Term/Phrase/Clause
`
`Claims
`
`EXHIBIT A – All Four Asserted Patents
`
`U.S. Patent No. 7,170,519
`Preliminary Construction
`
`1, 5, 12, 14, 15,
`16, 17, 18, 20,
`21, 22, 25, 28,
`31, 32, 40, 41,
`42, 43, 44, 45,
`48, 50, 54, 56,
`57
`34, 54, 55, 56,
`58
`
`1, 6, 18, 33, 34,
`37, 46, 57, 58
`
`1, 2, 5, 6, 7, 8, 9,
`12, 13, 14, 15,
`16, 17, 28, 31,
`33, 34, 37, 38,
`39, 40, 41, 42,
`43, 44, 45, 50,
`54, 57,
`58
`5, 6, 7
`
`“graph style data item”
`
`“graph style data structure”
`
`“graph style metadata”
`
`“non‐textual format” //
`“non‐textual formatted
`output”
`
`“wherein the graph style
`data items include a second
`association between the
`statistical roles and the
`different variables”
`
`A data item which exists substantially
`independent of the application generating
`the data and the application generating the
`graphical output.
`
`A structure that uses a metadata approach
`whose abstraction is at a level above the
`particular type of graphic used to display
`the data.
`Metadata that is at a level above the
`particular type of graphic used to display
`the data and is used independent of the
`graphic type used to depict the data.
`Indefinite.
`
`
`
`Indefinite.
`
`
`
`
`Preliminary Identification of
`Extrinsic Evidence
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones regarding how it is not
`clear what non-textual format and
`non-textual formatted output
`means, and how the format and/or
`formatted output can be text.
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones regarding how it is
`unclear what is meant by graph
`style data items including a second
`
`SAS Institute Inc.
`EXHIBIT 2001
`Page 1 of 6
`
`
`
`Claims
`
`EXHIBIT A – All Four Asserted Patents
`
`U.S. Patent No. 7,170,519
`Preliminary Construction
`
`1, 5, 12, 14, 15,
`16, 17, 18, 20,
`21, 22, 25, 28,
`31, 32, 40, 41,
`42, 43, 44, 45,
`48, 50, 54, 56,
`57
`34, 54, 55, 56,
`58
`
`1, 6, 18, 33, 34,
`37, 46, 57, 58
`
`1, 2, 5, 6, 7, 8, 9,
`12, 13, 14, 15,
`16, 17, 28, 31,
`33, 34, 37, 38,
`39, 40, 41, 42,
`43, 44, 45, 50,
`54, 57,
`58
`5, 6, 7
`
`“graph style data item”
`
`“graph style data structure”
`
`“graph style metadata”
`
`“non‐textual format” //
`“non‐textual formatted
`output”
`
`“wherein the graph style
`data items include a second
`association between the
`statistical roles and the
`different variables”
`
`A data item which exists substantially
`independent of the application generating
`the data and the application generating the
`graphical output.
`
`A structure that uses a metadata approach
`whose abstraction is at a level above the
`particular type of graphic used to display
`the data.
`Metadata that is at a level above the
`particular type of graphic used to display
`the data and is used independent of the
`graphic type used to depict the data.
`Indefinite.
`
`
`
`Indefinite.
`
`
`
`
`Preliminary Identification of
`Extrinsic Evidence
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones regarding how it is not
`clear what non-textual format and
`non-textual formatted output
`means, and how the format and/or
`formatted output can be text.
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones regarding how it is
`unclear what is meant by graph
`style data items including a second
`
`SAS Institute Inc.
`EXHIBIT 2001
`Page 1 of 6
`
`
`
`37, 38, 39
`
`Indefinite.
`
`
`
`“wherein the graph style
`metadata identifies a data
`variable as having a
`category role and identifies
`another data variable as
`having a response role, said
`category role and said
`response role being used by
`in different output non-
`textual formats”
`
`“the graph generator
`module”
`
`34, 58
`
`35 U.S.C. § 112(6)
`§ 112(6) applies.
`
`Function: receives data to be displayed in a
`non-textual format; having data access to
`the graph style data structure; generating at
`least one graphical output based upon the
`received data
`
`Structure: None.
`
`
`association between the statistical
`roles and the different variables.
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones regarding this term
`regarding how it is unclear as to
`whether “said category role and
`said response role” are used
`“by”/“in” “different output non-
`textual formats.”
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones regarding the lack of
`corresponding structure for this
`term.
`
`
`
`Term/Phrase/Clause
`
`Claims
`
`U.S. Patent No. 7,447,686
`Preliminary Construction
`
`“a superset of the SQL
`standard”
`
`27, 28
`
`Indefinite
`
`Alternative Construction for “superset”: a
`set which includes another set or sets
`
`
`Preliminary Identification of
`Extrinsic Evidence
`Oxford Dictionary of English (3rd
`Ed.) (“superset”)
`
`Defendants reserve the right to rely
`on the expert testimony of Dr. Mark
`
`SAS Institute Inc.
`EXHIBIT 2001
`Page 2 of 6
`
`
`
`“wherein the switching of
`the association includes
`switching pointing of the
`first method to the second
`method for the first
`software driver”
`
`“wherein the first
`component software object
`is associated with a
`first method to textualize”
`
`“wherein a first software
`driver textualizes through a
`second method”
`
`45
`
`1
`
`1
`
`Indefinite.
`
`
`
`Indefinite.
`
`
`
`
`Indefinite.
`
`
`
`Jones regarding this term.
`
`Defendants reserve the right to rely
`on the expert testimony of Dr. Mark
`Jones regarding how it is not clear
`what it means to include switching
`pointing of the first method to the
`second method for first software
`driver.
`Defendants reserve the right to rely
`on the expert testimony of Dr. Mark
`Jones regarding how it is not clear
`what is meant by a first method to
`textualize.
`
`Defendants reserve the right to rely
`on the expert testimony of Dr. Mark
`Jones regarding how it is not clear
`how or if the first software driver
`textualizes through a second
`method at least because the claim
`also states that because of the
`switching of the association of the
`first component software object, the
`first component software object
`textualizes through the second
`method; that the patent discloses a
`driver overriding the method by
`which a component object
`textualizes but lacks written
`description support for a first
`software driver textualizing through
`a second method; and that
`
`SAS Institute Inc.
`EXHIBIT 2001
`Page 3 of 6
`
`
`
`“wherein a second software
`driver textualizes through a
`third method”
`
`1
`
`Indefinite.
`
`
`
`
`
`
`
`Term/Phrase/Clause
`
`Claims
`
`U.S. Patent No. 8,498,996
`Preliminary Proposed Construction
`
`“native” / “non-native”
`
`1, 2, 5, 6, 13, 19,
`20, 23, 24, 31,
`37, 38, 41, 42,
`48, 49
`
`Indefinite.
`
`
`
`the patent does not enable a first
`software driver textualizing through
`a second method.
`Defendants reserve the right to rely
`on the expert testimony of Dr. Mark
`Jones regarding how it is not clear
`how or if the second software
`driver textualizes through a third
`method; that the patent discloses a
`driver overriding the method by
`which a component object
`textualizes but lacks written
`description support for a second
`software driver textualizing through
`a third method; and that the patent
`does not enable a second software
`driver textualizing through a third
`method.
`
`
`
`Preliminary Identification of
`Extrinsic Evidence
`Defendants also reserve the right to
`rely on the expert testimony of Dr.
`Mark Jones regarding how a person
`of skill in the art would not
`understand this term, including
`because it is unclear what the term
`native means in this context and to
`what or in relation to what a native
`
`SAS Institute Inc.
`EXHIBIT 2001
`Page 4 of 6
`
`
`
`
`
`Term/Phrase/Clause
`
`Claims
`
`U.S. Patent No. 6,920,458
`Preliminary Construction
`
`“data model”
`
`“index structure”
`
`a set of attributes related to the run of a
`data mining application, including the
`name and location of the data set that was
`analyzed and the resulting analysis.
`
`A pre-determined structure within the
`model repository for storing and indexing
`the generated data models to allow search
`and retrieval of the generated data models.
`
`1, 2, 3, 4, 5,
`6, 9, 11, 12,
`14, 15, 24,
`25, 26, 27,
`28, 61, 63,
`64, 65, 66,
`67, 70, 72,
`73, 75, 76,
`85, 86, 87,
`88, 89
`1, 4, 5, 11,
`12, 14, 15,
`24, 26, 27,
`28, 61, 65,
`66, 72, 73,
`76, 87, 88,
`89
`
`
`
`“model repository facility”
`
`1, 3, 61, 64
`
`35 U.S.C. § 112(6)
`§ 112(6) applies.
`
`
`syntax is native to.
`
`Antonio Goncalves, Beginning Java
`EE 6 with GlassFish 3 (2nd Ed.
`2010) at 151-160.
`
`Preliminary Identification of
`Extrinsic Evidence
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones regarding the meaning
`of this term.
`
`SASPROD_WPL_EDTEX
`00393125;
`SASPROD_WPL_EDTEX
`00393448;
`SASPROD_WPL_EDTEX
`00393217
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones regarding the meaning
`of this term.
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`
`SAS Institute Inc.
`EXHIBIT 2001
`Page 5 of 6
`
`
`
`Function: exporting the generated data
`models to the model repository.
`
`Structure: Steps 112 through 141 of Figs.
`7A through 7C
`
`§ 112(6) applies.
`
`Function: building the index structures
`stored in the model repository.
`
`Structure: Figs. 8A through 8C
`
`
`Mark Jones regarding the meaning
`of this term, its function, and the
`corresponding structure, if any,
`described in the specification.
`
`Defendants reserve the right to rely
`on the expert testimony of Dr.
`Mark Jones regarding the meaning
`of this term, its function, and the
`corresponding structure, if any,
`described in the specification.
`
`“model repository facility”
`
`27, 88
`
`
`
`
`SAS Institute Inc.
`EXHIBIT 2001
`Page 6 of 6
`
`
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