Trials@uspto.gov
`571-272-7822
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`Paper No. 44
`Entered: April 17, 2024
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
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`APPLE INC. and GOOGLE LLC,1
`Petitioner,
`
`v.
`
`SPACETIME3D, INC.,
`Patent Owner.
`________________
`
`IPR2023-00242
`Patent 8,881,048 B2
`________________
`
`Record of Oral Hearing
`Held: March 18, 2024
`________________
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`
`
`Before HUBERT C. LORIN, DAVID C. McKONE, and
`SHEILA F. McSHANE, Administrative Patent Judges.
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`1 Google LLC, which filed a petition in IPR2023-00577, has been joined as a
`party in this proceeding.
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`IPR2023-00242
`Patent 8,881,048 B2
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`APPEARANCES:
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`ON BEHALF OF THE PETITIONER, APPLE INC.:
`
`
`W. KARL RENNER, ESQ.
`ANDREW PATRICK, ESQ.
`KENNETH DARBY, ESQ.
`USMAN KHAN, ESQ.
`Fish & Richardson P.C.
`1000 Maine Avenue SW, Suite 1000
`Washington, D.C. 20024
`(202) 783-5070
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`
`
`ON BEHALF OF THE PETITIONER, GOOGLE LLC:
`
`
`YINAN LIU, ESQ.
`Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
`Two Seaport Lane
`Boston, Massachusetts 02210
`(617) 646-1652
`
`
`
`ON BEHALF OF THE PATENT OWNER, SPACETIME3D, INC.:
`
`
`TODD E. FITZSIMMONS, ESQ.
`Fitzsimmons IP Law, P.C.
`P.O. Box 199
`Gardena, California 90248
`(571) 210-8000
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`IPR2023-00242
`Patent 8,881,048 B2
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`GREGORY CORDREY, ESQ.
`Jeffer Mangels Butler & Mitchell LLP
`3 Park Plaza, #1100
`Irvine, California 92614
`(949) 623-7236
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`The above-entitled matter came on for hearing at 1:05 PM EDT on
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`Monday, March 18, 2024, at the U.S. Patent and Trademark Office, 600 Dulany
`Street, Alexandria, Virginia.
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`IPR2023-00242
`Patent 8,881,048 B2
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`P R O C E E D I N G S
`- - - - -
` JUDGE LORIN: Good afternoon. Please be seated.
`Good afternoon. This is an oral hearing in IPR2023-00242. Petitioner is
`Apple Inc., and Patent Owner is SpaceTime3D, Inc. The proceeding
`concerns U.S. Patent Number 8,881,048. I'm Judge Lorin. I'm accompanied
`with Judge McKone and Judge McShane. They're appearing remotely on
`video.
`All right, let's begin with Petitioner Apple. Please introduce
`yourselves for the record.
`MR. RENNER: Thank you, Your Honor. Karl Renner for Apple.
`I'm joined here presently with Kenneth Darby, Andrew Patrick, and Usman
`Khan. On the phone we have from Apple, Alan Tatier. And counsel for
`Google asked me to introduce her, and that's Yinan Liu.
`JUDGE LORIN: Very good. Thank you. Counsel for Patent Owner?
`MR. FITZSIMMONS: I'm sorry, Your Honor. Todd Fitzsimmons on
`behalf of SpaceTime3D, Inc. And with me is Greg Cordrey, also on behalf
`of Patent Owner.
`JUDGE LORIN: Very good. Very good. Thank you very much.
`MR. FITZSIMMONS: Thank you, Your Honor.
`USPTO This is [USPTO] from (inaudible). Sorry for the
`interruption. We don't hear. Judge Lorin. I don't know if your mic is on or
`not on your (inaudible). Thank you.
`JUDGE LORIN: No, you're right. I'm sorry. The mic is on now.
`Sorry. Thank you.
`USPTO: Thank you.
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`JUDGE LORIN: All right. I'd like to remind the parties that the
`hearing is open to the public. A full transcript of the hearing will become
`part of the record. Both parties have filed demonstratives. We received
`them. Demonstrative exhibits will be considered only to the extent they are
`helpful to the panel, that they articulate the positions taken during the
`hearing, or reflect arguments or evidence that was made of record during the
`trial.
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`The parties will have seen our hearing order, which is, I think, paper
`32. We stated that each party would receive 60 minutes to present their
`arguments. So, by the way, because the Judges are remote on video, please
`speak up for their benefit. Also, it will be very helpful if you identify the
`slides. That'll also be helpful to the Judges.
`All right, Counsel, you may begin, Counsel for Apple. Would you
`like to reserve any time?
`MR. RENNER: Thank you, Your Honor. Yes, I'd like to reserve 20
`minutes.
`JUDGE LORIN: All right, thank you.
`MR. RENNER: Thank you, Your Honors, and good afternoon. Karl
`Renner on behalf of Apple.
`Apple's petition offered two grounds and each of those grounds put in
`dispute the obviousness of all claims. Throughout the proceedings that have
`ensued, really, we've seen four contested issues come into focus. In fact, the
`Table of Contents reflected here on slide 2, please, that the four issues bear
`on four claim terms. With each, we'll explore whether and how to interpret
`the claim terms in question, and correspondingly, whether or not the impact
`of the prior art on obviousness is present. Our plan is, in fact, to use most of
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`our time today to do just that unless Your Honors had other things you
`wanted us to address, and in doing so, we're hoping to fill the issues out.
`Before I get to this, though, I wanted to address one item that is
`related, and it's relating to the idea that the four terms in question here, we
`might think of them as claim constructions, but, in fact, I think that'd be a
`misnomer presently. One of the things is for sure, when you do claim
`construction, it's to get a better understanding of what, in fact, the claim
`terms mean. The terms, in fact, that are the point of the construction is to
`explore their meaning. It's quite another, though, to ask for an
`understanding of how those terms might be further narrowed through the
`import of other limitations in what would be called a claim construction
`endeavor. Here we have, we believe, that latter situation.
`In each case, we'll demonstrate, we'll take you through it for each of
`the terms in question, we'll look at the proposed claim constructions that are
`on the table, and we'll map the claims that are said to be being construed to
`see that each one of those terms actually appears in the proposed claim
`construction before Your Honors. And as a consequence, this is less a
`proceeding about claim construction and more an effective amendment. We
`know this to be improper. Claim construction canons tell us that we're not to
`inject meaning and additional limitations, that is, through claim construction
`into claims. They're instead there to provide claim construction, which is to
`gain clarity. And again and again, you're going to see that those terms
`apply, and then additional terms are present.
`I'm not going to belabor this point anymore. I think we ought to get
`into the specifics of terms to really give it body. But I wanted to make sure
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`that you heard that at the outset, so you'd have the context of where we're
`going to be heading with the variety of our arguments today.
`Slide 3, please. You can see the '048 patent here reproduced. Just a
`moment on it so we can orient and get started in a common voice. This
`interface calls for the entry by a user of a URL, an address, after which
`there'd be the impression of a carriage return, and after that there'd be a
`production of a 3D object and a 3D display, a screen, a space, if you will.
`That object would bear a texturized version of a part of a web page, a
`portion, they say, of a web page that corresponded to the URL that was in
`selection. The process of introducing that URL and creating that object to
`be repeated again and again to produce what you do see on this slide, a
`variety of these slices, these 3D slices, or they're effectively thumbnails.
`And if a user wants to see one of them better, because they are, after
`all, askew, they can select, use -- manipulate the user interface to get a 2D
`view. That would be, you know, a plain 2D view right in front of you to get
`a better look. That might actually cover up some of the objects that were in
`3D and that's the process that they call replacing the 3D.
`Now, if you go to slide 4 -- you look at slide 4, you can see claim 1,
`which is really where we find all of the terms that are going to be in
`question. We've highlighted here which of the terms or which of the
`sections of the claim are implicated. I'll reserve more comment on this until
`I get into the first and the second and the third and the fourth of the terms,
`but this is here for your convenience, so we can refer back to it and get some
`context to where these terms appear.
`I move to slide 6, please. We look at what the art is in the instituted
`ground 1. It's not all the art. We've only produced here, the Robertson and
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`Gettman references and you know that the combination actually included
`Gralla as well. But there's been no dispute over the introduction or
`integration of what's in Gralla, that is, web browser functionality. The
`dispute really pertains to what is in Robertson and Gettman and whether it
`applies to the terms in question.
`As to Robertson, on the upper left you can see a three-dimensional
`interface designed to allow a user to see a bunch of, you know, URL-
`generated images and thumbnails, if you will, selectable, and allowing still
`that in Robertson you could, in fact, select -- manipulate the user by -- the
`interface by selecting one of these to generate what is up on the right, a
`three-dimensional space -- out of three-dimensional space, a visible view
`that corresponds to what's been selected. There's really two different things
`that could happen in response to the selection of something using those
`thumbnails. The first of which is a high resolution -- a higher resolution
`thumbnail that's of expanded size could be presented in 2D. That's shown in
`figure 9, the upper right. The other is, they don't show this but they
`describe, alternatively, a web page could be produced in a conventional --
`importantly, the word "conventional" -- browser application window, again
`in two dimensions. Robertson contemplates that whatever you do to create
`this, you can expand that window, you could fill the space with that window,
`maximize it effectively.
`As for Gettman, it complements the teachings of Robertson as it
`relates to what happens after a user selects one of those thumbnails. That is,
`when you've selected a thumbnail, how do you get to this window? What
`does it look like? And Gettman tells us also that you use a conventional
`browser. It names Mozilla, also names conventional as opposed to Internet
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`IPR2023-00242
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`Explorer, which was what was named before by the earlier Robertson
`writing. And so you move toward this browser in this window, but you do it
`in a single step. You don't need to maximize in addition to render, you just
`go straight to. If there's a selection of user manipulation that's in Robertson,
`you direct to a user manipulation by creating a two-dimensional display.
`We think this is perfectly congruent, in fact, complementary. And
`more than that, there's been some contentions that Robertson would have its
`teachings, I don't know, affected, destroyed, diminished if you integrated
`Gettman, because Robertson has an interest that's expressed in making sure
`you can see those objects in that thumbnail of image. But as you can see
`how the combination comes together, Gettman's introduction has nothing to
`do with obfuscating or diminishing the view of the thumbnails, which is the
`upper left. It's about moving toward once you've got a selection, what
`Robertson also does, which is another visual that covers some of them, on
`the right.
`Slide 7, please. We go to the second ground just to introduce it. And
`in the second ground we see the Sauve and the Tsuda references. Upper left,
`Sauve, it's a tabbed browser interface. We've seen these used quite often,
`tabs across the top. They enable access to two-dimensional renderings that
`are below, and thumbnail images, something along those lines, something
`that's designed to give you enough, Sauve says, detail to make sure a user
`can actually make selections among the things that are there. So, Sauve has
`an interest in not crowding that interface too much. You know, it's got to
`rely on a person of ordinary skill to figure out how many objects you're
`going to put on that screen, so you enable that selection.
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`IPR2023-00242
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`To it we combine -- or with respect to it, we combine the Tsuda
`reference's teachings and there it's a 3D-GUI. So those two-dimensional
`boxes there that are underneath the tabs are replaced, you can see when you
`bring the arrows down to the bottom to the combination figure, with what
`would be three-dimensional renderings. Well, why would you do that?
`We've offered several motivations into the record and none of them have
`been challenged. Petition at 57 to 61 expressed those and they're also in the
`opening declaration at 156 to 162. A 3D stack is simply a more efficient
`way to efficiently show information. A 3D stack is a metaphor that helps
`users to find things and to remember them. And the market forces and
`designs were heading this direction, a more sophisticated type of a display.
`Slide 9 we get to the first of the limitations, and this is the replacing.
`We call it limitation because after all, the term starts with “replacing.” In
`green, you can see it's highlighted. The text is “replacing the first and
`second objects within the 3D space with a window within a 2D space.” To
`put that into context, as I promised, we'll turn back to slide 4 and you can see
`the full claim and you can kind of see where this as well as the others would
`fit into it. Not long on this, it's just a long claim, so we wanted to make sure
`you got a sense of where this sat before we started getting deep into it. It's a
`lot of words. We don't think it's very complex or difficult to understand, but,
`again, better to put it into context. The first two steps, upper left,
`“receiving,” that's about getting from the user web pages. There's no dispute
`about these terms. We really don't spend any time on them.
`The second part of the claim is where we'll spend the last of the
`constructions. It's the part where we're going to create a 3D display,
`thumbnails perhaps, other portions of web pages. And that includes subsets
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`for rendering, capturing, and texturing. So you're going to take images and
`then get them into a 3D -- you're going to manipulate and get them into a
`three-dimensional space by doing the steps of this rendering, capturing, and
`texturing, says the '048 patent. And here the only disputed term is with
`respect to the texturing step. It has to do with whether or not there's a
`chronology involved in handling first and second things.
`The third part is what we're going to talk about here on this claim
`term, the first of our constructions, as it relates to displaying additional
`information, additional to those thumbnails or whatever the portions of the
`images are that relate to that web page for which the 3D display was created.
`The receiving step is found here, as you can see.
`Now, if we turn to slide 11, we can see the constructions that have
`been put to this terminology. To left, you've got the Apple construction,
`plain meaning. It's not really construction at all, just plain meaning. There's
`no disavowal, there's no lexicography, there's no reason to depart from it.
`And we know from well-healed and established Federal Circuit jurisdiction
`that you really don't want to depart from plain meaning, plain ordinary
`meaning of claim terms, unless there's either lexicography or disavowal, and
`that's that Stryker case and the whole lineage there. So we see no reason to
`depart from this.
`What we see, however, is from the Patent Owner you've got at its
`response, and actually it came from the POPR, you may remember this
`language, the back-and-forth between 3D and 2D spaces showed up as early
`as the POPR, but it resurfaced at the POR, despite the negative treatment in
`the ID. We commented --
`JUDGE McKONE: Counsel?
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`MR. RENNER: Please?
`JUDGE McKONE: I guess you can hear me okay?
`MR. RENNER: I can, yes, thank you.
`JUDGE McKONE: Great. By replacement, is it Petitioner's position
`that, you know, replacement is simply, I see two objects on the screen and
`they're replaced when I put something on top of those two objects and don't
`see them anymore? Is that what replacement essentially is, in your view?
`MR. RENNER: Yes, Your Honor, it is. And I'd like to --
`JUDGE McKONE: So we can debate what it's replaced with, but I
`just want to at least start with that.
`MR. RENNER: That's correct. That's consistent with -- effectively
`that's consistent with what the specification uses to describe what's being
`done in a replacing type of situation. I think I've got --
`JUDGE McKONE: Counsel, is it more of a visual display?
`MR. RENNER: Yeah, the --
`JUDGE McKONE: Purely a visual thing. It's merely a display. It's
`not what's happening on the back end or something? It's simply I see the
`objects and then I don't because they've been replaced?
`MR. RENNER: Think of it as from the perspective of the user or the
`perspective of the display. You no longer see -- you no longer have the
`image that was once a 3D image in front of you. It's been covered up by a
`2D, therefore replaced. And that's how the specification, again, describes
`the operation. But more important than that, the word "replacing" is, in fact,
`we think, well satisfied as a consequence of that being what the perspective
`of a user and/or display sees.
`JUDGE McKONE: Thank you.
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`MR. RENNER: You're welcome. Now, as mentioned, there's been an
`evolution of the position by the Patent Owner here. Once there was a
`construction in the Patent Owner's reply, and now there's quite a different
`construction offered at the sur-reply you can see on the right-hand side. It's
`not clear, but it looks like the Patent Owner has abandoned the middle.
`They're not saying more about it at this point in the latest brief, so we think
`that's behind us, but we'll spend our time as a consequence on the Patent
`Owner sur-reply construction at the outset. We'll back around just to be
`complete and address that Patent Owner response construction just before
`we depart from this. But let's start, shall we, at the Patent Owner sur-reply.
`So, the far right is the text we're going to look at, and given the
`chronology, it appears that that's what we ought to be looking at. But there
`are minor, it might appear, but very meaningful differences and divergences
`in the plain meaning here. And I want to remind you of the theme that I had
`mentioned earlier, that the terms that are being construed actually appear in
`the proposed construction that we see in front of us. The term "replacing,"
`it's there. "Objects," objects is there, and the "3D space" is there as well.
`Well, it says "within the 3D space," with a window that's there as well, and
`within a 2D space, it says "within a 2D space." So, it seems to repeat or
`reproduce each of the words that are in the claim.
`So far, not so bad, right? But SpaceTime didn't stop there. In fact, it
`added a variety of additional limitations through this proposed instruction or
`this interpretation. And those include a replacement of, or substitution, if
`you will, of the claim's suggestion for a replacing of objects, replacing
`objects, and now it says replacing images. That's a very different situation.
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`Moreover, the replacing of images are “textured on objects,” it says.
`So it requires now replacing images textured on objects, not just replacing
`objects. And the replacing with a window that used to be claimed or is
`claimed has been substituted with “replacing with a window (including the
`rendered first webpage).” We see no reason to diverge from the plain
`meaning of the patent claim for any of these and there's certainly, again, no
`disavowal lexicography. So, we would suggest or submit and request that
`you reject that proposed construction.
`Returning, and I promise, too, to the back-and-forth construction, just,
`again, to make sure we're completing the story. We see again divergence
`from the plain language. Here we'll start upside down. I'll start with what it
`adds. It adds several unrecited limitations. The first of those is it adds a
`requirement for replacement of the entire 3D environment or space with a
`2D space. That's not in the claim. It's not in the plain language. It requires
`replacement of the entire 2D environment or space with a 3D space. After
`all, it says back and forth, so I'm not sure which comes first, but you'd have
`to have a replacement in each direction. Again, not in the claim or not in the
`plain language. And then there is the notion of back and forth, which is
`again missing from the plain language.
`And in addition, it omits the plain language that actually does exist. It
`omits any reference at all to replacing objects in a window. In fact, it doesn't
`even mention objects, doesn't require objects, doesn't require even one
`object, doesn't require a window. So, we think this is equally, if not more,
`unsustainable than the third construction or the second construction that they
`have offered in the sur-reply.
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`Now, in considering that, and we think that it's an unsustainability of
`each of those constructions, we would spend our time here together talking
`just for a moment about the plain meaning as it actually was in the claim,
`and how the art does, in fact, address the replacing term when construed
`using the plain meaning or interpreted using its plain meaning. If I could go
`to slide 24, that'll help us to guide that conversation.
`The only dispute that exists as to the plain meaning of "replacing"
`hasn't really got to do with the claim terms. It has to do with what Robertson
`and Gettman say. SpaceTime's contention is that everything in those
`references takes place in 3D, that there can be no 2D in the disclosure.
`Therefore there can be no replacing of a 3D object or 3D objects with a
`window within 2D space. But there's no dispute that Robertson and
`Gettman both invoke a conventional browser. We talked about that.
`Robertson talks about Internet Explorer, and Gettman, it talks about Mozilla
`and also names outright a conventional browser. And there's no debate on
`this record, and the factual record is clear, that a conventional browser
`presents web pages in a window within a 2D space. We all know this to be
`true, because your own experience will tell you this is true. But according to
`SpaceTime, when you put a browser's output into a 3D space, that somehow
`a 2D space is somehow just not there. We think the record says otherwise,
`and we'll talk a little about that.
`To this point, you can see on this slide in blue highlighting, we show
`an excerpt from the reply, which of course cites to record evidence, and we'll
`go through the record evidence in a moment. But the quote says, "running a
`2D web browser within a 3D space does not change the characteristics of the
`browser." So, even if we accept that we're living in a 3D only environment,
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`you can see that we've got record evidence, uncontested and unopposed, that
`tells us that a browser actually would still be working in a 2D environment.
`That's how a browser works. And let's pause, and I won't go deeper into that
`until we look at the evidence.
`If I could have you follow me then to slide 71. We wanted to
`reproduce a little of that evidence, and it occurred to me in the preparation
`for this that we want to look at that together. So it's paragraph 125 from the
`original declaration from Dr. Fuchs that is shown here, and the yellow
`highlighting is the key. When we talk about the fundamental characteristics
`of a conventional browser, we're talking about a browser that includes and
`operates within 2D space. Conventional browsers like Internet Explorer and
`Mozilla, they have been designed, in fact, for 2D applications at their core.
`And in paragraph 125 of this declaration, Dr. Fuchs gives a technical
`reasoning for this. He says that a "POSITA would have known," I'm reading
`the yellow text now, "would have known that Robertson's reference to
`Internet Explorer suggests a 2D space in the sense that Internet Explorer was
`designed to render webpages using 2D coordinate systems." He gives an
`example, Cascading Style Sheets. He tells us that, "In other words, most
`Internet webpages were coded in 2D layouts and," therefore, "thus,
`conventional web browsers like Internet Explorer were built to render those
`webpages in 2D spaces defined by 2D coordinate systems."
`JUDGE McKONE: Well, let me say, if a browser, a conventional
`browser, is itself a 2D space, how can that be a window within a two-
`dimensional space?
`MR. RENNER: Yeah. Thank you, Your Honor. The browser is the
`program, right, and the browser program, it's going to build an environment
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`within which it'll work. So, it's going to build in an environment and it's the
`window that it has, and that window is within a 2D space that it has to work.
`The browser won't work if it builds a window in a 3D space for its own
`operation. So it's really a product of how browsers launch and work, that
`they're going to persist in a window that's within a 2D space, is how we
`think of it.
`And he clarifies this in his next -- if I go to slide 72, you can see that
`we saw this argument from -- you capture, I think, well, the argument that
`SpaceTime has raised, and we saw that argument. So, we went ahead and
`we augmented with the supplemental declaration on this very point. We
`wanted to confirm for the record.
`And I'll mention in passing, Your Honor, that before I leave the
`original deck, that there was a deposition that occurred with respect to this
`declaration, but there were no questions asked about this passage or this part
`of his testimony. There was no question made to it. Nevertheless, we
`wanted to be sure we gave additional testimony to this very point, and that's
`found in slide 72, paragraph 56.
`Dr. Fuchs here reiterated, and he bolstered this point with the final
`sentence. He'll conclude, and he says, "These statements would still hold
`true even if a conventional 2D browser presenting conventional 2D
`webpages were incorporated into a 3D-GUI." We think that stands to
`reason, and he has explained it above, that conventional web browsers are
`built to work in the context of a 2D space. And the 2D space must exist for
`the conventional browsers to work. So that window that they are working
`within is within a 2D space. Otherwise, they just can't work.
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`And as the '048 patent makes exceptionally clear, it's difficult to
`understand how a display within a 3D space can handle interactive web
`pages using a conventional browser without a 2D space, a concept that
`SpaceTime asks us to embrace. And the absence of any discussion on that
`point in Robertson and Gettman we think is really telling. It leads to a
`logical conclusion that neither intended to communicate that the use of the
`disclosed conventional browsers, that they disclose, that is, would do exactly
`what a conventional browser does, and that is display into a window in a 2D
`space.
`Just imagine what would happen if Robertson and Gettman were
`talking about a web browser scenario where everything takes place in a 3D
`environment without a 2D space. They'd have to disclose with respect to
`that, according to SpaceTime, steps like capturing and rendering and
`texturizing to get the image that they would produce into a 3D space. They
`don't do any of this. They don't disclose anything other than conventional
`web browsers. And they don't talk about specializing them or adapting their
`outputs. They give you examples where just a conventional browser does
`the trick.
`Now, because the evidence, we believe, conclusively shows
`conventional browsers operating in conjunction with 2D spaces and we see
`conventional browsers as one of the embodiments that is offered by each one
`of these references, we don't think that there's really a legitimate question
`here by SpaceTime.
`I'm happy to entertain questions about that. If there are none, I would
`move to the “in response to” construction.
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`JUDGE LORIN: I have a question. Just want to get my bearings
`right here. If we could bring up slide 6, showing Robertson, let me make
`sure I understand your position here. But this figure, figure 9, so the 3D
`space is everything you see behind it, correct. All these small windows that
`are sort of hanging in 3D. Is this what you're saying, this is the 3D space?
`MR. RENNER: Yes, Your Honor.
`JUDGE LORIN: So, that's shown in figure 8A. That will be a 3D
`space. When this -- I see it here, it says Microsoft looks like -- almost like a
`web page. Are you saying that this web page is in 2D? That's a 2D space?
`MR. RENNER: Yes, Your Honor, that's correct.
`JUDGE LORIN: That's what you're saying?
`MR. RENNER: Mm-hmm. From the perspective of the user as well
`as the display. And frankly, because a browser opens a window within a 2D
`space to operate. But that's correct, Your Honor.
`JUDGE LORIN: Okay. So, the replacing is just a matter of
`superimposing?
`MR. RENNER: Correct, also, Your Honor. That is a way to replace.
`JUDGE LORIN: All right. Very good. Okay. I understand your
`position. Thank you very much.
`MR. RENNER: You're welcome. See if there's something here that I
`-- there's testimony, I want to -- I'll see if on rebuttal, I may bring up a little
`more testimony on that very point.
`Slide 20, if you could, please. That's what I'm looking for, thank you,
`Counsel. Yeah, this is from the paragraph prior to 125 that I had shown you
`on slide 71 it was. Here in paragraph 124, the paragraph prior, we see the
`reasoning here that's explained by Dr. Fuchs, Robertson's substantially fill
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`the screen. What he means by that, the statement means, is that the browser
`window is maximized to a full screen view that takes up the entire screen
`and effectively replaces the 3D space, both from the user's perspective of
`what content is viewable, that is only the 2D browser window, and from the
`computer's standpoint, in terms of what content is being displayed, and that
`is only the 2D browser window. So he's describing what Robertson does,
`but it's the same that holds when you apply Gettman to get to the full screen.
`And that is, again, there were no questions offered on that. There was no
`additi