IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`John Albert Kembel, et al.
`In re Patent of:
`8,020,083
`U.S. Patent No.:
`September 13, 2011
`Issue Date:
`Appl. Serial No.: 11/932,585
`Filing Date:
`October 31, 2007
`Title:
`SYSTEM AND METHODS FOR CREATING AND AUTHORING
`INTERNET CONTENT USING APPLICATION MEDIA
`PACKAGES
`
` Attorney Docket No.: 39843-0148IP1
`
`DECLARATION OF DR. DOUGLAS C. SCHMIDT
`
`I, Dr. Douglas C. Schmidt, of Nashville, Tennessee, declare that:
`
`QUALIFICATIONS AND BACKGROUND INFORMATION
`My qualifications can be found in my Curriculum Vitae, which is
`
`1.
`
`submitted with this Declaration as Exhibit 1004 and includes a complete list of my
`
`education, patents and publications, employment and research history, and
`
`professional activities and awards.
`
`2.
`
`I am currently tenured as the Cornelius Vanderbilt Professor of
`
`Engineering with the Department of Electrical Engineering and Computer Science
`
`at Vanderbilt University in Nashville, TN, where I also serve as the Associate
`
`Chair of the Computer Science Department. I have been a full-time university
`
`professor since 1994, and I was previously a tenured professor at the University of
`
`California, Irvine with the Electrical and Computer Engineering department from
`
`2000 to 2003 and Washington University in St. Louis, MO with the Computer
`
`1
`
`SAMSUNG 1003
`
`
`
`John Albert Kembel, et al.
`In re Patent of:
`8,020,083
`U.S. Patent No.:
`September 13, 2011
`Issue Date:
`Appl. Serial No.: 11/932,585
`Filing Date:
`October 31, 2007
`Title:
`SYSTEM AND METHODS FOR CREATING AND AUTHORING
`INTERNET CONTENT USING APPLICATION MEDIA
`PACKAGES
`
` Attorney Docket No.: 39843-0148IP1
`
`DECLARATION OF DR. DOUGLAS C. SCHMIDT
`
`I, Dr. Douglas C. Schmidt, of Nashville, Tennessee, declare that:
`
`QUALIFICATIONS AND BACKGROUND INFORMATION
`My qualifications can be found in my Curriculum Vitae, which is
`
`1.
`
`submitted with this Declaration as Exhibit 1004 and includes a complete list of my
`
`education, patents and publications, employment and research history, and
`
`professional activities and awards.
`
`2.
`
`I am currently tenured as the Cornelius Vanderbilt Professor of
`
`Engineering with the Department of Electrical Engineering and Computer Science
`
`at Vanderbilt University in Nashville, TN, where I also serve as the Associate
`
`Chair of the Computer Science Department. I have been a full-time university
`
`professor since 1994, and I was previously a tenured professor at the University of
`
`California, Irvine with the Electrical and Computer Engineering department from
`
`2000 to 2003 and Washington University in St. Louis, MO with the Computer
`
`1
`
`SAMSUNG 1003
`
`
`
`Subscriptions
`D.
`The Internet is known to host various forms of in-demand digital
`
`25.
`
`content, so systems have been created that are directed to providing “up-to-date”
`
`information on a recurring basis (a “subscription”). SAMSUNG-1005, 13:1-13;
`
`SAMSUNG-1006, 3:58-67, 2:1-13; SAMSUNG-1009, 1:13-26. One early example
`
`of Internet subscriptions was the “PointCast” system first released to the public in
`
`February, 1996. SAMSUNG-1017. PointCast was designed to “display regularly
`
`updated news in place of a user’s more conventional screensaver” and included
`
`categories for “News, Companies, Industries, Weather, Sports, and Lifestyle.” Id.
`
`As one example of data retrieved through a subscription, a user can be subscribed
`
`to receive regular updates of information related to stocks. SAMSUNG-1005, FIG.
`
`3A, SAMSUNG-1006, 10:48-55; SAMSUNG-1009, 1:13-20. One additional
`
`example of a subscription service is Microsoft’s Channel Definition Format (CDF),
`
`which is discussed by both Brown and Wecker. SAMSUNG-1005, 13:1-13;
`
`SAMSUNG-1006, 3:3-16.
`
`INTERPRETATIONS OF THE ’083 PATENT CLAIMS AT ISSUE
`
`26.
`
`I understand that, for purposes of my analysis in this inter partes
`
`review proceeding, the terms appearing in the patent claims should be interpreted
`
`according to their “broadest reasonable construction in light of the specification of
`
`the patent in which it appears.” 37 C.F.R. § 42.100(b). In that regard, I understand
`
`16
`
`
`
`ADDITIONAL REMARKS
`
`180. I currently hold the opinions set expressed in this declaration. My
`
`analysis may continue, however, and I may acquire additional information and/or
`
`attain supplemental insights that may result in added observations and opinions.
`
`181. I declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be true.
`
`Moreover, these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both
`
`under Section 1001 of Title 18 of the United States Code.
`
`
`
`Dated:
`
`02/22/2023
`
`By:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`113
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`John Albert Kembel, et al.
`In re Patent of:
`9,369,545
`U.S. Patent No.:
`June 14, 2016
`Issue Date:
`Appl. Serial No.: 13/975,227
`Filing Date:
`August 23, 2013
`Title:
`ACCESSING AND DISPLAYING NETWORK CONTENT
`
` Attorney Docket No.: 39843-0150IP1
`
`DECLARATION OF DR. DOUGLAS C. SCHMIDT
`
`I, Dr. Douglas C. Schmidt, of Nashville, Tennessee, declare that:
`
`QUALIFICATIONS AND BACKGROUND INFORMATION
`My qualifications can be found in my Curriculum Vitae, which is
`
`1.
`
`submitted with this Declaration as Exhibit 1004 and includes a complete list of my
`
`education, patents and publications, employment and research history, and
`
`professional activities and awards.
`
`2.
`
`I am currently tenured as the Cornelius Vanderbilt Professor of
`
`Engineering with the Department of Electrical Engineering and Computer Science
`
`at Vanderbilt University in Nashville, TN, where I also serve as the Associate
`
`Chair of the Computer Science Department. I have been a full-time university
`
`professor since 1994, and I was previously a tenured professor at the University of
`
`California, Irvine with the Electrical and Computer Engineering department from
`
`2000 to 2003 and Washington University in St. Louis, MO with the Computer
`
`Science and Engineering department from 1994 to 2000. In addition, I served as
`
`1
`
`SAMSUNG 1003
`
`
`
`SAMSUNG-1006, 3:58-67, 2:1-13; SAMSUNG-1009, 1:13-26. One early example
`
`of Internet subscriptions was the “PointCast” system first released to the public in
`
`February, 1996. SAMSUNG-1017. PointCast was designed to “display regularly
`
`updated news in place of a user’s more conventional screensaver” and included
`
`categories for “News, Companies, Industries, Weather, Sports, and Lifestyle.” Id.
`
`As one example of data retrieved through a subscription, a user can be subscribed
`
`to receive regular updates of information related to stocks. SAMSUNG-1005, FIG.
`
`3A, SAMSUNG-1006, 10:48-55; SAMSUNG-1009, 1:13-20. One additional
`
`example of a subscription service is Microsoft’s Channel Definition Format (CDF),
`
`which is discussed by both Brown and Wecker. SAMSUNG-1005, 13:1-13;
`
`SAMSUNG-1006, 3:3-16.
`
`INTERPRETATIONS OF THE ’545 PATENT CLAIMS AT ISSUE
`
`26.
`
`I understand that, for purposes of my analysis in this inter partes
`
`review proceeding, the terms appearing in the patent claims should be interpreted
`
`according to their “broadest reasonable construction in light of the specification of
`
`the patent in which it appears.” 37 C.F.R. § 42.100(b). In that regard, I understand
`
`that the best indicator of claim meaning is its usage in the context of the patent
`
`specification as understood by a POSITA. I further understand that the words of
`
`the claims should be given their plain meaning unless that meaning is inconsistent
`
`with the patent specification or the patent’s history of examination before the
`
`17
`
`
`
`ADDITIONAL REMARKS
`
`222. I currently hold the opinions set expressed in this declaration. But my
`
`analysis may continue, and I may acquire additional information and/or attain
`
`supplemental insights that may result in added observations.
`
`223. I declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be true;
`
`and further that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both
`
`under Section 1001 of Title 18 of the United States Code.
`
`
`
`Dated: 03/28/2023
`
`
`
`By:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`133
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`John Albert Kembel, et al.
`In re Patent of:
`8,510,407
`U.S. Patent No.:
`August 13, 2013
`Issue Date:
`Appl. Serial No.: 11/932,553
`Filing Date:
`October 31, 2007
`Title:
`DISPLAYING TIME-VARYING INTERNET BASED DATA
`USING APPLICATION MEDIA PACKAGES
`
` Attorney Docket No.: 39843-0149IP1
`
`DECLARATION OF DR. DOUGLAS C. SCHMIDT
`
`I, Dr. Douglas C. Schmidt, of Nashville, Tennessee, declare that:
`
`QUALIFICATIONS AND BACKGROUND INFORMATION
`My qualifications can be found in my Curriculum Vitae, which is
`
`1.
`
`submitted with this Declaration as Exhibit 1004 and includes a complete list of my
`
`education, patents and publications, employment and research history, and
`
`professional activities and awards.
`
`2.
`
`I am currently tenured as the Cornelius Vanderbilt Professor of
`
`Engineering with the Department of Electrical Engineering and Computer Science
`
`at Vanderbilt University in Nashville, TN, where I also serve as the Associate
`
`Chair of the Computer Science Department. I have been a full-time university
`
`professor since 1994, and I was previously a tenured professor at the University of
`
`California, Irvine with the Electrical and Computer Engineering department from
`
`2000 to 2003 and Washington University in St. Louis, MO with the Computer
`
`Science and Engineering department from 1994 to 2000. In addition, I served as
`
`1
`
`SAMSUNG 1003
`
`
`
`which is discussed by both Brown and Wecker. SAMSUNG-1005, 13:1-13;
`
`SAMSUNG-1006, 3:3-16.
`
`INTERPRETATIONS OF THE ’407 PATENT CLAIMS AT ISSUE
`
`26.
`
`I understand that, for purposes of my analysis in this inter partes
`
`review proceeding, the terms appearing in the patent claims should be interpreted
`
`according to their “broadest reasonable construction in light of the specification of
`
`the patent in which it appears.” 37 C.F.R. § 42.100(b). In that regard, I understand
`
`that the best indicator of claim meaning is its usage in the context of the patent
`
`specification as understood by a POSITA. I further understand that the words of
`
`the claims should be given their plain meaning unless that meaning is inconsistent
`
`with the patent specification or the patent’s history of examination before the
`
`Patent Office. I also understand that the words of the claims should be interpreted
`
`as they would have been interpreted by a POSITA at the time of the invention was
`
`made (not today). Because I do not know at what date the invention as claimed
`
`was made, I have used the earliest priority date of U.S. Patent No. 8,510,407 as the
`
`point in time for claim interpretation purposes. That date was April 26, 1999.
`
`27.
`
`I understand that the following terms should be interpreted as follows:
`
`“networked information monitor” (“NIM”)
`
`28.
`
`I understand that for the purposes of the present proceeding, this term,
`
`which appears in claims 1, 11, 13, and 23, should be construed to mean “a fully
`
`17
`
`
`
`
`
`ADDITIONAL REMARKS
`
`233. I currently hold the opinions set expressed in this declaration. But my
`
`analysis may continue, and I may acquire additional information and/or attain
`
`supplemental insights that may result in added observations.
`
`234. I declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be true;
`
`and further that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both
`
`under Section 1001 of Title 18 of the United States Code.
`
`
`
`Dated: March 9th, 2023
`
` By:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`129
`
`
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