Patent Owner’s
`Oral Argument Presentation†
`
`Netflix, Inc. v. GoTV Streaming, LLC, Nos. IPR2023-00757 & IPR2023-00758
`re U.S. Patent Nos. 8,989,715 and 8,478,245
`
`Before Richard M. Lebovitz, Brian J. McNamara, and Steven M. Amundson,
`Administrative Patent Judges
`
`August 6, 2024
`
`Presented by Joshua Wyde,
`Counsel for Patent Owner
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE;
`
`GoTV
`Ex. 2031
`
`1
`
`
`Oral Argument Presentation†
`
`Netflix, Inc. v. GoTV Streaming, LLC, Nos. IPR2023-00757 & IPR2023-00758
`re U.S. Patent Nos. 8,989,715 and 8,478,245
`
`Before Richard M. Lebovitz, Brian J. McNamara, and Steven M. Amundson,
`Administrative Patent Judges
`
`August 6, 2024
`
`Presented by Joshua Wyde,
`Counsel for Patent Owner
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE;
`
`GoTV
`Ex. 2031
`
`1
`
`
`
`Table of Contents
`
`I.
`
`Custom Configuration Is Not Applicable to Compiled Content
`
`Page
`
`3
`
`II. Custom Configuration Does Not Configure Rendering Blocks “Customized To” Identified Applications 13
`
`III. Compiled Content Is Not Generated from Application Execution or Transmitted to Wireless Device
`
`IV.
`
`’245 Patent Missing Same Independent Claim Limitations
`
`V.
`
`Identified Application Is Not in a Library of Applications (’715 Unique)
`
`VI.
`
`Identified Engine Does Not Read Compiled Content (’245 Unique)
`
`VII.
`
`Identified Rendering Block Is Not a Ticker (’245 Unique)
`
`22
`
`37
`
`38
`
`41
`
`43
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`2
`
`
`
`[1f/9f/17f] wherein said custom configuration is
`applicable to said first and second compiled content
`
`Custom Configuration Is Not Applicable to Compiled Content
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 51–54; Sur-Reply 17–20
`
`3
`
`
`
`Custom Configuration Configures Compiled Content
`
`Ex. 1001 3:13–15
`
`
`The server sends custom The server sends custom
`
`configuration to the client and configuration to the client and
`
`the client configures the GUI’s the client configures the GUI’s
`
`rendering blocks to set how rendering blocks to set how
`
`compiled content will “operate compiled content will “operate
`
`and look.”and look.”
`Ex. 1001 7:55–63; 10:56–58; 18:40–42
`
`Ex. 1001 Fig. 1B
`
`
`Compiled content of the requested Compiled content of the requested
`
`application is sent separatelyapplication is sent separately
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 9
`
`4
`
`
`
`Content Reference Allows Configuration to be “Applicable”
`
`
`Compiled Compiled
`
`Content PageContent Page
`
`Ex. 1001 Fig. 4.
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`
`By referencing IDs of By referencing IDs of
`
`rendering blocks rendering blocks
`
`customized by the custom customized by the custom
`
`configuration the configuration the
`
`rendering blocks are rendering blocks are
`
`“applicable” (i.e., “applicable” (i.e.,
`
`applied) to the compiled applied) to the compiled
`
`contentcontent
`
`POR 8
`
`POR 8
`
`5
`
`
`
`Pet. IDs HTML/UI Skin as “Compiled Content”/“Cust. Config.”
`
`
`Petitioner identifies the “converted Petitioner identifies the “converted
`
`resource files . . . in Hariki’s UI resource files . . . in Hariki’s UI
`
`content package” on the device content package” on the device
`
`as “the claimed ‘custom as “the claimed ‘custom
`
`configuration.’” configuration.’”
`
`Pet. 30
`
`
`Petitioner identifies the “compiled Petitioner identifies the “compiled
`
`content” as “HTML files” from “World-content” as “HTML files” from “World-
`
`Wide Web (WWW) server [102].”Wide Web (WWW) server [102].”
`Pet. 38–39 (quoting Ex. 1006 [0021])
`
`HTML
`
`
`HTML may come from another HTML may come from another
`
`server without the UI authoring server without the UI authoring
`
`tool like 106 or any other content tool like 106 or any other content
`
`provider on the internet.provider on the internet.
`Ex. 1006 [0021]
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`Ex. 1006 Fig. 1
`
`POR 51; Sur-Reply 18–19
`
`6
`
`
`
`UI Skin Operates on Background, Buttons, Alerts, Title Bars
`
`From Ex. 1006 Fig. 1
`
`
`
`BackgroundBackground
`
`
`AlertAlert
`
`soundssounds
`
`†
`
`
`Soft Soft
`
`ButtonButton
`
`
`UI Skin Converted Resources operates on “rendering UI Skin Converted Resources operates on “rendering
`
`blocks” such as the device’s “backgrounds, title blocks” such as the device’s “backgrounds, title
`
`bars, buttons, and alert sounds.”bars, buttons, and alert sounds.”
`
`Pet 47 (quoting Ex. 1006 [0022])
`
`From Ex. 1006 Fig. 5
`
`† Image of T-Mobile G1 from The Dream Has Come True: T-Mobile G1 with Google (Sept. 23, 2008), available at
`https://www.phonearena.com/news/The-dream-has-come-true-T-Mobile-G1-with-Google_id3181
`POR 51–52; Sur-Reply 18–19
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`7
`
`
`
`Browser Application Is Not Identified HTML Compiled Content
`
`
`
`Identified Compiled ContentIdentified Compiled Content
`
`Petitioner identified a
`browser as the application
`
`Title Bar
`
`†
`
`From Ex. 1006 Fig. 1
`
`From Ex. 1006
`Fig. 5
`
`
`Petitioner identified HTML inside Petitioner identified HTML inside
`
`browser as compiled content browser as compiled content
`Pet. 38–39 (quoting Ex. 1006 [0021])
`
`
`UI SkinUI Skin
`
`Converted ResourcesConverted Resources
`
`† Image of T-Mobile G1 from Repost of Larry’s 2008 review of the first Android phone (first appeared in Mercury News
`on Oct. 16, 2008), available at https://www.larrysworld.com/repost-of-larrys-sept-2008-look-at-the-first-android-
`phone/
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 51–52
`
`8
`
`
`
`UI Skin is Not Applied to HTML Content
`
`†
`
`Mr. Lipoff, P.E.
`
`HTML sets how the page is
`displayed, not UI skin
`resources
`
`Ex. 2022 ¶156; accord Pet. 11, 38
`
`HTML standard has no
`provision for interfacing
`with the UI skin accessed
`through Hariki-specific
`local API
`
`Ex. 2022 ¶¶156–57
`
`Petitioner left these arguments unrebutted
`
`Reply 21–22
`
`† Image of T-Mobile G1 from Repost of Larry’s 2008 review of the first Android phone (first appeared in Mercury
`News on Oct. 16, 2008), available at https://www.larrysworld.com/repost-of-larrys-sept-2008-look-at-the-first-
`POR 52; Sur-Reply 19–20
`android-phone/
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`9
`
`
`
`Hariki-Harris HTML Displays Properly before Sent to Device
`
`
`Location of Hariki’s Location of Hariki’s
`
`UI content packageUI content package
`
`
`“[A]utomated testing “[A]utomated testing
`
`environment will make environment will make
`
`sure content will sure content will
`
`display[] correctly display[] correctly
`
`before they are before they are
`
`deployed to a device.”deployed to a device.”
`
`Ex. 1007 [0035]
`
`Ex. 1006 Fig. 1
`
`Petitioner again left this argument unrebutted
`
`Reply 21–22
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 52–54; Sur-Reply 19–20
`
`10
`
`
`
`Petitioner Does Not Meet Inherency’s High Bar
`
`Reply 22
`
`
`Does not mention HTML once; says UI Skin “allows” Does not mention HTML once; says UI Skin “allows”
`
`an application program to access the resource, not an application program to access the resource, not
`
`that is must or naturally does; configuration can be that is must or naturally does; configuration can be
`
`“backgrounds, title bars, buttons, alert sounds”“backgrounds, title bars, buttons, alert sounds”
`
`PAR Pharm., Inc. v. TWI Pharm., Inc.,
`773 F.3d 1186, 1196 (Fed. Cir. 2014)
`
`A party must “meet a high standard in order to rely on inherency to
`establish the existence of a claim limitation in the prior art
`in an
`obviousness analysis—the limitation at
`issue necessarily must be
`present, or the natural result of the combination of elements explicitly
`disclosed by the prior art.”
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`Sur-Reply 18–19
`
`11
`
`
`
`Dr. Bederson Parrots Argument without Further Explanation
`
`Reply 22
`
`Ex. 1002 ¶ 148
`
`Sur-Reply 18–19
`
`12
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`
`
`[1b/9b] 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
`
`. custom configuration that configures a plurality of
`.
`[17b] .
`rendering blocks of said wireless device to render content
`in a
`manner customized to an application . . .
`
`Custom Configuration Does Not Configure Rendering Blocks
`“Customized To” Identified Applications
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 49–52; Sur-Reply 17–20
`
`13
`
`
`
`“Customized To” Means “Created For”
`
`[1b/9b] 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
`
`. custom configuration that configures a plurality of
`.
`[17b] .
`rendering blocks of said wireless device to render content
`in a
`manner customized to an application . . .
`
`Patent Owner
`“created for”
`
`POR 16–17
`
`Petitioner
`plain and ordinary
`meaning
`
`Pet. 19
`
`(“associated with”
`or
`“related to”)
`
`Reply 2–3
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 16–17; Sur-Reply 1–4
`
`14
`
`
`
`“Customized to Said Application” = “Application-Specific”
`
` When discussing software,
`“customized to said application” is
`the equivalent to “application-
`specific”
`
`Mr. Stuart Lipoff, P.E.
`
`Dr. Benjamin B. Bederson
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`Ex. 2031 84:17–85:1
`
`POR 16
`
`15
`
`
`
`Application-Specific Means “Created For”
`
`Mr. Stuart Lipoff, P.E.
`
` “Application-Specific” means
`“created or written for a specific
`application” (i.e., being built, fit, or
`altered according to individual
`application specifications)
`
`Ex. 2022 ¶121 (citing dictionary Ex. 2026); Id. (citing Ex. 2027)
`
` HTML Harris produces is customized for a
`device because this “HTML is an example of
`files that are tailored to a particular mobile
`device”
`Ex. 2031 41:14–42:16 (emphasis added)
`
`Dr. Benjamin B. Bederson
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 16–17
`
`16
`
`
`
`Specification: Each Application Has Corresponding Configuration
`
`Each
`application has
`“corresponding”
`custom
`configuration
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`Ex. 1001 16:50–53; see also id. 19:25–29 (same)
`
`Id. Fig. 5
`
`POR 16–17
`
`17
`
`
`
`Fed. Cir. Approves Using Definition Not Found in Hac Verba
`
`Masimo Corp. v. Sotera Wireless, Inc.,
`No. 2022-1415, 2023 WL 6307959, at *3 (Fed. Cir. Sept. 28, 2023)
`
`Affirmed term as the definition of a claim limitation even though the
`“specification does not use the term” because “there is nothing
`inconsistent between the plain meaning [the PTAB] derived from the
`intrinsic evidence and the meaning it drew from the dictionary”
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`Sur-Reply 3
`
`18
`
`
`
`Petitioner Conflates Limitations
`
`[i] wherein said custom configuration is associated with an
`application
`
`and
`
`[ii] configures said plurality of rendering blocks to render
`content in a manner customized to said application
`
`Limitation 1b/9b
`
`Kyocera Senco Indus. Tools Inc. v. Int’l Trade Comm’n,
`22 F.4th 1369, 1382 (Fed. Cir. 2022) (citation omitted)
`
`There is “a presumption that [separately listed] components are distinct.”
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`Sur-Reply 1–2
`
`19
`
`
`
`Hariki’s Objective Is Not Displaying HTML per UI Skin
`
` Hariki only mentions “HTML” once:
`
`Sur Reply 12–13
`
` WWW server serves
`any client computer
`
`Id.
`
` Browsers access any
`web server
`
`Id.
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`Reply 15
`
`Ex. 1006 [0021]
`
`Sur-Reply 12–13
`
`20
`
`
`
`Browser Does Not Processes HTML from 102 in Custom Manner
`
`“There is no teaching that the UI
`skin is influenced in any way by
`a particular web server, or that
`web content from a particular
`web server is influenced
`by a UI skin, much less that a UI
`skin is specifically ‘customized
`to’ (read: designed
`for) any web server.”
`
`Ex. 2022 ¶146
`(cited by POR 36–37)
`
`HTML HTML
`
`Ex. 1006 Fig. 1
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`21
`
`
`
`[1d/9d/17d] wherein said compiled content is generated in part from
`execution of said application [by said server]
`
`transmits
`.
`.
`.
`/
`to said wireless device,
`[1c/9c/17c] [transmitting,
`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
`
`Compiled Content Is Not Generated from Application
`Execution or Transmitted to Wireless Device
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 18–33, 43–51; Sur-Reply 6–10, 16–17
`
`22
`
`
`
`Generated in Part from Execution Means Application Outputs
`
`[1d/9d] wherein said compiled content is generated in part from execution of
`said application
`
`[17d] wherein said compiled content is generated in part from execution of
`said application by said server
`
`Petitioner
`plain and ordinary
`meaning
`
`Pet. 19
`
`(“upon,” i.e., application
`may be a “triggering
`event” causing another
`application to generate
`compiled content)
`
`Reply 11–14
`
`Patent Owner
`“said application
`produces/outputs some
`part of the compiled
`content during its
`execution”
`
`POR 28–29; Sur-Reply 4–6
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 28–29; Sur-Reply 4–6
`
`23
`
`
`
`Patent-at-Issue Differentiates “Application” from “Client”
`
`
`
`ApplicationsApplications
`
`Client
`
`Ex. 1001 Fig. 5
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 5; Sur-Reply 4–5
`
`24
`
`
`
`’715 Patent Teaches Application Execution Generates Content
`
`Ex. 1001 19:39–40
`
`Id. 3:29–41
`
`Id. 2:25–26
`
`Id. 16:61–62
`
`Id. 19:38–40
`
`POR 29–30; Reply 12; Sur-Reply 4–6
`
`25
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`
`
`“Triggering” Client Does Not Generate Compiled Content
`
`Client identifies Client identifies the
`
`
`application, and application and
`
`receives compiled receives compiled
`
`content generated by content generated by
`
`the applicationthe application
`
`
`Application Application
`
`generates at least generates at least
`
`in part the in part the
`
`compiled contentcompiled content
`
`Ex. 1001 Fig. 6 ; see also id. 5:53–54 (teaching
`compiled content is the “output” of application),
`2:25–26 (same), id. 6:9–11 (same)
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 30–31
`
`26
`
`
`
`’715 Patent Teaches Application May Generate “In Part”
`
`Ex. 1001 3:29–34
`
`
`Dynamic content Dynamic content
`
`includes includes
`
`generation done generation done
`
`“in part” by “in part” by
`
`template enginetemplate engine
`
`Static content
`entirely generated
`by application
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`Ex. 1001 Fig. 5
`
`POR 32
`
`27
`
`
`
`Patent Owner Captures Plain Meaning in the Field
`
`Mr. Stuart Lipoff, P.E.
`
` “Generated from execution” means
`that which is produced during
`execution according to an
`algorithm, program, or set of rules
`
`Ex. 2022 ¶116 (citing Ex. 2023)
`
` With software, “generated” means
`“output”
`
`Id. (citing Ex. 2024)
`
`Lyft, Inc. v. Rideshare Displays, Inc.,
`IPR2021-01602-7, at 21 (PTAB Apr. 11, 2022)
`Construed “generated” in accordance with its plain and ordinary meaning
`of “originated or produced” (citing Merriam Webster)
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 28–29
`
`28
`
`
`
`“D” Limitations Recapitulation
`
`the application
`requires
`limitation
`the
`generate (i.e., be the “source of”)
`the
`compiled content;
`
`running
`the
`“from execution” means
`application is the source of the compiled
`content, not a “but for” cause or “triggering
`event”; and
`
`the “in part” refers to the generation.
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 28–29
`
`29
`
`
`
`Application Is Remote So Generated Content Can Be Transmitted
`
`
`
`Application generates the compiled contentApplication generates the compiled content
`
`1[d]/9[d]/17[d] wherein said compiled content is generated in part from
`execution of said application [by said server]
`
`1[c]/9[c]/17[c] [transmitting, to said wireless device, / . . . 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
`
`
`To transmit the application-generated content To transmit the application-generated content
`
`to the device the application must be remoteto the device the application must be remote
`
`Petitioner
`
`plain and ordinary
`meaning
`
`Pet. 19
`
`Petition: may be local
`District Ct: must be remote
`Reply: may be inconsistent
`Pet. 36 n.10; Exs. 2019–21; Ex. 2022 ¶¶106–07; Reply 5–11
`
`Patent Owner
`application must be
`remote
`
`POR 18–27; Sur-Reply 6–10
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 18–27; Sur-Reply 6–10
`
`30
`
`
`
`From the Outset Application Characterized as Remote
`
`Ex. 1001, Abstract
`
`SciMed Life Sys., Inc. v. Advanced Cardiovascular Sys., Inc.,
`242 F.3d 1337, 1342 (Fed. Cir. 2001)
`
`Restricting limitation in part in light of the abstract, because
`
`“from the outset the specification” characterized the limitation “from the outset the specification” characterized the limitation
`as having the restriction.
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 19–20
`
`31
`
`
`
`Patent Disparages a Contrary Reading
`
`Description of the Prior Art
`
`vs.
`
`’715 Patent Invention
`
`Ex. 1001 2:3–14
`
`Id. 2:38–41; see also 4:21–25; 5:56–62; 6:34–42; 20:21–25
`
`UltimatePointer, LLC v. Nintendo Co., Ltd.,
`816 F.3d 816, 823–24 (Fed. Cir. 2016)
`Extolling virtues of one feature, and criticism of its opposite, limits the claims to
`the feature, even if another construction was plausible if the claims were
`divorced from the specification
`
`TF3 Ltd. v. Tre Milano, LLC,
`894 F.3d 1366, 1372–73 (Fed. Cir. 2018)
`
`“[I]t is not reasonable to read the claims more broadly than the description in the
`specification, thereby broadening the claims to read on the prior art over which
`the patentee asserts improvement.”
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 20
`
`32
`
`
`
`No § 112 Support for a Contrary Reading
`
` Patent-at-Issue exclusively notes the “application is
`executed on the server”
`
`Ex. 1001 3:8–9; 5:54–56; 6:6–7; 6:29–31; 6:38–39; 13:11–13; 16:44–45; 18:56–58; 19:38–39.
`
` All relevant figures and flow charts show the application
`is executing on a server and transmitting compiled
`content pages to the remote client
`
`Id. Figs. 1B, 2A–B, 5, & 6 (item 640)
`
`Wang Labs., Inc. v. Am. Online, Inc.,
`197 F.3d 1377, 1382–83 (Fed. Cir. 1999)
`
`“[C]laims are not properly construed to have a meaning or scope that would lead to
`their invalidity for failure to satisfy the requirements of patentability.”
`
`Ruckus Wireless, Inc. v. Innovative Wireless Sols., LLC,
`824 F.3d 999, 1004 (Fed. Cir. 2016)
`
`“[C]anon favoring constructions that preserve claim validity . . . counsels against”
`“construing the instant claims to encompass . . . subject matter [that] would likely
`render the claims invalid for lack of written description.”
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 20–21
`
`33
`
`
`
`Petitioner’s Claim Differentiation Argument Fails
`
`1c-d
`
`compiled content is generated in part from execution of said application/transmitting,
`to said wireless device [said] compiled content . . .
`
`3
`
`wherein said compiled content
`operating on a remote server.
`
`is partially resultant
`
`from said application
`
` “Operating on a server” is narrower than
`“remote operation”
`
`Ex. 2022 ¶¶101–03, 110
`
` Petitioner leaves argument unrebutted
`
`Reply 7–8
`
`Sinorgchem Co. v. Intern. Trade Com’n,
`511 F.3d 1132, 1140 (Fed. Cir. 2007)
`
`When a dependent claim is “narrower in scope, the claims are not
`rendered identical and present no claim differentiation problem”
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 22; Sur-Reply 9
`
`34
`
`
`
`§ 112 Support Trumps Claim Differentiation
`
`Littelfuse, Inc. v. Mersen USA EP Corp.,
`29 F.4th 1376, 1380 (Fed. Cir. 2022)
`The “presumption of differentiation in claim scope is not a hard and fast rule,” so
`“any presumption created by the doctrine of claim differentiation will be overcome by
`a contrary construction dictated by the written description.”
`
`Curtiss-Wright Flow Control Corp. v. Velan, Inc.,
`438 F.3d 1374, 1382 (Fed. Cir. 2006).
`
`A court may not “rely[] on the claim differentiation presumption” if the presumption
`leads to a construction “not consistent with the overall context of this invention and
`this field of art as described in the specification.”
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 22–23
`
`35
`
`
`
`Parties’ Agree on Browser’s Function and Location
`
`Parties agree that a browser:
`1. Merely “triggers” a web server to generate HTML during the
`web server’s execution. See, e.g:
`
`2.
`
`Is not “remote.” See, e.g:
`
`Reply 21
`
`Ex. 2031 60:18–22
`See also Pet. 36–37 (“To the extent PO contends that the ‘associated’ application must be remote to the mobile
`device . . . the server also provides content data such as HTML files through a web server process.”)
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 46; Reply 21
`
`36
`
`
`
`’245 Patent Missing Same Independent Claim Limitations
`
`’715 Patent Limitation
`
`’245 Patent Limitation
`
`1f/
`9f/
`17f
`
`wherein said custom configuration is
`applicable to said first and second
`compiled content
`
`1g/
`12g/
`23h.3
`
`wherein said custom configuration is
`applicable to both said first and
`second compiled content
`
`1b/
`9b/
`17b
`
`1d/
`9d/
`17d
`
`1c/
`9c/
`17c
`
`[that]
`configuration
`custom
`[a/said]
`plurality
`of
`configures
`rendering blocks
`[of
`said wireless
`device]
`to render content
`in a
`manner customized to [an/said]
`application
`
`1b/
`12b/
`23f
`
`.
`.
`.
`custom configuration
`[configures/is operable to configure]
`said plurality of rendering blocks to
`in
`a manner
`render
`content
`customized to said application
`
`. . . compiled content is generated in
`part
`from execution
`of
`said
`application [by said server]
`
`1c/
`12c/
`23b
`
`. . . compiled content generated in
`part
`from execution
`of
`said
`application
`
`[transmitting, to said wireless device,
`/ . . . transmits compiled content to
`said wireless device, said] compiled
`content . . .
`
`1c/
`12c/
`23b
`
`[receiving/said
`operable
`to
`content . . .
`
`also
`transceiver
`receive]
`compiled
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`37
`
`
`
`17[a] a library of applications;
`
`17[b] 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
`
`Identified Application Is Not in a Library of Applications
`(’715 Unique)
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 54–56; Sur-Reply 20–21
`
`38
`
`
`
`Residing Together or Some Relation Does Not a Suite Make
`
`Pet 37
`
`From Ex. 2004 (cited by Ex. 2022 ¶144)
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 40–42, 55–56
`
`39
`
`
`
`Web Server Not Designed to Work with Authoring Tool
`
`Reply 23
`
`Reply 15 (Section III.A1)
`
` Hariki only mentions “HTML” once and
`teaches the WWW server serves any client
`computer, including those without a UI Skin
`
`Sur Reply 12–13
`
` Hariki’s does not say its objective is for HTML
`from server 102 to work with a UI skin
`
`Ex. 2002 ¶¶144–46
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 12–13; Sur-Reply 20–21
`
`40
`
`
`
`[23g] an engine for reading said compiled content and responsive thereto
`for causing said graphical user interface to generate said renderable
`content based on said render commands
`
`Identified Engine Does Not Read Compiled Content
`(’245 Unique)
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 51–53; Sur-Reply 19
`
`41
`
`
`
`Hariki’s Browser Identified as the Application Reads HTML
`
`
`Engine receives and Engine receives and
`
`reads application’s reads application’s
`
`compiled contentcompiled content
`
`
`
`Compiled ContentCompiled Content
`
`
`Remote application Remote application
`
`generates compiled generates compiled
`
`content during executioncontent during execution
`
`
`HTML identified as HTML identified as
`
`compiled contentcompiled content
`
`
`Local Local
`
`browser browser
`
`identified as identified as
`
`application application
`
`reads HTMLreads HTML
`
`From
`Ex. 1006
`Fig. 5
`
`From Ex. 1001 Fig. 5
`
`Ex. 1001 Fig. 1B
`
`From Ex. 1006 Fig. 1
`
`
`API engines called API engines called
`
`by browser do not by browser do not
`
`read HTML Petitioner read HTML Petitioner
`
`identified as identified as
`
`compiled contentcompiled content
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 51–53; Sur-Reply 19
`
`42
`
`
`
`[11/22/32] . . . wherein said plurality of rendering blocks of said graphical
`user interface comprises: a first block that controls the rendering of
`ticker information across [a/said] display screen of said wireless
`device . . .
`
`Identified Rendering Block Is Not a Ticker (’245 Unique)
`
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 54–55; Sur-Reply 19–20
`
`43
`
`
`
`No Indication Title Bars Scroll, So Not “Tickers”
`
`Ex. 1001, 9:44–45
`See also 8:35; 14:7–9; Ex. 2022 ¶143–146 (citing Ex. 2028; Ex. 2029, 82:3–11
`
`†
`
`Title Bar
`
`† Image of T-Mobile G1 from Repost of Larry’s 2008 review of the first Android phone (first appeared in
`Mercury News on Oct. 16, 2008), available at https://www.larrysworld.com/repost-of-larrys-sept-2008-
`look-at-the-first-android-phone/
`DEMONSTRATIVE EXHIBIT—NOT EVIDENCE
`
`POR 54–55; Sur-Reply 19–20
`
`44
`
`Ex. 1005 [0024]
`
`
`
`End of Presentation
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`45
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
