Mirror Worlds, LLC v. Apple, Inc.

Filing 251

RESPONSE in Opposition re 229 MOTION for Summary Judgment OF INVALIDITY OF US PATENT NO. 6,613,101 filed by Apple, Inc.. (Attachments: # 1 Text of Proposed Order, # 2 Declaration of Steven K. Feiner Ph.D., # 3 Exhibit 1 to Declaration of Steven K. Feiner Ph.D., # 4 Declaration of Jeffrey G. Randall in Opposition to Motion for Summary Judgment, # 5 Exhibit 1 to Randall Declaration, # 6 Exhibit 2 to Randall Declaration, # 7 Exhibit 3 to Randall Declaration, # 8 Exhibit 4 to Randall Declaration, # 9 Exhibit 5 to Randall Declaration, # 10 Exhibit 6 to Randall Declaration, # 11 Exhibit 7 to Randall Declaration, # 12 Exhibit 8 to Randall Declaration, # 13 Exhibit 9 to Randall Declaration, # 14 Exhibit 10 to Randall Declaration, # 15 Exhibit 11 to Randall Declaration, # 16 Exhibit 12 to Randall Declaration)(Randall, Jeffrey)

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Mirror Worlds, LLC v. Apple, Inc. Doc. 251 Att. 13 Randall Declaration Exhibit 9 Dockets.Justia.com 1 04860.P624 Ute l!. 5 1~Y3 IN THE UNITED STATES PATENT AND TRADEMARtiiS1#fflidJl! Filed: April 30, 1992 For: METHOD AND APPARATUS FOR ORGANIZING INFORMATION IN A COMPUTER SYSTEM RESPONSE TO OFFICE ACTION Commissioner of Patents and Trademarks Washington, D.C. 20231 Sir: In response to the Office Action mailed June 3, 1993, please enter the following amendments and consider the following remarks. r f I m 111, r (/ i / ' 1;q'L} / iff IN THE TITLE Please delete the present title and insert the following title: Method and Apparatus for Organizing Information into Collections of Documents and for Viewing Documents in a Computer System. IN THE SPECIFICATION j .~ Immediately ~I 0"'-- ~~r.0 before the penod on Ime-28-of page 48, please add the ~I following--and which is now U.S. Patent No. 5,202,828--. IN THE CLAIMS 1\ W./j~t?1 )'dr (Amend ). A method for organizing information in a computer display device and a first plurality of documents, said filing system having method comprising : -1- 724 FH 176 APMW0025487 [providl graphical representatio ] displaying at some time on said display device a of a first document and a graphical representation of a second document from sal first plurality of documents; creating a colle ion of documents comprising a second plurality of documents having said first doc ment and said second document; representation of said collection of documents on said display device; ocuments in said collection by displaying an indicia of said at least one d r~Y,1( t f> 1 37 (Amen d). A method for organizing information in a computer system having a dis y device, said method comprising: . .. . a [providing" representation of a first do ument and a representation of a second document; ion of documents comprising said first and said second documents; displaying a represe tation of said collection of documents; and. determining a represe ation of said collection when a third document is added to said collection b sed on one of: (a) an internal representation of each of the documents in said collection, and (b) a user defined specification. ~ c!?-~6 "1# , (Amended). A computer filing system for organizing information in processor, a bus, and memory for storing a computer system having information including a pluralit of documents, said computer filing system comprising: a display means for oducing a display of graphical representations, said display means oupled to said processor; a cursor control means co pled to said processor, said cursor control means for controlling the position f a cursor on said display; -2- 724 FH 177 APMW0025488 a s itch means for indicating a selection of an object displayed on said display, said s itch means coupled to said processor and having a first and a second positio . epresentation of a first document and a graphical representation of a second ocument, said cursor control means and said said graphical representations of said first and said second documents collection of documents comprisin a means for creating a raphical representation of said collection of documents comprising said first an said second document; and a means for determining a presentation of said collection, said to create a means for determining providing a represe tation based on an internal representation of said first and said second REMARKS The Examiner rejected certain claims under 112, first paragraph. These rejections have been noted, and the claims have been amended to overcome these rejections. The rejections concerning "providing" and "and" have been addressed by amending the pertinent claims. The Examiner's comments concerning lines 7-8 of claim 1 have been noted. It is submitted that no amendment is necessary because the claim is not ambiguous. It is true that there are two pluralities of documents, a first plurality of documents and a second plurality of documents. However, it is clear that the first and second documents are in both the first plurality of documents and the second plurality of documents. It is noted that the first plurality of documents may contain other documents which are not in the second plurality of documents and vice versa. Concerning claim 66, the Examiner has stated that lines 11-14 are "considered to be unclear." It is submitted that with the present amendment, these lines are now clear in that the graphical representations of the first and second documents are displayed on a display device which is part of the computer filing system. Thus, these graphical representations are indeed -3- 724 FH 178 APMW0025489 presented by being displayed on the display device. It is noted that the representation of the collection as required in the last subparagraph of this claim 66 is a representation that need not be displayed. This representation has been described in various ways, including for example, the vector representation of a collection of documents. It is submitted that in view of the specification, claim 66 is not ambiguous or "unclear." Applicant has provided a new title in order to satisfy the Examiner's request concerning a new title. Applicant has also amended the specification to refer to the patent number which is now available for the application referred to on page 48 of the present application. Applicant has also submitted separately the PTO Form 1449 along with two patents which were cited in the PCT search for the corresponding PCT application. These references were cited as "defining the general state of the art which is not considered to be part of the particular. evidence ..." The remaining rejection by the Examiner is under 102(e) on the basis of a U.S. patent to Levine. It is respectfully submitted that Levine does not anticipate or render obvious the present invention. Levine describes a direct manipulation user interface system which has stamps which may be aligned together and moved as an aligned group which is referred to as a stack. It is noted that Levine merely describes certain visual aspects and certain user interactions with the computer system of Levine without describing any of the underlying functionality provided by the system of the present invention. In many ways, the Levine system with its stack of stamps represents nothing more than a "dumb" collection of documents without the features of the present invention. For example, there is no teaching or suggestion in Levine that a representation of the collection of documents, such as, for example, a vector representation as described in the present application be provided for the collection of documents. Moreover, there is no disclosure or suggestion in Levine that any of the documents in a collection of documents may be viewed by displaying an indicia of the document. Rather, in Levine, only the document which is the top stamp on the top of a stack can be viewed in a full screen mode by selecting it. See, column 12, lines 50-53 of Levine. Thus, Levine actually -4- 724 FH 179 APMW0025490 teaches away from the present invention in that Levine allows the user to see only a full screen view of a particular document if that document is on top of the stack. Thus, Levine does not teach or suggest the required step of "viewing at least one of the documents in said collection by displaying an indicia of said at least one document." See claim 1. Also, Levine fails to disclose or suggest a representation of a collection of documents. For example, Levine does not disclose "determining a representation of said collection when the third document is added to said collection..." See claim 37. It is noted that there are numerous dependent claims which add further limitations which are neither suggested nor taught by Levine. See, for example, claims 7, 8 , 1 7 and 18. In conclusion, it is respectfully submitted that Levine does not anticipate and does not render obvious the presently claimed invention. Applicant hereby petitions for an extension of time to respond the pending Office Action and has enclosed herewith a check for the extension fee. . ' her charges, please charge our Deposit Account No. 'VI Very truly yours, BLAKELY, SOKOLOFF, TAYLOR & ZAFMAN Date:P-L<:; 3 ,1993 12400 Wilshire Blvd. Seventh Floor Los Angeles, CA 90025 (408) 720-8598 EXpRESS MAIL CERTIFICATE OF MAILING "Express Mail" maifing label number -.LTB5065402~~(s;,:.81l.L7 _ Dale a Deposit December 3 1993 I hereby certify that this paper or fee is being deposited with the United States Postal Service "Express Mail Post Office to Addressee" service under 37 CFR 1.10 on the date indicated above and is addressed to the Commissioner of Patents and Trademarks, Washington, D.C. 20231. TridaPires (Typsd or printed name of person mailing paper or fee) I~McA--?~ (Signature of person mailingpaper or fee) -5- 724 FH 180 APMW0025491

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