Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 1 of 27 PageID #: 5240
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 12-1595-LPS
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`C.A. No. 12-1596-LPS
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`C.A. No. 12-1599-LPS
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`C.A. No. 12-1601-LPS
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`ARENDI S.A.R.L.,
`
`
`Plaintiff,
`
`
`v.
`
`LG ELECTRONICS, INC.,
`LG ELECTRONICS USA, INC. and
`LG ELECTRONICS MOBILECOMM U.S.A.,
`INC.,
`
`
`Defendants.
`ARENDI S.A.R.L.,
`
`
`Plaintiff,
`
`
`v.
`
`APPLE INC.,
`
`
`Defendant.
`
`
`ARENDI S.A.R.L.,
`
`
`Plaintiff,
`
`
`v.
`
`MICROSOFT MOBILE INC.,
`
`
`Defendant.
`
`ARENDI S.A.R.L.,
`
`
`Plaintiff,
`
`
`v.
`
`MOTOROLA MOBILITY LLC
`f/k/a MOTOROLA MOBILITY, INC.,
`
`
`Defendant.
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`

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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 2 of 27 PageID #: 5241
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`C.A. No. 12-1602-LPS
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`C.A. No. 13-919-LPS
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`C.A. No. 13-920-LPS
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`ARENDI S.A.R.L.,
`
`
`Plaintiff,
`
`
`v.
`
`SONY MOBILE COMMUNICATIONS (USA)
`INC. f/k/a SONY ERICSSON MOBILE
`COMMUNICATIONS (USA) INC.,
`SONY CORPORATION and
`SONY CORPORATION OF AMERICA,
`
`
`Defendants.
`ARENDI S.A.R.L.,
`
`
`Plaintiff,
`
`
`v.
`
`GOOGLE LLC,
`
`
`Defendant.
`
`
`ARENDI S.A.R.L.,
`
`
`Plaintiff,
`
`
`v.
`
`OATH HOLDINGS INC., and
`OATH INC.,
`
`
`
`Defendants.
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`

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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 3 of 27 PageID #: 5242
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`PLAINTIFF’S ANSWERING BRIEF IN OPPOSITION TO
`DEFENDANTS’ MOTION FOR JUDGMENT ON THE PLEADINGS
`
`SMITH, KATZENSTEIN & JENKINS LLP
`
`Neal C. Belgam (No. 2721)
`Eve H. Ormerod (No. 5369)
`Beth A. Swadley (No. 6331)
`1000 West Street, Suite 1501
`Wilmington, DE 19801
`Tel: (302) 652-8400
`nbelgam@skjlaw.com
`eormerod@skjlaw.com
`bswadley@skjlaw.com
`
`Attorneys for Plaintiff Arendi S.A.R.L.
`
`Of Counsel:
`
`Stephen Susman
`Seth Ard
`Max Straus
`Beatrice Franklin
`SUSMAN GODFREY, LLP
`1301 Avenue of the Americas, 32nd Floor
`New York, New York 10019
`Tel: (212) 336-8330
`ssusman@susmangodfrey.com
`sard@susmangodfrey.com
`mstraus@susmangodfrey.com
`bfranklin@susmangodfrey.com
`
`John Lahad
`SUSMAN GODFREY, LLP
`1000 Louisiana Street, Suite 5100
`Houston, Texas 77002-5096
`Tel: (713) 651-9366
`jlahad@susmangodfrey.com
`
`Dated: August 13, 2019
`
`
`
`
`
`

`

`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 4 of 27 PageID #: 5243
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`
`
`
`I.
`II.
`III.
`IV.
`
`V.
`
`
`
`TABLE OF CONTENTS
`
`
`
`Introduction ..........................................................................................................................1
`Statement of Facts ................................................................................................................2
`Legal Standard .....................................................................................................................4
`Argument .............................................................................................................................4
`A.
`The Patents-in-Suit Are Eligible
`Improvements
`in Computer
`Functionality ............................................................................................................4
`The Claimed Inventions Disclose an Inventive Concept .......................................14
`B.
`Conclusion .........................................................................................................................20 
`
`
`
`
`
`
`i
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`

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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 5 of 27 PageID #: 5244
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`
`TABLE OF AUTHORITIES
`
`
`
`Page(s)
`
`Cases
`
`Aatrix Software, Inc. v. Green Shades Software, Inc.,
`882 F.3d 1121 (Fed. Cir. 2018)..........................................................................................14, 15
`
`Affinity Labs of Texas, LLC v. DirectTV, LLC,
`838 F.3d 1253 (Fed. Cir. 2016)............................................................................................2, 20
`
`Amdocs (Israel) Ltd. v. Opennet Telecom, Inc.,
`841 F.3d 1288 (Fed. Cir. 2016)........................................................................................ passim
`
`Ancora Techs., Inc. v. HTC Am. Inc.,
`908 F.3d 1343 (Fed. Cir. 2018)........................................................................................ passim
`
`Arendi S.A.R.L. v. Apple, Inc.,
`832 F. 3d 1355 (Fed. Cir. 2016)...........................................................................................3, 18
`
`Bascom Global Internet Services, Inc. v. AT&T Mobility LLC,
`827 F.3d 1341 (Fed. Cir. 2016)........................................................................................ passim
`
`Berkheimer v. HP, Inc.,
`881 F.3d 1360 (Fed. Cir. 2018)....................................................................................14, 15, 16
`
`BSG Tech LLC v. Buyseasons, Inc.,
`899 F.3d 1281 (Fed. Cir. 2018)................................................................................................19
`
`Cellspin Soft, Inc. v. Fitbit, Inc.,
`927 F.3d 1306 (Fed. Cir. 2019)................................................................................................15
`
`Content Extraction & Transmission LLC v. Wells Fargo Bank,
`776 F.3d 1343 (Fed. Cir. 2014)................................................................................................12
`
`Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc.,
`880 F.3d 1356 (Fed. Cir. 2018)........................................................................................ passim
`
`Data Engine Technologies LLC v. Google LLC,
`906 F.3d 999 (Fed. Cir. 2018).......................................................................................... passim
`
`DDR Holdings, LLC v. Hotels.com, L.P.,
`773 F.3d 1245 (Fed. Cir. 2014)......................................................................................2, 15, 16
`
`Enfish, LLC v. Microsoft Corp.,
`822 F.3d 1327 (Fed. Cir. 2016)......................................................................................5, 11, 12
`
`
`
`ii
`
`

`

`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 6 of 27 PageID #: 5245
`
`
`Finjan, Inc. v. Blue Coat Sys., Inc.,
`879 F.3d 1299 (Fed. Cir. 2018)........................................................................................ passim
`
`In re TLI Comm’cns LLC Patent Litig.,
`823 F.3d 607 (Fed. Cir. 2016)..................................................................................................19
`
`Intellectual Ventures I LLC v. AT&T Mobility LLC,
`235 F. Supp. 3d 577 (D. Del. 2016) ...........................................................................................4
`
`Intellectual Ventures I LLC v. Capital One Bank (USA),
`792 F.3d 1363 (Fed. Cir. 2015)......................................................................................2, 19, 20
`
`Interval Licensing LLC v. AOL, Inc.,
`896 F.3d 1335 (Fed. Cir. 2018)................................................................................................13
`
`MAZ Encryption Techs. LLC v. Blackberry Corp.,
`C.A. No. 13-304-LPS, 2016 WL 5661981 (D. Del. Sept. 29, 2016) .........................................4
`
`Mortg. Grader, Inc. v. First Choice Loan Servs. Inc.,
`811 F.3d 1314 (Fed. Cir. 2016)..........................................................................................18, 19
`
`Trading Techs. Int’l, Inc. v. CQG, Inc.,
`675 F. App’x 1001 (Fed. Cir. 2017) ........................................................................................11
`
`Two-Way Media Ltd. v. Comcast Cable Commc’ns, LLC,
`874 F.3d 1329 (Fed. Cir. 2017)................................................................................................13
`
`Statutes
`
`35 U.S.C. § 101 ....................................................................................................................1, 12, 15
`
`
`
`iii
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`

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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 7 of 27 PageID #: 5246
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`
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`Plaintiff Arendi S.A.R.L. (“Arendi”) files this opposition to Defendants’ Rule 12(c)
`
`motion, which contends that the asserted claims of U.S. Patent Nos. 7,917,843 (“the ’843 patent”),
`
`8,306,993 (“the ’993 patent”), 7,496,854 (“the ’854 patent”), and 7,921,356 (“the ’356 patent”)
`
`(collectively, “the patents-in-suit,” attached as Exhibits 1-4) are ineligible under 35 U.S.C. §101.
`
`I.
`
`Introduction
`
`As they did during claim construction, Defendants mischaracterize the inventions, hoping
`
`oversimplification leads to an ineligibility ruling. Properly characterized, the claimed inventions
`
`are directed to improved methods and systems of information handling between computer
`
`programs. The claims permit working in a document in one computer program while
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`simultaneously searching for and retrieving information from a different program or information
`
`source with little to no user intervention. In addition to improving information handling between
`
`programs, the inventions overcome users’ difficulty in accessing, maintaining, and manipulating
`
`foreign information management programs. The inventions provide significant efficiency gains
`
`and performance improvements for both the user and the computer system. Inventions similarly
`
`drawn to software-based improvements in the capabilities of a computer and associated benefits
`
`to the user have repeatedly passed muster under step one of Alice. See, e.g., Ancora Techs., Inc. v.
`
`HTC Am. Inc., 908 F.3d 1343, 1347-49 (Fed. Cir. 2018) (summarizing cases).
`
`The ill fit of Defendants’ letter-writing analogy highlights the key features of the inventions
`
`that place them firmly within the camp of eligible subject matter. First, the inventions allow the
`
`user to locate, retrieve, and use information from an outside data source without having to leave
`
`or stop working within a document. By contrast, the drafter in Defendants’ analogy must cease
`
`work and relinquish her letter to an assistant. Second, the user does not have to understand the
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`structure or operation of the second data source—unlike a situation where the drafter must rely on
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`
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`

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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 8 of 27 PageID #: 5247
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`a second person to retrieve address information from a database dependent on someone’s active
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`upkeep and maintenance.
`
`Defendants fare no better at step two. As in cases like DDR Holdings, LLC v. Hotels.com,
`
`L.P., 773 F.3d 1245 (Fed. Cir. 2014), Amdocs (Israel) Ltd. v. Opennet Telecom, Inc., 841 F.3d
`
`1288 (Fed. Cir. 2016), and Bascom Global Internet Services, Inc. v. AT&T Mobility LLC, 827 F.3d
`
`1341 (Fed. Cir. 2016), the asserted claims here provide a novel solution to a technological problem,
`
`creating significant workflow improvements and efficiencies when users draw on outside data
`
`sources while working within a document. This is wholly unlike the claims at issue in cases like
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`Affinity Labs of Texas, LLC v. DirectTV, LLC, 838 F.3d 1253 (Fed. Cir. 2016), and Intellectual
`
`Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363 (Fed. Cir. 2015), which tautologically
`
`defined their invention rather than creating any actual technological improvements.  
`
`II.
`
`Statement of Facts
`
`The shared specification of the ’843, ’356, and ’854 patents explains the need to retrieve
`
`information from a data source external to a document, such as a database. It also observes that
`
`information in the database becomes stale and, therefore, “must constantly be updated by the user,”
`
`which requires the user to have access to the database and understand how to use and modify the
`
`database or else rely on the intervention of an administrator. Ex. 1, ’843 patent, at 1:27-35, 1:43-
`
`49. The invention obviates the need for the user to be familiar with the database in order to search
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`for, retrieve, and modify information, while allowing the user to search for and import information
`
`into the document without pausing her work. The Abstract summarizes the invention accordingly:
`
`A method, system and computer readable medium for providing . . . a function item,
`such as a key, button, icon, or menu, tied to a user operation in a computer, whereby
`a single click on the function item in a window or program on a computer screen,
`or one single selection in a menu in a program, initiates retrieval of name and
`addresses and/or other person or company related information, while the user works
`simultaneously in another program, e.g., a word processor.
`
`2
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`

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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 9 of 27 PageID #: 5248
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`Ex. 1, at Abstract; see also id. at 2:14-23 (similar language used to achieve “objects” of the
`
`invention). The Federal Circuit similarly described the ’843 patent as “directed to providing
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`beneficial coordination between a first computer program displaying a document and a second
`
`computer program for searching an external information source. The patent allows a user to access
`
`and conduct a search using the second computer program while remaining in the first computer
`
`program displaying the document.” Arendi S.A.R.L. v. Apple, Inc., 832 F. 3d 1355, 1357 (Fed. Cir.
`
`2016).
`
`Use of the invention, the specification adds, “requires little to no training on the part of a
`
`user” and can be implemented “with a minimal number of user commands.” Ex. 1, at 9:51-54. The
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`invention simplifies the process of creating and updating records in the database, allowing such
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`tasks to be performed directly from the document. See id. at 9:57-60. And, while the specification
`
`adds that the user may select the information to be searched, id. at 10:14-19, certain claims
`
`expressly eschew such user intervention, see, e.g., Ex. 3, ’854 patent, at claim 13, which further
`
`optimizes the invention’s information handling capabilities.
`
`The ’993 patent is a continuation of a different application, but it generally describes the
`
`same goals and advantages of its invention. The ’993 patent recounts computer users’ need to
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`retrieve information “from an information management source external to the word processor.”
`
`Ex. 2, ’993 patent, at 1:40-41. It further notes users’ difficulties “constantly” updating that
`
`information management source. Id. at 1:50-56.
`
`Arendi initiated these lawsuits in late 2012 and early 2013. The cases were stayed pending
`
`IPR in February 2014. D.I. 35 (Case No. 13-919). This Court effectively lifted the stay in
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`September 2018, D.I. 80, and entered a revised scheduling order on October 23, 2018. D.I. 85.
`
`Defendants waited nearly nine months since the Court lifted the stay to file their Rule 12(c) motion.
`
`3
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`

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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 10 of 27 PageID #: 5249
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`III. Legal Standard
`
`When evaluating a motion for judgment on the pleadings, the Court must accept all factual
`
`allegations in a complaint as true and view them in the light most favorable to the non-moving
`
`party. Intellectual Ventures I LLC v. AT&T Mobility LLC, 235 F. Supp. 3d 577, 584 (D. Del. 2016)
`
`(citing Rosenau v. Unifund Corp., 539 F.3d 218, 221 (3d Cir. 2008)). A Rule 12(c) motion will
`
`not be granted “unless the movant clearly establishes that no material issue of fact remains to be
`
`resolved and that he is entitled to judgment as a matter of law.” Id. (quotations omitted).
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`Ultimately, a motion for judgment on the pleadings can be granted “only if no relief could be
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`afforded under any set of facts that could be proved.” Id. at 585 (quotations omitted).
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`IV. Argument
`
`A.
`
`The Patents-in-Suit Are Eligible Improvements in Computer Functionality
`
`At Alice step one, “the claims are considered in their entirety to ascertain whether their
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`character as a whole is directed to excluded subject matter.” MAZ Encryption Techs. LLC v.
`
`Blackberry Corp., C.A. No. 13-304-LPS, 2016 WL 5661981, at *2 (D. Del. Sept. 29, 2016)
`
`(emphasis in original) (citation omitted). In software cases, “this inquiry often turns on whether
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`the claims focus on ‘the specific asserted improvement in computer capabilities . . . or, instead, on
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`a process that qualifies as an “abstract idea” for which computers are invoked merely as a tool.’”
`
`Finjan, Inc. v. Blue Coat Sys., Inc., 879 F.3d 1299, 1303 (Fed. Cir. 2018) (alteration in original)
`
`(quoting Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1335–36 (Fed. Cir. 2016)).
`
`The asserted claims of the patents-in-suit are directed to a specific way of improving
`
`information searching and retrieval between two different computer programs without disrupting
`
`the user’s work or requiring the user to be familiar with and have access to an external information
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`source. The specification describes the novel solution as “providing a function item,” such as a
`
`button, that “initiates retrieval of name and addresses and/or other person or company related
`
`4
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`

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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 11 of 27 PageID #: 5250
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`information, while the user works simultaneously in another program, e.g., word processor.” Ex.
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`1, at 2:15-23. The specification further notes that the invention solves users’ need to “constantly”
`
`update the information database, which requires that they either “learn how to use and have access
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`to the database” or otherwise rely on a system administrator. Id. at 1:44-49. In Enfish, an invention
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`“designed to improve the way a computer stores and retrieves data in memory” provided “a
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`solution to a problem in the software arts.” 822 F.3d at 1339. The eligible invention ran on a
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`general-purpose computer, but provided benefits “such as increased flexibility, faster search times,
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`and smaller memory requirements.” Id. at 1337. Recent Federal Circuit decisions relying on
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`Enfish—Ancora, Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc., 880 F.3d 1356, 1362-
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`63 (Fed. Cir. 2018), Data Engine Technologies LLC v. Google LLC, 906 F.3d 999 (Fed. Cir. 2018),
`
`and Finjan—confirm the eligibility of software-based inventions that, like the claims here,
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`improve computer usability and efficiency and “make non-abstract improvements to computer
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`technology.” Enfish, 822 F.3d at 1335.
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`In Ancora, the Federal Circuit held that a method of looking up whether a user or a
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`computer held a valid software license was not directed to an abstract idea. 908 F.3d at 1348. The
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`claim at issue recited:
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`A method of restricting software operation within a license for use with a computer
`including an erasable, non-volatile memory area of a BIOS of the computer, and a
`volatile memory area; the method comprising the steps of:
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`selecting a program residing in the volatile memory,
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`using an agent to set up a verification structure in the erasable, non-volatile memory
`of the BIOS, the verification structure accommodating data that includes at least
`one license record,
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`verifying the program using at least the verification structure from the erasable non-
`volatile memory of the BIOS, and
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`acting on the program according to the verification.
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`5
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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 12 of 27 PageID #: 5251
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`Id. at 1345-36. The Federal Circuit held that the claim was drawn to “[i]mproving security—here,
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`against a computer’s unauthorized use of a program” using “a specific technique that departs from
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`earlier approaches to solve a specific computer problem.” Id. at 1348. According to the Court, this
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`method of “verifying” a computer program constituted a solution to a computer-functionality
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`problem and passed muster under Alice step one. Id. at 1349.
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`
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`Likewise, in Data Engine, the Federal Circuit held eligible a claim “directed to a specific
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`method for navigating through three-dimensional electronic spreadsheets.” 906 F.3d at 1008. In
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`contrast to conventional spreadsheets, the Court said, “the method claimed in the Tab Patents
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`includes user-familiar objects, i.e., paradigms of real-world objects which the user already knows
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`how to use, such as notebook tabs.” Id. at 1003 (quotations omitted). The Court noted that
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`according to the specification, “prior art computer spreadsheets were not user friendly,” “required
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`users to master many complex and arbitrary operations,” and required users to “search though
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`complex menu systems to find appropriate commands to execute simple computer tasks.” Id. at
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`1008. The Court therefore held that the claimed invention “solved this known technological
`
`problem in computers in a particular way—by providing a highly intuitive, user-friendly interface
`
`with familiar notebook tabs for navigating the three-dimensional worksheet environment.” Id.
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`
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`In Core Wireless, the Federal Circuit held that claims directed to “an improved user
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`interface for computing devices” were not abstract because they were “directed to a particular
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`manner of summarizing and presenting information in electronic devices.” 880 F.3d at 1362. The
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`representative claim disclosed a computing device “comprising a display screen . . . configured to
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`display on the screen a menu listing one or more applications” and “an application summary that
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`can be reached directly from the menu, wherein the application summary displays a limited list of
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`data offered within the one or more applications, each of the data in the list being selectable to
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`6
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`

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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 13 of 27 PageID #: 5252
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`launch the respective application,” from an unlaunched state, and to enable the selected data to be
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`seen within the respective application. Id. at 1359. In finding eligibility, the Court relied on the
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`claim’s reference to “a particular manner by which the summary window must be accessed” and
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`the restraint on “the type of data that can be displayed in the summary window,” as well as the
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`requirement that the summary window display applications in an unlaunched state. Id. at 1362-63.
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`The Court also looked to the specification’s description of prior systems’ shortcomings,
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`noting that they required the user “to scroll around and switch views many times to find the right
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`data/functionality” and to “drill down through many layers to get to desired data or functionality.”
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`Id. at 1363 (quotations omitted). “Rather than paging though multiple screens of options, only
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`three steps may be needed from start up to reaching the required data/functionality” with the
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`patented invention, which “clearly indicates that the claims are directed to an improvement in the
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`functioning of computers, particularly those with small screens.” Id. (quotations omitted).
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`Finally, in Finjan, the Federal Circuit held that a claim directed to “a method of providing
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`computer security by scanning a downloadable and attaching the results of that scan to the
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`downloadable itself in the form of a ‘security profile’” was not abstract. 879 F.3d at 1303. The
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`representative claim stated a three-step method comprising:
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`receiving by an inspector a Downloadable;
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`generating by the inspector a first Downloadable security profile that identifies
`suspicious code in the received Downloadable; and
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`linking by the inspector the first Downloadable security profile to the
`Downloadable before a web server makes the Downloadable available to web
`clients.
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`Id. The Court held that this claim “recite[s] specific steps—generating a security profile that
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`identifies suspicious code and linking it to a downloadable—that accomplish the desired result”
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`7
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`

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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 14 of 27 PageID #: 5253
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`and is “directed to a non-abstract improvement in computer functionality, rather than the idea of
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`computer security writ large.” Id. at 1305.
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`
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`Viewed as a whole, the claims in this case, like those in Enfish, Ancora, Data Engine, Core
`
`Wireless, and Finjan are directed to a specific solution to a computer-functionality problem:
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`having to cease work in an electronic document in order to manually find related information in
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`another possibly-unfamiliar and difficult-to-access digital repository. To that end, the claims
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`require, among other things, analyzing the document for first information while the document is
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`being displayed, retrieving first information, and then searching outside the document for second
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`information related to the first information, which can then be inserted into the document or
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`otherwise used, e.g., to send an email or fax or to dial a phone number. See, e.g., Ex. 1, at claim 1;
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`Ex. 4, ’356 patent, at claim 1. Certain claims add limitations to the foregoing, such as performing
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`the analyzing step “without user designation” of the text to be analyzed or performing the search
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`following “a single execute command.” See, e.g., Ex. 2, at claim 1.
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`
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`The asserted claims are sufficiently specific and no more abstract than those that the
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`Federal Circuit held eligible in the decisions discussed above. In Ancora, the claimed method
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`disclosed “selecting a program,” “using an agent to set up a verification structure,” “verifying the
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`program using at least the verification structure,” and “acting on the program.” 908 F.3d at 1346.
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`In Finjan, the claimed steps were simply “receiving . . . a Downloadable,” “generating . . . a
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`security profile,” and “linking . . . [the] security profile to the Downloadable.” 879 F.3d at 1303.
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`These three- and four-step methods each provided “a specific technique that departs from earlier
`
`approaches to solve a specific computer problem,” Ancora, 908 F.3d at 1348, and “specific steps
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`. . . that accomplish a desired result,” Finjan, 879 F.3d at 1305. And in Core Wireless, the Court
`
`found eligible claims requiring a device configured to display “a menu listing one or more
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`applications” and “an application summary” that (a) can be reached directly from the menu and
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`(b) provides the ability to launch applications from a “selectable” list as defining a “particular
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`manner of summarizing and presenting information in electronic devices.” 880 F.3d at 1359-60,
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`1362.
`
`Comparing claim 12 in Data Engine to claim 1 of the ’843 patent confirms that the latter
`
`qualifies as “a specific solution to then-existing technological problems in computers” Data
`
`Engine, 906 F.3d at 1008, and not merely information handling writ large.
`
`Data Engine Claim 12
`12. In an electronic spreadsheet system for
`storing and manipulating information, a
`computer-implemented method of representing a
`three-dimensional spreadsheet on a screen
`display, the method comprising:
`
`displaying on said screen display a first
`spreadsheet page from a plurality of spreadsheet
`pages, each of said spreadsheet pages
`comprising an array of information cells
`arranged in row and column format, at least
`some of said information cells storing user-
`supplied information and formulas operative on
`said user-supplied information, each of said
`information cells being uniquely identified by a
`spreadsheet page identifier, a column identifier,
`and a row identifier;
`
`while displaying said first spreadsheet page,
`displaying a row of spreadsheet page identifiers
`along one side of said first spreadsheet page,
`each said spreadsheet page identifier being
`displayed as an image of a notebook tab on said
`screen display and indicating a single respective
`spreadsheet page, wherein at least one
`spreadsheet page identifier of said displayed row
`of spreadsheet page identifiers comprises at least
`one user-settable identifying character;
`
`receiving user input for requesting display of a
`second spreadsheet page in response to selection
`
`’843 Patent, Claim 1
`1. A computer-implemented method for
`finding data related to the contents of a
`document using a first computer program
`running on a computer, the method
`comprising:
`
`displaying the document electronically
`using the first computer program;
`
`while the document is being displayed,
`analyzing, in a computer process, first
`information from the document to
`determine if the first information is at least
`one of a plurality of types of information
`that can be searched for in order to find
`second information related to the first
`information;
`
`retrieving the first information;
`
`providing an input device, configured by
`the first computer program, that allows a
`user to enter a user command to initiate an
`operation, the operation comprising (i)
`performing a search using at least part of
`the first information as a search term in
`order to find the second information, of a
`specific type or types, associated with the
`search term in an information source
`external to the document, wherein the
`specific type or types of second
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`with an input device of a spreadsheet page
`identifier for said second spreadsheet page;
`
`in response to said receiving user input step,
`displaying said second spreadsheet page on said
`screen display in a manner so as to obscure said
`first spreadsheet page from display while
`continuing to display at least a portion of said
`row of spreadsheet page identifiers; and
`
`receiving user input for entering a formula in a
`cell on said second spreadsheet page, said
`formula including a cell reference to a particular
`cell on another of said spreadsheet pages having
`a particular spreadsheet page identifier
`comprising at least one user-supplied identifying
`character, said cell reference comprising said at
`least one user-supplied identifying character for
`said particular spreadsheet page identifier
`together with said column identifier and said row
`identifier for said particular cell.
`
`Just as claim 12 was directed to “a specific method for navigating through three-dimensional
`
`information is dependent at least in part on
`the type or types of the first information,
`and (ii) performing an action using at least
`part of the second information;
`
`in consequence of receipt by the first
`computer program of the user command
`from the input device, causing a search for
`the search term in the information source,
`using a second computer program, in order
`to find second information related to the
`search term; and
`
`if searching finds any second information
`related to the search term, performing the
`action using at least part of the second
`information, wherein the action is of a type
`depending at least in part on the type or
`types of the first information.
`
`electronic spreadsheets,” id., ’843 claim 1 is directed to a specific method of searching for and
`
`retrieving information while contemporaneously working in an electronic document. And, the
`
`steps in claim 12 are a collection of displaying certain information and receiving inputs, not unlike
`
`the steps in claim 1.
`
`Further, as in Core Wireless and Data Engine, the specification of the patents-in-suit notes
`
`the shortcomings of the prior art approaches and the advantages of the invention. In Core Wireless,
`
`the prior art approaches required the user to “scroll around,” “switch views,” and “drill down
`
`through many layers”; the invention was “clearly . . . directed to an improvement in the functioning
`
`of computers” because it spared users from having to navigate to, open, and then navigate within
`
`separate applications, thus enhancing efficiency. 880 F.3d at 1363; see also Data Engine, 906 F.3d
`
`at 1009 (invention eligible for similar efficiency enhancing benefits). The claimed inventions in
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`Case 1:13-cv-00919-LPS Document 139 Filed 08/13/19 Page 17 of 27 PageID #: 5256
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`this case provide increases in efficiency by eliminating the user’s need to stop working in a
`
`document residing in one computer program, switch to a different computer program, search for
`
`the necessary or related information in that program or external source, retrieve that information,
`
`and then return to the original computer program and input (or otherwise use) the information.
`
`And the claimed invention here provides these benefits “with a minimal number of user
`
`commands” and with “little to no training on the part of a user.” Ex. 1, at 9:51-54; see also Trading
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`Techs. Int’l, Inc. v. CQG, Inc., 675 F. App’x 1001 (Fed. Cir. 2017) (finding non-abstract claims
`
`that reduced the time it took to place and execute a trading order). The specification also reflects,
`
`as the specifications did in Core Wireless and Data Engine, that prior art approaches “were not
`
`user friendly” and “required users to master many complex and arbitrary operations.” See Ex. 1,
`
`at 1:43-49 (explaining that “information in the database must constantly be updated by the use