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`EXHIBIT J
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`Case 2:22-cv-00263-JRG-RSP Document 122-11 Filed 09/07/23 Page 2 of 59 PageID #:
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`EXHIBIT A-1
`
`Kubala in View of Hammond and Beyer ‘728
`For U.S. Patent No. 8,213,970
`
`
`
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`

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`Exhibit A-1 – Kubala in View of Hammond and Beyer ‘728
`U.S. Pat. Pub. No. 2006/0218232 (“Kubala”) in combination with U.S. Pat. No. 6,854,007 (“Hammond”) and U.S. Pat. No. 7,031,728
`(“Beyer ‘728”) renders obvious claims 10-13 of the ‘970 patent.
`Kubala published on September 28, 2006 and is prior art to the ‘970 patent under at least pre-AIA 35 U.S.C. § 102(b).
`Hammond published on February 8, 2005 and is prior art to the ‘970 patent under at least pre-AIA 35 U.S.C. § 102(b).
`Beyer ‘728 published on April 18, 2006 and is prior art to the ‘970 patent under at least pre-AIA 35 U.S.C. § 102(b).
`It would have been obvious to combine Hammond’s teachings with Kubala as both Kubala and Hammond relate to exchanging and
`tracking recipient-device acknowledgements for electronic messages. A person having ordinary skill in the art would have been
`motivated to modify Kubala with the teachings of Hammond in order to increase the chances that a recipient responds to an electronic
`message that requires response by using the message tracking techniques described in Hammond.
`It would have been obvious to combine Beyer ‘728’s teachings of mapping systems and obtaining information regarding a recipient
`device with Kubala as both Kubala and Beyer ‘728 relate to messaging other individuals using the communications capability of a
`mobile device. See Beyer ‘728 at 4:26-39 (“[T]he operator can activate different maps, change map scales, select which fixed entities
`are desired to be displayed, display the information concerning the symbol the operator has touched, initiate phone voice calls, send
`messages (text, photographs and videos), enter symbols and information representative of other entities, view the locations and
`statuses of the other communications net participants, establish conference calls, pre-establish conference sub-nets that, when
`activated, cause all the phone numbers that are specified to be conference for voice, text and photograph and video communications,
`and transmit messages to remote phones which cause the remote phones to make calls, verbal announcements, vibrate, increase sound
`levels and other functions.”)
`Beyer ’728 describes expeditiously initiating communication with nearby users using a geographic map display that displays the location
`of other users on the geographic map. See, e.g., Beyer ’728 at 5:9-20 (“Each cellular phone/PDA/GPS has the communications hardware
`along with the circuitry in software to initiate a voice telephone call or transmit data messages, photographs, or videos by touching the
`screen with a stylus or finger at the symbol location displayed on the screen of the desired phone to be called and then selecting the
`“call” software switch on the display touch screen. The software will then cause the cellular phone to call to the specific phone number
`represented by the symbol on the screen. This is done automatically. This action alleviates completely the necessity of actually looking
`up a phone number and manually entering the phone numbers required to make a cellular phone call.”). Beyer ’728 describes that the
`disclosed technique is useful for overcoming challenges with text messages. See id. at 1:61-2:54; see also Kubala at ¶ 32 (noting that
`“[a]lthough the term “e-mail message” is used throughout the description of the present invention, an e-mail message [may] comprise
`
`Exhibit A-1, Page 1
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`various types of electronic messages, e.g., text messages, instant messages, fax messages, voicemail messages, video messages, audio
`messages, and other types of messages; the present invention is applicable to various types of electronic communication applications
`and/or devices within which the various types of electronic messages can be processed”).
`
` person of ordinary skill in the art would have appreciated that providing such map/location functionality together with obtaining
`other information regarding a recipient device (e.g., the “location and status data” discussed herein) in Kubala would have allowed
`Kubala’s sender PDA/cell phone to monitor the locations of recipient PDA/cell phones in connection with sending an email, to check
`if the recipients are nearby and/or in a position to respond to an electronic message. Kubala itself recognizes that “it would be
`advantageous to provide productivity-enhancing features within e-mail applications.” See Kubala at ¶ 8. A person having ordinary
`skill in the art would have recognized that Beyer ‘728’s map/location functionality is simply another productivity-enhancing feature in
`the same e-mail context. This combination would have facilitated interaction among users based on relative position (i.e., based on
`Beyer ’728’s mapping and location-based communications techniques) and in particular enabling users to send and receive messages
`to nearby devices as shown on a geographical map displayed by a mobile device). This would have furthered Kubala’s goal of
`providing features in e-mail applications that reduce the amount of time between the receipt of an important e-mail message by a
`recipient and the generation of a response to that e-mail message by the recipient. Kubala at ¶ 7.   
`Additional reasons to combine Kubala, Hammond, and Beyer ‘728 are discussed in the accompanying contentions.
`Further, a person of ordinary skill in the art would have had a reasonable expectation of success in combining Beyer ‘728 with Kubala
`(and/or Kubala-Hammond) as Kubala and Beyer ‘728 both involve PDA/cell phones running software. See Beyer ‘728 at 6:5-33.
`
`
` A
`
`‘970 Patent
`Claim
`10[pre] A method of
`receiving,
`acknowledging and
`responding to a
`forced message alert
`from a sender
`PDA/cell phone to a
`recipient PDA/cell
`phone, wherein the
`
`Prior Art
`Kubala discloses a method of receiving, acknowledging and responding to a forced message alert
`from a sender PDA/cell phone to a recipient PDA/cell phone, wherein the receipt,
`acknowledgment, and response to said forced message alert is forced by a forced message alert
`software application program.
`
`See e.g., Kubala at Abstract (“A method, system, apparatus, or computer program product is
`presented for processing electronic messages. An electronic message is received for a recipient
`from a sender, and a data field is detected in the received electronic message that indicates a
`request by the sender for a response from the recipient for the received electronic message.”).
`
`Exhibit A-1, Page 2
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`receipt,
`acknowledgment, and
`response to said
`forced message alert
`is forced by a forced
`message alert
`software application
`program, said method
`comprising the steps
`of:
`
`
`Kubala also discloses a plurality of PDA/cell phones that communicate with each other. See id. at
`¶¶ 27, 32-33, FIG. 1. In other words, one PDA/cell phone sends an electronic message (i.e. “a
`sender PDA/cell phone”) and another PDA/cell phone receives it (i.e., a “recipient PDA/cell
`phone”).
`Kubala also discloses that the communication system was known to “generate return receipts to
`the sender when the sender’s e-mail message is received at its intended destination or when the
`recipient opens the e-mail message, thereby providing an acknowledgement that a particular
`message has been received and/or opened.” See also, e.g., id. at ¶ 6 (“Other prior art solutions
`have provided the ability to generate return receipts to the sender when the sender’s e-mail
`message is received at its intended destination or when the recipient opens the e-mail message,
`thereby providing an acknowledgement that a particular message has been received and/or
`opened.”). A person of ordinary skill in the art at the time of the invention would have
`understood that return receipts could be implemented with the enhanced email application
`described in Kubala, for example, to provide the enhanced e-mail application of Kubala with
`additional “[p]roductivity-enhancing features.”
`
`See also, e.g., id. at FIGS. 5-6, 9.
`
`
`Exhibit A-1, Page 3
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`Exhibit A-1, Page 4
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`Exhibit A-1, Page 5
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`Kubala describes a forced message alert software application program (e.g., enhanced email
`application that includes mandatory-response functional unit 212) including a list of required
`possible responses to be selected by a participant recipient of a forced message response loaded
`on each participating PDA/cell phone (e.g., mandatory response functional unit 212).
`
`Kubala’s mandatory response flag 216 that is attached to email message 214 reads on “attached a
`forced message alert software packet to a voice or text message creating a forced message alert.
`See e.g., Kubala at ¶ 35 (“A user of e-mail application 206, which contains mandatory response
`functional unit 210, operates e-mail application 206 to request that an important outgoing e-mail
`message is flagged as an e-mail message to which its recipient is required to provide a mandatory
`response. E-mail application 206 relies on functional unit 210 either to assist in the generation of
`an outgoing message or to perform the necessary modifications to an outgoing message so that it
`is flagged as an e-mail message to which its recipient is required to provide a mandatory
`response. For example, email message 214 contains mandatory response flag 216; mandatory
`response flag 216 acts as an indicator from e-mail application to e-mail application 208 that e-
`mail message 214 should be handled as an important message with a required mandatory
`response.”). See also id. at ¶¶ 13, 36.
`
`See also, e.g., id. at ¶ 32 (“It should be noted that the present invention supports electronic
`messages of many different formats. Although the term ‘e-mail message’ is used throughout the
`description of the present invention, an e-mail message comprise various types of electronic
`messages, e.g., text messages, instant messages, fax messages, voicemail messages, video
`messages, audio messages, and other types of messages;”).
`
`See also, e.g., id. at FIG. 2.
`
`
`
`Exhibit A-1, Page 6
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`See also, e.g., id. at FIG. 11C. FIG. 11C shows an example of alerting a user by displaying a
`menu 1120 of possible responses to a sender’s message.
`
`
`
`
`
`See also, e.g., id. at ¶ 57 (“[I]n this example [FIG. 11C], when “INSTANT” button 1118 is
`selected, the e-mail application determines which menu item within menu 1120 has been selected
`by the user as a quick response to the original e-mail message, thereby fulfilling the sender’s
`request that the recipient is required to provide a mandatory response. The text strings that are
`used as menu items may be obtained in a variety of manners. . . the text strings may be
`configurable through the enhanced e-mail application by allowing user-specifiable or system-
`administrator-specifiable parameters.”).
`
`
`
`Exhibit A-1, Page 7
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`See also, e.g., id. at ¶ 54 (“With reference now to FIGS. 11A-11D, a set of diagrams represent a
`set of GUI windows through which an e-mail application alerts a user by displaying warning
`messages and error messages to the user as a result of a user action when the e-mail application
`has an e-mail message that contains a mandatory request flag. FIGS. 11A-11D may be used in
`different scenarios depending upon the manner in which the enhanced e-mail application is
`implemented or configured to handle an e-mail message that contains a mandatory response flag.
`Other scenarios could be handled in different ways that are not illustrated within FIGS. 11A-11D,
`and these different processes would also be considered as embodiments of the present invention
`because each different process would represent a different way of attempting to fulfill a request
`from the sender of the original message that the recipient should or must provide a reply message
`in response to the original message.”).
`
`See also, e.g., id. at FIG. 11A, ¶ 54 (FIG. 11A shows an example of alerting a user by displaying
`a warning message 1102 when an e-mail message that contains a mandatory request flag is
`received, and that the recipient “must provide a reply message in response to the original
`message.”). This demonstrates that the response to said forced message alert is forced by the
`combination of Kubala’s enhanced email application 208 and mandatory response functional unit
`212.
`
`
`
`See also, e.g., id. at ¶ 55 (“Referring now to FIG. 11A, window 1102 is displayed to the recipient,
`and window 1102 contains an error message for the recipient that informs the user that the user
`must reply to the message that is being received before closing the e-mail message.”).
`
`
`Kubala discloses receiving an electronically transmitted electronic message.
`
`
`
`
`10[a]
`
`receiving an
`electronically
`
`Exhibit A-1, Page 8
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`transmitted electronic
`message;
`
`Kubala discloses the claimed forced message alert application program as the combination of an
`enhanced email application 208 and mandatory response functional unit 212 on a receiving
`computing device 204 (e.g., receiving PDA) that receives email message 214, as illustrated in
`FIG. 2. See Kubala at FIG. 2, ¶¶ 33-36.
`
`See e.g., Kubala at ¶ 27 (“In the depicted example [of FIG. 1A], distributed data processing
`system 100 may include the Internet with network 101 representing a worldwide collection of
`networks and gateways that use various protocols to communicate with one another, such as
`Lightweight Directory Access Protocol (LDAP), Transport Control Protocol/Internet Protocol
`(TCP/IP) Hypertext Transport-Protocol (HTTP), Wireless Application Protocol (WAP), etc. Of
`course, distributed data processing system 100 may also include a number of different types of
`networks, such as, for example, an intranet, a local area network (LAN, or a wide area network
`(WAN). For example, server 102 directly supports network 109 and client 110; network 109
`incorporates wireless communication links. Network enabled phone 111 and PDA 112 can
`directly transfer data between themselves across wireless link 113 using an appropriate
`technology, e.g., via BluetoothTM wireless technology or Wi-Fi technology (IEEE 802.11) that
`allows the creation of so-called personal area networks (PAN) or personal ad-hoc networks.
`Phone 111 connects to network 109 through wireless link 114, and PDA 113 connects to network
`109 through wireless link 105. In a similar manners, PDA 113 [sic] can transfer data to PDA 107
`via wireless link 116.”).
`
`Even with a different construction requiring communication via a server, Kubala describes that a
`server supports a network 109 and a client 110, allowing the PDAs/cell phones to “communicate
`with one another” using TCIP/IP for example and “directly transfer data between themselves”
`using, for example, “BluetoothTM wireless technology or WiFi technology (IEEE 802.11).” See
`also, e.g., id. at ¶¶ 27-28.
`
`See also, e.g., id. at FIG. 1A.
`
`
`Exhibit A-1, Page 9
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`See also, e.g., id. at ¶ 32 (“It should be noted that the present invention supports electronic
`message of many different formats. Although the term “e-mail message” is used throughout the
`description of the present invention, an e-mail message comprise various types of electronic
`messages, e.g., text messages, instant messages, fax messages, voicemail messages, video
`messages, audio messages, and other types of messages; the present invention is applicable to
`various types of electronic communication applications and/or devices within which the various
`types of electronic messages can be processed.
`
`See also, e.g., id. at ¶ 33 (“With reference now to FIG. 2, a block diagram depicts an exchange of
`e-mail messages between email applications that have been enhanced to include functionality to
`implement an embodiment of the present invention. Computing devices 202 and 204 represent
`one of a variety of possible data processing systems that are able to support an embodiment of the
`present invention, e.g., such as the data processing systems that are shown in FIG. 1A.
`Computing devices 202 and 204 support the execution of e-mail applications 206 and 207,
`
`Exhibit A-1, Page 10
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`

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`respectively, which exchange e-mail messages as a form of electronic communication, e.g.,
`through a LAN, through the Internet, or through some other type of communication link.”).
`
`Kubala’s mandatory response flag 216 that is attached to email message 214 reads on “attached a
`forced message alert software packet to a voice or text message creating a forced message alert.
`See e.g., Kubala at ¶ 35 (“E-mail application 206 relies on functional unit 210 either to assist in
`the generation of an outgoing message or to perform the necessary modifications to an outgoing
`message so that it is flagged as an e-mail message to which its recipient is required to provide a
`mandatory response. For example, email message 214 contains mandatory response flag 216;
`mandatory response flag 216 acts as an indicator from e-mail application to e-mail application
`208 that e-mail message 214 should be handled as an important message with a required
`mandatory response.”).
`
`See also, e.g., id. at FIG. 2.
`
`
`
`10[b]
`
`identifying said
`electronic message as
`a forced message
`alert, wherein said
`forced message alert
`
`
`Kubala discloses identifying said electronic message as a forced message alert, wherein said
`forced message alert comprises of a voice or text message and a forced message alert application
`software packet, which triggers the activation of the forced message alert software application
`program within the recipient PDA/cell phone.
`
`
`
`
`Exhibit A-1, Page 11
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`comprises of a voice
`or text message and a
`forced message alert
`application software
`packet, which
`triggers the activation
`of the forced message
`alert software
`application program
`within the recipient
`PDA/cell phone;
`
`The claimed “forced message alert [that] comprises of a voice or text message and a forced
`message alert application software packet” is met by Kubala’s disclosure of email message 214
`and the mandatory response flag 216. Kubala explains that e-mail message 214 may be a text
`message, voicemail message, audio message, video message, or other type of message. See
`Kubala at ¶ 32. Kubala also explains that “mandatory response flag 216 acts as an indicator . . .
`to e-mail application 208 that e-mail message 214 should be handled as an important message
`with a required mandatory response. Mandatory response flag 216 may be implemented in a
`variety of data formats.” See id. at ¶ 35. See also id. at FIGS. 3-4, ¶¶ 36-41.
`
`See 10[a] (recipient PDA/cell phone identifies electronic message as forced message alert and
`triggers activation of application program).
`
`See e.g., Kubala at ¶ 35 (“A user of e-mail application 206, which contains mandatory response
`functional unit 210, operates e-mail application 206 to request that an important outgoing e-mail
`message is flagged as an e-mail message to which its recipient is required to provide a mandatory
`response. E-mail application 206 relies on functional unit 210 either to assist in the generation of
`an outgoing message or to perform the necessary modifications to an outgoing message so that it
`is flagged as an e-mail message to which its recipient is required to provide a mandatory
`response. For example, email message 214 contains mandatory response flag 216; mandatory
`response flag 216 acts as an indicator from e-mail application to e-mail application 208 that e-
`mail message 214 should be handled as an important message with a required mandatory
`response.”).
`
`Kubala describes various embodiments for requiring a response to an e-mail message, which can
`include text messages, voicemail messages, and audio messages. See e.g., Kubala at ¶ 32 (“an e-
`mail message [may] comprise various types of electronic messages, e.g., text messages, instant
`messages, fax messages, voicemail messages, video messages, audio messages, and other types
`of messages.)” See e.g., id. at ¶ 54 (Each of Kubala’s embodiments “represent[s] a different way
`of attempting to fulfill a request from the sender of the original message that the recipient should
`or must provide a reply in response to the original message.” See e.g., id. at ¶ 53 (“[T]he user
`must reply to the received e-mail message in some manner before the e-mail application will
`allow the user to perform some other action.”).
`
`
`Exhibit A-1, Page 12
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`

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`Case 2:22-cv-00263-JRG-RSP Document 122-11 Filed 09/07/23 Page 15 of 59 PageID #:
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`
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`See also, e.g., id. at FIG. 2.
`
`
`
`See also, e.g., id. at FIG. 11C. FIG. 11C shows an example of alerting a user by displaying a
`menu 1120 of possible responses to a sender’s message.
`
`
`
`
`
`See also, e.g., id. at FIG. 11A, ¶ 54 (FIG. 11A shows an example of alerting a user by displaying
`a warning message 1102 when an e-mail message that contains a mandatory request flag is
`
`
`
`Exhibit A-1, Page 13
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`

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`received, and that the recipient “must provide a reply message in response to the original
`message.”).
`
`
`
`
`
`See also, e.g., id. at ¶ 55 (“Referring now to FIG. 11A, window 1102 is displayed to the recipient,
`and window 1102 contains an error message for the recipient that informs the user that the user
`must reply to the message that is being received before closing the e-mail message.”).
`
`See also, e.g., id. at ¶ 49 (“[I]f a reply has not been made for the e-mail message, then the
`recipient is alerted (step 812), and the process loops back to step 802 so that the user can continue
`reviewing the e-mail message until the user generates a reply message, e.g., in the manner that is
`shown in FIG. 9. In this manner, the e-mail application strictly adheres to a requirement that the
`user must reply to the received e-mail message in some manner before the email application will
`allow the user to perform some other action;”).
`
`Accordingly, Kubala discloses that receiving the forced message alert comprising the voice or
`text message and a forced message alert application software packet (Kubala’s email message
`214 and mandatory response flag 216) causes the receiving unit to carry out actions based on
`receiving the e-mail message 214 with the mandatory response flag 216 using mandatory
`response functional unit 212 (including requiring a response to the e-mail message 214).
`The combination of Kubala and Hammond disclose transmitting an automatic acknowledgment
`of receipt to the sender PDA/cell phone, which triggers the forced message alert software
`application program to take control of the recipient PDA/cell phone and show the content of the
`text message and a required response list on the display recipient PDA/cell phone or to repeat
`audibly the content of the voice message on the speakers of the recipient PDA/cell phone and
`show the required response list on the display recipient PDA/cell phone.
`
`
`Exhibit A-1, Page 14
`
`10[c]
`
`transmitting an
`automatic
`acknowledgment of
`receipt to the sender
`PDA/cell phone,
`which triggers the
`forced message alert
`software application
`
`

`

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`Kubala discloses “transmitting an automatic acknowledgement of receipt to the sender PDA/cell
`phone.” For example, Kubala discloses that it was known to “generate return receipts to the
`sender when the sender’s e-mail message is received at its intended destination or when the
`recipient opens the e-mail message, thereby providing an acknowledgment that a particular
`message has been received and/or opened.” See Kubala at ¶ 6.
`
`Hammond also discloses “transmitting an automatic acknowledgement of receipt to the sender
`PDA/cell phone.” See e.g., Hammond at 5:20-23 states that “the recipient computer systems
`provide receipts when messages are received and when messages are reviewed.” See also e.g., id.
`FIG. 2, 6:56-62 states that “[A]s an illustrative example of a Message Tracking Table, consider
`Message Tracking Table 127 shown in FIG.2. The illustrated Message Tracking Table contains
`entries for email electronic messages that are read by recipients, and each recipient of an email
`message can have unique message tracking information. Thus, a separate entry is created in the
`Message Tracking Table for each recipient of each message.”
`
`
`program to take
`control of the
`recipient PDA/cell
`phone and show the
`content of the text
`message and a
`required response list
`on the display
`recipient PDA/cell
`phone or to repeat
`audibly the content of
`the voice message on
`the speakers of the
`recipient PDA/cell
`phone and show the
`required response list
`on the display
`recipient PDA/cell
`phone; and
`
`Exhibit A-1, Page 15
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`

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`
`
` A
`
` POSA would have understood that return receipts could be implemented with the enhanced
`email application described in Kubala, for example, to provide the enhanced e-mail application
`of Kubala with additional “[p]roductivity-enhancing features.”
`
`Kubala discloses “triggers the forced message alert software application program to take control
`of the recipient PDA/cell phone” as claimed. For example, FIG. 2 of Kubala illustrates an
`enhanced email application 208 that includes a mandatory-response functional unit 212 on
`computing device 204. The combined enhanced email application 208 and mandatory-response
`
`Exhibit A-1, Page 16
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`

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`functional unit 212 read on the claimed “forced message alert software application program to
`take control of the recipient PDA/cell phone.” Kubala explains that the mandatory response
`functional unit 210 provides an email message 218 in response to an email message with a
`mandatory-response flag. See Kubala at ¶ 35: (“The present invention addresses this need by
`enhancing the functionality of an e-mail application in the following manner. A user of e-mail
`application 206, which contains mandatory response functional unit 210, operates e-mail
`application 206 to request that an important outgoing e-mail message is flagged as an e-mail
`message to which its recipient is required to provide a mandatory response. E-mail application
`206 relies on functional unit 210 either to assist in the generation of an outgoing message or to
`perform the necessary modifications to an outgoing message so that it is flagged as an e-mail
`message to which its recipient is required to provide a mandatory response. For example, email
`message 214 contains mandatory response flag 216; mandatory response flag 216 acts as an
`indicator from e-mail application 206 to e-mail application 208 that e-mail message 214 should
`be handled as an important message with a required mandatory response. Mandatory response
`flag 216 may be implemented in a variety of data formats, as explained hereinbelow.”).
`
`See also Kubala at ¶¶ 13, 33, 36.
`
`Kubala describes various embodiments for requiring a response to an e-mail message, which can
`include text messages, voicemail messages, and audio messages. See e.g., Kubala at ¶ 32 (“an e-
`mail message [may] comprise various types of electronic messages, e.g., text messages, instant
`messages, fax messages, voicemail messages, video messages, audio messages, and other types
`of messages.)” See e.g., id. at ¶ 54 (Each of Kubala’s embodiments “represent[s] a different way
`of attempting to fulfill a request from the sender of the original message that the recipient should
`or must provide a reply in response to the original message.” See e.g., id. at ¶ 53 (“[T]he user
`must reply to the received e-mail message in some manner before the e-mail application will
`allow the user to perform some other action.”).
`
`Kubala also discloses the claimed “show the content of the text message and a required response
`list on the display on the display recipient PDA/cell phone” as claimed. Kubala’s FIG. 11C
`illustrates a response list to be shown on the display of a recipient PDA/cell phone. The specific
`embodiment in FIG. 11 C that shows how a user can select an automated response shows that a
`user can select CANCEL to close the message without sending a reply. However, Kubala also
`
`Exhibit A-1, Page 17
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`explicitly describes that “the recipient can be prevented from closing a review of the received e-
`mail message, from deleting the received e-mail message, and from exiting the e-mail application
`until the recipient has responded to the received email message.” See e.g., id. at ¶ 9. See e.g., id.
`at ¶ 60 (“In addition, the recipient being required to respond to the e-mail message is a
`configurable feature which may be required, for example, when the recipient first reviews the e-
`mail message).
`
`
`
`
`
`See also, e.g., id. at ¶ 57 (“‘INSTANT’ button 1118 closes window 1112 and then creates a reply
`e-mail message with an automatically generated reply message in which the message body is
`predetermined or pre-configured; in this example, when “INSTANT” button 1118 is selected, the
`e-mail application determines which menu item within menu 1120 has been selected by the user
`as a quick response to the original e-mail message, thereby fulfilling the sender’s request that the
`recipient is required to provide a mandatory response. The text strings that are used as menu
`items may be obtained in a variety of manners. . . . the text strings may be configurable through
`the enhanced e-mail application by allowing user-specifiable or system-administrator-specifiable
`parameters.”).
`
`Kubala also discloses “to repeat audibly the content of the voice message on the speakers of the
`recipient PDA/cell phone and show the required response list on the display recipient PDA/cell
`phone” as claimed. Kubala explains that e-mail message 214 may be a text message, or a
`voicemail or audio message. See Kubala at ¶ 32. Kubala discloses that when a reply to an email
`message with an associated mandatory-response flag has not been made, the enhanced email
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`Exhibit A-1, Page 18
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`application 208 loops back to alert the recipient via 1012, as illustrated in FIG. 10. The looping
`back at 1012 has the effect of resending the message to the user until the user replies to the
`received email message as required. See id. at ¶ 53, FIG. 10.
`
`
`
`See also, e.g., id. at ¶ 49 (“[I]f a reply has not been made for the e-mail message, then the
`recipient is alerted (step 812), and the process loops back to step 802 so that the user can continue
`reviewing the e-mail message until the user generates a reply message, e.g., in the manner that is
`shown in FIG. 9. In this manner, the e-mail application strictly adheres to a requirement that the
`user must reply to the received e-mail message in some manner before the email application will
`allow the user to perform some othe