`
`
`
`
`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. 8,478,245
`____________________
`
`PETITION FOR INTER PARTES REVIEW
`
`Petition Filing Date: April 7, 2023
`
`
`
`
`
`
`
`
`
`
`
`

`

`7680451.1
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`IPR2023-00757
`U.S. Patent No. 8,478,245
`
`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 AND STUTORY GROUNDS (37 C.F.R.
`§42.204(B)) ...................................................................................................... 2 
`IV.  OVERVIEW OF THE ’245 PATENT ............................................................ 3 
`A. 
`Client Devices Receiving Remotely Executed Applications ................ 3 
`Graphics, Rendering, and Graphical User Interfaces ............................ 4 
`Wireless mobile devices ........................................................................ 7 
`Client-Server Architectures ................................................................... 8 
`The Specification ................................................................................. 12 
`B. 
`The Prosecution History ...................................................................... 16 
`C. 
`LEVEL OF ORDINARY SKILL IN THE ART ........................................... 17 
`V. 
`VI.  CLAIM CONSTRUCTION .......................................................................... 17 
`VII.  THE PRIMARY PRIOR ART REFERENCES ............................................ 18 
`A.  Overview of Hariki .............................................................................. 18 
`B. 
`Overview of Harris .............................................................................. 20 
`C. 
`Other Evidence Regarding the State of the Art ................................... 24 
`VIII.  DETAILED EXPLANATION OF THE GROUNDS ................................... 24 
`A.  Ground 1: Hariki in view of Harris renders obvious Claims 1-33 ...... 24 
`1. 
`Claim 1 ...................................................................................... 24 
`2. 
`Claim 2 ...................................................................................... 52 
`3. 
`Claim 3 ...................................................................................... 55 
`
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`U.S. Patent No. 8,478,245
`Claim 4 ...................................................................................... 56 
`4. 
`Claim 5 ...................................................................................... 57 
`5. 
`Claim 6 ...................................................................................... 58 
`6. 
`Claim 7 ...................................................................................... 62 
`7. 
`Claim 8 ...................................................................................... 62 
`8. 
`Claim 9 ...................................................................................... 64 
`9. 
`10.  Claim 10 .................................................................................... 65 
`11.  Claim 11 .................................................................................... 65 
`12.  Claim 12 .................................................................................... 66 
`13.  Claim 13 .................................................................................... 68 
`14.  Claim 14 .................................................................................... 68 
`15.  Claim 15 .................................................................................... 68 
`16.  Claim 16 .................................................................................... 69 
`17.  Claim 17 .................................................................................... 69 
`18.  Claim 18 .................................................................................... 69 
`19.  Claim 19 .................................................................................... 69 
`20.  Claim 20 .................................................................................... 70 
`21.  Claim 21 .................................................................................... 70 
`22.  Claim 22 .................................................................................... 70 
`23.  Claim 23 .................................................................................... 70 
`24.  Claim 24 .................................................................................... 78 
`25.  Claim 25 .................................................................................... 78 
`26.  Claim 26 .................................................................................... 80 
`
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`U.S. Patent No. 8,478,245
`27.  Claim 27 .................................................................................... 81 
`28.  Claim 28 .................................................................................... 81 
`29.  Claim 29 .................................................................................... 81 
`30.  Claim 30 .................................................................................... 81 
`31.  Claim 31 .................................................................................... 82 
`32.  Claim 32 .................................................................................... 82 
`33.  Claim 33 .................................................................................... 82 
`IX.  SECONDARY CONSIDERATIONS ........................................................... 83 
`X.  DISCRETIONARY DENIAL IS NOT WARRANTED UNDER
`EITHER § 314 OR § 325 .............................................................................. 83 
`A. 
`Fintiv Factors ....................................................................................... 83 
`B. 
`Becton Dickinson/Advanced Bionics/General Plastics Factors ......... 86 
`XI.  MANDATORY NOTICES ........................................................................... 87 
`A. 
`Real Parties-in-Interest ........................................................................ 87 
`B. 
`Related Matters .................................................................................... 87 
`C. 
`Lead and Back-Up Counsel, and Service Information Under 37 C.F.R.
`§ 42.8(b)(3) .......................................................................................... 87 
`Service Information Under 37 C.F.R. § 42.8(b)(4) ............................. 88 
`D. 
`Fees………………………………………………………………….88 
`E. 
`XII.  CONCLUSION .............................................................................................. 88 
`
`
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`7680451.1
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`IPR2023-00757
`U.S. Patent No. 8,478,245
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`EXHIBIT LIST
`Description
`
`Exhibit
`Number
`1001 U.S. Patent No. 8,478,245 (“’245Pat”)
`1002
`Expert Declaration of Ben Bederson (“Bederson”)
`1003 Curriculum Vitae of Benjamin B. Bederson, Ph.D.
`1004
`File History of U.S. Patent No. 8,478,245 (“’245FH”)
`1005 U.S. Patent Application Publication No. 2007/0150617 (“Hariki”)
`1006 U.S. Patent Application Publication No. 2003/0023755 (“Harris”)
`1007 U.S. Patent No. 7,447,486 (“Tamura”)
`1008 U.S. Patent No. 6,996,627 (“Carden”)
`1009 U.S. Patent No. 6,669,564 (“Young”)
`1010 U.S. Patent No. 6,732,183 (“Graham”)
`1011 U.S. Patent No. 6,507,727 (“Henrick”)
`1012 Webpage excerpt from Computer History Museum at
`https://www.computerhistory.org/tdih/april/6/ (last accessed March 29, 2023)
`
`1013
`
`https://www.webdesignerdepot.com/2009/05/the-evolution-of-cell-phone-
`design-between-1983-2009/
`
`1014
`Excerpts from Dan R. Olsen, Jr., Developing user interfaces (1998)
`1015 Alok Sinha, Client-server computing, in Communications of the ACM, 35, 7
`(1992)
`
`1016
`
`1017
`
`Tim Berners-Lee, Robert Cailliau, Ari Luotonen, Henrik Frystyk Nielsen,
`and Arthur Secret, The World-Wide Web. Communications of the ACM 37,
`8 76-82 (August 1994), available at http://dx.doi.org/10.1145/179606.179671
`
`Eric Kasten, HTML: A Gentle Introduction, Linux Journal (July 1995),
`
`iv
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`

`7680451.1
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`Exhibit
`Number
`
`
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`IPR2023-00757
`U.S. Patent No. 8,478,245
`
`Description
`
`available at https://www.linuxjournal.com/article/1081
`1018 U.S. Patent Application Publication No. 2013/0124961 (“Linburn”)
`1019 U.S. Patent No. 8,111,326 (“Talwar”)
`1020 Docket Control Order, GovTV Streaming, LLC v. Netflix, Inc., No. 2:22-cv-
`07556-RGK-SHK, Dkt. 61 (C.D. Cal. Feb. 13, 2023)
`1021 Complaint in GovTV Streaming, LLC v. Netflix, Inc., No. 2:22-cv-07556-
`RGK-SHK (C.D. Cal. October 17, 2022)
`1022 U.S. Patent Application Publication No. 2003/0106022 (“Goodacre”)
`https://web.archive.org/web/20070406171650/http://www.zenzui.com/produc
`1023
`ts.html
`
`
`
`v
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`

`7680451.1
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`Claim 1
`
`[1pre]
`
`1[a]
`
`1[b]
`
`[1c]
`
`[1d]
`
`[1e]
`
`[1f]
`
`[1g]
`
`Claim 2
`
`[2]
`
`
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`IPR2023-00757
`U.S. Patent No. 8,478,245
`LISTING OF CHALLENGED CLAIMS
`
`A method of rendering content on a wireless device, said method
`comprising:
`
`receiving 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;
`
`receiving compiled content 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;
`
`using a graphical user interface comprising said plurality of rendering
`blocks to generate renderable content based on said compiled content and
`said custom configuration; and
`
`rendering said renderable content on said wireless device, wherein said
`receiving compiled content comprises: receiving first compiled content
`specific to a first page of said application; and receiving second compiled
`content specific to a second page of said application
`
`wherein said custom configuration is applicable to both said first and
`second compiled content.
`
`A method as described in claim 1 wherein said using a graphical user
`interface comprising said plurality of rendering blocks to generate
`renderable content comprises: processing said compiled content using a
`reader of said wireless device; and issuing commands from said reader to
`individual rendering blocks of said graphical user interface based on said
`rendering commands of said compiled content.
`
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`A method as described in claim 1 wherein said render able content
`comprises audio content and display content.
`
`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 6 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 con tent 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 further said identifying said custom
`configuration comprises receiving an identifier that identifies said custom
`configuration.
`
`7680451.1
`
`Claim 3
`
`[3]
`
`Claim 4
`
`[4]
`
`Claim 5
`
`[5]
`
`Claim 6
`
`[6]
`
`Claim 7
`
`[7]
`
`Claim 8
`
`[8]
`
`Claim 9
`
`[9]
`
`Claim 10
`
`vii
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`
`[10]
`
`Claim 11
`
`[11]
`
`Claim 12
`
`[12pre]
`
`[12a]
`
`[12b]
`
`[12c]
`
`[12d]
`
`[12e]
`
`[12f]
`
`A method as described in claim 1 further comprising receiving and
`storing said custom configuration.
`
`A method as described in claim 1 wherein said plurality of rendering
`blocks of said graphical user interface comprises: a first block that
`controls the rendering of ticker information across a display screen of
`said wireless device; a second block that controls the rendering of button
`images on said display screen; and a third block that controls the
`rendering of audio on a speaker of said wireless device.
`
`A non-transitory computer usable medium comprising instructions
`therein that when executed by a processor implement a method of
`rendering content on a wireless device, said method comprising:
`
`receiving 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;
`
`receiving compiled content 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;
`
`using a graphical user interface comprising said plurality of rendering
`blocks to generate renderable content based on said compiled content and
`said custom configuration; and
`
`rendering said renderable content on said wireless device, wherein said
`receiving compiled content comprises: receiving first compiled content
`specific to a first page of said application; and receiving second compiled
`content specific to a second page of said application,
`
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`wherein said custom configuration is applicable to both said first and
`second com piled content.
`
`A non-transitory computer usable medium as described in claim 12
`wherein said using a graphical user interface comprising said plurality of
`rendering blocks to generate renderable content comprises: processing
`said compiled content using a reader of said wireless device; and issuing
`commands from said reader to individual rendering blocks of said
`graphical user interface based on said rendering commands of said
`compiled content.
`
`A non-transitory computer usable medium as described in claim 12
`wherein said renderable content comprises audio content and display
`content.
`
`A non-transitory computer usable medium as described in claim 12
`wherein said compiled content is partially result ant from said application
`operating on a remote server.
`
`A non-transitory computer usable medium as described in claim 12
`wherein said compiled content is specific to the rendering capabilities of
`said wireless device.
`
`A non-transitory computer usable medium as described in claim 12
`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.
`
`[12g]
`
`Claim 13
`
`[13]
`
`Claim 14
`
`[14]
`
`Claim 15
`
`[15]
`
`Claim 16
`
`[16]
`
`Claim 17
`
`[17]
`
`Claim 18
`
`ix
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`U.S. Patent No. 8,478,245
`
`[18]
`
`Claim 19
`
`[19]
`
`Claim 20
`
`[20]
`
`Claim 21
`
`[21]
`
`Claim 22
`
`[22]
`
`A non-transitory computer usable medium as described in claim 17
`wherein said custom configuration comprises a Syntax that is generic
`regarding said wireless device type.
`
`A non-transitory computer usable medium as described in claim 12
`wherein said custom configuration comprises configuration information
`and content specific to said application.
`
`A non-transitory computer usable medium as described in claim 12
`wherein said custom configuration is one of a plurality of memory-stored
`custom configurations stored by said wireless device and wherein further
`said identifying said custom configuration comprises receiving an
`identifier that identifies said custom configuration.
`
`A non-transitory computer usable medium as described in claim 12
`wherein said method further comprises receiving and storing said custom
`configuration.
`
`A non-transitory computer usable medium as described in claim 12
`wherein said plurality of rendering blocks of said graphical user interface
`comprises: a first block that controls the rendering of ticker information
`across a display screen of said wireless device; a second block that
`controls the rendering of button images on said display screen; and a third
`block that controls the rendering of audio on a speaker of said wireless
`device.
`
`Claim 23
`[23pre] A wireless device operable to communicate with a remote server, said
`wireless device comprising:
`a transceiver coupled to a bus and operable to receive a custom
`configuration that is associated with an application,
`said transceiver also operable to receive compiled content generated in
`part from execution of said application and
`
`[23b]
`
`[23a]
`
`x
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`comprising a plurality of rendering commands expressed in a syntax that
`is generic to said wireless device;
`a memory coupled to said bus and operable to store said compiled content
`and said custom configuration;
`a processor coupled to said bus and operable to implement the following:
`a graphical user interface comprising a plurality of rendering blocks and
`operable to generate renderable content based on said compiled content
`and said custom configuration
`wherein said custom configuration is operable to configure said plurality
`of rendering blocks to render content in a manner customized to said
`application;
`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;
`a display device coupled to said bus and operable to render a portion of
`said renderable content, wherein said com piled content comprises: a first
`compiled content specific to a first page of said application; and a second
`compiled content specific to a second page of said application, wherein
`said custom configuration is applicable to both said first and second
`compiled content.
`
`The wireless device as described in claim 23 wherein said engine is
`further operable to issue commands to individual rendering blocks of said
`graphical user interface based on said plurality of rendering commands of
`said compiled content.
`
`The wireless device as described in claim 23 further comprising an audio
`rendering device coupled to said bus and wherein said renderable content
`comprises audio content and display content.
`
`The wireless device as described in claim 23 wherein 25 said compiled
`content is partially resultant from said application operating on a remote
`server.
`
`[23c]
`
`[23d]
`
`[23e]
`
`[23f]
`
`[23g]
`
`[23h]
`
`Claim 24
`
`[24]
`
`Claim 25
`
`[25]
`
`Claim 26
`
`[26]
`
`Claim 27
`
`xi
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`U.S. Patent No. 8,478,245
`
`The wireless device as described in claim 23 wherein said compiled
`content is specific to the rendering capabilities of said wireless device.
`
`The wireless device as described in claim 23 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.
`
`The wireless device as described in claim 28 wherein said custom
`configuration is expressed in a syntax that is generic to said wireless
`device type.
`
`The wireless device as described in claim 23 wherein said custom
`configuration comprises configuration information and content specific to
`said application.
`
`The wireless device as described in claim 23 wherein said custom
`configuration is one of a plurality of memory-stored custom
`configurations stored in said memory.
`
`The wireless device as described in claim 23 wherein said plurality of
`rendering blocks of said graphical user interface comprises: a first block
`that controls the rendering of ticker information across said display
`screen of said wireless device; a second block that controls the rendering
`of button images on said display screen; and a third block that controls
`the rendering of audio on a speaker of said wireless device.
`
`[27]
`
`Claim 28
`
`[28]
`
`Claim 29
`
`[29]
`
`Claim 30
`
`[30]
`
`Claim 31
`
`[31]
`
`Claim 32
`
`[32]
`
`Claim 33
`
`xii
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`
`[33]
`
`The wireless device as described in claim 23 wherein said plurality of
`rendering blocks of said graphical user interface comprises: a first block
`that controls the rendering of a scroll bar on said display screen of said
`wireless device; a second block that controls the rendering of an input
`box on said display screen of said wireless device; and a third block that
`control the rendering of a text display region on said display screen of
`said wireless device.
`
`xiii
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`7680451.1
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`
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`IPR2023-00757
`U.S. Patent No. 8,478,245
`
`I.
`
`INTRODUCTION
`Netflix, Inc. (“Petitioner”) respectfully requests inter partes review of claims
`
`1-33 of U.S. Patent No. 8,478,245 (“the ’245 patent” or “’245Pat”), filed on
`
`August 1, 2007, 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. Please assess any fee deficiency or credit to
`
`Deposit Account No. 232405.
`
`II. GROUNDS FOR STANDING (37 C.F.R. §42.104(A))
`Petitioner certifies that the ’245 patent is available for inter partes review
`
`(“IPR”). 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) (served
`
`10/25/2022).
`
`
`
`1
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`

`

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`III. STATEMENT OF PRECISE RELIEF REQUESTED FOR EACH
`CLAIM CHALLENGED 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 Error! Reference source not found.).
`
`U.S. Patent Application Publication No. 2003/0023755 (“Harris”), published
`January, 30, 2003; prior art under 35 U.S.C. §102(b) (Exhibit Error! Reference
`source not found.)
`
`
`Ground
`
`Claims
`
`Basis
`
`1-33
`
`35 U.S.C. §103 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 35 U.S.C. §§101 and 112.
`
`
`
`2
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`IV. OVERVIEW OF THE ’245 PATENT2
`A.
`Client Devices Receiving Remotely Executed Applications
`Downloading content to a client device 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. Users were turning from
`
`traditional media sources, such as television and newspaper, to the Internet to
`
`receive media content. EXError! Reference source not found., 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 transmitting/receiving data via a cellular
`
`
`2 This background and the Grounds of Unpatentability herein, are further supported
`
`by the Declaration of Petitioner’s expert, Dr. Ben Bederson, who has over 30 years
`
`of experience related to remote application execution. (EXError! Reference
`
`source not found.)
`
`3 Additional references cited in this Petition that are not part of the unpatentability
`
`grounds are used to demonstrate 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.”)
`
`
`3
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`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.
`
`EXError! Reference source not found., 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. EXError! Reference source not found., 1:29-34; EXError! Reference
`
`source not found., Abstract; see also EXError! Reference source not found.,
`
`Abstract. Prior to the ’245 patent, it was a known problem that transmission of
`
`content was limited by, for example, bandwidth and connection rates of mobile
`
`devices. EXError! Reference source not found., 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 POSITAs at the time of the alleged
`
`inventions claimed in the ’245 Patent. Bederson, ¶¶46.
`
`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
`
`
`
`4
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`drawbacks. For instance, the interface was difficult for users to learn, because to
`
`
`
`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
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`intuitive—a novice user could not use the user interface by simply experimenting
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`with the interface.
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`An advancement to the command-line interface was the Graphical User
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`Interface (“GUI”). GUIs offer visual interfaces on display screens that are designed
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`for simplicity and ease of learning. A common and well-known example of a GUI
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`uses the “desktop metaphor,” where files and applications of the computer system
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`are represented as graphical icons on a virtual desktop shown on the computer
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`screen, and where the user interacts with those icons using a pointing device such
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`as a mouse cursor. Windows 3.1, released by Microsoft in 1992,4 was one example
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`of such a GUI:
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`4 See, e.g., https://www.computerhistory.org/tdih/april/6/ (last accessed March 29,
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`2023) (EXError! Reference source not found.).
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`7680451.1
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`IPR2023-00757
`U.S. Patent No. 8,478,245
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`Figure A. Screenshot of Microsoft Windows 3.1 taken by Benjamin B. Bederson
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`on March 28, 2023 using an emulator running in VMWare Fusion. Bederson, ¶48.
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`One main goal of GUIs was to make the user interface more intuitive and
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`easy to learn by implementing concepts that are analogues to the real—dragging an
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`icon to move across the computer screen “desktop,” for example, resembles the act
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`of moving an object in the real world. Part of the process for generating GUIs
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`involves “rendering” the graphics—that is, deciding which specific color each
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`pixel on the screen should be so as to form the visual elements of the interface. Id.,
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`¶50. This rendering technology has been well-known for decades. Id., ¶50. For
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`example, a 1998 book titled “Developing User Interfaces” describes many of the
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`technical elements of this rendering. Id., ¶50 (citing Dan R. Olsen, Jr., Developing
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`user interfaces (1998) (EX). For example, on page 51, it discusses “the basic 2D
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`IPR2023-00757
`U.S. Patent No. 8,478,245
`primitives that are required to present information to the users so they can
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`
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`interactively manipulate it.” Id., p. 51. It covers topics including the coordinate
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`systems of 2D computer graphics, how to represent shapes such as lines with
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`pixels, how to manage the drawing of text at different sizes with different fonts,
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`etc. Bederson, ¶50.
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`By 2007, such rendering technologies were fairly standardized and built into
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`essentially every computer operating system that supported GUIs, including
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`desktop and mobile devices. While many systems rendered application GUIs on
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`the same device that executed the application, there were also other well-known
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`architectures that rendered GUIs on remote devices (e.g., “clients”). In this case,
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`the application ran on other computers and sent graphics commands to a client
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`computer to be rendered.
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`Wireless mobile devices
`Mobile phones, a common type of wireless device, have been around since
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`the 1980s. In the 2000s, mobiles phones using Third Generation technology, or 3G,
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`were introduced. This technology was capable of transferring voice data (such as a
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`phone call) and transferring other types of data, including emails and instant
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`messages. By 2000, wireless phones included touch screens and increased graphics
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`capacity. In 2003, the PalmOne Treo 600 and BlackBerry 7210 included color
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`IPR2023-00757
`U.S. Patent No. 8,478,245
`screens. EXError! Reference source not found.. PDAs (Personal Digital
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`
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`Assistants) were another common wireless device available in the early 2000s.
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`Client-Server Architectures
`Historically, computers were big and expensive and they provided “time
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`shared” access to multiple terminals. Sometimes those terminals (a.k.a. “clients”)
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`were “dumb” or “thin,” and provided primarily input and output capabilities while
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`most of the computation was provided at the “server.” Other times, those clients
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`had greater computation capability. In the early 1980s with the introduction of
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`“personal computers,” those clients (while still often connected to servers) had
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`sufficient computational capabilities to run independently.
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`The relationship between “clients” and “servers” is so foundational to the
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`history of computers that it is often used to define the nature of the computing
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`architecture as well as the user experience. The state of client-server computing
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`was described in a 1992 article in Communications of the ACM—a broad interest
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`magazine of the main professional international computer society. See EXError!
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`Reference source not found. (“Sinha”). Sinha characterized some of the key
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`elements of client-side computing, including that the client typically communicates
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`with the server, transmitting queries or commands, performs data analysis on query
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`or command results from the server and presents the GUI. On the server-side,
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`servers typically provide a service to the client, responding to the queries or
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`IPR2023-00757
`U.S. Patent No. 8,478,245
`commands–and do so in a way that hides much of the details of its implementation
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`
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`so that clients with various kinds of software and hardware can work with it. Sinha
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`also explains that as far back as 1992, it was common to have the GUI of an
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`application displayed on a computer remote from the application. It describes the X
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`Window System that commonly ran on Unix environments which “provides
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`network transparency so that an application displaying a chart on a screen could be
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`running on a local machine or a remote machine thousands