IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`In re Inter Partes Review of:
`U.S. Patent No. 7,170,519
`
`For: Computer‐Implemented System and
`Method for Generating Data Graphical
`Displays
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`DECLARATION OF STEPHEN GRAY
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`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`US Patent and Trademark Office
`PO Box 1450
`Alexandria, Virginia 22313-1450
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`I.
`II.
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`Table of Contents
`Introduction ..................................................................................................... 7
`Legal Understandings ..................................................................................... 9
`A.
`Legal Standard for Prior Art ................................................................. 9
`B.
`Legal Standards for Anticipation and Obviousness ............................. 9
`C.
`Legal Standards for Claim Construction ............................................ 14
`III. TECHNICAL BACKGROUND .................................................................. 19
`A.
`Internet and Web Technology ............................................................ 20
`B.
`HTTP .................................................................................................. 21
`C.
`Client-Server Computing ................................................................... 22
`D.
`Style Sheets ........................................................................................ 23
`E. Markup Language ............................................................................... 25
`IV. OVERVIEW OF THE CITED PRIOR ART ............................................... 26
`A. Davis (EX 1005) ................................................................................. 26
`B.
`Rousseeuw (Ex. 1008) ........................................................................ 30
`C.
`Excel (Ex. 1007) ................................................................................. 37
`D. Harold (Ex. 1006) ............................................................................... 48
`E.
`Krause (Ex. 1009) ............................................................................... 50
`V. OVERVIEW OF THE ‘519 PATENT ......................................................... 52
`VI. LEVEL OF ORDINARY SKILL ................................................................. 58
`VII. Claim Construction ....................................................................................... 58
` Means-Plus-Function Terms .............................................................. 58
`“data source generating means” – Claims 27 and 49 ......................... 59
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`“graph generator module” – Claims 34 .............................................. 61
`VIII. Application of the prior art to the claims ...................................................... 64
`IX. Claims 1-4, 12-18, 21, 27, 29, 30, 34-47, 49, 51-53, and 56 are
`obvious over Davis and Harold .................................................................... 65
`A. Motivation to Combine Davis and Harold ......................................... 65
`B.
`Analysis .............................................................................................. 66
`Claim 1 [pre] ...................................................................................... 66
`Claim element 1[a] ............................................................................. 68
`Claim element 1[b] ............................................................................. 72
`Claim element 1[c] ............................................................................. 73
`Claim element 1[d] ............................................................................. 79
`Claim element 1[e] ............................................................................. 79
`Claim element 1[f].............................................................................. 88
`Claims 2 and 3 .................................................................................... 91
`Claim 4 ............................................................................................... 93
`Claim element 5a ................................................................................ 97
`Claim element 5b .............................................................................. 101
`Claim element 5c .............................................................................. 104
`Claim 6 ............................................................................................. 107
`Claim 14 ........................................................................................... 109
`Claim 15 ........................................................................................... 111
`Claim 16 ........................................................................................... 115
`Claim 17 ........................................................................................... 116
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`Claim 18 ........................................................................................... 119
`Claim 21 ........................................................................................... 121
`Claim 27 ........................................................................................... 124
`Claim 29 ........................................................................................... 128
`Claim 30 ........................................................................................... 130
`Claim 34 ........................................................................................... 130
`Claims 35-38 and 42-46, and 49 ...................................................... 137
`Claim 47 ........................................................................................... 140
`Claim 39 ........................................................................................... 140
`Claim 51 ........................................................................................... 141
`Claims 52 and 53 .............................................................................. 144
`Claim 56 ........................................................................................... 148
`Claims 22-26 are obvious in view of Davis, Rousseeuw, and Krause ....... 148
`A. Motivation to Combine Davis/Harold with Rousseeuw and
`Krause ............................................................................................... 148
`Analysis ............................................................................................ 162
`Claim 22 ........................................................................................... 162
`Claim 23 ........................................................................................... 165
`Claim 24 ........................................................................................... 166
`Claim 25 ........................................................................................... 167
`Claim 26 ........................................................................................... 167
`XI. Claims 7-11 are obvious in view of Davis in view of excel ....................... 168
`A. Motivation to Combine Davis/Harold and Excel2000 ..................... 168
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`X.
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`B.
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`Claim element 7[a] ........................................................................... 173
`Claim element 7[b] ........................................................................... 175
`Claim element 7[c] ........................................................................... 176
`Claim 8 ............................................................................................. 183
`Claim 9 ............................................................................................. 183
`Claim 10 ........................................................................................... 184
`Claim 11 ........................................................................................... 184
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`LIST OF EXHIBITS
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`1001 U.S. Patent No. 7,170,519 to Patel (“the ’519 Patent”)
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`1002 CV of Stephen Gray
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`1003
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`1004
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`Expert Declaration of Stephen Gray
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`File History of U.S. Patent No. 7,170,519 to Patel
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`1005 U.S Patent No. 6,920,608 to Davis (“Davis”)
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`1006
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`XML Bible by Elliotte Rusty Harold (“Harold”)
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`1007 Microsoft Excel 2000 Bible by John Walkenbach (“Excel”)
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`1008
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`1009
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`1010
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`1011
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`Robust Regression and Outlier Detection by Peter Rousseeuw et al.
`(“Rousseeuw”)
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`The Basics of S and S-Plus by Andreas Krause et al. (“Krause”)
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`Reserved
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`SAS Institute Inc.’s Preliminary Claim Constructions and Extrinsic
`Evidence Pursuant to P.R.4-2
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`I, Stephen Gray, hereby declare and state as follows:
`
`I.
`1.
`
`INTRODUCTION
`I have been retained as a technical consultant on behalf World Programming
`
`Ltd., the petitioner in the present proceeding, and I am being compensated at my
`
`usual and customary hourly rate. I understand that the petition names World
`
`Programming Ltd. (“WPL”) as the real party-in-interest. I have no financial interest
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`in, or affiliation with, the petitioner, real party-in-interest, or the patent owner, which
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`I understand to be SAS Institute, Inc. (“SAS”). My compensation is not dependent
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`upon the outcome of, or my testimony in, the present inter partes review or any
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`litigation proceedings.
`
`2.
`
`I have reviewed each of the following, among other materials:
`
` The list of exhibits cited in my report; and
`
` The documents cited as background references in the Technical
`
`Background Section (III) of my report below.
`
`3.
`
`I understand that SAS Technologies has accused WPL of infringing U.S.
`
`Patent No. 7,170,519 in a matter captioned SAS Institute, Inc., v. World
`
`Programming Ltd. Et. Al; C.A. No. 2:18-cv-00295-JRG.
`
`4.
`
`I understand that the application leading to the issuance of the ‘519 was a
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`provisional application Ser. No. 60/368,896 titled “COMPUTER-IMPLEMENTED
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`SYSTEM AND METHOD FOR REPORT GENERATION” filed March 29, 2002.
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`Thus, for the purposes of my analysis, I assume the time of the purported invention
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`to be March 29, 2002 and I have provided an overview of the technical background
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`by March 2002.
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`5. My background, qualifications, and experience relevant to the issues in this
`
`proceeding are summarized below. My curriculum vitae is identified in the Petition
`
`as EX 1002.
`
`6.
`
`Since the mid-1970s, I have designed, developed, and deployed computing
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`systems and products that operate in server, client, and graphical user interface
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`environments. As such, I have acquired expertise and am an expert in the areas of
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`distributed computing architecture and design, graphical user interfaces, website
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`platforms, eCommerce systems, image processing systems, operating systems, local
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`area and wide area networks, and various programming languages used in the
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`development of those systems and products. I have been employed by or retained as
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`a consultant, including acting as a litigation consultant, for numerous companies
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`such as Burroughs, Facebook, Filenet, Fujitsu, Marriott Corporation, IBM,
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`Microsoft, MCI, Northern Telecom, Olivetti, TRW, and Xerox, and others.
`
`7.
`
`I have several relevant professional experiences that demonstrate my expertise
`
`in the field of graphical user interfaces, client-server website platforms, and
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`eCommerce systems. For example, in 2001 to 2002, as Chief Technology Officer
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`for Networld Exchange Inc., I was responsible for the design, development and
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`deployment of a suite of products that delivered eCommerce functions. These
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`functions were provided over the Internet and included product catalog information
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`display, purchase and/or purchase order creation, order delivery to fulfillment
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`systems, and order status reporting. The products that I had responsibility for
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`provided an electronic shopping graphical user interface for business-to-business
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`and business-to-consumer transactions. The systems were designed to support both
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`vendors of products as well as customers. Each of these user interfaces were an
`
`optimization based on the specific user class.
`
`II.
`
`8.
`
`LEGAL UNDERSTANDINGS
`A. Legal Standard for Prior Art
`I understand that an issued U.S. patent also qualifies as prior art to a
`
`challenged patent if the application for that patent was filed in the United States
`
`before the invention of the challenged patent. I understand that a, book, article
`
`published in a magazine or trade publication similarly is prior art to a challenged
`
`patent if the publication occurs before the date of invention, or more than one year
`
`before the effective filing date of the challenged patent (again, more than one year
`
`before April 15, 2002, with regard to the ’519 patent). I understand that to qualify as
`
`prior art, a reference must contain an enabling disclosure that allows one of ordinary
`
`skill to practice the claims without undue experimentation.
`
`B.
`Legal Standards for Anticipation and Obviousness
`I understand that a patent claim is anticipated when a single piece of prior art
`
`9.
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`describes every element of the claimed invention, either expressly or inherently,
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`arranged in the same way as in the claim. For inherent anticipation to be found, it is
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`required that the missing descriptive material is necessarily present in the prior art.
`
`I understand that, for the purpose of an inter partes review, prior art that anticipates
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`a claim can include both patents and printed publications from anywhere in the
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`world.
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`10.
`
`I understand that a patent claim is unpatentable and invalid if the subject
`
`matter of the claim as a whole would have been obvious to a person of ordinary skill
`
`in the art of the claimed subject matter as of the time of the invention at issue. I
`
`understand that the following factors must be evaluated to determine whether the
`
`claimed subject matter is obvious: (1) the scope and content of the prior art; (2) the
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`difference or differences, if any, between each claim of the patent and the prior art;
`
`and (3) the level of ordinary skill in the art at the time the patent was filed. Unlike
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`anticipation, which allows consideration of only one item of prior art, I understand
`
`that obviousness may be shown by considering more than one item of prior art.
`
`Moreover, I have been informed and I understand that so-called objective indicia of
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`non-obviousness, also known as “secondary considerations,” like the following are
`
`also to be considered when assessing obviousness: (1) commercial success; (2) long-
`
`felt but unresolved needs; (3) copying of the invention by others in the field; (4)
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`initial expressions of disbelief by experts in the field; (5) failure of others to solve
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`the problem that the inventor solved; and (6) unexpected results. I also understand
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`that evidence of objective indicia of non-obviousness must be commensurate in
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`scope with the claimed subject matter.
`
`11.
`
`I understand that evidence of a motivation to combine references may come
`
`from a suggestion, teaching, or motivation to combine prior art references found in
`
`the references themselves and may also come from the direction of the marketplace.
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`12.
`
`I understand that if a technique has been used to improve one device or
`
`method, and a person of ordinary skill in the art would recognize that it would
`
`improve similar devices or methods in the same way, using the technique is obvious
`
`unless its actual application is beyond his or her skill.
`
`13.
`
`I also understand that practical and common-sense considerations should
`
`guide a proper obviousness analysis, because familiar items may have obvious uses
`
`beyond their primary purposes. I further understand that a person of ordinary skill in
`
`the art looking to overcome a problem will often be able to fit the teachings of
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`multiple publications together like pieces of a puzzle, although the prior art need not
`
`be like two puzzle pieces that must fit perfectly. I understand that obviousness
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`analysis therefore takes into account the inferences and creative steps that a person
`
`of ordinary skill in the art would employ under the circumstances.
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`14.
`
`I understand further that a particular combination may be proven obvious by
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`showing that it was obvious to try the combination. For example, when there is a
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`design need or market pressure to solve a problem and there are a finite number of
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`identified, predictable solutions, a person of ordinary skill has good reason to pursue
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`the known options within his or her technical grasp because the result is likely the
`
`product not of innovation but of ordinary skill and common sense.
`
`15.
`
`I understand that the combination of familiar elements according to known
`
`methods may be proven obvious when it does no more than yield predictable results.
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`When a work is available in one field of endeavor, design incentives and other
`
`market forces can prompt variations upon it, either in the same field or a different
`
`one. I understand that if a person of ordinary skill can implement a predictable
`
`variation, obviousness likely bars its patentability.
`
`16.
`
`It is also my understanding that there are additional considerations that may
`
`be used for further guidance as to when a claim is obvious, including the following:
`
` the claimed invention is a simple substitution of one known element for
`another to obtain predictable results;
`
` the claimed invention uses known techniques to improve similar
`devices or methods in the same way;
`
` the claimed invention applies a known technique to a known device or
`method that is ready for improvement to yield predictable results; and
`
` there existed at the time of invention a known problem for which there
`was an obvious solution encompassed by the patent’s claims.
`It is also my understanding that a proper obviousness analysis focuses on what
`
`17.
`
`was known or obvious to a hypothetical person of ordinary skill in the art at the time
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`of the invention, not just the patentee. Accordingly, I understand that any need or
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`problem known in the field of endeavor at the time of invention and addressed by
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`the patent can provide a reason for combining the elements in the manner claimed.
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`18.
`
`I understand that a claim can be obvious in light of a single reference, without
`
`the need to combine references, if the elements of the claim that are not found
`
`explicitly or inherently in the reference can be supplied by the common sense of one
`
`of ordinary skill in the art.
`
`19.
`
`I understand that a person of ordinary skill could have combined two pieces
`
`of prior art or substituted one prior art element for another if the substitution can be
`
`made with predictable results, even if the swapped-in element is different from the
`
`swapped-out element. In other words, the prior art need not be like two puzzle pieces
`
`that must fit perfectly together. The relevant question is whether prior art techniques
`
`are interoperable with respect to one another, such that that a person of skill would
`
`view them as a design choice, or whether a person of skill could apply prior art
`
`techniques into a new combined system.
`
`20.
`
`In sum, my understanding is that prior art teachings are properly combined
`
`where a person of ordinary skill in the art having the understanding and knowledge
`
`reflected in the prior art and motivated by the general problem facing the inventor,
`
`would have been led to make the combination of elements recited in the claims.
`
`Under this analysis, the prior art references themselves, or any need or problem
`
`known in the field of endeavor at the time of the invention, can provide a reason for
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`combining the elements of multiple prior art references in the claimed manner.
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`21.
`
`I have been informed and understand that the obviousness analysis requires a
`
`comparison of the properly construed claim language of each claim to the prior art
`
`on a limitation-by-limitation basis.
`
`22.
`
`I have been formed that when a claim is expressed in so-called “Markush
`
`form” using the style typically expressed as “a member selected from the group
`
`consisting of A, B, and C,” that the entire element is disclosed by the prior art if one
`
`alternative among the set (e.g. A, B, C) in the Markush group is found in the prior
`
`art.
`
`23.
`
`C. Legal Standards for Claim Construction
`I have been instructed by counsel on the law regarding claim construction and
`
`patent claims, and I understand that a patent may include two types of claims,
`
`independent claims and dependent claims. As noted above, I understand that an
`
`independent claim stands alone and includes only the limitations it recites. A
`
`dependent claim can depend from an independent claim or another dependent claim.
`
`I understand that a dependent claim includes all the limitations that it recites in
`
`addition to all the limitations recited in the claim from which it depends.
`
`24.
`
`It is my understanding that claim terms of are given the meaning the terms
`
`would have to a person of ordinary skill in the art at the time of the Invention, in
`
`view of the specification and file history.
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`25.
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`In comparing the claims of the ’686 Patent to the prior art, I have carefully
`
`considered the ’686 Patent and its file history in light of the understanding of a
`
`person of ordinary skill at the time of the alleged invention.
`
`26.
`
`I understand that to determine how a person of ordinary skill would
`
`understand a claim term, one should look to those sources available that show what
`
`a person of skill in the art would have understood the claim language to mean. Such
`
`sources include the words of the claims themselves, the remainder of the patent’s
`
`specification, the prosecution history of the patent (all considered “intrinsic”
`
`evidence), and “extrinsic” evidence concerning relevant scientific principles, the
`
`meaning of technical terms, and the state of the art at the time of the invention.
`
`27.
`
`I understand that, in construing a claim term, one looks primarily to the
`
`intrinsic patent evidence, including the words of the claims themselves, the
`
`remainder of the patent specification, and the prosecution history.
`
`28.
`
`I understand that extrinsic evidence, which is evidence external to the patent
`
`and the prosecution history, may also be useful in interpreting patent claims when
`
`the intrinsic evidence itself is insufficient.
`
`29.
`
`I understand that words or terms should be given their ordinary and accepted
`
`meanings unless it appears that the inventors were using them to mean something
`
`different. In making this determination, the claims, the patent specification, and the
`
`prosecution history are of paramount importance. Additionally, the specification and
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`prosecution history must be consulted to confirm whether the patentee has acted as
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`its own lexicographer (i.e., provided its own special meanings for particular terms),
`
`or intentionally disclaimed, disavowed, or surrendered any claim scope.
`
`30.
`
`I understand that the claims of a patent define the scope of the rights conferred
`
`by the patent. The claims particularly point out and distinctly claim the subject
`
`matter that the patentee regards as his invention. Because the patentee is required to
`
`define precisely what he claims his invention to be, it is improper to construe claims
`
`in a manner different from the plain import of the terms used consistent with the
`
`specification. Accordingly, a claim construction analysis must begin and remain
`
`centered on the claim language itself. Additionally, the context in which a term is
`
`used in a challenged claim can be highly instructive. Likewise, other claims of the
`
`patent in question, both challenged and un-challenged, can inform the meaning of a
`
`claim term. For example, because claim terms are normally used consistently
`
`throughout a patent, the usage of a term in one claim can often illuminate the
`
`meaning of the same term in other claims. Differences among claims can also be a
`
`useful guide in understanding the meaning of particular claim terms. I understand
`
`that a dependent claim must further limit the claim from which it depends.
`
`31.
`
`I understand that the claims of a patent define the purported invention. I
`
`understand that the purpose of claim construction is to understand how one skilled
`
`in the art would have understood the claim terms at the time of the purported
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`invention.
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`32.
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`I understand that a person of ordinary skill in the art is deemed to read a claim
`
`term not only in the context of the particular claim in which the disputed term
`
`appears, but in the context of the entire patent, including the specification. For this
`
`reason, the words of the claim must be interpreted in view of the entire specification.
`
`The specification is the primary basis for construing the claims and provides a
`
`safeguard such that correct constructions closely align with the specification.
`
`Ultimately, the interpretation to be given a term can only be determined and
`
`confirmed with a full understanding of what the inventors actually invented and
`
`intended to envelop with the claim as set forth in the patent itself.
`
`33.
`
`I understand that it is improper to place too much emphasis on the ordinary
`
`meaning of the claim term without adequate grounding of that term within the
`
`context of the specification of the challenged patent. Hence, claim terms should not
`
`be broadly construed to encompass subject matter that is not supported when the
`
`claims are read in light of the invention described in the specification. Art
`
`incorporated by reference or otherwise cited during the prosecution history is also
`
`highly relevant in ascertaining the breadth of claim terms.
`
`34.
`
`I understand that the role of the specification is to describe and enable the
`
`invention. In turn, the claims cannot be of broader scope than the invention that is
`
`set forth in the specification. Care must be taken to avoid defining a claim as a series
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`of words that, when removed from the context of the patent, leads to an overall result
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`that departs significantly from the patented invention.
`
`35.
`
`I understand that claim terms must be construed in a manner consistent with
`
`the context of the intrinsic record. In addition to consulting the specification, one
`
`should also consider the patent’s prosecution history, if available. The prosecution
`
`file history provides evidence of how both the Patent Office and the inventors
`
`understood the terms of the patent, particularly in light of what was known in the
`
`prior art. Further, where the specification describes a claim term broadly, arguments
`
`and amendments made during prosecution may require a narrower interpretation.
`
`36.
`
`I understand that while intrinsic evidence is of primary importance, extrinsic
`
`evidence—that is, all evidence external to the patent and prosecution history,
`
`including expert and inventor testimony, dictionaries, and learned treatises—can
`
`also be considered. For example, technical dictionaries may help one better
`
`understand the underlying technology and the way in which one of skill in the art
`
`might use the claim terms. Extrinsic evidence should not be considered, however,
`
`divorced from the context of the intrinsic evidence. Evidence beyond the patent
`
`specification, prosecution history, and other claims in the patent should not be relied
`
`upon unless the claim language is ambiguous in light of these intrinsic sources.
`
`Furthermore, while extrinsic evidence can shed useful light on the relevant art, it is
`
`less significant than the intrinsic record in determining the legally operative meaning
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`of claim language.
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`37.
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`I understand that in general, a term or phrase found in the introductory words
`
`of the claim, also known as the preamble of the claim, should be construed as a
`
`limitation if it recites essential structure or steps, or is necessary to give life,
`
`meaning, and vitality to the claim. Conversely, a preamble term or phrase is not
`
`limiting where a patentee defines a structurally complete invention in the claim body
`
`and uses the preamble only to state a purpose or intended use for the invention. In
`
`making this distinction, I understand that one should review the entire patent to gain
`
`an understanding of what the inventors claim they actually invented and intended to
`
`encompass by the claims.
`
`38.
`
`I understand that language in the preamble limits claim scope (i) if dependence
`
`on a preamble phrase for antecedent basis (i.e., the body of the claim refers back to
`
`words in the preamble) indicates a reliance on both the preamble and claim body to
`
`define the claimed invention; (ii) if reference to the preamble is necessary to
`
`understand limitations or terms in the claim body; or (iii) if the preamble recites
`
`additional structure or steps that the specification identifies as important.
`
`III. TECHNICAL BACKGROUND
`39. Below I have included information that provides a technical background and
`
`a state of the art around and before March 2002 that can be helpful in understanding
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`technical aspects of my analyses and provides an overview of the technology at issue
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`in this matter. This overview also provides what I believe to have been the general
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`understanding of a person of ordinary skill in the art around and before March 2002,
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`when the earliest application to which the ‘519 Patent claims priority was filed.
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`A.
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`Internet and Web Technology
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`40. The Internet is a worldwide network comprised of interconnected computer
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`networks. Various types of computing devices connected to the Internet can
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`exchange data, for example, in emails, text documents, video files, and audio files.
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`There are various services that can be implemented over the Internet, including e-
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`mail, file transfer, remote computer control, newsgroups, online games, and
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`financial transactions. The Internet Engineering Task Force (IETF) is an open body
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`concerned with the evolution of the Internet architecture and the smooth operation
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`of the Internet. I also refer to various Requests for Comments (RFCs), which are
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`technical documents about the Internet that are edited by the RFC Editor.
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`41. A major feature of the Internet is the World Wide Web or “WWW,” which
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`uses hypertext to link documents located on different domain names together
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`through the use of Uniform Resource Locators (URLs). An important protocol used
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`in the Web is the Hypertext Transfer Protocol (HTTP), which is used to transfer data
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`over the Internet’s World Wide Web. HTTP generally operates using hardware and
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`software devices called clients and servers. At the time of the alleged invention, one
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`type of client device that was widely used to access web servers was the personal
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`computer.
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`42. A website is a collection of web pages which are digital files commonly
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`written using HyperText Markup Language (HTML). The HTML standard allows
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`for the retrieval of resources from multiple URLs and thus potentially different
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`servers. A website can be “hosted” on website servers connected to the Internet. The
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`website server can store and provide access to the website for users.
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`B. HTTP
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`43. The Hypertext Transfer Protocol (“HTTP”) is a request-response protocol.
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`C