`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`NETFLIX, INC.,
`Petitioner,
`
`v.
`
`GoTV Streaming, LLC,
`Patent Owner
`____________________
`
`Case: IPR2023-00757
`U.S. Patent No. 8,989,715
`____________________
`
`PETITION FOR INTER PARTES REVIEW
`
`Petition Filing Date: April 7, 2023
`
`
`
`
`
`
`
`
`
`
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`
`I. 
`II. 
`III. 
`
`TABLE OF CONTENTS
`INTRODUCTION ........................................................................................... 1 
`GROUNDS FOR STANDING (37 C.F.R. §42.104(A)) ................................. 1 
`STATEMENT OF PRECISE RELIEF REQUESTED FOR EACH
`CLAIM CHALLENGED, INCLUDING CLAIMS AND STUTORY
`GROUNDS (37 C.F.R. §42.204(B)) ............................................................... 2 
`IV.  OVERVIEW OF THE ’715 PATENT ............................................................ 3 
`A. 
`Background of Serving Remotely Executed Applications to Client
`Devices .................................................................................................. 3 
`1. 
`Graphics, Rendering, and Graphical User Interfaces ................. 4 
`2.  Wireless mobile devices ............................................................. 7 
`3. 
`Client-Server Architectures ........................................................ 8 
`The ’715 Specification ........................................................................ 12 
`B. 
`The Prosecution History ...................................................................... 17 
`C. 
`LEVEL OF ORDINARY SKILL IN THE ART ........................................... 18 
`V. 
`VI.  CLAIM CONSTRUCTION .......................................................................... 19 
`VII.  THE PRIMARY PRIOR ART REFERENCES ............................................ 19 
`A.  Overview of Hariki .............................................................................. 19 
`B. 
`Overview of Harris .............................................................................. 21 
`C. 
`Other Evidence Regarding the State of the Art ................................... 25 
`VIII.  DETAILED EXPLANATION OF THE GROUNDS ................................... 25 
`A.  Ground 1: Hariki in view of Harris renders obvious Claims 1-20 ...... 25 
`1. 
`Claim 1 ...................................................................................... 25 
`2. 
`Claim 2 ...................................................................................... 53 
`
`i
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`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`Claim 3 ...................................................................................... 53 
`3. 
`Claim 4 ...................................................................................... 54 
`4. 
`Claim 5 ...................................................................................... 56 
`5. 
`Claim 6 ...................................................................................... 60 
`6. 
`Claim 7 ...................................................................................... 60 
`7. 
`Claim 8 ...................................................................................... 62 
`8. 
`Claim 9 ...................................................................................... 63 
`9. 
`10.  Claim 10 .................................................................................... 64 
`11.  Claim 11 .................................................................................... 65 
`12.  Claim 12 .................................................................................... 65 
`13.  Claim 13 .................................................................................... 65 
`14.  Claim 14 .................................................................................... 65 
`15.  Claim 15 .................................................................................... 66 
`16.  Claim 16 .................................................................................... 66 
`17.  Claim 17 .................................................................................... 66 
`18.  Claim 18 .................................................................................... 73 
`19.  Claim 19 .................................................................................... 73 
`20.  Claim 20 .................................................................................... 73 
`IX.  SECONDARY CONSIDERATIONS ........................................................... 73 
`X.  DISCRETIONARY DENIAL IS NOT WARRANTED UNDER
`EITHER § 314 OR § 325 .............................................................................. 74 
`A. 
`Fintiv Factors ....................................................................................... 74 
`B. 
`Becton Dickinson/Advanced Bionics/General Plastics Factors ......... 77 
`
`ii
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`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`XI.  MANDATORY NOTICES ........................................................................... 78 
`A. 
`Real Parties-in-Interest ........................................................................ 78 
`B. 
`Related Matters .................................................................................... 78 
`C. 
`Lead and Back-Up Counsel, and Service Information Under 37 C.F.R.
`§ 42.8(b)(3) .......................................................................................... 78 
`Service Information Under 37 C.F.R. § 42.8(b)(4) ............................. 79 
`D. 
`Fees ………………………………………………………………..79 
`E. 
`XII.  CONCLUSION .............................................................................................. 79 
`
`
`
`
`iii
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`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`
`EXHIBIT LIST
`
`Description
`
`U.S. Patent No. 8,989,715 (“’715Pat”)
`
`Expert Declaration of Ben Bederson (“Bederson”)
`
`Curriculum Vitae of Benjamin B. Bederson, Ph.D.
`
`File History of U.S. Patent No. 8,989,715 (“’715FH”)
`
`File History of U.S. Patent No. 8,478,245 (“’245FH”)
`
`U.S. Patent Application Publication No. 2007/0150617 (“Hariki”)
`
`U.S. Patent Application Publication No. 2003/0023755 (“Harris”)
`
`U.S. Patent No. 7,447,486 (“Tamura”)
`
`U.S. Patent No. 6,996,627 (“Carden”)
`
`U.S. Patent No. 6,669,564 (“Young”)
`
`U.S. Patent No. 6,732,183 (“Graham”)
`
`U.S. Patent No. 6,507,727 (“Henrick”)
`
`Webpage excerpt from Computer History Museum at
`https://www.computerhistory.org/tdih/april/6/ (last accessed March
`29, 2023)
`
`https://www.webdesignerdepot.com/2009/05/the-evolution-of-cell-
`phone-design-between-1983-2009/
`
`Exhibit
`Number
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`Excerpts from Dan R. Olsen, Jr., Developing user interfaces (1998)
`
`1016
`
`1017
`
`Alok Sinha, Client-server computing, in Communications of the
`ACM, 35, 7 (1992)
`
`Tim Berners-Lee, Robert Cailliau, Ari Luotonen, Henrik Frystyk
`Nielsen, and Arthur Secret, The World-Wide Web, Communications
`
`iv
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`
`Exhibit
`Number
`
`Description
`
`of the ACM 37, 8 76-82 (August 1994), available at
`http://dx.doi.org/10.1145/179606.179671
`
`1018
`
`1019
`
`1020
`
`1021
`
`1022
`
`Eric Kasten, HTML: A Gentle Introduction, Linux Journal (July
`1995), available at https://www.linuxjournal.com/article/1081
`
`U.S. Patent Application Publication No. 2013/0124961 (“Linburn ”)
`
`U.S. Patent No. 8,111,326 (“Talwar”)
`
`Docket Control Order, GovTV Streaming, LLC v. Netflix, Inc., No.
`2:22-cv-07556-RGK-SHK, Dkt. 61 (C.D. Cal. Feb. 13, 2023)
`
`Complaint in GovTV Streaming, LLC v. Netflix, Inc., No. 2:22-cv-
`07556-RGK-SHK (C.D. Cal. October 17, 2022)
`
`
`v
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`LISTING OF CHALLENGED CLAIMS
`
`A method of generating content that is renderable by a wireless
`device, said method comprising:
`
`transmitting, to said wireless device, an identification of a custom
`configuration of a plurality of rendering blocks of said wireless
`device,
`
`wherein said custom configuration is associated with an application
`and configures said plurality of rendering blocks to render content in a
`manner customized to said application; and
`
`transmitting, to said wireless device, compiled content comprising (i)
`first compiled content specific to a first page of said application and
`(ii) second compiled content specific to a second page of said
`application,
`
`wherein said compiled content is generated in part from execution of
`said application,
`
`wherein said compiled content comprises render commands expressed
`in a syntax that is generic to said wireless device, and
`
`wherein said custom configuration is applicable to said first and
`second compiled content,
`
`wherein said compiled content and said custom configuration are
`usable by a graphical user interface comprising said plurality of
`rendering blocks to generate renderable content based on said
`compiled content and said custom configuration.
`
`A method as described in claim 1 wherein said renderable content
`comprises audio content and display content.
`
`Claim 1
`
`[1pre]
`
`1[a]
`
`1[b]
`
`[1c]
`
`[1d]
`
`[1e]
`
`[1f]
`
`[1g]
`
`Claim 2
`
`[2]
`
`Claim 3
`
`vi
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`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`
`A method as described in claim 1 wherein said compiled content is
`partially resultant from said application operating on a remote server.
`
`A method as described in claim 1 wherein said compiled content is
`specific to the rendering capabilities of said wireless device.
`
`A method as described in claim 1 wherein each of said plurality of
`rendering blocks operates specific to a wireless device type of said
`wireless device and each is instructed using a syntax that is generic to
`said wireless device type.
`
`A method as described in claim 5 wherein said custom configuration
`comprises a syntax that is generic regarding said wireless device type.
`
`A method as described in claim 1 wherein said custom configuration
`comprises configuration information and content specific to said
`application.
`
`A method as described in claim 1 wherein said custom configuration
`is one of a plurality of memory-stored custom configurations stored
`by said wireless device, and wherein said method further comprises
`transmitting an identifier that identifies said custom configuration.
`
`A non-transitory computer readable medium comprising instructions
`therein that when executed by a processor implement a method of
`generating content that is renderable by a wireless device, said
`method comprising:
`
`[3]
`
`Claim 4
`
`[4]
`
`Claim 5
`
`[5]
`
`Claim 6
`
`[6]
`
`Claim 7
`
`[7]
`
`Claim 8
`
`[8]
`
`Claim 9
`
`[9pre]
`
`vii
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`
`transmitting, to said wireless device, an identification of a custom
`configuration of a plurality of rendering blocks of said wireless
`device,
`
`wherein said custom configuration is associated with an application
`and configures said plurality of rendering blocks to render content in a
`manner customized to said application; and
`
`transmitting, to said wireless device, compiled content comprising (i)
`first compiled content specific to a first page of said application and
`(ii) second compiled content specific to a second page of said
`application,
`
`wherein said compiled content is generated in part from execution of
`said application,
`
`wherein said compiled content comprises render commands expressed
`in a syntax that is generic to said wireless device, and
`
`wherein said custom configuration is applicable to said first and
`second compiled content,
`
`wherein said compiled content and said custom configuration are
`usable by a graphical user interface comprising said plurality of
`rendering blocks to generate renderable content based on said
`compiled content and said custom configuration.
`
`A non-transitory computer readable medium as described in claim 9
`wherein said renderable content comprises audio content and display
`content.
`
`A non-transitory computer readable medium as described in claim 9
`wherein said compiled content is partially resultant from said
`application operating on a remote server.
`
`[9a]
`
`[9b]
`
`[9c]
`
`[9d]
`
`[9e]
`
`[9f]
`
`[9g]
`
`Claim 10
`
`[10]
`
`Claim 11
`
`[11]
`
`Claim 12
`
`viii
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`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`
`A non-transitory computer readable medium as described in claim 9
`wherein said compiled content is specific to the rendering capabilities
`of said wireless device.
`
`A non-transitory computer readable medium as described in claim 9
`wherein each of said plurality of rendering blocks operates specific to
`a wireless device type of said wireless device and each is instructed
`using a syntax that is generic to said wireless device type.
`
`A non-transitory computer readable medium as described in claim 13
`wherein said custom configuration comprises a syntax that is generic
`regarding said wireless device type.
`
`A non-transitory computer readable medium as described in claim 9
`wherein said custom configuration comprises configuration
`information and content specific to said application.
`
`A non-transitory computer readable medium as described in claim 9
`wherein said method further comprises transmitting an identifier that
`identifies said custom configuration.
`
`A server that is programmed to generate content that is renderable by
`a wireless device, comprising:
`
`[12]
`
`Claim 13
`
`[13]
`
`Claim 14
`
`[14]
`
`Claim 15
`
`[15]
`
`Claim 16
`
`[16]
`
`Claim 17
`
`[17pre]
`
`[17a]
`
`a library of applications
`
`[17b]
`
`a library of custom configuration data comprising a custom
`configuration that configures a plurality of rendering blocks of said
`wireless device to render content in a manner customized to an
`application from said library of applications requested by said
`wireless device; and
`
`ix
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`
`a layout solver that transmits compiled content to said wireless
`device, said compiled content comprising (i) first compiled content
`specific to a first page of said application and (ii) second compiled
`content specific to a second page of said application,
`
`wherein said compiled content is generated in part from execution of
`said application by said server,
`
`wherein said compiled content comprises render commands expressed
`in a syntax that is generic to said wireless device, and
`
`wherein said custom configuration is applicable to said first and
`second compiled content,
`
`wherein said compiled content and said custom configuration are
`usable by a graphical user interface comprising said plurality of
`rendering blocks to generate renderable content based on said
`compiled content and said custom configuration.
`
`A server as described in claim 17 wherein said renderable content
`comprises audio content and display content.
`
`A server as described in claim 17 wherein said compiled content is
`specific to the rendering capabilities of said wireless device.
`
`A server as described in claim 17 wherein said custom configuration
`comprises configuration information and content specific to said
`application.
`
`[17c]
`
`[17d]
`
`[17e]
`
`[17f]
`
`[17g]
`
`Claim 18
`
`[18]
`
`Claim 19
`
`[19]
`
`Claim 20
`
`[20]
`
`x
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`
`I.
`
`INTRODUCTION
`Netflix, Inc. (“Petitioner”) respectfully requests inter partes review of claims
`
`1-20 of U.S. Patent No. 8,989,715 (“the ’715 patent” or “’715Pat”), filed on April
`
`18, 2013, and claims priority to application no. 11/888,803, filed August 1, 2007,
`
`both assigned to GoTV Streaming, LLC (“PO” or “GoTV”).
`
`As demonstrated below, there is a high likelihood that Petitioner will prevail
`
`with respect to each of the challenged claims and, therefore, Petitioner respectfully
`
`requests that the Board institute trial.
`
`II. GROUNDS FOR STANDING (37 C.F.R. §42.104(A))
`Petitioner certifies that the ’715 patent is available for inter partes review
`
`(“IPR”) and Petitioner is not barred or estopped from requesting IPR to challenge
`
`the claims on the grounds herein. Petitioner files this Petition within one year of
`
`service of Patent Owner’s complaint against Petitioner. See GoTV Streaming, LLC
`
`v. Netflix, Inc., No. 2:22-cv-07556-RGK-SHK (C.D. Cal. Oct. 17, 2022) (Netflix,
`
`Inc., served 10/25/2022).
`
`
`
`1
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`III. STATEMENT OF PRECISE RELIEF REQUESTED FOR EACH
`CLAIM CHALLENGED, INCLUDING CLAIMS AND STUTORY
`GROUNDS (37 C.F.R. §42.204(B))
`Petitioner respectfully requests review and cancellation under 35 U.S.C.
`
`§311 of the challenged claims in view of:1
`
`Prior Art
`
`U.S. Patent Application Publication No. 2007/0150617 (“Hariki”), filed July 25,
`2006, published January 28, 2007, priority December 22, 2005; prior art under 35
`U.S.C. §102(a) (Exhibit 1006).
`
`U.S. Patent Application Publication No. 2003/0023755 (“Harris”), published
`January, 30, 2003; prior art under 35 U.S.C. §102(b) (Exhibit 1007)
`
`
`Ground
`
`Claims
`
`Basis
`
`1-20
`
`35 U.S.C. §103 based on Hariki in view of Harris
`
`1
`
`
`
`1 Petitioners do not concede that any challenged claims satisfy other requirements
`
`for patentability that cannot be raised in IPR, including Section 101 and 112.
`
`
`
`2
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`
`IV. OVERVIEW OF THE ’715 PATENT2
`A. Background of Serving Remotely Executed Applications to Client
`Devices
`Downloading content from a remote device through a network was well-
`
`known before 2007. By 2000, following the dot-com boom of the late 1990s, the
`
`popularity of the Internet increased, and users were turning from traditional media
`
`sources, such as television and newspaper, to the Internet to receive media content.
`
`EX1008, 1:12-16.3 A user might go to media servers containing information from
`
`various content providers.
`
`Id., 1:16-19. For example,
`
`techniques
`
`for
`
`
`2 This background, and the Grounds of Unpatentability herein, are further
`
`supported by the Declaration of Petitioner’s expert, Ben Bederson, who has over
`
`30 years of experience related to remote application execution. Declaration of Ben
`
`Bederson (“Bederson”) (EX1002).
`
`3 To the extent that any of the references in this section are cited in this Petition, it
`
`merely demonstrates POSITAs’ knowledge, the state of the art, and/or as evidence
`
`that POSITAs would have been motivated to make the combinations in the manner
`
`discussed in this Petition. KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 420 (2007)
`
`(“[A]ny need or problem known in the field of endeavor at the time of invention
`
`and addressed by the patent can provide a reason for combining the elements in the
`
`manner claimed.”). These exhibits are not part of the unpatentability grounds.
`
`
`
`3
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`transmitting/receiving data via a cellular phone were developed well before 2003,
`
`so that users can experience content with a large amount of data, such as video and
`
`music, on their cellular phones. EX1009, 1:17-20.
`
`Those in the art recognized that, at least by 2007, servers could provide to a
`
`remote client automatic delivery of multimedia content, such as entertainment
`
`content. EX1008, 1:29-34; EX1010, Abstract; see also EX1011, Abstract. Prior to
`
`the ’715 patent, it was a known problem that transmission of content was limited
`
`by, for example, bandwidth and connection rates of mobile devices. EX1012, 1:42-
`
`57. A common goal was to improve network efficiency from a transmitter to a
`
`terminal. Id.
`
`As described below, client/server architectures, rendering technologies, and
`
`wireless devices were well-known to those of ordinary skill in the art at the time of
`
`the alleged inventions claimed in the ’715 Patent. Bederson, ¶¶ 47- 65.
`
`1. Graphics, Rendering, and Graphical User Interfaces
`In computing, whether mobile or desktop, a user interface is the boundary
`
`where interactions between humans and computers occur. An early type of user
`
`interface is the command-line interface, where the user enters text commands to
`
`the computer via the keyboard and the computer executes those commands. The
`
`command-line interface was simple and efficient, but it suffered from several
`
`drawbacks. For instance, the interface was difficult for users to learn, because to
`
`
`
`4
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`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`operate the computer, they first had to learn all the commands. Generally,
`
`commands in command-line interfaces were not expressed in natural language, but
`
`rather arbitrary abbreviations and acronyms that users had to memorize. For
`
`example, in the early Microsoft DOS operation system, text commands included
`
`“cd,” “dir,” and “chkdsk.” This resulted in a user interface that was not very
`
`intuitive—a novice user could not use the user interface by simply experimenting
`
`with the interface.
`
`An advancement to the command-line interface was the Graphical User
`
`Interface (“GUI”). GUIs offer visual interfaces on display screens that are designed
`
`for simplicity and ease of learning. A common and well-known example of a GUI
`
`uses the “desktop metaphor,” where files and applications of the computer system
`
`are represented as graphical icons on a virtual desktop shown on the computer
`
`screen, and where the user interacts with those icons using a pointing device such
`
`as a mouse cursor. Windows 3.1, released by Microsoft in 1992,4 was one example
`
`of such a GUI:
`
`
`4 See, e.g., https://www.computerhistory.org/tdih/april/6/ (last accessed March 29,
`
`2023) (EX1013).
`
`
`
`5
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`
`
`
`Figure A. Screenshot of Microsoft Windows 3.1 taken by Benjamin B. Bederson
`
`on March 28, 2023 using an emulator running in VMWare Fusion. Bederson, ¶ 48.
`
`One main goal of GUIs was to make the user interface more intuitive and
`
`easy to learn by implementing concepts that are analogues to the real—dragging an
`
`icon to move across the computer screen “desktop,” for example, resembles the act
`
`of moving an object in the real world that a user is already familiar with. Part of
`
`the process for generating GUIs involves “rendering” the graphics—that is,
`
`deciding which specific color each pixel on the screen should be so as to form the
`
`visual elements of the interface. Id., ¶50. This rendering technology has been well-
`
`known for decades. Id., ¶50. For example, a 1998 book titled “Developing User
`
`Interfaces” describes many of the technical elements of this rendering. Id., ¶50
`
`(citing Dan R. Olsen, Jr., Developing user interfaces (1998) (EX10161015)). For
`
`
`
`6
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`example, on page 51, it discusses “the basic 2D primitives that are required to
`
`present information to the users so they can interactively manipulate it.” Id., p. 51.
`
`It covers topics such as the coordinate systems of 2D computer graphics, how to
`
`represent shapes such as lines with pixels, how to manage the drawing of text at
`
`different sizes with different fonts, etc. Bederson, ¶50.
`
`By 2007, such rendering technologies were fairly standardized and built into
`
`essentially every computer operating system that supported GUIs, including
`
`desktop and mobile devices. While many systems rendered application GUIs on
`
`the same device that executed the application, there were also other well-known
`
`architectures that rendered GUIs on remote devices (e.g., “clients”). In this case,
`
`the application ran on other computers and sent graphics commands to a client
`
`computer to be rendered.
`
`2. Wireless mobile devices
`Mobile phones, a common type of wireless device, have been around since
`
`the 1980s. During the 1990s, great improvements were made in mobile phone
`
`technology that made mobile phones smaller and more energy-efficient. In the
`
`2000s, mobiles phones using Third Generation technology, or 3G, were
`
`introduced. This technology was not only capable of transferring voice data (such
`
`as a phone call) but was also capable of transferring other types of data, including
`
`emails and instant messages. By 2000, wireless phones included touch screens and
`
`
`
`7
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`increased graphics capacity. In 2003, the PalmOne Treo 600 and BlackBerry 7210
`
`included color screens. EX1014. PDAs (Personal Digital Assistants) were another
`
`common kind of wireless device available in the early 2000s.
`
`3.
`Client-Server Architectures
`Historically, computers were big and expensive and they provided “time
`
`shared” access to multiple terminals. Sometimes those terminals (a.k.a. “clients”)
`
`were “dumb” or “thin,” and provided primarily input and output capabilities while
`
`most of the computation was provided at the “server.” Other times, those clients
`
`had greater computation capability, and in the early 1980s with the introduction of
`
`“personal computers,” those clients (while still often connected to servers) had
`
`sufficient computational capabilities to run independently.
`
`The relationship between “clients” and “servers” is so foundational to the
`
`history of computers that it is often used to define the nature of the computing
`
`architecture as well as the user experience. The state of client-server computing
`
`was described in a 1992 article in Communications of the ACM a broad interest
`
`magazine of the main professional international computer society. See EX1016
`
`(“Sinha”). Sinha characterized some of the key elements of client-side computing,
`
`including that the client typically communicates with the server, transmitting
`
`queries or commands, performs data analysis on query or command results from
`
`the server and presents the GUI. On the server-side, servers typically provide a
`
`
`
`8
`
`

`

`IPR2023-00757
`U.S. Patent No. 8,989,715
`service to the client, responding to the queries or commands–and do so in a way
`
`that hides much of the details of its implementation so that clients with various
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`kinds of software and hardware can work with it. Sinha also explains that as far
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`back as 1992, it was common to have the GUI of an application displayed on a
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`computer remote from the application. It describes the X Window System that
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`commonly ran on Unix environments which “provides network transparency so
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`that an application displaying a chart on a screen could be running on a local
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`machine or a remote machine thousands of miles away.” Id., 91.
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`One particularly important set of clients and servers communicate over the
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`Internet in what has come to be called the World Wide Web (“WWW”). Tim
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`Berners-Lee initially developed the WWW in 1990. While Internet-based
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`communications had been around for some time at that point, the WWW simplified
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`things by combining a few basic technologies, including web servers, web
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`browsers, HTTP, and HTML. The Internet was an enabling technology, allowing
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`computers to communicate arbitrary information between any location in the
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`world. See EX1017.
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`Web servers are computers on the Internet that run software to listen to web
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`“requests” and respond to those requests, typically by returning (i.e., serving) a
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`document that was requested. Subject to hardware resource limitations, a web
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`server may serve any number of web pages. Static web pages may be stored on a
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`server’s hard drives and processed in memory. Server-generated web pages, such
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`as those generated in response to a user’s search request, are generated and
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`processed in memory. See EX1017, 76-78. Web servers used the Hypertext
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`Transfer Protocol (HTTP), a simple request/response network protocol that was
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`developed by Berners-Lee, which allows an HTTP connection to be made from a
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`client to a host.
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`Web browsers are client applications, that provide a user interface for
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`displaying data fetched from web servers. Somewhat like a word processing
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`program that can open a document and render it, a web browser can open a special
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`kind of document written using Hypertext Markup Language (HTML) and render
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`it. However, web browsers have additional features including that they can fetch
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`those documents across the Internet from web servers using the HTTP protocol.
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`Web browser requests are made to specific servers that are identified by Uniform
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`Resource Locators (“URLs”). HTML documents can include references to images
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`or other data, such as audio files, that are specified via URLs and are fetched from
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`specific web servers via those URLs. The browser then displays those separately
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`retrieved images integrated with the textual document. Web browsers also can
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`interpret the HTML documents they display to recognize hyperlinks that, when
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`clicked on by a user, fetch additional documents or data referenced by another
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`URL that is specified by the HTML’s hyperlink. If the link points to a document,
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`the newly fetched HTML document is then displayed, typically replacing the
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`previously displayed document. As Berners-Lee described in 1994, these URLs
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`identify a single specific server, offering a “Universal” way of locating and
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`accessing for any network communications protocol, including HTTP. See
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`EX1017, 76-78.
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`HTML is a textual document format for describing the visual presentation of
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`documents, including embedded objects such as images and forms as well as links
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`to other documents. It consists of plain text that will be displayed as such along
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`with “tags” which surround portions of text and are used to modify how that text is
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`displayed. Tags are formed by a word surrounded by a pair of angle brackets with
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`a matching closing tag that is prefixed with a forward slash. For example, the
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`following is a simple HTML snippet: “Here is some <B>bold text</B>.” See
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`EX1018. When this HTML is interpreted by a web browser, it would be displayed
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`as following:
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`Here is some bold text.
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`HTML can include links to other documents. It specifies those links with an
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`“anchor” tag (i.e., <A ...> and a closing </A> tag) along with URLs to indicate the
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`location of the other document. URLs are created in text with a specific structured
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`format including several elements such as the address (often represented by a
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`domain name) of a web server the other document is on, and the location (or
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`“path”) of that document on the web server. An example of an anchor tag follows
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`where the “HREF” parameter specifies the URL of the document to be fetched and
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`displayed when the link is clicked (see EX1018, 3):
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`<A HREF=“http://remote.host.name/docs/foo.html”>Foodocument</A>
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`As shown in these examples, HTML provides a syntax that is generic and
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`can be used to define applications in a way that can work on client computer. In
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`general, web sites are collections of HTML-based web pages that are stored or
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`generated on a web server that is typically accessed by a single domain address. In
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`order for a user to view those web sites, they would direct their web browser to
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`load the web page located at a specific URL. At that point, the web browser would
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`communicate with the web server specified by the URL via the World Wide Web
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`to fetch the desired web page and would then render the page for display. See
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`EX1018, 1-3. Web pages supported multimedia and rich interactive content well
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`before 2007. A key part of HTML is that it allowed the ability to download
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`separately defined images or icons from web servers and embed them in a web
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`page.
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`B.
`The ’715 Specification
`The ’715 patent is directed to “[a] method of rendering content on a wireless
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`device.” ’715Pat, Abstract. The specification explains that “a wireless device . . . is
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`operable to communicate with a server and receive a series of low level basic
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`commands that layout content, position, etc. for rendering application content on
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`the wireless device.” Id., 2:46-50. Figure 1A is described as “an exemplary
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`communication system 100A in accordance with one embodiment of the present
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`invention including wireless clients and a remote server.” Id., 5:65-6:1. The system
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`includes “one or more wireless devices 110 [] coupled to a server 130 through a
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`network 120.” Id., 6:1-3.
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`’715Pat, FIG. 1.
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`
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`Figures 2A and 2B show “communication sequence[s] 200A and 200B
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`between a wireless device 210 and a remote server 230.” Id., 11:9-12. “At step 212
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`the client 210 sends a message to the server 230 identifying the wireless device
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`type and its capabilities along with a request to access an application o