Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 1093

RESPONSE in Opposition re 1050 MOTION FOR LEAVE TO SUPPLEMENT THEIR P.R. 3-1 INFRINGEMENT CONTENTIONS WITH RESPECT TO FRITO-LAY, INC.'S HAPPINESS.LAYS.COM filed by Frito-Lay, Inc.. (Attachments: # 1 Declaration of J. Yee, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Text of Proposed Order)(McSwane, Douglas)

EXHIBIT 1

method

computer
network
environment,
comprising:

a

its default and expected use,

Page 1 of 165

instructions to users, and causes them to use Frito-Lay, Inc.'s website in an infringing manner in

Lay, Inc, provides the infrastructure (e,g, servers, Frito-Lay, Inc.'s website, etc,), in addition to

program in a computer network environment, comprising the following elements, In addition, Frito-

in

program

website (and/or any combination thereof), operate in a hypermedia network environment that
includes client workstations executing browsers and comprises a method for running an application

an

for Users of Frito-Lay, Inc.'s website Frito-Lay.com, the website itself, and/or the servers hosting that

Exemplary evidence from FritQ-Lay, Inc.'s websites

application

running

iA

* Allegation not limited to the browser in use

lpre

Claim I Claim Language

Of The '906 Patent By Frito-Lay, Inc.'s Websites*

Claim Chart For Frito-Lay, Inc. Showing Infringement

A method for

1 pre

Exemplary evidence from Frito-Lay, Inc.'s websites

* Allegation not limited to the browser in use

method comprising:

environment, the

network

workstation and one
network
server
coupled to the

one client

comprises at least

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Users of Frito-Lay, Inc.'s website Frito-Lay,com, the website itself, and/or the servers hosting that
running an website (and/or any combination thereof), operate in a distributed hypermedia network environment,
application program wherein the network environment comprises at least one client workstation and one network server
in a distributed coupled to the network environment, the method comprising the following claim elements, In addition,
hypermedia network Frito-Lay, Inc, provides the infrastructure (e,g, servers, Frito-Lay, Inc.'s website, etc,), in addition to
environment,
instructions to users, and causes them to use Frito-Lay, Inc.'s website in an infringing manner in its
wherein the network default and expected use,
environment

Claim Language

Claim

Of The '985 Patent By Frito-Lay, Inc.'s Websites*

Claim Chart For Frito-Lay, Inc. Showing Infringement