] “computer memory storing a registry of:
`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 has a
`preferred UI object, and b) an address of the
`web service;” ................................................................ 59
`[1.b] “an authoring tool configured to: define a
`(UI) object for presentation on the display,
`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:
`1) selected by a user of the authoring tool; or 2)
`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,” ............................. 93
`[1.c] “[the authoring tool configured to:] access
`said computer memory to select the symbolic
`name corresponding to the web component of
`the defined UI object,” .............................................. 105
`[1.d] “[the authoring tool configured to:]
`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” ......................................... 106
`ii
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`ii)
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`iii)
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`iv)
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`v)
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`vi)
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`vii)
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`[1.e] “[the authoring tool configured to:]
`produce an Application including the selected
`symbolic name of the defined UI object, where
`said Application is a device-independent code;
`and a Player, where said Player is a device-
`dependent code,” ........................................................ 113
`[1.f] “wherein, when the Application and Player
`are provided to 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 dvice 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 present an
`output value in the defined UI object.” ................... 127
`Claim 2 ................................................................................... 146
`i)
`“The system of claim 1, where said registry
`includes definitions of input and output related
`to said web service.” .................................................. 146
`Claim 7 ................................................................................... 150
`i)
`“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.” ..................................................... 150
`Claim 11 ................................................................................. 151
`iii
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`2.
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`3.
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`4.
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`i)
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`“The system of claim 1, where said code is
`provided over said network.” ................................... 151
`CONCLUSION ........................................................................................... 156
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`
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`X.
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`iv
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`I, Sandeep Chatterjee, Ph.D., declare as follows:
`
`INTRODUCTION
`I have been retained on behalf of Google LLC (“Petitioner”) as an
`1.
`
`
`
`I.
`
`independent expert consultant in this proceeding before the United States Patent
`
`and Trademark Office (“PTO”) regarding U.S. Patent No. 9,471,287 (“the ’287
`
`patent”) (Ex. 1001). I have been asked to consider whether certain references
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`discloses or suggests the features recited in claims 1, 2, 7, and 11 (“the challenged
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`claims”) of the ’287 patent. My opinions are set forth below.
`
`2.
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`Experantis LLC (“Experantis”) is being compensated at my standard
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`rate of $825 per hour for the time I spend on this matter. This compensation is in
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`no way contingent on the nature of my findings, the presentation of my findings in
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`testimony, or the outcome of this or any other proceeding. Neither Experantis nor
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`I have any personal or financial stake or interest in this proceeding.
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`II. BACKGROUND AND QUALIFICATIONS
`3. My qualifications for forming the opinions in this report are
`
`summarized here and explained in more detail in my curriculum vitae (Exhibit
`
`1003), which also includes a list of my publications.
`
`4.
`
`I am the Chief Executive Officer of Experantis LLC, a technology
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`consulting company. Previously, I was the Executive Vice President and Chief
`
`Technology Officer of SourceTrace Systems, Inc., a technology and services
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`company enabling the delivery of secure remote electronic services over landline
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`and wireless telecommunications networks.
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`5.
`
`I received my bachelor’s degree in Electrical Engineering and
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`Computer Science from the University of California, Berkeley in 1995. I received
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`my master’s degree in Computer Science from the Massachusetts Institute of
`
`Technology (MIT) in 1997, and my doctorate in Computer Science from MIT in
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`2001. I received a certificate of completion for an executive education program on
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`global leadership from Harvard University in 2011. My doctoral dissertation at
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`MIT, entitled “Composable System Resources for Networked Systems,” which
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`involved networked client architectures and systems, was selected as one of the top
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`inventions in the history of MIT’s Laboratory for Computer Science. This
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`U.S. Patent No. 9,471,287
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`invention is showcased in a time capsule at the Museum of Science in Boston,
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`Massachusetts.
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`6.
`
`In 2011, I was named a Young Global Leader. This honor, bestowed
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`each year by the World Economic Forum, recognizes and acknowledges the top
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`leaders—all below the age of 40—from around the world for their professional
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`accomplishments, commitment to society, and potential to contribute to shaping
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`the future of the world. In 2016, I was appointed to the World Economic Forum’s
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`expert network as an expert in technology and innovation, and I advise world
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`leaders on issues related to technology and innovation.
`
`7.
`
`From
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`1997,
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`I was
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`the
`
`Entrepreneur-in-Residence
`
`at
`
`FidelityCAPITAL, the venture capital arm of Fidelity Investments. In 1999, I
`
`founded and served as President and Chief Technology Officer (CTO) of Satora
`
`Networks, which developed tools and technologies for building appliances and
`
`services for the Internet using wireless and other technologies to extend computing
`
`beyond the desktop.
`
`8.
`
`In 2001, I joined Bluestone Software’s Mobile Middleware Labs as a
`
`Senior Engineer developing applications and systems infrastructure for enterprise
`
`Java/J2EE, Web services, and enterprise mobile solutions. After the completion of
`
`Hewlett-Packard’s (“HP”) acquisition of Bluestone, I became a Senior Member of
`
`
`
`
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`7
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`the Technical Staff at HP’s Middleware Division. I was responsible for
`
`architecting and developing the company’s next-generation Web services platform
`
`for enterprise as well as mobile environments, known as the Web Services
`
`Mediator. I also worked with HP’s worldwide software operations to add
`
`extensions into the Java 2 Enterprise Edition (J2EE) application server to easily
`
`support mobile applications and content, as well as flexible integration with other
`
`software systems using the eXtensible Markup Language (XML) and web services
`
`technologies. Service oriented architectures and systems use web services
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`technologies.
`
`9.
`
`I am the co-author, with James Webber, of the book Developing
`
`Enterprise Web Services: An Architect’s Guide, which is listed in my curriculum
`
`vitae. (Ex. 1003, 18). This book discusses Web services, which implement
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`capabilities that are available to other applications over the Web via industry
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`standard network and application interfaces and protocols. An application can use
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`the capabilities of a web service by simply invoking it across a network without
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`having to integrate it. As such, web services represent reusable software
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`components that are URL addressable. This book has been adopted by over 100
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`universities and colleges around the world, and has been translated or reprinted in a
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`number of countries. I was also part of the Expert Group that developed the JSR-
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`
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`00172 J2ME (Java 2 Platform, Micro Edition) Web Services Specification, the
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`worldwide industry standard for mobile web services.
`
`10.
`
`I have extensive experience in architecting, developing, optimizing,
`
`deploying and managing web-based computing systems,
`
`including web
`
`applications, web services and web sites, and I explained these concepts
`
`extensively in my above-identified book. I also have experience in many other
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`computing technologies, including in the areas of programming and networking
`
`(e.g., using or designed for the Internet and Web, including with related
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`technologies such as web browsers, applets, and virtual machines) to name a few,
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`and have developed computer systems implementing these and numerous other
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`technologies in the course of my academic and professional work.
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`9
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`III. SUMMARY OF OPINIONS1
`11. The opinions contained in this Declaration are based on the
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`documents I reviewed, my professional judgment, as well as my education,
`
`experience, and knowledge regarding graphical user interfaces.
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`12.
`
`In forming my opinions expressed in this Declaration, I reviewed the
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`’287 patent (Ex. 1001); the prosecution file history for the ’287 patent (Ex. 1004);
`
`U.S. Patent No. 9,063,755 (Ex. 1005); Prosecution History of U.S. Patent No.
`
`9,063,755 (Ex. 1006); U.S. Patent Publication No. 2007/0118844 (“Huang”) (Ex.
`
`1007); U.S. Patent Publication No. 2007/0067421 (“Angelov”) (Ex. 1008); U.S.
`
`Patent Publication No. 2007/0079282 (“Nachnani”) (Ex. 1009); U.S. Patent
`
`Publication No. 2006/0129972 (“Tyburski”) (Ex. 1011); U.S. Patent Publication
`
`No. 2006/0271537 (“Chandrasekharan”) (Ex. 1012); U.S. Patent Publication No.
`
`2004/0143645 (“Cheenath”) (Ex. 1014); Stroustrup, B., The C++ Programming
`
`Language, Third Edition (1998) (“Stroustrup”) (Ex. 1015); U.S. Patent Publication
`
`No. 2007/0094609 (“Gilboa”) (Ex. 1016); U.S. Patent No. 7,873,625 (“Mourra”)
`
`
`1 My citations to non-patent publications are to the original page numbers of such
`
`publications, and my citations to U.S. Patents are to the column:line number or
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`paragraph number of the patents or published patent applications, as applicable.
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`10
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`U.S. Patent No. 9,471,287
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`(Ex. 1017); U.S. Patent Publication No. 2006/0230462 (“Prabakar”) (Ex. 1018);
`
`U.S. Patent Publication No. 2009/0055345 (“Mehta”) (Ex. 1019); U.S. Patent No.
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`7,549,153 (“Butterworth”) (Ex. 1020); U.S. Patent No. 8,117,233 (“Liu”) (Ex.
`
`1021); U.S. Patent No. 7,191,160 (“Hoeft”) (Ex. 1022); U.S. Patent No. 8,548,939
`
`(“Enenkiel”) (Ex. 1023); U.S. Patent Publication No. 2004/0006765 (“Goldman”)
`
`(Ex. 1024); Lindholm et al., The Java Virtual Machine Specification, Addison-
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`Wesley (1997) (“Lindholm”) (Ex. 1025); U.S. Patent No. 6,677,965 (“Ullmann”)
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`(Ex. 1026); Chatterjee, S. et al., Developing Enterprise Web Services: An
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`Architect’s Guide, Prentice Hall PTR Pearson Education, Inc. (2004) (“Chatterjee-
`
`2004”) (Ex. 1027); U.S. Patent No. 8,595,186 (“Mandyam”) (Ex. 1028); U.S.
`
`Patent No. 6,779,153 (“Kagle”) (Ex. 1029); U.S. Patent No. 6,571,389 (“Spyker”)
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`(Ex. 1030); U.S. Patent No. 6,549,932 (“McNally”) (Ex. 1031); U.S. Patent No.
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`7,814,423 (“Musson”) (Ex. 1032); and any other materials I refer to in this
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`Declaration in support of my opinions.
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`13. My opinions have also been guided by my appreciation of how a
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`person of ordinary skill in the art would have understood the challenged claims and
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`the specification of the ’287 patent at the time of the alleged invention. I have
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`been asked to initially consider the time of the alleged invention as the 2008 time
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`frame, including and up to April 7, 2008, which I understand is the filing date of a
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`provisional application to which the ’287 patent claims priority (Ex. 1001, Cover).
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`My opinions reflect how one of ordinary skill in the art would have understood the
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`’287 patent, the prior art to the patent, and the state of the art at the time of the
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`alleged invention.
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`14. As I discuss in detail below, it is my opinion that certain references
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`disclose or suggest all the features recited in the challenged claims of the ’287
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`patent.
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`IV. PERSON OF ORDINARY SKILL IN THE ART
`15. Based on my knowledge and experience, I understand what a person
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`of ordinary skill in the art would have known at the time of the alleged invention.
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`My opinions herein are, where appropriate, based on my understandings as to a
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`person of ordinary skill in the art at that time. In my opinion, based on the
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`materials and information I have reviewed, and based on my experience in the
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`technical areas relevant to the ’287 patent, a person of ordinary skill in the art at
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`the time of the alleged invention of the ’287 patent would have had at a bachelor’s
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`degree in electrical engineering, computer science, or the equivalent thereof, and at
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`least two years of experience with programming relating to websites. More
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`education can substitute for practical experience and vice versa. I apply this
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`understanding in my analysis herein.
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`16. My analysis of the ’287 patent and my opinions in this declaration are
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`from the perspective of one of ordinary skill in the art, as I have defined it above,
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`during the relevant time frame stated above. During this time frame, I possessed at
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`least the qualifications of a person of ordinary skill in the art, as defined above.
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`V. TECHNICAL BACKGROUND
`In this section, I discuss the state of the art with respect to certain
`17.
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`technologies relevant to the subject matter of the ’287 patent. In particular, during
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`the time preceding April 2008, a person of ordinary skill in the art would have
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`been aware of various developments in the areas of computing, including regarding
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`websites, web services, graphical user interface and portable code, as I discuss
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`below.
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`A. Websites
`18. A person of ordinary skill would have known in the relevant time
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`frame about computer networks, including the Internet, which was known to be a
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`distributed network formed from interconnected computer networks, including the
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`World Wide Web (“Web” or “web”). A person of ordinary skill would have
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`known that the Web includes websites provided by web servers, which are
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`computers that store and retrieve computer files representing web pages that are
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`requested by and displayed to users of the Internet. (Ex. 1029, 1:19-24.) It was
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`known that web pages generally include text, images, animation, audio and other
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`multimedia forms for presentation to viewers or users of the websites. (Id., 1:24-
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`26.) It was further known that “[i]n the Web environment, client machines
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`communicate with Web servers using Hypertext Transfer Protocol (HTTP), which
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`uses a standard page description language known as Hypertext Markup Language
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`(HTML)” and that “HTML provides basic document formatting and allows the
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`developer to specify ‘links’ to other servers and files.” (Id., 1:26-32.)
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`19. A person of ordinary skill would have known that web browsers may,
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`for example, reside on a client computer, and are used to display the web pages.
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`(Ex. 1030, 1:48.) It was known in the relevant time frame that software programs,
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`such as programs implemented in the Java programming language, “have found
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`extensive use on the World Wide Web,” as “[t]hese programs include full-featured
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`interactive, standalone applications, as well as smaller programs, known as applets,
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`that run in a Java-enabled Web browser.” (Ex. 1031, 9:1-6.)
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`Declaration of Sandeep Chatterjee, Ph.D.
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`B. Web Services
`20. As I discussed above in Section V.A, in the relevant time frame a
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`person of ordinary skill in the art would have been familiar with the Web and
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`websites. (See above at Section V.A.) A person of ordinary skill would also have
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`known that the Web was commonly used for providing various services remotely.
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`Indeed, a person of ordinary skill would have known that web services represent a
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`new architectural paradigm for implementing software. Such a skilled person
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`would have known of web services since at least as early as the late 1990s. (Ex.
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`1027, xvii.)2 Web services implement capabilities that are available to other
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`applications (or even other web services) via network/application interfaces and
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`protocols, extending the capabilities of a computing system beyond those of a
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`single computer. (Id., 1-14.) A person of ordinary skill would have known that a
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`computer program can use the capabilities of a web service by simply invoking it
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`across a network without having to implement such capabilities with locally
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`situated computing resources. As such, a person of ordinary skill would have
`
`known that web services represent reusable software building blocks that are
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`2 My citations to Chatterjee-2004 (Exhibit 1027) are with respect to the book’s
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`internal pagination.
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`Declaration of Sandeep Chatterjee, Ph.D.
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`addressable by a uniform resource locator (URL), as I explained in my book that I
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`mentioned above in Section II. (Id., 2; see also above at Section II.) In other
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`words, a person of ordinary skill would have known that knowing a service’s
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`address made it possible to access and use the web service via a Web connection.
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`21. A person of ordinary skill would have known that web services
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`expose their capabilities to client applications, not their implementations. This
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`allows web services to be implemented in any programming language and on any
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`computing platform and still be compatible with all client applications. A web
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`service typically describes its own capabilities, publishes its own programmatic
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`interface and implements its own functionality that is available as a hosted service.
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`(Ex. 1027, 4.) A client software program invokes the functionality of a web
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`service by sending it messages as input, and receiving return messages as output
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`from the web service so that the results can be used with the client software
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`program. In other words, a person of ordinary skill would have known that a web
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`service receives input from a client software program (that invokes the web
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`service), process the input in some manner, and provides output, e.g., as shown in
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`Figure 1-2 of my book:
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`Declaration of Sandeep Chatterjee, Ph.D.
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`(Ex. 1027, 5 (FIG. 1-2); see also id., 1-14.)
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`22. A person of ordinary skill would have known that a key enabler for
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`Web services is XML, which stands for “eXtensible Markup Language.” (Id., 15;
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`see also id., 16-70 (discussion of XML in my book).) Although HTML and XML
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`are similar in that both are human-readable markup languages, HTML is for
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`presentation markup while XML is for semantic markup. This attribute of XML
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`supports expressing application and functional semantics
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`in a platform-
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`independent manner that enables any-to-any information exchange. (Id., 10; see
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`also id. 15-70.) A person of ordinary skill would have known that other core
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`technologies of web services are Simple Object Access Protocol (SOAP), Web
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`Services Description Language (WSDL), and UDDI (Universal Description,
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`Discovery and Integration). (See id., 71-143.) These were well-known
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`technologies that a person of ordinary skill would have known about and known
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`how to implement in various computing contexts for implementing web services.
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`C. Graphical User Interface
`It was well known in the relevant time frame that a computer program
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`typically includes a user interface to enable a user of the program to interface with
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`the program, e.g., by providing input to the program or receiving output from the
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`program. Indeed, it would have been expected for a program to include a user
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`interface if the program is to be used by a user. A person of ordinary skill would
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`have known of many types of user interfaces for displaying information to a user,
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`including graphical user interfaces that show information visually to the user.
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`Mandyam, which “relates to applications and user interfaces for mobile computing
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`devices, and particularly to methods and systems for creating, publishing, sharing,
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`and delivering mobile software applications,” discloses some examples of a user
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`graphical user interface. (Ex. 1028, 1:14-17.)
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`24. For example, Mandyam discloses:
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`FIG. 37 shows various embodiments of web user
`interface displays that a user may be presented with to
`create a mobile widget. In some embodiments, an end-
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`user is not required to do any programming that generates
`the mobile widget. As such, anyone capable of using a
`web browser and filling web forms can use such a user
`interface to publish a mobile widget. As an example, a
`topical expert, a blogger, a website owner or a content
`publisher can use this user interface to publish a mobile
`widget. Though not mentioned, the same user interface
`may also be presented via mobile web browser so that
`mobile users may also create and publish new mobile
`widgets and share them with others.
`(Ex. 1028, 52:20-31; see also id., FIGS. 37A-37F (reproduced below).)
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`(Id., FIGS. 37A-37B.)
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`25. Mandyam describes Figure 37A as follows:
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`As in FIG. 37(a), the widget publisher may be asked to
`enter a few keywords on the topic on which he wants to
`create a widget. Text may be presented to the user,
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`Declaration of Sandeep Chatterjee, Ph.D.
`U.S. Patent No. 9,471,287
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`such as “Use this wizard to publish your own mobile
`widget. At this time, you may create a mash-up widget
`which aggregates content around a topic from several
`content sources. Star by entering a few keywords. … The
`user may enter the information in a text box 3705 and
`submit it by selecting the ‘Start’ key 3710 or an
`equivalent. The query may be transmitted back to a
`central server and parsed. A next control 3750 can be
`provided to enter the inputted data and proceed to the
`screen of FIG. 27(c).
`(Id., 52:41-55.)
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`(Id., FIGS. 37C-37D.) Mandyam’s description of Figure 37D includes:
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`The display in FIG. 37(d) allows the widget publisher to
`pick information sources 3735 to aggregate into his
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`widget. The user can select one or more sources to add
`to the widget. Several information source choices 3735
`may be presented to the publisher. … An information
`source may be the result of running the query on any of
`these search engines. The publisher can select this by
`selecting the checkbox next to any of these provided
`choices. The sources may also include data repositories,
`news sites, and so forth.
`(Id., 52:64-53:9; see also id., FIGS. 37E-37F (below).)
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`(Id., FIGS. 37E-37F.)
`26. Thus, various
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`types of graphical user
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`interface controls and
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`components were known, including text boxes, check boxes, buttons, and many
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`others. A person of ordinary skill would have been skilled at programming and
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`configuring software systems and would have known how to implement user
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`interface controls to achieve successful and operable software systems.
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`D. Code Portability
`27. A person of ordinary skill would have known in the relevant time
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`frame that one way to develop software code was to develop code specific to a
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`given computing device on which the code is to be executed, and another way is to
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`develop code that is portable across various types of computing devices without
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`having to rewrite the code for each intended device. For example, Gilboa
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`demonstrates that it was well known to develop device-specific code which
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`contains instructions for a computing device and takes into account the runtime
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`environment of the device:
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`As part of 306, one or more runtime tools may generate
`one or more runtime environment platform-specific
`representations based upon the abstract representation
`generated in 304. For example, a runtime representation
`may be created for a particular device or for a particular
`runtime programming
`language environment. For
`example, for a target device supporting a runtime
`Java environment, a XGL-to-Java compiler may be
`used to generate Java code based upon the abstract
`representation. The generated Java code may then be
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`executed by the Java runtime to display a GUI on the
`target device. For a device supporting a runtime Flash
`environment, a XGL-to-Flash compiler may be used
`to generate Flash code based upon
`the abstract
`representation. The generated Flash code may then be
`executed by the Flash runtime to display a GUI on the
`device. … Various
`other
`runtime
`target
`representations and for other runtime platforms may
`also be generated. Customized runtime tools may be
`developed
`to
`facilitate
`generation
`of
`runtime
`representations and GUIs for different GUI platforms. In
`some embodiments, the same device may support
`different runtime environment platforms and different
`runtime representations and GUIs may be generated for
`the different platforms for the same device. One or more
`runtime tools (e.g., compilers, interpreters, source coded
`generators, etc.) may be used in the runtime environment.
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`(Ex. 1016, ¶[0054]; see also id., ¶[0043] (“Flash runtime 122 may execute Flash
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`code 120 to generate/display a GUI 124 on a target device comprising a Flash
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`platform.”); Ex. 1011, ¶[0033] (“Computing device 110 … generates device-
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`specific application 180[, which] is communicated to a respective mobile device
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`200 for subsequent execution on the device.”).)
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`28. Tyburski explains that “[t]he proliferation of mobile consumer
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`electronic devices” has “created a need for specialized computing skills to produce
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`device specific applications” and that “[t]he variety in device architectures,
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`functions, and data transfer methods coupled with limited application storage
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`capacity has created an ever-increasing number of device specific applications
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`across many different mobile-device types.” (Ex. 1011, ¶[0019]; see also id.,
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`¶[0008] (“[T]oday’s more powerful computing platforms do not address problems
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`for developing mobile-device application software caused by the widely varying
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`operating systems, application interfaces, user input interfaces, data display types
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`and sizes, memory sizes, etc. across many different mobile-device types.”).)
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`29. Tyburski describes one known way (among many) for implementing
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`portable code, which can be used to streamline software development so that code
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`does not have to be rewritten for each computing device on which execution is
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`desired. Tyburski discloses with reference to Figure 1 (below) that instruction set
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`155 (shown above in Figure 1) “is [an] abstraction of an application program that
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`is intended to be executed on a designated mobile device 200,” and “[a] software
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`developer…enters the individual instructions that comprise the instruction set
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`155.” (Id