UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`
`v.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`DODOTS LICENSING SOLUTIONS LLC,
`Patent Owner
`_____________________________
`
`Case No. IPR2023-00621 (Patent 8,020,083)
`Case No. IPR2023-00701 (Patent 8,510,407)
`Case No. IPR2023-00756 (Patent 9,369,545)
`_____________________________
`
`Patent Owner’s Demonstratives
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`1
`
`

`

`Agenda
`
`I.
`
`II.
`
`Timeline and Internet in the
`Late 1990s
`Introduction to DoDots and the
`Kembel Brothers
`A.
`Story of the Kembels
`B. Browsers
`C. DoDots’ Solution
`D. Recognition
`
`V.
`
`III. Patents and Claims
`IV. Motivation to Combine and
`Prima Facie Case
`Failed Combinations
`A. Brown and Wecker
`B.
`Shimada and Buchholz
`C. Other References
`VI. Remaining Secondary
`Considerations
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`2
`
`

`

`I
`
`Timeline and Internet in the Late 1990s
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`3
`
`

`

`Timeline
`
`Priority date: April 26, 1999
`
`Trapped in
`Browser
`
`Downloadable HTML
`Motorola PageWriter
`Active Desktop
`
`Investments
`$250M Valuation
`Industry Praise
`Adoption by Large Companies
`250K Users
`
`Apple App Store / Android Apps
`
`Patents Not Contested
`
`Lenovo, Apple, Samsung IPRs
`
`IPR2023-00701: Sur-Reply, 1
`Note: citations to the 701 IPR are exemplary. In most
`cases similar citations are made across the IPRs. They
`are set forth in each applicable POR and Sur-Reply.
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`4
`
`

`

`Internet in the Late 1990s
`
`https://www.axiom.tech/looking-back-at-
`the-y2k-scare/
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`5
`
`DODOTS-2061
`
`

`

`Dr. Ted Selker
`
`DODOTS-2011
`
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`
`6
`
`

`

`Internet in the Late 1990s
`
`IPR2023-00701: DODOTS-2060;
`Sur-Reply, 1
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`IPR2023-00701: DODOTS-
`2066; Sur-Reply, 19
`
`IPR2023-00701:
`DODOTS-2010, ¶139;
`Sur-Reply, 1
`
`

`

`Internet in the Late 1990s
`
`DR. TED SELKER
`
`MODEM
`24
`
`IPR2023-00701:
`DODOTS-2010, ¶138-
`39; Sur-Reply, 1
`
`IPR2023-00701: Wecker (SAMSUNG-1006), Fig.
`1; DODOTS-2010, ¶123; POR, 14
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`8
`
`

`

`Internet in the Late 1990s
`
`DR. GREENSPUN
`
`IPR2023-00701: Greenspun Decl.
`(SAMSUNG-1029) ¶82 n.4
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`9
`
`

`

`Goliath and Goliath
`
` Netscape had 70 – 75% of the browser
`market
` Microsoft tried to make inroads by
`“subsum[ing] Internet Navigation into
`the P.C. operating system.”
` Public outcry led the DOJ to get involved
` The Internet was controlled by browsers
`
`IPR2023-00701: DODOTS-
`2061, 2; Sur-Reply, 1
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`10
`
`

`

`II
`
`Introduction to the Kembels
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`11
`
`

`

`John and George
`
`JOHN KEMBEL
`
`GEORGE KEMBEL
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`

`

`Long-felt Need / Known Problem
`
`JOHN KEMBEL
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`IPR2023-00701: DODOTS-2021 ¶3, 8;
`POR, 74, 78
`
`

`

`Ah-ha
`
`JOHN KEMBEL
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`14
`
`IPR2023,00407: J. Kembel Dep. Tr. (SAMSUNG-1031), 18:7-9;
`Sur-Reply, p. 23;
`
`

`

`John and George / Failure of Microsoft
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`15
`
`IPR2023-00701: DODOTS-2022; Sur-Reply,
`25, 28
`
`

`

`John and George
`
`IPR2023-00701: DODOTS-2023; Sur-
`Reply, 28-29
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`16
`
`

`

`Fully Configurable
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2023-00701:
`DODOTS-2043, p. 27;
`Sur-Reply, 27
`
`17
`
`

`

`DoDots
`
`IPR2023-00701: DODOTS-2021,
`¶32; POR, 2
`
`IPR2023-00701:
`DODOTS-2043, p. 27;
`Sur-Reply, 27
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`18
`
`

`

`III.
`
`Patents and Claims
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`19
`
`

`

`Patents at Issue
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`20
`
`

`

`Core Claim Limitations
`
`Network information
`monitor (NIM) template
` a data structure
` that defines the
`characteristics of a NIM,
`including
`• the NIM frame
`• view, and
`• control characteristics
` and that excludes
`executable
`applications/compiled code
`
`
`Network information
`nominator (NIM)
` a fully configurable frame,
`with one or more controls,
`through which content is
`presented to the user
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`21
`
`

`

`Core Claim Limitations
`
`Network information
`monitor (NIM) template
`
`
`Network information
`nominator (NIM)
`
`407 Patent (IPR2023-
`00701, SAMSUNG-1001),
`23:1-45
`
`IPR2023-00701: DODOTS-2023, p. 4; Sur-Reply,
`29
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`22
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`

`

`Fully Configurable
`
`1. A computer-implemented method . . . comprising:
`transmitting a request to the server over the network, the request requesting fully configurable frame, with one or more controls, through which
`content is presented to the user [defined by]a data structure that defines the characteristics of a NIM, including the NIM frame, view, and control
`characteristics, and that excludes executable applications/compiled code;
`receiving the requested fully configurable frame, with one or more controls, through which content is presented to the user [defined by] a data
`structure that defines the characteristics of a NIM, including the NIM frame, view, and control characteristics, and that excludes executable
`applications/compiled code from the server over the internet, the requested fully configurable frame, with one or more controls, through which
`content is presented to the user [defined by] a data structure that defines the characteristics of a NIM, including the NIM frame, view, and control
`characteristics, and that excludes executable applications/compiled code having been transmitted from the server over the network responsive
`to the transmitted request, the fully configurable frame, with one or more controls, through which content is presented to the user [defined by] a
`data structure that defines the characteristics of a NIM, including the NIM frame, view, and control characteristics, and that excludes executable
`applications/compiled code comprising:
`a definition of a viewer GUI within which content in a web browser-readable language may be presented on the display of the client computing
`device; and
`a definition of a first content element for the fully configurable frame, with one or more controls, through which content is presented to the user
`[defined by] a data structure that defines the characteristics of a NIM, including the NIM frame, view, and control characteristics, and that
`excludes executable applications/compiled code, the definition of the first content element referencing a first network location from which the
`first content element for the fully configurable frame, with one or more controls, through which content is presented to the user [defined by] a data
`structure that defines the characteristics of a NIM, including the NIM frame, view, and control characteristics, and that excludes executable
`applications/compiled code is served over the network;
`responsive to instructions included in the requested fully configurable frame, with one or more controls, through which content is presented to the
`user [defined by] a data structure that defines the characteristics of a NIM, including the NIM frame, view, and control characteristics, and that
`excludes executable applications/compiled code, presenting the viewer GUI defined by the fully configurable frame, with one or more controls,
`through which content is presented to the user on the display of the client computing device separate from and outside of any other GUI that
`includes user controls for specifying the first network location from which the first content element for the fully configurable frame, with one or
`more controls, through which content is presented to the user is served over the network;
`responsive to instructions included in the requested fully configurable frame, with one or more controls, through which content is presented to the
`user [defined by] a data structure that defines the characteristics of a NIM, including the NIM frame, view, and control characteristics, and that
`excludes executable applications/compiled code, transmitting over the network a first content request to the first network location referenced by
`the definition of the first content element for the fully configurable frame, with one or more controls, through which content is presented to the
`user [defined by] a data structure that defines the characteristics of a NIM, including the NIM frame, view, and control characteristics, and that
`excludes executable applications/compiled code;
`receiving, over the network, the first content element transmitted responsive to the first content request;
`presenting the received the first content element in the viewer GUI defined by the fully configurable frame, with one or more controls, through
`which content is presented to the user a data structure that defines the characteristics of a NIM, including the NIM frame, view, and control
`characteristics, and that excludes executable applications/compiled code, wherein the definition of the viewer GUI and/or the first content
`element define all controls for enabling a user to interact with the first content element through the viewer graphical user interface.
`
`NIM Template: a data structure that defines the
`characteristics of a NIM, including the NIM
`frame, view, and control characteristics, and
`that excludes executable
`applications/compiled code.
`
`NIM: fully configurable frame, with one or more
`controls, through which content is presented to
`the user
`
`IPR2023-00701: Pet., 4 (bold in original)
`
`545 Patent, Claim 1
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`23
`
`

`

`Fully Configurable
`
`DR. TED SELKER
`
`IPR2023-200701: Selker Decl.; DODOTS-2010, ¶29
`and POR, 6-7
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`24
`
`

`

`Fully Configurable
`
`DR. TED SELKER
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`25
`
`IPR2023-00701: SAMSUNG-1030, 136:8-25; Sur-Reply, 26
`
`

`

`Remaining Claim Construction
`
`Contested
` “execute the template”
`(083 Patent)
`
`IPR2023-0062: POR, 9; Sur-Reply, 18
`
`Uncontested
` “client computing device”
`(407 Patent; 545 Patent)
` “client device”
`(083 Patent)
`
`IPR2023-00701: POR, 9-10 see generally Reply
`IPR2023-00621: POR, 9-10; see generally Reply
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`26
`
`

`

`IV
`
`Motivation to Combine and Prima Facie Case
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`27
`
`

`

`Obviousness
`
`A determination of whether a patent claim
`is invalid as obvious under § 103 requires
`consideration of all four Graham factors,
`and it is error to reach a conclusion of
`obviousness until all of those factors are
`considered.
`
`IPR2023-00701: Artic Cat Inv. v. Bombardier Rec. Prods., 876 F.3d 1350, 1358;
`Sur-Reply, 3-4
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`28
`
`

`

`Bodily Incorporation
`
`The Board found that . . . Intel has not
`specifically explained how a person of
`ordinary skill in the art would have modified
`King[] . . . to incorporate a shared bus as
`disclosed in Arimilli.
`* * *
`To be sure, evidence that the teachings and
`concepts of the prior art were (either actually
`or apparently) incompatible such that a
`skilled artisan would not have reasonably
`expected to succeed in combining those
`teachings is relevant to the obviousness
`analysis. But the Board never made a factual
`finding that King’s bus system could not be
`modified to include Arimilli’s . . . . As we
`just explained, the Board merely stated that
`combining the relevant aspects of the two
`references requires a modification that the
`references did not teach and that Intel did not
`provide.
`
`the
`between
`differences
`Fundamental
`references are central to this motivation to
`combine inquiry.
`
`Adidas AG v. Nike, Inc., 963 F.3d 1355, 1359 (Fed. Cir. 2020);
`Samsung Elecs. Co. v. Elm 3DS Innovations, LLC, 925 F.3d
`1373, 1381 (Fed. Cir. 2019) (incompatibility of references
`from “the same technological field” insufficient to establish
`compatibility/obviousness.
`
`Intel Corp. v. Pact XPP Schweiz AG, No. 2022-1038, 2023 U.S. App.
`LEXIS 4436, at *8-9 (Fed. Cir. Feb. 24, 2023); IPR2023-00701 Sur-
`Reply, 7-8
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`29
`
`

`

`Bodily Incorporation
`
`TriVascular’s proposed substitution would
`destroy the basic objective of the barbs,
`which is to penetrate surrounding tissue. . . .
`Moreover, in order to meet the claimed
`limitations, not only the barbs but also the
`underlying recesses in Samuels ’851 would
`need to be replaced with inflatable non-
`penetrating protrusions. . . . Thus, the Board's
`findings regarding the lack of a motivation to
`combine are
`supported by
`substantial
`evidence.
`
`TriVascular, Inc. v. Samuels, 812 F.3d 1056, 1067 (Fed. Cir. 2016); U.S. Patent No.
`5,423,851.; IPR2023-00701 Sur-Reply, 8,11
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`30
`
`

`

`Terminology
`
` “NIM definition,” “NIM
`template,” “Dot
`template”
` “NIM,” “Application
`Media Package,” “Dot”
`
` Markup Languages
`(XML, HTML, HTT,
`HDML)
`
`IPR2023-00701: POR, 15; DODOTS-2010, ¶185; Sur-Reply, 14
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`31
`
`

`

`Terminology
`
` “Mobile channel”
`• Script
`• Data file
`• CDF
`• “subscription”
` “Part of a Channel”
` “Channel Definition
`Format (CDF)”
` HTML instructions / tags
` “Components”
` User-viewable content
`
`IPR2023-00701: Reply, 2
`
`IPR2023-00701: Pet., 13
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`32
`
`IPR2023-00701: Wecker (SAMSUNG-1006), Fig.
`6; Pet., 31
`
`

`

`Terminology
`
` blending
` executing visual basic scripts
` operating a loadable transport
` processing with Internet Explorer 4.0
`and (deskhtml.dll)
` rendering
`
`IPR2023-00701: Reply, 2
`
` “template”
`• Brown
`• Wecker*
`• Shimada
`• Buchholz
`• Beer
`• Krishna
`• Darnell
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`33
`
`

`

`NIM/NIM Template
`
`1. A computer-implemented method . . . comprising:
`transmitting a request to the server over the network, the request requesting
`NIM template;
`receiving the requested NIM template from the server over the internet, the
`requested NIM template having been transmitted from the server over the
`network responsive to the transmitted request, the NIM template comprising:
`a definition of a viewer GUI within which content in a web browser-readable
`language may be presented on the display of the client computing device; and
`a definition of a first content element for the NIM template, the definition of
`the first content element referencing a first network location from which the
`first content element for the NIM template is served over the network;
`responsive to instructions included in the requested NIM template, presenting
`the viewer GUI defined by the NIM on the display of the client computing device
`separate from and outside of any other GUI that includes user controls for
`specifying the first network location from which the first content element for
`the NIM is served over the network;
`responsive to instructions included in the requested NIM template, transmitting
`over the network a first content request to the first network location referenced
`by the definition of the first content element for the NIM template;
`receiving, over the network, the first content element transmitted responsive to
`the first content request;
`presenting the received the first content element in the viewer GUI defined by
`the NIM template, wherein the definition of the viewer GUI and/or the first
`content element define all controls for enabling a user to interact with the first
`content element through the viewer graphical user interface.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`545 Patent, Claim 1
`
`IPR2023-00701: Brown
`(SAMSUNG-1005), Fig. 7;
`Sur-Reply, 10
`
`34
`
`

`

`Gaps
`
`?
`
`?
`
`?
`
`subchannel
`CDF FILES
`201
`
`RADIO
`RECEIVER
`AND DRIVER
`201
`
`SCRIPT
`TEMPLATES
`204
`
`DATA
`204
`
`?
`
`IPR2023-00701: Brown
`(SAMSUNG-1005), Fig.
`7; Sur-Reply, 10
`
`IPR2023-00701: Wecker
`(SAMSUNG-1006), Fig.
`6; Sur-Reply, 10
`
`LOADBLE
`TRANSPORT
`220
`
`HTML
`PAGE
`224
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`
`

`

`Gaps
`
`IPR2023-00701: Schmidt Decl. (SAMSUNG-1003) ¶111
`IPR2023-00756: Schmidt Decl. (SAMSUNG-1003) ¶64
`
`DR. SCHMIDT
`
`IPR2023-00701: DODOTS-2010, ¶179; Sur-Reply, 9
`
`DR. TED SELKER
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`36
`
`

`

`Motivation to Combine
`
`IPR2023-00701: Brown (SAMSUNG-1005), 13:4-13
`
`IPR2023-00701: Pet., 12
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`37
`
`

`

`Motivation to Combine
`
` Windows 95 / Windows CE
` Same programming languages
`
`Johns Manville Corp. v. Knauf Insulation, Inc., IPR No. 2018-00827, Paper 9, p. 17 (citing
`PersonalWeb Techs., LLC v. Apple, Inc., 848 F.3d 987, 994 (Fed. Cir. 2017)) (“mere
`compatibility of references is insufficient to support obviousness.”); DODOTS-2010, ¶153-
`57.
`
`to improve data transfer times, increase
`usability,
`standardize
`interfaces
`across
`different devices, reduce client-side storage
`requirements, and/or to capitalize on the
`growing need to display internet content in a
`customizable way. . . .
`
`and/or other relevant business or technical
`reasons
`
`Hulu, LLC v. Sound View Innovations, LLC, Case IPR2018-00582, Paper 34 (August 5, 2019)
`(informative decision) (“a generic desire for ‘improved access times’ in the Reply strikes
`us as merely a bald statement . . . .”)
`
`IPR2023-00701: Pet., 12-15, 69
`
`IPR2023-00701: Sur-Reply, 5
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`38
`
`

`

`Motivation to Combine
`
` Wecker’s “mobile channel ‘script files’”
`being like templates
`
`desktop
`
`desktop components would be implemented
`as mobile channels, such that a user would
`download desktop components,
`
`. . . application of known techniques (e.g.,
`rendering content using
`templates/script
`files) to a known structure (e.g., Brown’s
`composite desktop)
`to yield predictable
`results.
`
`. . . techniques of downloading template files
`stored on remote devices (e.g., as part of a
`channel)
`
`IPR2023-00701: Pet., 12-14; Reply, 2
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`39
`
`

`

`Motivation to Combine Concepts
`
`Brown Disclosure
`desktop.htt file
`
`HTML tags
`(in desktop.htt
`file)
`
` URL
`
`(HTML tags)
`
`
`
`
` CDF file
`
`(at URL)
`
`
`
`
`
`
`
`
`subscription
`
`
`
`(URL at URL)
`
`
`
`
`user-viewable
`components
`Active Desktop
`
`Techniques
`rendering content
`using script files
`subscribing
`
`Wecker
`Disclosure
`script
`templates
`mobile
`channels
`
`Reasonable
`Expectation
`common assignee,
`Microsoft
`common operating
`system, Windows 95
`
`Asano Disclosure
`adjustable pedal
`with a fixed pivot
`
`Techniques
`mounting sensor
`on pivot
`
`Smith Disclosure
`sensor
`
`Reasonable
`Expectation
`had already been
`accomplished in
`Smith
`Rixon taught how
`to avoid wire-
`chafing
`
`downloading
`
`implementing
`
`requesting
`
`storing
`
`“a model similar to
`Wecker’s mobile
`channel
`subscription model”
`“managing
`templates remotely
`and separately from
`Internet content”
`
`common operating
`system, Windows CE
`(407 and 083 IPRs)
`
`data files
`(content)
`
`CDF files
`desktop
`computer
`
`KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 424-25
`(2007); IPR2023-00701, Sur-Reply 7
`
`IPR2023-00701: Sur-Reply 2-3, 7-9, 15; Reply, 1-3; POR,
`15, 20; 42-43; Pet., 12, 14-15
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`40
`
`

`

`V.A
`
`Failed Combinations | Brown and Wecker
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`41
`
`

`

`Brown
`
`User-Viewable Webpage
`
`HTT System File
`
`DESKTOP.HTT
`code
`
`Registry
`
`data contained in the registry
`
`Internet Explorer 4.0 (deskhtml.dll)
`
`Microsoft
`
`User-Viewable Component
`
`IPR2023-00701: Brown (SAMSUNG-1005), Figs. 3a
`and 4, 11:29-46; Sur-Reply, 9.
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`42
`
`

`

`Brown
`
`Internet Explorer 4.0 (deskhtml.dll)
`
`Microsoft
`
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`43
`
`IPR2023-00701: 407 Patent (SAMSUNG-
`1001), 2:1-5, 25-36; POR, 4, 39, 74;
`DODOTS-2010, ¶108
`
`

`

`Brown
`
`”
`http://www.microsoft.com/ie/ie40/gallery/ticker.htm
`
`http://www.microsoft.com/ie/ie40/
`gallery/cdf/g__stock.cdf
`
`www.microsoft.com/ie/images/ulg/ulg__ie40.jpg
`
`http ://
`
`http://www.microsoft.com/ie/
`”
`images/ulg/ulg__ie40.jpg
`
`http://www.uspto.gov/
`
`http://www.uspto.gov/
`
`IPR2023-00701: Brown (SAMSUNG-1005) 11:43-
`12:43; Sur-Reply, 16
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`44
`
`

`

`Brown
`
`INSTRUCTIONS
`
`IPR2023-00701: Brown (SAMSUNG-1005), 6:20-32;
`Fig. 7; POR, 36; Sur-Reply, 10
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`45
`
`

`

`Brown
`
`IPR2023-00701; Brown (SAMSUNG-1005), 6:33-40; DODOTS-2010, ¶47; POR, 11
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`46
`
`

`

`Brown
`
`<IMG
`
`1.5
`
`>
`
`< IFR AM E
`
`< IFR AM E
`
`< OBJECT
`
`>
`
`1.5
`
`>
`
`>
`< OBJECT
`
`IPR2023-00701: Pet. p. 9
`(annotation in Petition)
`
`IPR2023-00701: Pet. p. 26 (presentation
`and annotations revised); Sur-Reply, 14.
`
`>
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`47
`
`

`

`Independent NIMS
`
`545 Patent
`12. The method of claim 1, further comprising causing
`the networked information monitor to communicate
`with another networked information monitor.
`
`407 Patent
`2. The method of claim 1, further comprising,
`responsive to reception of one or more elements
`included in the received time-varying content,
`modifying a feature of said viewer graphical user
`interface defined by the networked information monitor
`template in accordance with a modification
`corresponding to the received one or more elements.
`12. The client computing device of claim 1, wherein the
`one or more computer program modules are further
`configured:
`to transmit, over the network to a networked
`information monitor server, a request for the networked
`information monitor template;
`to receive, from the networked information monitor
`server over the network, the networked information
`monitor template; and
`to store the networked information monitor template to
`the electronic storage.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`083 Patent
`4. The client device of claim 1, wherein the plurality of
`networked information monitor templates further
`comprises a second networked information monitor
`template defining a second networked information
`monitor, wherein the second networked information
`monitor template comprises:
`(1) a second content reference that comprises a
`second network location, which is different from the
`network location in the content reference of the first
`networked information monitor template, at which
`content for the second networked information monitor
`is accessible via the TCP/IP protocol; and
`(2) a definition of a graphical user interface of the
`second networked information monitor that lacks
`controls for manually navigating a network, and that
`includes a second frame within which content received
`from the second network location can be displayed;
`and
`(3) instructions configured (i) to cause the second
`networked information monitor to request content from
`the second network location in the second content
`reference via the TCP/IP protocol, and (ii) to cause the
`second networked information monitor to generate the
`graphical user interface of the second networked
`information monitor with the content received from the
`second network location via the TCP/IP protocol within
`the frame.
`
`083 Patent
`5. The client device of claim 4, wherein the one or more
`processors are further configured to execute the
`second networked information monitor template such
`that the graphical user interface of the second
`networked information monitor is presented to the user
`on the electronic display separately and discretely from
`the user interface of the first networked information
`monitor, and having content therein received from the
`second content reference
`6. The client device of claim 1, wherein the one or more
`processors are further configured to transmit a request
`to a server for a further networked information monitor
`template responsive to reception of a user request for a
`further networked information monitor defined by the
`further networked information monitor template.
`
`IPR2023-00701: Sur-Reply, 11, 23
`
`48
`
`

`

`Wecker
`
`DR. TED SELKER
`
`IPR2023-00701: DODOTS-2010, ¶121
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`49
`
`IPR2023-00701: Wecker (SAMSUNG-
`1006), Fig. 4
`
`

`

`Wecker
`
`RADIO
`RECEIVER
`AND DRIVER
`201
`
`CDF FILES
`201
`
`SCRIPT
`TEMPLATES
`204
`
`DATA
`204
`
`LOADBLE
`TANSPORT
`220
`
`files
`
`channel definition format (CDF)
`
`script
`
`data files
`
`(HTML)
`
`HDML
`
`IPR2023-00701: Wecker (SAMSUNG-1006), 1:55-62; 3:8-16
`POR p. 14-15; Sur-Reply p. 16; DODOS-2010, ¶128
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`50
`
`

`

`Brown and Wecker
`
`CDF files 201
`HTML pages 224
`204
`data 202
`CDF files 201.
`204
`
`subchannel
`
`script templates
`
`script template
`CDF file 201
`
`CDF file 201
`
`data
`
`CDF file 201
`
`data
`
`HTML page 224
`
`data
`blending script templates 204,
`more complex
`full HTML pages
`
`data 202
`
`CDF files 201
`
`full HTML pages.
`
`IPR2023-00701: Wecker (SAMSUNG-1006),
`10:25-48, Fig. 7; POR, 15 (annotations revised)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`51
`
`

`

`V.B
`
`Failed Combinations | Shimada and Buchholz
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`52
`
`

`

`Shimada and Buchholz
`
`PETITIONER
`
`DR. SCHMIDT
`
`IPR2023-00701: 407 Pet. p. 68-69
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`53
`
`IPR2023-00701: SAMSUNG-1029 ¶84 and n.5
`
`

`

`Shimada
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`54
`
`IPR2023-00701: Pet., 76-77Reply, 25; Sur-Reply, 21;
`
`

`

`Shimada
`
`SCREEN
`CONFIGURATI ON
`EXPANDING
`DEVICE
`
`103
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`55
`
`IPR2023-00701: POR p. 50 (citing Shimada Fig. 1)
`
`

`

`Shimada
`
`103
`
`SCREEN
`CONFIGURATI ON
`EXPANDING
`DEVICE
`
`103
`
`SCREEN
`CONFIGURATION
`TEMPLATE
`
`IPR2023-00701: POR p. 50 (citing Shimada Fig. 1)
`
`IPR2023-00701: POR p. 61
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`56
`
`

`

`Shimada
`
`IPR2023-00701: Pet. p. 71-72 (citing Shimada Fig. 17 (Pet.
`annotation, DoDots’ highlight)
`
`IPR2023-00701: DODOTS-2010 ¶267
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`57
`
`

`

`Shimada
`
`5
`
`6
`
`7
`
`8
`
`1
`
`2
`
`3
`
`4
`
`9
`
`10
`
`2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2023-00701: DODOTS ¶182-193
`
`58
`
`

`

`Shimada
`
`IPR2023-00701: DODOTS-2010,
`¶280-82; Sur-Reply 22
`
`IPR2023-00701: 407 Pet., 75
`(Petitioner’s annotations)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`59
`
`

`

`Shimada
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2023-00701: SAMSUNG-
`1003 ¶169 (citing Fig. 18)
`
`60
`
`

`

`Buchholz
`
`Motorola PageWriterTM 2000
`
`Radio Frequency (RF)
`
`Motorola RF-Orchestra!
`Transmitter and RF-Audience
`
`Motorola Wireless Messaging
`Gateway (WMGTM)
`Administrator! Paging terminal
`and RF-Conductor! TM message
`distributor
`
`IPR2023-00701; Wecker (SAMSUNG-1006),
`2:65-3:15; Fig. 1; Sur-Reply, 19
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`61
`
`

`

`Shimada and Buchholz
`
`Buchholz (SAMSUNG-1009), 5:11-13; Fig. 1;
`Sur-Reply p. 19
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`62
`
`

`

`Shimada and Buchholz
`
`DR. GREENSPUN
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`63
`
`IPR2023-00701: Greenspun Decl. (SAMSUNG-
`1029) ¶58, 82 n.4; Sur-Reply, 20
`
`

`

`V.C
`
`Failed Combinations | Other References
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`64
`
`

`

`Beer
`
`PR2023-00407: Beer (SAMSUNG-1007), 3:34-40;
`Sur-Reply, 17
`
`Beer (SAMSUNG-1007), Fig. 3
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`65
`
`

`

`Darnell and Krishna (545)
`
`IPR2023-00756: Krishna (SAMSUNG-1021), cover, 3:30-36; Sur-
`Reply, 18
`
`IPR2023-00756: Darnell (SAMSUNG-1011); Sur-
`Reply, 17
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`66
`
`

`

`VI
`
`Other Secondary Considerations
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`67
`
`

`

`Nexus
`
`There is a presumption of nexus for objective
`considerations when the patentee shows that
`the asserted objective evidence is tied to a
`specific
`product
`and
`that
`product
`“is the invention disclosed and claimed in the
`patent.”
`* * *
`The presumption of nexus is rebuttable: a
`patent challenger may respond by presenting
`evidence that shows the proffered objective
`evidence was “due to extraneous factors
`other than the patented invention.”
`
`WBIP, LLC v. Kohler Co.,
`829 F.3d 1317, 1329
`(Fed. Cir. 2016)
`
`A showing of nexus can be made in two
`ways: (1) via a presumption of nexus, or (2)
`via a showing that the evidence is a direct
`result of the unique characteristics of the
`claimed invention
`
`Volvo Penta of the Ams., LLC v. Brunswick Corp., 81 F.4th
`1202, 1210 (Fed. Cir. 2023)
`
`“We have never held that the existence of
`one or more unclaimed features, standing
`alone, means nexus may not be presumed.”
`
`Teva Pharms. Int’l GmbH
`v. Eli Lilly & Co., 8 F.4th
`1349, 1361 (Fed. Cir.
`2021) (cleaned up)
`
`IPR2023-00701: Sur-Reply, 22-24
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`68
`
`

`

`Independent NIMS
`
`545 Patent
`12. The method of claim 1, further comprising causing
`the networked information monitor to communicate
`with another networked information monitor.
`
`407 Patent
`2. The method of claim 1, further comprising,
`responsive to reception of one or more elements
`included in the received time-varying content,
`modifying a feature of said viewer graphical user
`interface defined by the networked information monitor
`template in accordance with a modification
`corresponding to the received one or more elements.
`12. The client computing device of claim 1, wherein the
`one or more computer program modules are further
`configured:
`to transmit, over the network to a networked
`information monitor server, a request for the networked
`information monitor template;
`to receive, from the networked information monitor
`server over the network, the networked information
`monitor template; and
`to store the networked information monitor template to
`the electronic storage.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`083 Patent
`4. The client device of claim 1, wherein the plurality of
`networked information monitor templates further
`comprises a second networked information monitor
`template defining a second networked information
`monitor, wherein the second networked information
`monitor template comprises:
`(1) a second content reference that comprises a
`second network location, which is different from the
`network location in the content reference of the first
`networked information monitor template, at which
`content for the second networked information monitor
`is accessible via the TCP/IP protocol; and
`(2) a definition of a graphical user interface of the
`second networked information monitor that lacks
`controls for manually navigating a network, and that
`includes a second frame within which content received
`from the second network location can be displayed;
`and
`(3) instructions configured (i) to cause the second
`networked information monitor to request content from
`the second network location in the second content
`reference via the TCP/IP protocol, and (ii) to cause the
`second networked information monitor to generate the
`graphical user interface of the second networked
`information monitor with the content received from the
`second network location via the TCP/IP protocol within
`the frame.
`
`083 Patent
`5. The client device of claim 4, wherein the one or more
`processors are further configured to execute the
`second networked information monitor template such
`that the graphical user interface of the second
`networked information monitor is presented to the user
`on the electronic display separately and discretely from
`the user interface of the first networked information
`monitor, and having content therein received from the
`second content reference
`6. The client device of claim 1, wherein the one or more
`processors are further configured to transmit a request
`to a server for a further networked information monitor
`template responsive to reception of a user request for a
`further networked information monitor defined by the
`further networked information monitor template.
`
`IPR2023-00701: Sur-Reply, 11, 23
`
`69
`
`

`

`Nexus
`
`DR. TED SELKER
`
`IPR2023-00701: DODOTS-2010, ¶286;
`Sur-Reply, 22
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`70
`
`

`

`Nexus
`
`DR. TED SELKER
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`71
`
`IPR2023-00701: DODOTS-2010, ¶287-
`291; Sur-Reply, 22
`
`

`

`Nexus
`
`JOHN KEMBEL
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`72
`
`IPR2023-00701: DODOTS-2021; Sur-Reply, 24
`
`

`

`Nexus
`
`JOHN KEMBEL
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`73
`
`IPR2023-00701: J. Kembel Dep. Tr. (SAMSUNG-1028), 21:22-
`22:14; Sur-Reply p. 24
`
`

`

`Awards
`
`GEORGE KEMBEL
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`74
`
`IPR2023-00701: DODOTS-2030 and
`DODOTS-2042; POR, 5, 81.
`
`

`

`Praise
`
`GEORGE KEMBEL
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2023-00701: DODOTS-2030; POR
`79-80
`
`75
`
`

`

`Commercial Success
`
`IPR2023-00701: DODOTS-2027 p. 29, 88;
`Sur-Reply, 27
`
`IPR2023-00701: DODOTS-2043 p. 3; Sur-Reply, 27
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`76
`
`

`

`Commercial Success
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`77
`
`IPR2023-00701: DODOTS-2043 p. 3; Sur-Reply, 27
`
`

`

`Samsung and Apple Grasp the Concepts
`
`IPR2023-00701: DODOTS-2055;
`DODOTS-2010 ¶304; POR, 1 n.1, 78
`
`Samsung
`
`Apple
`
`IPR2023-00701: DODOTS-2054; DODOTS-2010 ¶304;
`POR, 6, 78
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`78
`
`