Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 1 of 27 PageID #: 3811
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`59
`
`’578 patent
`claim 16
`
`“means for distributing an
`application launcher program
`associated with the application
`program to the client”
`
`92
`
`’578 patent
`claim 16
`
`“means for providing to the
`server a user set of the
`plurality of configurable
`preferences from one of the
`plurality of authorized users
`executing the application
`launcher program”
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in connection with
`block 52 of FIG. 2 and block 72
`of FIG. 3 and at col. 3:61-67,
`4:27-29, 5:4-7, 5:13-15, 5:27-29,
`7:40-7:50, 7:66-8: 14, 8:21-47,
`9:53-65, 10:50-53, 11:32-60,
`12:22-36 ; in the ‘466 patent, col.
`4:44-53, 8:12-16, 9:2-5, 9:42-57,
`12:42-52, 14:9-13, 14:27-46,
`15:4-9, 15:56-16:29
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`blocks 98 and 100 of FIG. 4 and
`at col. 8:1-14, 8:55-60, 9:5-17,
`10:12-15, 11:9-22, 11:32-54,
`12:22-36; and ‘466 patent at col.
`9:67-10:2
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 52 of
`FIG. 2 and blocks 72 and 74 of
`FIG. 3 and at col. 3:61-67, 4:27-
`29, 5:4-7, 5:13-15, 5:26-28,
`7:66-8:14, 8:21-47, 9:53-65,
`10:50-54, 11:32-60, 12:22-36;
`in the ‘466 patent, col. 4:44-53,
`9:2-5, 9:42-57, 12:42-52, 14:9-
`13,14:27-46, 15:4-9, 15:56-
`16:29
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with blocks 98 and
`100 of FIG. 4 and at col. 8:1-14,
`8:55-60, 9:5-17, 10:12-15, 11:9-
`22, 11:32-54, 12:22-36; and
`‘466 patent at col. 9:67-10:2
`
`
`
`1
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 2 of 27 PageID #: 3812
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`94
`
`’578 patent
`claim 16
`
`“means for receiving an
`application launcher program
`associated with the application
`program from the server”
`
`’578 patent
`claim 16
`
`’578 patent
`claim 16, 17
`
`“means for requesting that the
`server initiate execution of the
`application program using the
`obtained user set and the
`administrator set of the
`plurality of configurable
`preferences responsive to a
`request from the one of the
`plurality of authorized users”
`“means for installing an
`application program having a
`plurality of configurable
`preferences and a plurality of
`authorized users on the
`server/a server coupled to the
`network”
`
`99
`
`69
`
`
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 90 of FIG. 4 and at col.
`3:61-67, 4:27-29, 5:4-7, 5:13-15,
`5:27-29, 7:66-8:14, 9:53-65,
`10:50-54, 11:32-12:12, 12:22-36;
`in the ‘466 patent, col. 4:44-53,
`8:12-16, 9:2-5, 9:42-57, 12:42-
`52, 14:9-13, 14:27-46, 15:4-9,
`15:56-16:29
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described at 8:1-20, 10:47-11:8,
`11:32-54, 11:60-12: 36; and ‘466
`patent at col. 9:30-57, 12:43-52,
`15:56-16:12
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in connection with
`block 50 of FIG. 2 and blocks
`70-72 of FIG. 3 and at col. 2:6-
`10; 3:50-55; 4:24-26; 5:11-13;
`7:8-9, 7:50-65, 8:22-34, 9:57-63,
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 90 of
`FIG. 4 and at col. 3:61-67, 4:27-
`29, 5:4-7, 5:13-15, 5:26-28,
`7:66-8:14, 9:53-65, 10:50-54,
`11:32-12:12, 12:22-36; in the
`‘466 patent, col. 4:44-53, 9:2-5,
`9:42-57, 12:42-52, 14:9-13,
`14:27-46, 15:4-9, 15:56-16:29
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent at
`8:1-20, 10:47-11:8, 11:32-54,
`11:60-12: 36; and ‘466 patent at
`col.9:30-57, 12:37-52, 15:56-
`16:12
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 50 of
`FIG. 2 and blocks 70-72 of FIG.
`3 and at col. 2:6-10; 3:50-55;
`4:24-26; 5:11-13; 5:36-40, 7:8-
`
`2
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 3 of 27 PageID #: 3813
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`58
`
`’578 patent
`claim 17
`
`“means for distributing an
`application launcher program
`associated with the application
`program to a client coupled to
`the network”
`
`12:13-21 ; in the ‘466 patent, 4:9-
`27, 5:29-44, 7:22-24, 9:42-43,
`12:1-24, 14:51-53, 17:17-20:59
`
`9, 7:51-65, 9:57-63, 12:13-21;
`in the ‘466 patent, 4:10-27,
`5:29-36, 5:40-44, 7:22-24, 9:42-
`43, 14:51-53, 17:17-51, 17:52-
`67, 18:1-18, 18:23- 20:45
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in connection with
`block 52 of FIG. 2 and blocks 72
`& 74 of FIG. 3 and at col. 3:61-
`67, 4:27-29, 5:4-7, 5:13-15, 5:27-
`29, 7:40-7:50, 7:66-8: 14, 8:21-
`47, 9:53-65, 10:50-53, 11:32-60,
`12:22-36, ; in the ‘466 patent,
`col. 4:44-53, 8:12-16, 9:2-5,
`9:42-57, 12:42-52, 14:9-13,
`14:27-46, 15:4-9, 15:56-16:29
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 52 of
`FIG. 2 and blocks 72 and 74 of
`FIG. 3 and at col. 3:61-67, 4:27-
`29, 5:4-7, 5:13-15, 5:26-28,
`7:66-8:14, 8:21-47, 9:53-65,
`10:50-54, 11:32-60, 12:22-36;
`in the ‘466 patent, col. 4:44-53,
`9:2-5, 9:42-57, 12:42-52, 14:9-
`13, 14:27-46, 15:4-9, 15:56-
`16:29
`
`
`
`3
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 4 of 27 PageID #: 3814
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`79
`
`’578 patent
`claim 18
`
`“means for obtaining an
`administrator set of the
`plurality of configurable
`preferences from an
`administrator executing the
`configuration manager
`program”
`
`82
`
`’578 patent
`claim 18
`
`“means for of distributing a
`configuration manager
`program associated with the
`application program to a
`second client coupled to the
`network”
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 58 of FIG. 2 and block 76
`of FIG. 3 and at col. 8:1-14,
`8:61-9:25, 9:41-43, 9:66-10:1;
`‘466 patent , col. 4:59-65, 8:51-
`53, 8:64-9:5, 9:10-29, 10:28-
`11:26, 16:38-39, and ‘826 patent,
`col. 7:54-64, 8:6-23, 8:48-63, and
`15:37-21:63,
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 58 of FIG. 2 and blocks 76
`of FIG. 3 and at col. 7:66-8:11,
`8:48-54, 9:11-9:25
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with block 58 of
`FIG. 2 and block 76 of FIG. 3
`and at col. 8:1-14, 8:61-9:25,
`9:41-43, 9:66-10:1; ‘466 patent
`at col. 4:59-65, 8:51-53, 8:64-
`9:2, 9:10-29, 10:28-11:26,
`16:38-39 and ‘826 patent, col.
`7:54-64, 8:6-23, 8:48-63, and
`15:37-21:63,
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with block 58 of
`FIG. 2 and blocks 76 of FIG. 3
`and at col. 7:66-8:11, 8:48-51,
`9:11-9:25
`
`
`
`4
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 5 of 27 PageID #: 3815
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`64
`
`’578 patent
`claim 20
`
`56
`
`’578 patent
`claim 21
`
`101
`
`’578 patent
`claim 22
`
`“means for executing the
`application program using the
`obtained user set and the
`administrator set of the
`plurality of configurable
`preferences responsive to a
`request from the one of the
`plurality of authorized users
`through the application
`launcher program”
`“means for displaying an icon
`associated with the application
`program on a screen of the
`client and wherein the one of
`the plurality of authorized
`users executes the application
`launcher program by selecting
`the displayed icon”
`
`“means for retrieving the
`stored user set and the stored
`administrator set from the
`storage device”
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 86 of FIG. 3 and at 8:1-20,
`10:30-46, 11:3-8, 11:65-12:36;
`and ‘466 patent at col. 9:30-57,
`14:53-58, 15:21-27
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described the '578 patent in
`connection with block 86 of
`FIG. 3 and at 8:1-20, 10:30-46,
`11:3-8, 11:65-12:36; and ‘466
`patent at col. 9:30-57, 15:21-27
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 92-94 of FIG. 4 and at 8:1-
`14, 8:35-42, 10:54-65, 11:32-
`11:65 and ‘466 patent at col.
`8:16-22, 9:30-57, 14:53-58,
`15:21-27
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`blocks 80 and 84 of FIG. 3 and at
`col. 9:5-17, 10:16-29, 11:9-22, ;
`‘466 patent at col. 9:5-9, and
`‘826 patent at col. 12:14-17,
`12:43-59, 13:43-47, 13:51-58,
`14:10-49
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with block 92-94 of
`FIG. 4 and at 8:1-14, 8:35-42,
`10:54-65, 11:32-11:65; and in
`the ‘466 patent at col. 8:16-22,
`9:30-57, 14:53-58, 15:21-27
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with blocks 80 and
`84 of FIG. 3 and at col. 9:5-17,
`10:16-29, 11:9-22; and in the
`‘466 patent at col. 9:5-9 and
`‘826 patent at col. 12:14-17,
`12:43-59, 13:43-47, 13:51-58,
`
`
`
`5
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 6 of 27 PageID #: 3816
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`14:10-49
`
`103
`
`’578 patent
`claim 22
`
`“means for storing the
`obtained user set and the
`obtained administer set on a
`storage device coupled to the
`server”
`
`54
`
`’578 patent
`claim 23
`
`“means for determining if a
`user requesting execution of
`the application program is one
`of the plurality of authorized
`users”
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`blocks 76 and 80-82 of FIG. 3
`and at col. 9:5-17, 9:66-10:5,
`10:16-29; and ‘826 patent at col.
`4:47-56, 5:13-26, 12:17-20,
`12:38-59, 14:50-15:36, 22:2-7
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`blocks 72 and 78 of FIG. 3 and at
`col. 9:61-63, 10:6-12 ; ‘466
`patent at col. 9:58-67, 12:53-
`58,13:14-17, 13:57-61, 14:59-62,
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with blocks 76 and
`80-82 of FIG. 3 and at col. 9:5-
`17, 9:66-10:5, 10:16-29 and
`‘826 patent at col. 4:47-56,
`5:13-26, 12:17-20, 12:38-59,
`14:50-15:36, 22:2-7
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with blocks 72 and
`78 of FIG. 3 and at col. 9:61-63,
`10:6-12; and in the ‘466 patent
`at col. 9:58-67, 12:53-58, 13:14-
`
`
`
`6
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 7 of 27 PageID #: 3817
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`80
`
`’578 patent
`claim 24
`
`“means for obtaining default
`preference values for any of the
`plurality of configurable
`preferences which are not
`specified by the user set or the
`administrator set”
`
`74
`
`’578 patent
`claim 27
`
`“means for obtaining a second
`user set of the plurality of
`configurable preferences from
`a second one of the plurality of
`authorized users executing the
`application launcher program”
`
`15:22-34, 15:37-55 ; and ‘826
`patent at col. 4:32-36, 4:56-5:26;
`11:29-65, 12:21-23
`
`17, 13:57-61, 14:59-62, 15:22-
`34, 15:37-42 and ‘826 patent at
`col. 4:32-36, 4:56-5:26; 11:29-
`65, 12:21-23
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 60 of FIG. 2 and block 76
`of FIG. 3 and at col. 9:30-47,
`10:1-5; ‘466 patent at col. 8:53-
`56; and ‘826 patent, at col. 9:15-
`11:28
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in connection with
`block 56 of FIG. 2 and blocks
`80-82 of FIG. 3 and at col. 8:55-
`60, 9:5-17, 10:13-25, 10:46-54,
`11:9-13, 11:16-22, 11:32-38,
`12:22-36, 14:12-39, and ‘826
`patent, col. 4:24-27, 4:46-60, 7:9-
`10, 13:51-54, 21:64-22:7-
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with block 60 of
`FIG. 2 and block 76 of FIG. 3
`and at col. 9:30-47, 10:1-5; and
`in the ‘466 patent at col. 8:53-
`56 and ‘826 patent, at col. 9:15-
`11:28
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 56 of
`FIG. 2 and blocks 80-82 of FIG.
`3 and at col. 8:1-14, 8:55-60,
`9:5-17, 10:13-25, 10:46-54,
`11:9-13, 11:16-22, 11:32-54,
`12:22-36, 14:12-39 and ‘826
`patent, col. 4:24-27, 4:46-60,
`
`
`
`7
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 8 of 27 PageID #: 3818
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`7:9-10, 13:51-54, 21:64-22:7-
`
`75
`
`’578 patent
`claim 28
`
`“means for obtaining a second
`user set of the plurality of
`configurable preferences from
`a second one of the plurality of
`authorized users executing the
`application launcher program
`on the second client”
`
`81
`
`’578 patent
`claim 29
`
`“means for obtaining the user
`set of the plurality of
`configurable preferences from
`one of the plurality of
`authorized users executing the
`application launcher program
`on the second client”
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 56 of FIG. 2 and blocks
`80-82 of FIG. 3 and at col. 8:55-
`60, 9:5-17, 10:13-25, 10:46-54,
`11:9-13, 11:16-22, 11:32-38,
`12:22-36, 14:12-39, and ‘826
`patent, col. 4:24-27, 4:46-60, 7:9-
`10, 13:51-54, 21:64-22:7-
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 56 of FIG. 2 and blocks
`80-82 of FIG. 3 and at col. 8:55-
`60, 9:5-17, 10:13-25, 10:46-54,
`11:9-13, 11:16-22, 11:32-38, ,
`12:22-36, 14:12-39 and ‘826
`patent, col. 4:24-27, 4:46-60, 7:9-
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 56 of
`FIG. 2 and blocks 80-82 of FIG.
`3 and at col. 8:1-14, 8:55-60,
`9:5-17, 10:13-25, 10:46-54,
`11:9-13, 11:16-22, 11:32-54,
`12:22-36, 14:12-39 and ‘826
`patent, col. 4:24-27, 4:46-60,
`7:9-10, 13:51-54, 21:64-22:7-
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 56 of
`FIG. 2 and blocks 80-82 of FIG.
`3 and at col. 8:1-14, 8:55-60,
`9:5-17, 10:13-25, 10:46-54,
`11:9-13, 11:16-22, 11:32-54,
`12:22-36, 14:12-39 and ‘826
`
`
`
`8
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 9 of 27 PageID #: 3819
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`10, 13:51-54, 21:64-22:7-
`
`patent, col. 4:24-27, 4:46-60,
`7:9-10, 13:51-54, 21:64-22:7-
`
`57
`
`’578 patent
`claim 30
`
`“means for distributing a
`second application launcher
`program associated with the
`second application program to
`the client coupled to the
`network”
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-40,
`implementing the algorithm
`described in connection with
`block 52 of FIG. 2 and blocks 72
`& 74 of FIG. 3 and at col. 3:61-
`67, 4:27-29, 5:4-7, 5:13-15, 5:27-
`29, 7:40-50, 7:66-8: 47, 9:53-65,
`10:50-53, 11:32-60, 12:22-36,
`14:12-39, ; in the ‘466 patent,
`col. 4:44-53, 8:12-16, 9:2-5,
`9:42-57, 12:42-52, 14:9-13,
`14:27-46, 15:4-9, 15:56-16:29
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 52 of
`FIG. 2 and blocks 72 and 74 of
`FIG. 3 and at col. 3:61-67, 4:27-
`29, 5:4-7, 5:13-15, 5:26-28,
`7:66-8:14, 8:21-47, 9:53-65,
`10:50-54, 11:32-60, 12:22-36,
`14:12-39; in the ‘466 patent,
`col. 4:44-53, 9:2-5, 9:42-57,
`12:42-52, 14:9-13,14:27-46,
`15:4-9, 15:56-16:29
`
`
`
`9
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 10 of 27 PageID #: 3820
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`65
`
`’578 patent
`claim 30
`
`68
`
`’578 patent
`claim 30
`
`“means for executing the
`second application program
`using the obtained second user
`set and the second
`administrator set of the second
`plurality of configurable
`preferences responsive to a
`request from the one of the
`second plurality of authorized
`users”
`
`“means for installing a second
`application program having a
`second plurality of
`configurable preferences and a
`second plurality of authorized
`users on the server”
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 86 of FIG. 3 and at 8:1-20,
`10:30-46, 11:3-8, 11:65-12:36,
`14:13-38 ; and ‘466 patent at col.
`9:30-57, 14:53-58, 15:21-27
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 50 of FIG. 2 and block 70-
`72 of FIG. 3 and at col. 2:6-10;
`3:50-55; 4:24-26; 5:11-13; 7:8-9,
`7:50-65, 8:22-34, 9:57-63, 12:13-
`21, ; in the ‘466 patent, 4:9-27,
`5:29-44, 7:22-24, 9:42-43, 12:1-
`24, 14:51-53, 17:17-20:59
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described the '578 patent in
`connection with block 86 of
`FIG. 3 and at 8:1-20, 10:30-46,
`11:3-8, 11:65-12:36; and ‘466
`patent at col. 9:30-57, 14:53-58,
`15:21-27
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 50 of
`FIG. 2 and blocks 70-72 of FIG.
`3 and at col. 2:6-10; 3:50-55;
`4:24-26; 5:11-13; 7:8-9, 7:51-
`65, 9:57-63, 12:13-21; in the
`‘466 patent, 4:10-27, 5:29- 5:40-
`44, 7:22-24, 9:42-43, 14:51-53,
`17:17- 18:1-18, 18:23 20:45
`
`
`
`10
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 11 of 27 PageID #: 3821
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`73
`
`’578 patent
`claim 30
`
`“means for obtaining a second
`administrator set of the second
`plurality of configurable
`preferences from the
`administrator”
`
`76
`
`’578 patent
`claim 30
`
`“means for obtaining a second
`user set of the second plurality
`of configurable preferences
`from one of the second
`plurality of authorized users
`executing the second
`application launcher program”
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 58 of FIG. 2 and block 76
`of FIG. 3 and at col. 8:1-14,
`8:61-9:25,9:41-43, 9:66-10:1 ;
`‘466 patent , col. 4:59-65, 8:51-
`53, 8:64-9:5, 9:10-29, 10:28-
`11:26, 16:38-39, and ‘826 patent,
`col. 7:54-64, 8:6-23, 8:48-63, and
`15:37-21:63
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 56 of FIG. 2 and blocks
`80-82 of FIG. 3 and at col. 8:55-
`60, 9:5-17, 10:16-25, 11:4-8,
`11:32-38, 12:22-36, 12:61-67,
`14:12-39, 15:66-16:12, 16:23-25,
`16:53-56 and ‘826 patent, col.
`4:24-27, 4:46-60, 7:9-10, 13:51-
`54, 21:64-22:7-
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with block 58 of
`FIG. 2 and block 76 of FIG. 3
`and at col. 8:1-14, 8:61-9:25,
`9:41-43, 9:66-10:1; ‘466 patent
`at col. 4:59-65, 8:51-53, 8:64-
`9:2, 9:10-29, 10:28-11:26,
`16:38-39 and ‘826 patent, col.
`7:54-64, 8:6-23, 8:48-63, and
`15:37-21:63
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 56 of
`FIG. 2 and blocks 80-82 of FIG.
`3 and at col. 8:1-14, 8:55-60,
`9:5-17, 10:13-25, 10:46-54,
`11:9-13, 11:16-22, 11:32-54,
`12:22-36, 14:12-39 and ‘826
`patent, col. 4:24-27, 4:46-60,
`7:9-10, 13:51-54, 21:64-22:7-
`
`
`
`11
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 12 of 27 PageID #: 3822
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`85
`
`’578 patent
`claim 31
`
`“means for providing a user set
`of the plurality of configurable
`preferences from one of a
`plurality of authorized users
`executing the application
`launcher program to the
`server”
`
`93
`
`’578 patent
`claim 31
`
`“means for receiving an
`application launcher program
`associated with an application
`program having a plurality of
`configurable preferences from
`a server coupled to the
`network”
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 86 of FIG. 3 and blocks 98
`& 100 of FIG. 4 and at 8:1-20,
`8:55-60, 9:5-17, 10:12-15, 10:30-
`46, 11:3-8, 11:9-22, 11:32-54,
`11:65-12:36; and ‘466 patent at
`col. 9:67-10:2
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 90 of FIG. 4 and at col.
`3:61-67, 4:27-29, 5:4-7, 5:13-15,
`5:27-29, 7:66-8:14, 9:53-65,
`10:50-54, 11:32-12:12, 12:22-
`36,; in the ‘466 patent, col. 4:44-
`53, 8:12-16, 9:2-5, 9:42-57,
`12:42-52, 14:9-13, 14:27-46,
`15:4-9, 15:56-16:29
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with blocks 98 and
`100 of FIG. 4 and at col. 8:1-14,
`8:55-60, 9:5-17, 9:67-10:2,
`10:12-15, 11:9-22, 11:32-54,
`12:22-36
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 90 of
`FIG. 4 and at col. 3:61-67, 4:27-
`29, 5:4-7, 5:13-15, 5:26-28,
`7:66-8:14, 9:53-65, 10:50-54,
`11:32-12:12, 12:22-36; in the
`‘466 patent, col. 4:44-53, 9:2-5,
`9:42-57, 12:42-52, 14:9-13,
`14:27-46, 15:4-9, 15:56-16:29
`
`
`
`12
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 13 of 27 PageID #: 3823
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`100
`
`’578 patent
`claim 31
`
`9
`
`’578 patent
`claim 32
`
`“means for requesting that the
`server provide an instance of
`the application program and a
`stored user set and an
`administrator set of the
`plurality of configurable
`preferences for use in executing
`the application program
`responsive to a request from
`the one of the plurality of
`authorized users”
`“computer readable program
`code means for distributing an
`application launcher program
`associated with the application
`program to a client coupled to
`the network”
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithms
`described at 11:3-8, 11:32-12:12,
`and ‘466 patent at col. 9:30-57
`
`a processor executing computer
`program instructions, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent at
`11:3-8, 11:32-12:12; and ‘466
`patent at col. 9:30-57
`
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithm
`described in connection with
`block 52 of FIG. 2 and blocks 72
`& 74 of FIG. 3 and at col. 3:61-
`67, 4:27-29, 5:4-7, 5:13-15, 5:27-
`29, 7:40-7:50, 7:66-8: -47, 9:53-
`65, 10;50-53, 11:32-60, 12:22-
`36; in the ‘466 patent, col. 4:44-
`53, 8:12-16, 9:2-5, 9:42-57,
`12:42-52, 14:9-13, 14:27-46,
`15:4-9, 15:56-16:29
`
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 52 of
`FIG. 2 and blocks 72 and 74 of
`FIG. 3 and at col. 3:61-67, 4:27-
`29, 5:4-7, 5:13-15, 5:26-28,
`7:66-8:14, 8:21-47, 9:53-65,
`10:50-54, 11:32-60, 12:22-36;
`in the ‘466 patent, col. 4:44-53,
`9:2-5, 9:42-57, 12:42-52, 14:9-
`13, 14:27-46, 15:4-9, 15:56-
`16:29
`
`
`
`13
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 14 of 27 PageID #: 3824
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`17
`
`’578 patent
`claim 32
`
`“computer readable program
`code means for installing an
`application program having a
`plurality of configurable
`preferences and a plurality of
`authorized users on a server
`coupled to the network”
`
`25
`
`’578 patent
`claim 32
`
`“computer readable program
`code means for obtaining a
`user set of the plurality of
`configurable preferences from
`one of the plurality of
`authorized users executing the
`application launcher program”
`
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithm
`described in connection with
`block 50 of FIG. 2 and blockS
`70-72 of FIG. 3 and at col. 2:6-
`10; 3:50-55; 4:24-26; 5:11-13;
`7:8-9,7:50-65, 8:22-34, 9:57-63,
`12:13-21; in the ‘466 patent, 4:9-
`27, 5:29-44, 7:22-24, 9:42-43,
`12:1-24, 14:51-53, 17:17-20:59
`
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 56 of FIG. 2 and blocks
`8082 of FIG. 3 and at col. 8:55-
`60, 9:5-17, 10:13-25, 10:46-54,
`11:9-13, 11:16-22, 11:32-38,
`12:22-36; and ‘826 patent, col.
`4:24-27, 4:46-60, 7:9-10, 13:51-
`54, 21:64-22:7-
`
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 50 of
`FIG. 2 and blocks 70-72 of FIG.
`3 and at col. 2:6-10; 3:50-55;
`4:24-26; 5:11-13; 7:8-9, 7:51-
`65, 9:57-63, 12:13-21; in the
`‘466 patent, 4:10-27, 5:29-40,
`5:40-44, 7:22-24, 9:42-43,
`14:51-53, 17:17-67, 18:1-18,
`18:23- 20:45
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithm
`described in the '578 patent in
`connection with block 56 of
`FIG. 2 and blocks 80-82 of FIG.
`3 and at col. 8:1-14, 8:55-60,
`9:5-17, 10:13-25, 10:46-54,
`11:9-13, 11:16-22, 11:32-54,
`12:22-36 and ‘826 patent, col.
`4:24-27, 4:46-60, 7:9-10, 13:51-
`54, 21:64-22:7-
`
`
`
`14
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 15 of 27 PageID #: 3825
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`26
`
`’578 patent
`claim 32
`
`“computer readable program
`code means for obtaining an
`administrator set of the
`plurality of configurable
`preferences from an
`administrator”
`
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 58 of FIG. 2 and blocks 76
`of FIG. 3 and at col. 8:1-14,
`8:61-9:25, 9:41-43, 9:66-10:1, ;
`‘466 patent , col. 4:59-65, 8:51-
`53, 8:64-9:5, 9:10-29, 10:28-
`11:26, 16:38-39,
`
`34
`
`’578 patent
`claim 32
`
`computer readable program
`code means for providing an
`instance of the application
`program using a stored user set
`and the administrator set of the
`plurality of configurable
`preferences for use in executing
`the application program
`responsive to a request from
`the one of the plurality of
`authorized users
`
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 86 of FIG. 3 and at 8:1-20,
`8:55-60, 10:30-54, 11:3-8, 11:65-
`12:36, , and ‘466 patent at col.
`9:30-57
`
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with block 58 of
`FIG. 2 and block 76 of FIG. 3
`and at col. 8:1-14, 8:61-9:25,
`9:41-43, 9:66-10:1; ‘466 patent
`at col. 4:59-65, 8:51-53, 8:64-
`9:2, 9:10-29, 10:28-11:26,
`16:38-39 and ‘826 patent,
`col.7:54-64, 8:6-23, 8:48-63,
`and 15:37-21:63
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with blocks 86 and
`at col. 8:1-20, 8:55-60, 10:30-
`54, 11:3-8, 11:65-12:52; and the
`'466 patent at col. 9:30-57
`
`
`
`15
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 16 of 27 PageID #: 3826
`
`Plaintiffs' # Claim
`
`Terms, Phrases and Clauses
`
`Defendants’ Prior Proposal
`
`Plaintiffs’ Proposal
`
`27
`
`’578 patent
`claim 33
`
`“computer readable program
`code means for obtaining an
`administrator set of the
`plurality of configurable
`preferences from an
`administrator executing the
`configuration manager
`program”
`
`30
`
`’578 patent
`claim 33
`
`“computer readable program
`code means for of distributing
`a configuration manager
`program associated with the
`application program to a
`second client coupled to the
`network”
`
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-40,
`implementing the algorithm
`described in connection with
`block 58 of FIG. 2 and block 76
`of FIG. 3 and at col. 8:1-14,
`8:61-9:25, 9:41-43, 9:66-10:1, ;
`‘466 patent , col. 4:59-65, 8:51-
`53, 8:64-9:5, 9:10-29, 10:28-
`11:26, 16:38-39, and ‘826 patent,
`col.7:54-64, 8:6-23, 8:48-63, and
`15:37-21:63
`
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithms
`described in connection with
`block 58 of FIG. 2 and blocks 76
`of FIG. 3 and at col. 7:66 -8:11,
`8:48-54, 9:11-9:25, 9:53-65,
`
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with block 58 of
`FIG. 2 and block 76 of FIG. 3
`and at col. 8:1-14, 8:61-9:25,
`9:41-43, 9:66-10:1; ‘466 patent
`at col. 4:59-65, 8:51-53, 8:64-
`9:2, 9:10-29, 10:28-11:26,
`16:38-39 and ‘826 patent,
`col.7:54-64, 8:6-23, 8:48-63,
`and 15:37-21:63
`computer program instructions
`for execution by a processor, as
`described in col. 7:26-50,
`implementing the algorithms
`described in the '578 patent in
`connection with block 58 of
`FIG. 2 and blocks 76 of FIG. 3
`and at col. 7:66-8:11, 8:48-51,
`9:11-9:25
`
`
`
`16
`
`

`

`Case 2:16-cv-00741-RWS Document 218-2 Filed 08/02/17 Page 17 of 27 PageID #: 3827
`
`Plaintiffs' # Claim
`
`Terms, Phrases