`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
`
`