Mirror Worlds, LLC v. Apple, Inc.

Filing 135

RESPONSE in Opposition re #132 SEALED MOTION to Dismiss Apple's Inequitable Conduct Defenses and Counterclaims filed by Apple, Inc.. (Attachments: #1 Text of Proposed Order, #2 Affidavit of Sonal N. Mehta, #3 Exhibit 1, #4 Exhibit 2, #5 Exhibit 3, #6 Exhibit 4, #7 Exhibit 5, #8 Exhibit 6, #9 Exhibit 7, #10 Exhibit 8, #11 Exhibit 9, #12 Exhibit 10, #13 Exhibit 11, #14 Exhibit 12, #15 Exhibit 13, #16 Exhibit 14, #17 Exhibit 15)(Mehta, Sonal)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 135 Att. 15

EXHIBIT 13

Dockets.Justia.com

EXHIBIT G

Invalidity of U.S. Pat. No. 6,006,227

by Mander et al., A 'Pile' Metaphor for Supporting Casual Organization of Information, CHI '92
Based upon the claim interpretations Plaintiff appears to be asserting and the applications of those interpretations to Defendant's products in Plaintiff's Preliminary Infringement Contentions, Mander, Pile anticipates and/or renders obvious, alone or in combination with other prior art identified in Defendant's Preliminary Invalidity Contentions, the asserted claims as described in part below. Nothing in these contentions should be interpreted as an acquiescence to or assertion of a particular claim construction by Defendant. 12

Claim Language 1. A computer system which organizes each data unit received by or generated by the computer system, comprising: means for generating a main stream of data units and at least one substream, the main stream for receiving each data unit received by or generated by the computer system, and each substream for containing data units only from the main stream; means for receiving data units from other computer systems: means for generating data units by the computer system; means for selecting a timestamp to identify each data unit; means for associating each data unit with at least one chronological indicator having the respective timestamp; means for including each data unit according to the timestamp in the respective chronological indicator in the main stream; and means for maintaining the main stream and the substreams as persistent streams. See, e.g., pp. 627-628. See, e.g., p. 629.

Disclosure

See, e.g., p. 633. See, e.g., p. 627-629. See, e.g., p. 631; Fig. 6. See, e.g., p. 631; Fig. 6. See, e.g., pp. 628-629. See, e.g., p. 629; Fig. 3.

12 To the extent Mander, Pile is argued by Plaintiff or found by the Court not to explicitly teach certain limitations in the asserted claims, such limitations would have been

inherent and/or obvious as described in Defendant's Preliminary Invalidity Contentions.

Claim Language 2. The computer system of claim 1, wherein each timestamp is selected from the group consisting of: past, present, and future times.

Disclosure

3. The computer system of claim 1, wherein each data unit includes textual data, video data, audio data and/or multimedia data.

See, e.g., p. 633.

4. The computer system of claim 1, wherein the means for receiving further comprises means for receiving data units from the World Wide Web.

5. The computer system of claim 1, wherein said means for receiving further comprises means for receiving data units from a client computer. 6. The computer system according to claim 1, further comprising: means for displaying alternative versions of the content of the data units.

See, e.g., p. 633. See, e.g., p. 629; Figs. 1-2.

9. A computer system according to claim 1 further comprising: means for archiving a data unit associated with a timestamp older than a specified time point while retaining the respective chronological indicator and/or a data unit having a respective alternative version of the content of the archived data unit.

10. The computer system of claim 1, wherein the computer program further comprises: means for operating on any of the streams using a set of operations selected by a user.

See, e.g., Figs. 3-5.

11. The computer system of claim 1 further comprising:

See, e.g., p. 633.

2

Claim Language means to generate substreams from existing substreams.

Disclosure

12. A computer system as in claim l, further comprising: means for generating a data unit comprising an alternative version of the content of another data unit; and means for associating the alternative version data unit with the chronological indicator of the another data unit.

See, e.g., p. 629; Figs. 1-2. See, e.g., p. 629; Figs. 1-2.

13. A method which organizes each data unit received by or generated by a computer system, comprising the steps of: generating a main stream of data units and at least one substream, the main stream for receiving each data unit received by or generated by the computer system, and each substream for containing data units only from the main stream; receiving data units from other computer systems; generating data units in the computer system; selecting a timestamp to identify each data unit; associating each data unit with at least one chronological indicator having the respective timestamp; including each data unit according to the timestamp in the respective chronological indicator in at least the main stream; and maintaining at least the main stream and the substreams as persistent streams.

See, e.g., pp. 627-628. See, e.g., p. 629.

See, e.g., p. 633. See, e.g., p. 627-629. See, e.g., p. 631; Fig. 6. See, e.g., p. 631; Fig. 6. See, e.g., pp. 628-629. See, e.g., p. 629; Fig. 3.

14. The method of claim 13, wherein each timestamp is selected from the group consisting of." past, present, and future times.

15. The method of claim 13, further comprising the step of displaying the streams See, e.g., Figs. 1-2, 6.

Claim Language on a display device as visual streams.

Disclosure

16. The method of claim 15, wherein the step of displaying the streams further comprises the steps of: a) receiving from a user one or more indications of one or more selected segments of the streams corresponding to one or more selected intervals of time, and b) displaying the selected segments.

See, e.g., Figs. 1-2, 6. See, e.g., Fig. 6. See, e.g., Fig. 6.

17. The method of claim 13, wherein each data unit includes textual data, video data, audio data and/or multimedia data.

See, e.g., p. 633.

20. The method of claim 13 further comprising the step of: displaying data from one of the data units in abbreviated form.

See, e.g., p. 629; Figs. 1-2.

22. The method of claim 13, further comprising the step of: archiving data units having timestamps older than a specified time point.

25. A computer system for organizing each data unit received by or generated by the computer system, comprising: means for generating a main stream of data units and at least one substream, the main stream for receiving each data unit received by or generated by the computer system, and each substream for containing data units only from the main stream; means for associating each data unit with at least one chronological indicator having a respective timestamp which identifies the data unit;

See, e.g., pp. 627-628. See, e.g., p. 629.

See, e.g., p. 631; Fig. 6.

4

Claim Language means for including each data unit according to the timestamp in a respective chronological indicator in the main stream; means for maintaining the main stream and the substreams as persistent streams; means for representing one or more data units of a selected stream on a display device as document representations, each document representation including the timestamp of the respective data unit and the order of appearance of each data representation on the display device determined by the timestamp of the respective data unit; means for selecting which data units are represented on the display device by selecting one of the document representations and displaying document representations corresponding to data units having timestamps within a range of a timepoint; and means for selecting one or more of the document representations with a pointing device so that the data units represented by the selected document representations are further displayed with a second document representation comprising an alternative version of the content of the respective data unit. See, e.g., pp. 628-629. See, e.g., p. 629; Fig. 3. See, e.g., p. 629; Figs. 1-2, 6(a).

Disclosure

See, e.g., Fig. 6.

See, e.g., p. 629; Figs. 1-2.

26. A computer system as in claim 25, wherein the document representations form a visual stream having a three-dimensional effect.

See, e.g., Figs. 1-2, 6.

27. A computer system as in claim 26, wherein the three-dimensional effect further comprises a perspective view.

See, e.g., Figs. 1-2, 6.

28. A computer system as in claim 25, wherein each document representation See, e.g., Figs. 1-2, 6. comprises a polygon and the polygons overlap to form a visual stream of polygons.

29. A computer system as in claim 25, wherein the alternate version is an abbreviated version.

See, e.g., p. 629.