1526 Gilpin Avenue
`Wilmington, DE 19806
`United States of America
`Tel: 302-449-9010
`Fax: 302-353-4251
`www.devlinlawfirm.com
`
`February 6, 2020
`
`VIA FEDERAL EXPRESS
`
`Dana Rao, Executive Vice President,
`General Counsel and Corporate Secretary
`ADOBE INC.
`345 Park Avenue
`San Jose, CA 95110-2704
`
`RE: Express Mobile, Inc.’s U.S. Patent Nos. 6,546,397, 7,594,168, 9,063,755,
`9,471,287, 9,507,571, and 9,928,044
`
`Dear Mr. Rao:
`
`I am writing to you on behalf of our client Express Mobile, Inc. (“Express Mobile”).
`
`Express Mobile is a leader in the business of developing mobile app and website design
`and creation technologies. Express Mobile is managed by individuals with many years of
`technology and business experience. The CEO of Express Mobile, Steve Rempell, has more than
`fifty years’ experience with technology companies with a substantial portion of his work pertaining
`to web-based technologies and applications.
`
`Express Mobile’s intellectual property includes U.S. Patent Nos. 6,546,397, 7,594,168,
`9,063,755, 9,471,287, 9,507,571, and 9,928,044 (the “Express Mobile patents”). These patents
`generally relate to tools and methods for the generation of web pages and/or browser-based and
`native app solutions as well as the integration of web services into these solutions. Copies of each
`of the patents can be obtained at www.google.com/patents or the United States Patent &
`Trademark Office.
`
`Express Mobile’s patents have been the subject of numerous challenges to their validity
`and, in each case, have been upheld as valid. Copies of the orders and/or decisions in each case
`are available upon request.
`
`Using the technology claimed by the Express Mobile patents, Adobe’s Express Cloud and
`Magento Cloud platforms build, host, and market websites for Adobe’s customers by letting the
`customers select settings representing website elements, storing these settings in a database, and
`retrieving stored information to generate websites. Adobe’s platforms also generate code in the
`form of players and applications that can interact with web services to provide content for display
`on users’ devices.
`
`For example, Adobe’s platforms infringe claim 15 of U.S. Patent No. 9,928,044 (the “’044
`patent) by a method which includes a computer memory and an authoring tool. The computer
`memory stores symbolic names required for evoking a web component related to a web service
`and an address of the web service. The authoring tool is configured to define a User Interface
`(“UI”) object for display on the device, where the UI object corresponds to a web component.
`
`Adobe v. Express Mobile - IPR2021-01227
`PO_EM287_2014-0001
`
`

`

`Devlin Law Firm
`February 6, 2020
`Page 2 of 2
`
`Each UI object is either: 1) selected by a user, or 2) automatically selected by the system as a
`preferred UI object corresponding to a symbolic name of the web component. The information
`representative of the UI object and related settings are stored in a database. An application is built
`consisting web page views. The application and a player are provided to a device and enables the
`device to provide one or more input values and corresponding input symbolic name to the web
`service and the web service to utilize the input symbolic name and the user provided one or more
`input values to generate one or more output values having an associated output symbolic name,
`while the player receives the output symbolic name and corresponding one or more output values
`and provide instructions for the display of the device to present an output value in the defined UI
`object.
`
`Thus, Adobe requires a license to the ’044 patent for such platforms.
`
`In light of Adobe’s sales of such platforms, Adobe may also wish to have its patent counsel
`examine the remaining Express Mobile patents to determine whether a non-exclusive license is
`needed as to those patents as well.
`
`Should Adobe have interest in a non-exclusive license to the Express Mobile patents,
`please contact us to discuss licensing terms.
`
`Very truly yours,
`
`Timothy Devlin
`
`Devlin Law Firm LLC
`1526 Gilpin Avenue
`Wilmington, Delaware 19806
`Tel.: (302) 449-9010
`Fax: (302) 353-4251
`www.devlinlawfirm.com
`
`Adobe v. Express Mobile - IPR2021-01227
`PO_EM287_2014-0002
`
`