Case 2:16-cv-00741-RWS Document 218-1 Filed 08/02/17 Page 1 of 8 PageID #: 3803
`
`Claim
`
`Terms, Phrases and Clauses Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`Plaintiffs'
`#
`6
`
`’766
`patent
`claim 13
`
`“computer readable
`program code means for
`determining the license
`availability for the selected
`one of the plurality of
`application programs for
`the user based on the
`maintained license
`management policy
`information”
`
`Computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 Patent,
`implementing the
`algorithms described at
`‘578 patent at col. 5:38-61;
`11:32-38; 12:37-56, 12:63-
`13:49; FIG. 5 blocks 188,
`190, 192; and ‘466 patent
`at col. 13:58-14:1, 14:9-23
`
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 patent,
`implementing the
`algorithms described in the
`‘578 Patent at 5:38-61;
`11:32-38; 12:37-62, 13:29-
`32, 13:42-47
`
`
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 patent,
`implementing the
`algorithms described in the
`‘578 Patent at 5:38-61,
`11:32-38, 12:37-46, 12:50-
`14:12; FIG. 5, blocks 188,
`190, 192 and ’466 patent
`at col. 13:58-14:1, 14:9-23
`
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 patent,
`implementing the
`algorithms described in the
`‘578 Patent at 5:38-61
`11:32-38; 12:37-62, 13:29-
`32, 13:42-47
`
`
`20
`
`’766
`patent
`claim 13
`
`“computer readable
`program code means for
`maintaining license
`management policy
`information for a plurality
`of application programs at
`a license management
`server, the license
`management policy
`information including at
`least one of a user identity
`based policy, an
`administrator policy
`override definition or a
`user policy override
`definition”
`
`
`
`1
`
`
`
`Claim
`
`Terms, Phrases and Clauses Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`Plaintiffs'
`#
`6
`
`’766
`patent
`claim 13
`
`“computer readable
`program code means for
`determining the license
`availability for the selected
`one of the plurality of
`application programs for
`the user based on the
`maintained license
`management policy
`information”
`
`Computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 Patent,
`implementing the
`algorithms described at
`‘578 patent at col. 5:38-61;
`11:32-38; 12:37-56, 12:63-
`13:49; FIG. 5 blocks 188,
`190, 192; and ‘466 patent
`at col. 13:58-14:1, 14:9-23
`
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 patent,
`implementing the
`algorithms described in the
`‘578 Patent at 5:38-61;
`11:32-38; 12:37-62, 13:29-
`32, 13:42-47
`
`
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 patent,
`implementing the
`algorithms described in the
`‘578 Patent at 5:38-61,
`11:32-38, 12:37-46, 12:50-
`14:12; FIG. 5, blocks 188,
`190, 192 and ’466 patent
`at col. 13:58-14:1, 14:9-23
`
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 patent,
`implementing the
`algorithms described in the
`‘578 Patent at 5:38-61
`11:32-38; 12:37-62, 13:29-
`32, 13:42-47
`
`
`20
`
`’766
`patent
`claim 13
`
`“computer readable
`program code means for
`maintaining license
`management policy
`information for a plurality
`of application programs at
`a license management
`server, the license
`management policy
`information including at
`least one of a user identity
`based policy, an
`administrator policy
`override definition or a
`user policy override
`definition”
`
`
`
`1
`
`
`
`Case 2:16-cv-00741-RWS Document 218-1 Filed 08/02/17 Page 2 of 8 PageID #: 3804
`
`Claim
`
`Terms, Phrases and Clauses Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`Plaintiffs'
`#
`36
`
`’766
`patent
`claim 13
`
`computer readable
`program code means for
`providing an unavailability
`indication to the client
`responsive to the selection
`if the license availability
`indicates that a license is
`not available for the user
`or an availability indication
`if the licensed availability
`indicates that a license is
`available for the user
`computer readable
`program code means for
`receiving at the license
`management server a
`request for a license
`availability of a selected
`one of the plurality of
`application programs from
`a user at a client
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 patent,
`implementing the
`algorithms described in the
`‘578 Patent at col. 5:44-53
`
`
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 patent,
`implementing the
`algorithms described in the
`‘578 patent at 5:38-61;
`11:32-38; 12:37-13:18,
`13:36-38; FIG. 5 block 186;
`and ‘466 patent at col.
`13:58-14:1, 14:9-23
`
`
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 patent,
`implementing the
`algorithms described in the
`‘578 Patent at 5:44-57, and
`the ‘466 patent at col.
`13:58-14:1, 14:9-23, 16:45-
`56
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 7:26-50 of
`the ‘578 patent,
`implementing the
`algorithms described in the
`‘578 patent at 5:38-61
`11:32-38; 12:37-13:18;
`13:36-38; FIG. 5 block 186;
`and ‘466 patent at col.
`13:58-61, 14:9-23
`
`
`39
`
`’766
`patent
`claim 13
`
`
`
`2
`
`
`
`Case 2:16-cv-00741-RWS Document 218-1 Filed 08/02/17 Page 3 of 8 PageID #: 3805
`
`Claim
`
`Terms, Phrases and Clauses Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`Plaintiffs'
`#
`47
`
`’293
`patent
`claim 17
`
`“computer readable
`program code means that
`distributes the file packet
`to the target on-demand
`server to make the
`application program
`available for use by a user
`at a client”
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 12:3-27,
`implementing the
`algorithms described in
`connection with block 116
`of FIG. 8 and FIG. 9B and at
`col. 17:61-65, 18:4-21, 18:
`30-36, 19:39-20:5
`
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 12:3-27,
`implementing the
`algorithms described in
`connection with FIG. 9A
`and blocks 156, 158, and
`168 of FIG. 9B and at col.
`18:37 – 19:38, 20:3-5,
`20:36-41
`
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 12:1-24 of
`the ’466 patent,
`implementing the
`algorithms described in the
`‘466 patent in connection
`with block 116 of FIG. 8 and
`FIG. 9B and at col. 17:58-
`62, 18:1-18, 18:26-32,
`19:34-67
`
`computer program
`instructions for execution
`by a processor, as
`described in col. 12:1-24 of
`the ’466 patent,
`implementing the
`algorithms described in the
`’466 patent in connection
`with FIG. 9A and blocks
`156, 158, and 168 of FIG.
`9B and at col. 18:33 –
`19:33, 19:65-67, 20:31-36
`
`
`48
`
`’293
`patent
`claim 17
`
`“computer readable
`program code means that
`prepares a file packet
`associated with the
`application program”
`
`
`
`3
`
`
`
`Case 2:16-cv-00741-RWS Document 218-1 Filed 08/02/17 Page 4 of 8 PageID #: 3806
`
`Claim
`
`Terms, Phrases and Clauses Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`Plaintiffs'
`#
`49
`
`’293
`patent
`claim 17
`
`“computer readable
`program code that
`provides to the network
`management server an
`application program to be
`distributed to remote
`servers”
`
`If subject to §112(6), then a
`processor executing
`computer program
`instructions, as described in
`col. 12:3-27, implementing
`the algorithms described in
`connection with block 110
`of FIG. 8, FIG. 9A, and at
`col. 8:33-56;14:24-31;
`17:35-40; 17:55-58; 18:46-
`53
`
`
`If subject to §112(6), then
`a processor executing
`computer program
`instructions, as described in
`col. 12:3-27, implementing
`the algorithms described in
`connection with FIG. 10,
`block 112 of FIG. 8, and
`block 132 of FIG. 9A and at
`col. 17:58-61, 18:39-19:1,
`19:19-21, 19:50-54
`
`If subject to section 112(6),
`then a processor executing
`computer program
`instructions,, as described
`in col. 12:1-24 of the ’466
`patent, implementing the
`algorithms described in the
`’466 patent in connection
`with block 110 of FIG. 8 and
`at col. 8:33-56; 14:24-31;
`17:35-40, 17:55-58; 18:42-
`49
`
`If subject to section 112(6),
`then a processor executing
`computer program
`instructions, as described in
`col. 12:1-24 of the ’466
`patent, implementing the
`algorithms described in the
`’466 patent in connection
`with FIG. 10, block 112 of
`FIG. 8, and block 132 of FIG.
`9A and at col. 17:55-58,
`18:35-67, 19:14-16, 19:45-
`49
`
`50
`
`’293
`patent
`claim 17
`
`“computer readable
`program code that
`specifies a source directory
`and a target directory for
`distribution of the
`application program”
`
`
`
`4
`
`
`
`Plaintiffs'
`#
`55
`
`Claim
`
`’766
`patent
`claim 7
`
`“means for determining
`the license availability for
`the selected one of the
`plurality of application
`programs for the user
`based on the maintained
`license management policy
`information”
`
`62
`
`’293
`patent
`claim 12
`
`“means for distributing the
`file packet to the target on-
`demand server to make
`the application program
`available for use by a user
`at a client”
`
`Case 2:16-cv-00741-RWS Document 218-1 Filed 08/02/17 Page 5 of 8 PageID #: 3807
`
`Terms, Phrases and Clauses Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`A processor executing
`computer program
`instructions, as described in
`col. 7:26-50 of the ‘578
`patent, implementing the
`algorithms described in the
`‘578 Patent at 5:38-61;
`11:32-38; 12:37-46, 12:50-
`14:12; FIG. 5, blocks 188,
`190, 192; and ‘’466 patent
`at col. 13:58-14:1, 14:9-23
`
`
`Except for intro, should be
`the same as 47.
`
`a processor executing
`computer program
`instructions, as described in
`col. 7:26-50 of the ‘578
`patent, implementing the
`algorithms described in the
`’578 Patent at 5:38-61,
`11:32-38, 12:37-46, 12:50-
`14:12; FIG. 5, blocks 188,
`190, 192 and ’466 patent at
`col. 13:58-14:1, 14:9-23
`
`a processor executing
`computer program
`instructions as described in
`col. 12:1-24 of the ’466
`patent, implementing the
`algorithms described in the
`’466 patent in connection
`with block 116 of FIG. 8 and
`FIG. 9B and at col. 17:58-
`62, 18:1-18, 18:26-32,
`19:34-67
`
`
`
`
`5
`
`
`
`Case 2:16-cv-00741-RWS Document 218-1 Filed 08/02/17 Page 6 of 8 PageID #: 3808
`
`Plaintiffs'
`#
`72
`
`Claim
`
`’766
`patent
`claim 7
`
`83
`
`’293
`patent
`claim 12
`
`Terms, Phrases and Clauses Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`“means for maintaining
`license management policy
`information for a plurality
`of application programs at
`a license management
`server, the license
`management policy
`information including at
`least one of a user identity
`based policy, an
`administrator policy
`override definition or a
`user policy override
`definition”
`“means for preparing a file
`packet associated with the
`application program”
`
` A processor executing
`computer program
`instructions, as described in
`col. 7:26-50 of the ‘578
`patent, implementing the
`algorithms described in the
`‘578 Patent at 5:38-61;
`11:32-38; 12:37-62,13:29-
`32, 13:42-47
`
`
`
`a processor executing
`computer program
`instructions, as described in
`col. 7:26-50 of the ‘578
`patent, implementing the
`algorithms described in the
`‘578 Patent at 5:38-61; 11-
`32-38; 12:37-62,13:29-32,
`13:42-47
`
`
`Except for intro, should be
`the same as 48.
`
`a processor executing
`computer program
`instructions as described in
`col. 12:1-24 of the ’466
`patent, implementing the
`algorithms described in the
`’466 patent in connection
`with FIG. 9A and blocks
`156, 158, and 168 of FIG.
`9B and at col. 18:33 –
`19:33, 19:65-67, , 21:31-36
`
`
`
`6
`
`
`
`Case 2:16-cv-00741-RWS Document 218-1 Filed 08/02/17 Page 7 of 8 PageID #: 3809
`
`Plaintiffs'
`#
`89
`
`Claim
`
`’766
`patent
`claim 7
`
`91
`
`’293
`patent
`claim 12
`
`Terms, Phrases and Clauses Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`“means for providing an
`unavailability indication to
`the client responsive to the
`selection if the license
`availability indicates that a
`license is not available for
`the user or an availability
`indication if the licensed
`availability indicates that a
`license is available for the
`user”
`“means for providing to
`the network management
`server an application
`program to be distributed
`to remote servers”
`
`A processor executing
`computer program
`instructions, as described in
`col. 7:26-50 of the ‘578
`patent, implementing the
`algorithms described in the
`‘578 Patent at 5:44-53, and
`the ‘466 patent at col.
`13:58-14:1, 14:9-23
`
`Except for intro, should be
`the same as 49.
`
`a processor executing
`computer program
`instructions, as described in
`col. 7:26-50 of the ‘578
`patent, implementing the
`algorithms described in the
`‘578 Patent at 5:44-57, and
`the ‘466 patent at col.
`13:58-14:1, 14:9-23, 16:45-
`56
`
`a processor executing
`computer program
`instructions, as described in
`col. 12:1-24 of the ’466
`patent, implementing the
`algorithms described in the
`’466 patent in connection
`with block 110 of FIG. 8 and
`at col. 8:33-56;14:24-31;
`17:35-40, 17:55-58, 18:42-
`47
`
`
`
`
`7
`
`
`
`Case 2:16-cv-00741-RWS Document 218-1 Filed 08/02/17 Page 8 of 8 PageID #: 3810
`
`Terms, Phrases and Clauses Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`A processor executing
`computer program
`instructions, as described in
`col. 7:26-50 of the ‘578
`patent, implementing the
`algorithms described in the
`‘578 patent at 5:38-61;
`11:32-38; 12:37-13:18,
`13:36-38; FIG. 5, block 186;
`and ‘466 patent at col.
`13:58-14:1, 14:9-23
`
`
`Except for intro, should be
`the same as 50.
`
`a processor executing
`computer program
`instructions, as described in
`col. 7:26-50 of the ‘578
`patent, implementing the
`algorithms described in the
`‘578 patent at 5:38-61;
`11:32-38; 12:37-13:18,
`13:36-38; FIG. 5, block 186;
`and ‘466 patent at col.
`13:58-14:1, 14:9-23
`
`
`a processor executing
`computer program
`instructions, as described in
`col. 12:1-24 of the ’466
`patent, implementing the
`algorithms described in the
`’466 patent in connection
`with FIG. 10, block 112 of
`FIG. 8, and block 132 of FIG.
`9A and at col. 17:55-58,
`18:35-67, 19:14-16, 19:45-
`49
`
`8
`
`Plaintiffs'
`#
`95
`
`Claim
`
`’766
`patent
`claim 7
`
`“means for receiving at the
`license management
`server a request for a
`license availability of a
`selected one of the
`plurality of application
`programs from a user at a
`client”
`
`102
`
`’293
`patent
`claim 12
`
`“means for specifying a
`source directory and a
`target directory for
`distribution of the
`application program”
`
`
`
`
`
`
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