Mirror Worlds, LLC v. Apple, Inc.

Filing 221

MOTION for Summary Judgment THAT THE ASSERTED CLAIMS OF U.S. PATENT NOS. 6,006,227, 6,638,313, 6,725,427 AND 6,768,999 ARE INVALID AS ANTICIPATED AND OBVIOUS by Apple, Inc.. (Attachments: #1 Text of Proposed Order, #2 Declaration of Jeffrey G. Randall in Support of Motion for Summary Judgment, #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, #18 Exhibit 16, #19 Exhibit 17, #20 Exhibit 18, #21 Exhibit 19, #22 Exhibit 20, #23 Exhibit 21, #24 Exhibit 22, #25 Exhibit 23, #26 Exhibit 24, #27 Exhibit 25, #28 Exhibit 26, #29 Exhibit 27, #30 Exhibit 28, #31 Exhibit 29)(Randall, Jeffrey)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 221 Att. 2

EXHIBIT 25

Dockets.Justia.com

EXHIBIT 25 Invalidity of U.S. Pat. No. 6,006,227 As Disclosed by Lucas Workscape Disclosure In its infringement contentions, Mirror Worlds has applied various claim limitations in an overly-broad manner, in an attempt to read those limitations on the accused products. See Ex. 13. While Apple disputes that approach, Apple has, for the purposes of this summary judgment motion, applied the same breadth of Mirror Worlds' infringement contentions to the prior art. Nothing in these disclosures should be interpreted as an acquiescence to or assertion of a particular claim construction by Mirror Worlds. The Lucas Workscape references include: · · · · · U.S. Patent No. 5,499,330 to Lucas et al. ("'330 patent") (Ex. 5.) Transcript of the Deposition of Peter Lucas, Ph.D. taken on June 16, 2010 ("Lucas Depo. Tr."). (Ex. 29.) "CHI '94 Video", which is a video that was publically disclosed at the CHI (computer-human interaction) conference in 1994. (Ex. 7.) Peter Lucas and Lauren Schneider, "Workscape: A Scriptable Document Management Environment," CHI '94 Conference Companion, pp. 9-10 (April 24-28, 1994). (Ex. 8.) Joseph M. Ballay, "Designing Workscape: An Interdisciplinary Experience," CHI '94 Conference, pp. 10-15 (April 24-28, 1994). (Ex. 9.)

'227 Patent Claim Language

See Lucas Depo. Tr. at 56:1-58:10; 170:13-172:4 for description of the relationship between publically disclosed references such as the CHI '94 Video and the '330 patent. See Lucas Depo. Tr. at 103:15-104:24 for discussion of the above listed "Workscape: A Scriptable Document Management Environment" publication. Emphasis is added in the disclosures below, unless otherwise indicated. Lucas Workscape describes a method which organizes each data unit received by or generated by a computer system. Support for organizing data units

13.

Claim 13 A method which organizes each data unit received by or generated by a computer system, comprising the steps of:

Disclosure · · · "Document display system for organizing and displaying documents as screen objects organized along strand paths" '330 patent at Tit le. "The system allows the user to organize and browse documents in an environment that resembles the real world of piles and papers" '330 patent at 1:52-54. "The project has the following specific design goals: First, to provide a single, uniform computer application, capable of presenting information to office workers without regard to the informat ion source or the form of its underlying representation. Second to define an interface paradigm which would permit users to organize and dealing meaningfully with hundreds of documents at once." CHI '94 Video at 1:12-1:37. Addit io nally, see e.g., Lucas Depo. Tr. at 14:25-16:21, 60:17-61:7, 93:8-20; 126:18-127:21.

'227 Patent Claim Language Claim construction order (Ex. 24):

Data unit = an item of information of significance to the user that the user considers as a unit.

·

Support for data units received by and from a computer system · "Whenever a new document is scanned, faxed or sent through electronic mail, and then subsequently fetched to a workspace, the system will annotate that document to indicate that it has not been read." '330 patent at 19:42-45. "The computer network that the system is connected to may have one repository available or it may have many. Some repositories are generic places to put documents, while others may be specialized. For example, a machine that sends and receives documents as faxes over telephone lines can be a repository. The user may choose to maintain a private repository on the local computer. Most repositories are on remote machines and the system gets documents from them over the network." '330 patent at 7:57-66. "Architecturally, Workscape employees a client server model between a user application known as the viewer and any number of network data repositories. The primary jo b of the viewer is to receive documents from repositories and render them in the user's workspace." CHI '94 Video at 4:44-5:02.

·

·

2

'227 Patent Claim Language · Addit io nally, see e.g., Lucas Depo. Tr. at 60:3-16; '330 patent at 8:24-29, 13:22-28, 18:30-42, Fig. 8, Fig. 14.

Disclosure

Support for data units generated by a computer system · "Certain tools generate small tag documents, which are attached to other documents as visual markers. The find tool placed a new tag on this e-mail message, since it's one that I haven't seen before. Since the tag is just a document, I can detach it from its parent and even drop it on another document." CHI '94 Video at 9:28-9:50. "Documents may be annotated using the sticker pad, which is a tool that generates small yellow documents with st icky backs." CHI '94 Video at 9:50-9:59. Addit io nally, see e.g., CHI '94 Video at 2:55-3:16, 10:52-11:30; Lucas Depo. Tr. at 40:8-41:2, 58:11-59:12; '330 patent at 4:43-48.

· ·

Lucas Workscape describes 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. Lucas Workscape describes generating streams using the FIND tool. The FIND tool is used to search repositories and/or the user's workspace(s). The documents retrieved from this FIND operation can be automatically time-ordered. Support for generating streams · "This is the find tool, whose purpose is to search for documents, either within the workspace or in network repositories. It contains an editable text field into which a user types a search expression. For instance, I may search for all documents of type e-mail and from Lee. It also contains a switch which activates the tool. As documents are found, they are gathered into a pile immediately behind the tool." CHI '94 Video at 7:38-8:09.

13A generat ing 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;

Claim construction order:

Stream = a time-ordered sequence of documents that functions as a diary

3

'227 Patent Claim Language of a person or an entity's electronic life and that is designed to have three main portions: past, present, and future

Disclosure

Main stream = a stream that is inclusive of every data unit, or document, received by or generated by the computer system time-ordering CHI '94 Video at 8:57. · Support for Past, Present, and Future Documents · A. "Q. Was there any capability to add documents with future dates to the front of the stack? Oh, of course, it made no difference at all. The dates were dates. If the most recent date were far into the future, it would still be the first one on the stack. But that made no difference whatsoever. There were also situations where the date had to be in the future, or at least in order to be useful, it did. There was a feature in Workscape called a reminder note, and it was a variant of the yellow sticky mechanism, which I described before, that had a field on it to put a date and time that the user wished to be reminded 4

Substream = a stream that is a subset of data units, or documents, yielded by a filter on a stream, the filter identifying certain documents within the stream

Addit io nally, see e.g., '330 patent at 9:8-13, 8:7-11, 1:57-61, 9:8-13, 8:51-53, 8:33-35, 9:26-29, Fig. 1; Lucas Depo. Tr. at 66:3-69:16.

'227 Patent Claim Language about something. And of course the only thing that would make sense would be for the date field of that to be in the future, at least initially... But again, I want to emphasize the generality of the architecture, dates are dates, past, present, or future." Lucas Depo. Tr. at 30:19-31:25. ·

Disclosure

"For example, the sticker pad has a control which can morph the notes it dispenses into one of three forms: A generic note, a reminder note, and a phone message form. Further, any Workscape document can be morphed into these forms simply by dropping it on the pad." CHI '94 Video at 11:40-12:00

CHI '94 Video at 11:50. · "Q. You also stated during the video: For example, the sticker pad has a control which can morph the notes it dispenses into one of three forms: A generic note, a reminder note and a phone message form. Further, any Workscape document can be morphed into these forms simply by dropping it on the pad. Can you describe again for me what a 5

'227 Patent Claim Language A. reminder note is. A reminder note was rendering of a document that had a script associated with it that would cause its date field, which would typically be a date in the future, a date and time in the future, to be constantly monitored. And the document would, by various techniques, bring itself to the user's attention when that future date and time arrived." Lucas Depo. Tr. at 87:3-20.

Disclosure

Support for a diary of a person or an entity's electronic life · See e.g., Lucas Depo. Tr. at 63:9-65:9.

Lucas Workscape describes generating a main stream. In particular, all documents are returned into a user's workspace when a wildcard search of a repository is performed using the FIND tool. The FIND tool also allows these search results to be time-ordered. Support for generating a main stream · "The find tool has many options, which are controlled by switches that are normally clipped away at the bottom of the tool. For example, I can indicate whether to search the workspace or a specific repository. In a further clip area are less frequently used controls, like those to specify the sort order o f documents within the pile." CHI '94 Video at 8:36-8:59.

6

'227 Patent Claim Language

Disclosure

time-ordering CHI '94 Video at 8:57. · "Each user may configure a special FIND tool (which serves as their IN BOX) that constantly watches the repositories for documents marked for their attention and brings them into their workspace. In this way, documents may be shared between users." '330 patent at 8:7-11. "Q. A. A. And how would you do that? I mean, is there a particular search query that could generate all of the documents from the repository? Yeah, typically -MR. SOLO: Objection, form. Typically there would be what at that time was called a wild card search, where I believe in the Digital systems of the time, you would use an asterisk, and an asterisk was a so-called wild card character that would match anything. So, if you simply did a search for, say, where the filter was give me every document named asterisk, it would conclude that you wanted all documents and would retrieve them all. 7

·

'227 Patent Claim Language Q. A. And what would happen once they were retrieved from Workscape, how would they be presented? Workscape was a highly scripted application, so is there is no single answer to that question. There could be a great number of different visual presentations. But what was fundamental was that the documents were always presented to the user in what we called a workspace, which is a three-dimensional virtual space rendered to the user that contained two dimensional representations of each document." Lucas Depo. Tr. at 23:18-24:19.

Disclosure

·

"Q.

A.

Back to the example of pulling all of the documents from the repository using the wild card search, could those be returned and displayed to the user in a temporal chronological order? Yes, one of the typical init ial visualizations in which search results were presented in Workscape was as a pile receding back into three dimensions. There was a technical device called a strand, which was basically a programming abstraction that we developed for this purpose. ... Very typically the standard way of displaying a search result was by creating a strand going straight back towards the back of the workspace and, therefore, presenting the documents in a pile. It was under the user control how the resulting documents were ordered. But typically the system would be configured to order them by date and time. 8

'227 Patent Claim Language So, for instance, you might have the most recently created documents in the front and the oldest documents in the box, although the user could just flip a switch, which would reverse that, and have the oldest documents in the front. I want to emphasize that that was by no means the only way that the documents could be arranged, but it was an extremely useful and a very common one." Lucas Depo. Tr. at 25:21-27:21. · "Q.

Disclosure

A. Q.

A. Q.

A.

Let me try this another way. Could a user use a wild card search query to retrieve all of those documents from that repository in the 1994 Workscape system? Yes. And all of those documents, including the texts, E-mails, pictures and the reminder notes, would be presented then to the user through the workspace user interface; isn't that correct? Workscape user, yes. I know Workscape, as of 1994, had lots of elegant features and functionality, but I again want to focus on the time-ordered sequencing of documents. Could a user use that wild card search function, query the repository and return all of the documents in a time-ordered sequence into Workscape? This may be splitting hairs, but they're not necessarily returned in a time-ordered sequence. They're returned in some sequence that's determined by the repository and then displayed in a time-ordered sequence. 9

'227 Patent Claim Language Q.

Disclosure

A.

Okay, fair enough. All of the documents from the repository would be returned and displayed to the user in the 1994 Workscape system in a time-ordered chronological sequence; is that correct? Correct. The only additional assumption is that the repository support wild card searches, which is typical. Lucas Depo. Tr. at 160:9-161:15.

Lucas Workscape describes generating at least one substream which contains data units only from the main stream. The FIND tool allows the user's workspace to be searched. The FIND tool also allows these search results to be time-ordered. Support for generating at least one substream which contains data units only from the main stream · "The find tool has many options, which are controlled by switches that are normally clipped away at the bottom of the tool. For example, I can indicate whether to search the workspace or a specific repository. In a further clip area are less frequently used controls, like those to specify the sort order of documents within the pile." CHI '94 Video at 8:36-8:59.

time-ordering 10

'227 Patent Claim Language CHI '94 Video at 8:57. · "Q.

Disclosure

A. Q.

A.

Q.

A. Q. A. Q.

So, now in Workscape, I would have all of the documents that were on the repository presented to the user through the viewer; correct? Yes. Now, if I wanted to perform that filtering search function, which we described earlier, to produce a sub-string of my wife's documents, how could I do that? There would have been many ways that that could have been done. I could have used the tag search tool to put a tag document on the ones that matched it. I could have used the find tool to filter it and create a separate pile and so on. The possible ways of splitt ing the results of that are limited only by the imagination of the scripter. But the things that I just mentioned could have been done out of the box. Terrific. So, using the 1994 Workscape system, then my wife could return -- strike that. Using the 1994 Workscape system, a user could filter and generate a sub-string of my wife's documents in a time-ordered sequence; is that correct? Sub-thread. Sub-thread? Yes. And those documents would be presented as a subset of the entire collection that existed on the repository; is that correct? 11

'227 Patent Claim Language A. Q. A. Q. A. Q. A. Q.

Disclosure

A. ·

Yes. And those could be displayed in the Workscape system as of 1994 also in a time-ordered sequence chronologically; is that correct? Yes. Do you recall we mentioned at the start of the example that those would include reminder notes? Do you recall that? Yes. I believe you testified earlier that reminder notes had the capability to include future dates; is that correct? By definit io n. By definit io n. So, both the original strand or sequence of documents that were presented to the user, and then the subset of documents that only relate to my wife's documents, would be including past, present and future documents; is that correct? Yes." Lucas Depo. Tr. at 161:16-163:17.

"As an alternative, the user requests that all mail messages received after a specified date be grouped in the foreground, and all others in the background. The knot 104 divides the two requested groups, and child documents 100a, 100b and 100c, in substrand 106, are those mail messages received after the specified date, and child documents 100d and 100e, in substrand 108, are those received prior to the specified date." '330 patent at 14:28-35. Addit io nally, see e.g., '330 patent at 9:66-10:7, 13:65-14:36; Lucas Depo. Tr. at 37:3-39:25.

·

13B

receiving data units from other computer systems;

Lucas Workscape describes receiving data units from other computer systems. Lucas Workscape discloses that data units may be received from other computer systems or "repositories," including computers that are networked. 12

'227 Patent Claim Language See "Support for data units received by and from a computer system" provided above in claim element 13. Lucas Workscape describes generating data units in the computer system. See "Support for data units generated by a computer system" provided above in claim element 13. Lucas Workscape describes selecting a timestamp to identify each data unit. Lucas Workscape describes that each data unit has associated with it attributes and attribute values. '330 patent at 2:62-65, 3:10-13. An attribute value could be among other things, a timestamp, such as a date. '330 patent at 4:3-7. Lucas Workscape describes that on each scanned data unit, a timestamp, such as a date, will be displayed. '330 patent at 4:46-48. Lucas Workscape allows the data stream to be ordered and identifiable chronologically. CHI '94 Video at 8:36-8:59, 10:52-11:30; '330 patent at 14:28-35. Support · · "All data are contained in documents. A document contains some number of attributes, each attribute having a name and a value." '330 patent at 2:62-65. "An attribute is a piece of data stored in a document. Each attribute has an attribute name and an attribute value. An attribute name uniquely identifies an attribute value within a document." '330 patent at 3:10-13. "The script language should be uniformly structured, in that the only storage entity (object) in the language is a document consisting of attribute/value pairs. Values may be atomic, such as strings, numbers, dates, or images, or they may be pointers (UID's) to other documents. Global objects may be stored as attributes in a universal "global" document which is visible to all scripts." '330 patent at 4:3-7. 13

Disclosure

13C generat ing data units in the computer system;

13D select ing a timestamp to identify each data unit;

Claim construction order:

Timestep to identify = a date and time value that uniquely identifies each document.

·

'227 Patent Claim Language · Date includes time

Disclosure "Each scanned document has an information sticker across its top displaying the name of the owner and the date it was scanned." '330 patent at 4:46-48.

CHI '94 Video at 8:34. Lucas Workscape describes associating each data unit with at least one chronological indicator having the respective timestamp. Lucas Workscape describes that each data unit has associated with it attributes and attribute values. '330 patent at 2:62-67, 3:10-13. An attribute value could be among other things, a timestamp, such as a date. '330 patent at 4:3-7. Lucas Workscape describes that on each scanned data unit, a timestamp, such as a date, will be displayed. '330 patent at 4:46-48. Lucas Workscape describes that the data stream is ordered and identifiable chronologically. CHI '94 Video at 8:36-8:59, 10:52-11:30; '330 patent at 14:28-35.

13E

associat ing each data unit with at least one chronological indicator having the respective timestamp;

Claim construction order:

Chronological indicator = a data structure containing at least a timestamp.

14

'227 Patent Claim Language Support · · See the support provided above for claim elements 13A and 13D. "This arranger tool, for example, is capable of organizing documents in free space according to users' specified criteria. For example, I can assign the X dimension to the To field and the Z dimension to creation date. Such mapping of document attributes to spatial dimensions can be a very powerful aid in visualizing patterns in a collection of documents." CHI '94 Video at 10:5211:30.

Disclosure

additional tool for timeordering CHI '94 Video at 11:11. · "As an alternative, the user requests that all mail messages received after a specified date be grouped in the foreground, and all others in the background. The knot 104 divides the two requested groups, and child documents 100a, 100b and 100c, in substrand 106, are those mail messages received after the specified date, and child documents 100d and 100e, in substrand 108, are those received prior to the specified date." '330 patent at 14:28-35.

13F

including each data unit according to the timestamp in the respective chronological

Lucas Workscape describes including each data unit according to the timestamp in the respective chronological indicator in at least the main stream. See disclosure provided above for claim element 13A. 15

Disclosure

Lucas Workscape describes maintaining streams of data units that are persistent streams. Support · "Each user may configure a special FIND tool (which serves as their IN BOX) that constantly watches the repositories for documents marked for their attention and brings them into their workspace." '330 patent at 8:7-10. "Q.

'227 Patent Claim Language indicator in at least the main stream; and 13G maintaining at least the main stream and the substreams as persistent streams.

Claim construction order: ·

Persistent streams = streams that are dynamically updated.

A.

In column 8 starting at line 7 through 11 -strike that. Column 8, starting at line 7 and continuing through line 11, it states: Each user may configure a special find tool (which serves as their in box) that constantly watches the repositories for documents marked for their attention and brings them into their workspace. Can you briefly describe what this means. It's the in box functionality that we referred to earlier. It is simply a find tool. The only way that it's special is that it's configured with a certain search query that filters documents that the user desires to have automatically brought into his or her workspace. So, for instance, new E-mail messages or documents that my secretary has scanned for me could be marked in the repository such that they would satisfy the criterion of the search that the special in box find tool is configured for. And the end result would be that these documents would automatically appear in my in box strand in a 16

'227 Patent Claim Language

Disclosure

Q. A.

Q. A.

way that's highly analogous to the way they would be brought into a physical in box in a traditional o ffice. Does this have any relationship to the persistence issue we discussed earlier? Yes, this search would be an example of a persistence search, because you want new documents that are created in the future to be subject to the operation. And you mentioned in your prior response automatic updating I believe. That's right, that's what persistence means, that the search doesn't just search for documents that exist at a particular period of time, but the search itself is ongoing, so that future documents would appear as well." Lucas Depo. Tr. at 101:13-103:2.

·

"For example, I can easily write a tool which runs all day, searching various data repositories for new information matching certain search criteria, gathers matching documents into a pile in my workspace, tags especially interesting ones with colored tags, forward certain ones to other users, etc." Workscape: A Scriptable Document Management Environment at p. 10. Addit io nally, see e.g., Lucas Depo. Tr. at 32:20-33:14, 40:1-17, 163:25-164:6.

·

14.

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

Lucas Workscape describes a method wherein each timestamp is selected from the group consisting of: past, present, and future times. Lucas Workscape describes the use of timestamps on data units. See the disclosure provided above for claim elements 13D, 13E, and 13F. Lucas Workscape describes generating a time-ordered stream of data units as shown above in claim element 13A. See "Support for Past, Present, and Future Documents" provided above for claim element 13A. 17

'227 Patent Claim Language

Disclosure

15. Support · ·

Claim 15 The method of claim 13, further comprising the step of displaying the streams on a display device as visual streams. Lucas Workscape describes displaying streams on a display device as visual streams. "Document Display System for Organizing and Displaying Documents as Screen Objects Organized as Screen Objects Organized Along Strand Paths" '330 patent at Title.

Claim construction order:

"The system displays documents eit her in a completely free-form, user controlled configuration or as strands, such that documents in a strand follow a strand path. The strand path is a two dimensional line through a three dimensional display space." '330 patent at 1:57-61. "The system uses a three dimensional workspace to provide a useful display of potentially thousands of documents. A workspace may display thousands of documents. In a preferred embodiment of a workspace, the workspace is wrapped at the edges, giving a fish-eye lens effect, so that every screen object that is not invisible has at least some portion of its rectangle within the screen display no matter what its position in the three dimensional workspace." '330 patent at 5:1421. "FIG. 1 shows a display device 10, including an example of a strand 15. The strand 15 is shown having child document screen objects 19a, 19b . . . 19e, and parent document screen object 17. The strand path is shown by line 20, and the mouse cursor is shown by element 21." '330 patent at 9:26-29.

Visual streams = a representation on a display device of a stream. ·

·

18

'227 Patent Claim Language

Disclosure

'330 patent at Fig. 1.

'330 patent at Fig. 3.

'330 patent at Fig. 5.

CHI '94 Video at 8:34.

19

'227 Patent Claim Language

Disclosure

CHI '94 Video at 11:16. · "In this demonstration the documents are first sorted in the depth dimension by date with the newest documents moving forward towards the viewer. Next, the documents are sorted in the x dimension by type, with, for example, email messages in one column, scan documents in another and so on." CHI '94 Video at 3:37-3:58.

See CHI '94 Video at 4:08. 20

'227 Patent Claim Language · See support provided above for Claim 15. Addit io nally, see e.g., CHI '94 Video at 2:55-3:16, 4:38; Lucas Depo. Tr. at 97:20-99:11.

Disclosure

Lucas describes 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. Support · "Other tools can be used to form interactive searches of documents along various dimensions. For instance, this date slider can be used to restrict the field of view to documents which were created within a specified range of dates." CHI '94 Video at 4:00-4:13.

Claim 16 16. The method of claim 15, wherein the step of displaying the streams further comprises the steps of: 16A 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

user selected interval o f time See CHI '94 Video at 4:21. 21

'227 Patent Claim Language

Disclosure

user selected interval o f time

See CHI '94 Video at 4:41. · In addition, users can specify certain subsets of documents to be displayed in "substrands." These substrands can be defined based on intervals of time, e.g., a substrand for "mail messages received after the specified date" or "received prior to the specified date." See '330 patent at 14:28-35, 9:6610:7, Fig. 9. "As an alternative, the user requests that all mail messages received after a specified date be grouped in the foreground, and all others in the background. The knot 104 divides the two requested groups, and child documents 100a, 100b and 100c, in substrand 106, are those mail messages received after the specified date, and child documents 100d and 100e, in substrand 108, are those received prior to the specified date." '330 patent at 14:28-35.

·

22

'227 Patent Claim Language

Disclosure

'330 patent at Fig. 9. · "Strand parents may further include a knot constraint, defining points in the strand that divide the strand into sub-strands. Knot constraints may be arbitrarily defined, and are generally invisible to the user. For example, knot constraints may be used to subdivide the strand into two sub-parts so that the user has a pile of mail that has been read, and a pile of new mail, both within a single strand. Knots are used to keep those sub-strands (or sub-piles) separated." '330 patent at 9:66-10:7.

16B

b) displaying the selected segments.

· Addit io nally, see e.g., Lucas Depo. Tr. at 71:19-73:11, 77:14-78:22. Lucas describes displaying selected stream segments. See support provided above for claim element 16A. Lucas Workscape describes a method in which each data unit can include textual data, video data, audio data and/or multimedia data. Support · "The project has the following specific design goals: First, to provide a single, uniform computer application, capable of presenting information to office workers without regard to the information source or the form of its underlying representation." CHI '94 Video at 1:12-1:28.

17.

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

23

'227 Patent Claim Language

Disclosure

See CHI '94 Video at 1:14. · "Workscape is a prototype office document management system designed to break the barriers between various types of electronic documents. It provides users with a common user interface for direct and scripted manipulation of information of heterogeneous forms and from diverse sources." Workscape: A Scriptable Document Management Environment at p. 9. "The disclosed system provides a similar, visually rich environment for handling documents with a computer system. Documents may be typed, scanned, or faxes sent by remote users." '330 patent at 1:49-52. "As an alternative, the user requests that all mail messages received after a specified date be grouped in the foreground, and all others in the background." '330 patent at 14:28-31. "Certain tools generate small tag documents, which are attached to other documents as visual markers. The find tool placed a new tag on this e-mail message, since it's one that I haven't seen before. Since the tag is just a document, I can detach it from its parent and even drop it on another document. Documents may be annotated using the sticker pad, which is a tool that generates small yellow documents with sticky backs. I can type a note on a sticker and then drop it onto any other document. The sticker will attach itself to the document, and then remain there until removed." CHI '94 Video at 9:28-10:10.

·

· ·

24

'227 Patent Claim Language

Disclosure

CHI '94 Video at 4:38. · Addit io nally, see e.g., Lucas Depo. Tr. at 61:21-63:8, 85:19-86:19, 91:12-93:7, 92:17-93:7.

See disclosure provided above for Claim 13. Lucas Workscape describes displaying data from one of the data units in abbreviated form. Lucas Workscape describes that alternative versions of the content of files can be displayed, including through use of its document renderers, which draw a rectangle of the screen object associated with each document in a workspace and which render the interior of each screen object. See '330 patent at 5:42-57. Lucas also discloses that a user can clip a document representation so as to restrict the viewable area of the screen object associated with that document in a view; clipping a document makes it look smaller without changing its position on the Z axis. See '330 patent at 19:26-33; CHI '94 Video at 6:26-6:53. Support · "The renderer process is performed by various specific renderers. A document renderer is that portion of the system that draws inside the rectangle of the screen object associated with each 25

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

'227 Patent Claim Language

Disclosure document in a workspace. The system supports multiple renderers, and which renderer is used for a particular document is determined by an attribute of that document. A workspace viewer is a process in the system responsible for outlining the screen objects of documents within the workspace and managing the display of selection indication. The interior of each screen object is rendered by its associated renderer, and the workspace viewer completes the view. The workspace viewer is also that part of the system which is responsible for maintaining the view of a workspace. That is, the workspace viewer contains the means for arranging documents in three-space." '330 patent at 5:42-57. · "To clip a document is to restrict the viewable area of the screen object associated with a document in a view. This may be done by dragging any edge of a screen object toward its center. Clipping makes documents look smaller without moving them back in the Z dimension. A clip stop constrains the clipping edge of a document such that it can only be clipped to a specified set of positions." '330 patent at 19:26-33. "Another primitive manipulation of documents is clipping. Dragging a document edge may clip the edge in, allowing the user to make the document smaller, while still being able to read it. These basic operations, X-Y dragging, Z dragging, and clipping constitute a basic vocabulary of actions, which may be applied to any kind of document, regardless of its underlying representation, or source on the network." CHI '94 Video at 6:26-6:53. "Q.

·

·

A.

I want to return to the rectangles that were presented to workspace on the Workscape viewer, were those abbreviated forms of the documents? MR. SOLO: Objection, form. Often they were, yes. It depends on the content of the document. If it was very simple, say an entry for a calendar, it might contain only the date. So, it could have been the entirety of the document. But more typically, if it was a multi-page scanned document or a long E-mail, then it would have to show some abbreviation, perhaps just the 26

'227 Patent Claim Language name, perhaps the first page. Again, as in everything else in the application, or almost everything else, it is under the control of the scripter. So, it's a very, very flexible approach." Lucas Depo. Tr at 34:5-22. · See disclosure provided above for Claim 13. Lucas Workscape describes archiving data units older than a specified time point. Lucas Workscape describes that documents could either be moved or copied to another storage medium (e.g. repository). By using the Lucas Workscape "Copy" tool, a user could archive data units having timestamps older than a specified time point. Support for archiving · A. Q. "Q. Addit io nally, see e.g., Lucas Depo. Tr. at 89:1-90:3, 165:16-166:5.

Disclosure

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

A.

Did the Workscape system provide for archiving of documents? What does that mean? Let me rephrase the question. Did the Workscape system provide a user with an interface that would permit him to move the documents from one repository to another repository? Yes. As I mentioned previously, there's a copy tool, and the copy tool would have been reconfigured as to which repository the copy went in, and therefore, by simply making a copy of the document using that copy tool directed towards a different repository, that 27

'227 Patent Claim Language operation could be accomplished." Lucas Depo. Tr. at 131:6-20.

Disclosure

Copy t o o l

"Designing Workscape: An Interdisciplinary Experience" at Fig. 4. · "Remo ving a document from the workspace may cause the document, and its permanent attributes to be written back to the repository." '330 patent at 20:23-26.

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