Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 1348

Additional Attachments to Main Document: 1347 Order,.. (Attachments: # 1 Exhibit C to 1342 (Part 2 of 17), # 2 Exhibit C to 1342 (Part 3 of 17), # 3 Exhibit C to 1342 (Part 4 of 17), # 4 Exhibit C to 1342 (Part 5 of 17), # 5 Exhibit C to 1342 (Part 6 of 17), # 6 Exhibit C to 1342 (Part 7 of 17), # 7 Exhibit C to 1342 (Part 8 of 17), # 8 Exhibit C to 1342 (Part 9 of 17), # 9 Exhibit C to 1342 (Part 10 of 17), # 10 Exhibit C to 1342 (Part 11 of 17), # 11 Exhibit C to 1342 (Part 12 of 17), # 12 Exhibit C to 1342 (Part 13 of 17), # 13 Exhibit C to 1342 (Part 14 of 17, # 14 Exhibit C to 1342 (Part 15 of 17), # 15 Exhibit C to 1342 (Part 16 of 17), # 16 Exhibit C to 1342 (Part 17 of 17)(Doan, Jennifer)

CLAIM CHART EXHIBIT 9
MOSAIC, HTML+, AND DISCLOSURE AND
TESTIMONY OF BILL JANSSEN

INVALIDITY CLAIM CHART FOR U.S. PATENT NO. 5,838,906
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“NCSA MOSAIC FOR X 2.0 AVAILABLE”, WWW-TALK, OCT-DEC, 1993 [PA-00292659] [ANDREESSEN93A],
NCSA MOSAIC TECHNICAL SUMMARY [PA-00292824] [ANDREESSEN 93B],
NCSA COLLAGE FOR THE MACINTOSH VERSION 1.0, OCTOBER 1992 [PA-00292677] [COLLAGE92],
MOSAIC SOFTWAR(E.G., THE CODEBASES FOUND AT [PA-NAT-00000044] – [PA-NAT-00000046])
MMY PERSONAL EXPERIENCE WITH THE MOSAIC BROWSER,
VIDEO: THE NATIONAL CENTER FOR SUPERCOMPUTING APPLICATIONS SOFTWARE DEVELOPMENT GROUP PRESENTS
NCSA MOSAIC [HARDIN 93]
“HTML+ (HYPERTEXT MARKUP LANGUAGE), HEWLETT-PACKARD, 1993 [RAGGETT93A] [PA-00321233]
DEPOSITION OF WILLIAM JANSSEN (MAY 11, 2011) [JANSSEN DEP.]
o EXHIBITS TO [JANSSEN DEP.], INCLUDING EXHIBIT 6 [PH_001_0000598210], EXHIBIT 8 [PH_001_0000598248],
EXHIBIT 9 [PA-00306624], EXHIBIT 10 [PH_001_0000588858]; EXHIBIT 11
o EXHIBITS TO [BINA DEP.] INCLUDING EXHIBIT 4 AND 7
o EXHIBITS TO [MCRAE DEP.] INCLUDING EXHIBIT 37 (APRIL AND JUNE MESSAGES)

(“MOSAIC, HTML+, AND BILL JANSSEN'S POSTINGS AND TESTIMONY”)
Claim Text from ’906 Patent
906-1.a:
A method for running an application program in a
computer network environment, comprising:

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an
application program. See, e.g., :
Compilation of code from the archive:
file://tip.ncsa.uiuc.edu/Web/xmosaic/xmosaic-0.5.tar.Z produced an
application program.
Other examples of prior art Mosaic distributions that operated as
application programs include the Mosaic Source Code identified above.
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a computer
network environment. See, e.g., :
From [Andreessen93b], “NCSA Mosaic provides extensive distributed
1

Claim Text from ’906 Patent

906-1.b:
providing at least one client workstation and one
network server coupled to said network
environment, wherein said network environment is
a distributed hypermedia environment;

Mosaic, HTML+, and Bill Janssen's postings and testimony
hypermedia capabilities that take advantage of the information base on the
global Internet.”
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a client
workstation. See, e.g., :
From [Andreessen93a], Mosaic was supported on the following client
workstations:
SGI (IRIX 4.0.2)
IBM (AIX 3.2)
Sun 4 (SunOS 4.1.2 with stock X11R4 and Motif 1.1
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a network
server. See, e.g., :
From [Andreessen93b], “NCSA Data Transfer Mechanism
communications support_ for integration with NCSA Collage and other
network_based DTM clients and information servers. . . . The scheme that
NCSA Mosaic uses to name information resources on the global network
is the Uniform Resource Locator mechanism . . . . Uniform Resource
Locators can point to documents residing on FTP or HTTP servers . . . . ”
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a
distributed hypermedia environment. See, e.g., :

906-1.c:

From [Andreessen93b], “NCSA Mosaic provides extensive distributed
hypermedia capabilities that take advantage of the information base on the
global Internet.”
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser

2

Claim Text from ’906 Patent
executing, at said client workstation, a browser
application, that parses a first distributed
hypermedia document to identify text formats
included in said distributed hypermedia document
and for responding to predetermined text formats
to initiate processing specified by said text
formats;

Mosaic, HTML+, and Bill Janssen's postings and testimony
application. See, e.g., :
Compilation of code from the archive file
://tip.ncsa.uiuc.edu/Web/xmosaic/xmosaic-0.5.tar.Z produced an
executable browser application.
Other examples of prior art Mosaic distributions that operated as
application programs include the Mosaic Source Code identified above.
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
browser application parses a hypermedia document. See, e.g., :
Mosaic parses a file to discover tags. From [Andreessen93a], Mosaic
parsed HTML files containing HTML tags. In addition, from
[Andreessen93a], Mosaic parsed files that contained HTML+ tags,
including tags for embedded, interactive fill-out forms.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a
hypermedia document with text formats. See, e.g., :

906-1.d:
utilizing said browser to display, on said client
workstation, at least a portion of a first hypermedia
document received over said network from said
server,

Mosaic parses hypermedia documents to discover tags. From
[Andreessen93a], Mosaic parsed HTML files containing HTML text
formats. In addition, from [Andreessen93a], Mosaic parsed files that
contained text formats in the form of HTML+ tags, including tags for
embedded, interactive fill-out forms.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that a
hypermedia document is received from the server. See, e.g., :
From [Andreessen93b], “NCSA Mosaic provides extensive distributed
hypermedia capabilities that take advantage of the information base on the
global Internet.” See above.
See generally [Hardin93] video.

3

Claim Text from ’906 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
browser displays a hypermedia document. See, e.g., :

906-1.e:
wherein the portion of said first hypermedia
document is displayed within a first browsercontrolled window on said client workstation,

From [Andreessen93b], “NCSA Mosaic provides extensive distributed
hypermedia capabilities that take advantage of the information base on the
global Internet.”
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that a
hypermedia document is displayed in a browser window. See, e.g., :
From [Andreessen93b], “A screen snapshot of NCSA Mosaic for X
viewing the Mosaic home page _ the document that is retrieved and
displayed when Mosaic is launched_ is in Figure 1.” The figure is shown
here:

4

Claim Text from ’906 Patent

906-1.f:
wherein said first distributed hypermedia
document includes an embed text format, located
at a first location in said first distributed
hypermedia document, that specifies the location

Mosaic, HTML+, and Bill Janssen's postings and testimony

See also generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an embed
text format at a first location in a hypermedia document. See, e.g., :
Mosaic parsed text formats in the form of HTML and HTML+ tags.
[Andreessen93a]. It would have been obvious for Mosaic to parse other

5

Claim Text from ’906 Patent
of at least a portion of an object external to the first
distributed hypermedia document,

Mosaic, HTML+, and Bill Janssen's postings and testimony
HTML+ tags, including the EMBED tag disclosed in [Raggett93a].
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
The EMBED tag was at a first location in the hypermedia document, and
the result is that an equation would appear in the browser window at a
location corresponding to the location of the EMBED tag.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
embed text format specifies the location of an object. See, e.g., :
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
It would have been obvious for the EMBED tag to specify the location of
an object, such as its filepath location. Other HTML embed tags, such as
the IMG tag, specified the location of an object using a filepath location.
In reference to the EMBED tag disclosed above, Dave Raggett also
disclosed that the EMBED text format could specify the location of an
object: "you can also put the foreign data in a separate file referenced by a
URL." (Janssen Dep. Ex. 9).
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an object
that is external to a hypermedia document. See, e.g., :

906-1.g:

The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
This displayed an equation object that was internal to the hypermedia
document.
However, Dave Raggett disclosed that the EMBED text format could also
specify the location of an object external to the hypermedia document:
"you can also put the foreign data in a separate file referenced by a URL."
(Janssen Dep. Ex. 9).
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the

6

Claim Text from ’906 Patent
wherein said object has type information
associated with it utilized by said browser to
identify and locate an executable application
external to the first distributed hypermedia
document, and

Mosaic, HTML+, and Bill Janssen's postings and testimony
object has associated type information. See, e.g., :
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
The tag provided for a "type" attribute that, in this example, was specified
as "application/eqn." Thus, this equation object has type information
associated with it.
As Dave Raggett disclosed, "[t]he browser identifies the format of the
embedded data from the 'type' attribute, specified as a MIME content
type." (Jannssen Dep. Ex. 9)
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
browser uses type information to identify and locate an executable application.
See, e.g., :
As Dave Raggett disclosed, "[t]he browser identifies the format of the
embedded data from the 'type' attribute, specified as a MIME content
type." (Jannssen Dep. Ex. 9)
Raggett further disclosed that "[t]he functions could be implemented as
separate programs driven via pipes… ."
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
executable application is external to the hypermedia document. See, e.g., :
As Dave Raggett disclosed, "[t]he browser identifies the format of the
embedded data from the 'type' attribute, specified as a MIME content
type." (Jannssen Dep. Ex. 9)
Raggett further disclosed that "[t]he functions could be implemented as
separate programs driven via pipes… ."
One mechanism Raggett disclosed for identifying and launching the
executable application was the use of X resources: "binding the MIME
content type to the function name for that format, e.g. via X resource… ."

7

Claim Text from ’906 Patent
906-1.h:
wherein said embed text format is parsed by said
browser to automatically invoke said executable
application to execute on said client workstation in
order to display said object and enable an end-user
to directly interact with said object within a
display area created at said first location within the
portion of said first distributed hypermedia
document being displayed in said first browsercontrolled window.

Mosaic, HTML+, and Bill Janssen's postings and testimony
(Janssen Dep. Ex. 9)
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
browser parses the embed text format. See, e.g., :
Mosaic parsed text formats in the form of HTML and HTML+ tags.
[Andreessen93a]. It would have been obvious for Mosaic to process other
HTML+ tags, including the EMBED tag disclosed in [Raggett93a].
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
The result is that an equation would appear in the browser window at a
location corresponding to the location of the EMBED tag.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose automatic
invocation of the executable application. See, e.g., :
In prior art Mosaic 2.4, helper applications display the hypermedia object
and the applications are invoked by the user, not automatically.
However, it was obvious and widely known to persons of ordinary skill at
the time how to automatically initiate invocation of an executable
application. The earlier discussion of inline embedding involved a
determination of the type of external application to be invoked and the
location of an external dataset to be accessed. The default invocation
would normally be automatic.
Dave Raggett disclosed automatic invocation of an executable application
through "binding the MIME content type to the function name for that
format, e.g. via X resources. …. The functions could be implemented as
separate programs … ." (Janssen Dep. Ex. 9) If the "type=" attribute were
bound in that fashion to separate programs, those programs would be
invoked automatically upon parsing of the "type=" attribute.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
executable application displays the object. See, e.g., :

8

Claim Text from ’906 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
Dave Raggett disclosed in connection with his EMBED tag that
"[b]rowsers can then be upgraded to display new formats without
changing their code at all."
As Bill Jannssen disclosed in connection with Dave Raggett's EMBED
tag, a browser could create and manage an X sub-window over an area
where an object is to be displayed. (Janssen Dep. Ex. 10.)
Bill Janssen further discussed that one could achieve this by passing a
window ID to an executable application as to allow that executable
application to paint its output in an X sub-window where an object is to be
displayed. (Janssen Dep. Ex. 8.)
The mechanism of passing a window ID to an executable application to
allow that application to paint its output in an X sub-window was
extensible, in that any application could be used. As one example, Bill
Janssen disclosed the use of XV in this capacity. (Janssen Dep. Ex. 8.) In
that scenario, XV would display an image object.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
executable application enables direct interaction with the object. See, e.g., :
For example, Bill Janssen disclosed embedded "insets" that provide
control panels. (Janssen Dep. Ex. 6.)
Bill Janssen also disclosed in connection with the EMBED tag that the
external program "is to handle all events and refresh on the sub-window…
." (Janssen Dep. Ex. 10.) By events, Janssen inherently disclosed user
interaction X events, as I discuss in the X Windows section of my report.
This was explained further by Janssen during the Janssen deposition:
The
21 idea is that -- this is basically a restatement of
22 an idea that I came up with back in 1987, I believe,
23 where you have one perim which creates an X window
24 which it does not want to manage itself for various

9

Claim Text from ’906 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
25 reasons. But it does want to control the placement
0041
1 of the window inside some larger user interface
2 context and wants to control the size of the window.
3 So it operates as the window's manager, what we call
4 it in X11 terminology. But it passes off control of
5 the inside of the window responding to mouse or
6 keyboard events and redrawing the window.
7
The reference to "refresh" there, "refresh
8 on the sub-window," is actually referring to the act
9 of repainting the window when part of it needs to be
10 repainted. And then the surrounding program, the
11 larger user interface context gets to handle the
12 configuration and the window movement.
The mechanism of passing a window ID to an executable application to
allow that application to paint its output in an X sub-window was
extensible, in that any application could be used. As one example, Bill
Janssen disclosed the use of XV in this capacity. (Janssen Dep. Ex. 8.) In
that scenario, XV would display an image object. XV was an application
program that enabled direct interaction with an object. For example, with
XV, a user could apply various special effects or scaling factors to a
displayed image object.
Bill Janssen further elaborated during the Janssen Deposition:
2 Q.
And using X11, if I understood your
3 explanation of what was being discussed on www-talk
4 on April 29th, 1993, you could have the browser pass
5 the window ID to XV, and then XV would allow a user
6 to manipulate an image directly with inline of the
7 Web page?
8 A.
That's a pretty good summary, yeah.
9 Q.
In 1993 did you believe that having
10 browsers and external viewers cooperate with each

10

Claim Text from ’906 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
11 other was an easy project?
12 A.
I'd call it straightforward, because I'd
13 certainly already done it several times in different
14 kinds of browsers. And I knew other people who had
15 done it. For example, the Andrew project at CMU,
16 the Slate project referred to apparently did it,
17 although I don't remember the Slate project. So
18 yes. I would say straightforward, not easy.
(Janssen Dep. at 30.)
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that
interaction with the object is at a first location in the hypermedia document. See,
e.g., :
Bill Janssen disclosed in connection with the EMBED tag that the external
program "is to handle all events and refresh on the sub-window… ."
(Janssen Dep. Ex. 10.) By events, Janssen inherently disclosed user
interaction X events such as mouse events that occur on the sub-window,
of the type that I discuss in the X Windows section of my report.
This was explained further by Janssen during the Janssen deposition:
The
21 idea is that -- this is basically a restatement of
22 an idea that I came up with back in 1987, I believe,
23 where you have one perim which creates an X window
24 which it does not want to manage itself for various
25 reasons. But it does want to control the placement
0041
1 of the window inside some larger user interface
2 context and wants to control the size of the window.
3 So it operates as the window's manager, what we call
4 it in X11 terminology. But it passes off control of
5 the inside of the window responding to mouse or

11

Claim Text from ’906 Patent

906-2.a:
The method of claim 1, wherein said executable
application is a controllable application and further
comprising the step of: interactively controlling
said controllable application on said client

Mosaic, HTML+, and Bill Janssen's postings and testimony
6 keyboard events and redrawing the window.
7
The reference to "refresh" there, "refresh
8 on the sub-window," is actually referring to the act
9 of repainting the window when part of it needs to be
10 repainted. And then the surrounding program, the
11 larger user interface context gets to handle the
12 configuration and the window movement.
Also, as explained by Bill Janssen during the Janssen Deposition:
2 Q.
And using X11, if I understood your
3 explanation of what was being discussed on www-talk
4 on April 29th, 1993, you could have the browser pass
5 the window ID to XV, and then XV would allow a user
6 to manipulate an image directly with inline of the
7 Web page?
8 A.
That's a pretty good summary, yeah.
9 Q.
In 1993 did you believe that having
10 browsers and external viewers cooperate with each
11 other was an easy project?
12 A.
I'd call it straightforward, because I'd
13 certainly already done it several times in different
14 kinds of browsers. And I knew other people who had
15 done it. For example, the Andrew project at CMU,
16 the Slate project referred to apparently did it,
17 although I don't remember the Slate project. So
18 yes. I would say straightforward, not easy.
(Janssen Dep. at 30.)
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose interactive
control via inter-process communications between a browser and an application.
See, e.g., :
Dave Raggett disclosed that "[t]he functions could be implemented as

12

Claim Text from ’906 Patent
workstation via inter-process communications
between said browser and said controllable
application.

906-3.a:
The method of claim 2, wherein the

Mosaic, HTML+, and Bill Janssen's postings and testimony
separate programs driven via pipes and stdin/stdout… ." (Janssen Dep.
Ex. 9)
With further reference to the example in which XV is an executable
application interoperating with the browser, Bill Janssen explained:
11 Q.
In Janssen Exhibit 11, what you have
12 described as program B, could that be a separate
13 stand-alone program such as the graphics program XV?
14 A.
It could.
15 Q.
And you have some lines going back and
16 forth between A and B. Does that indicate
17 inter-process communications between program A and
18 program B?
19 A.
It does.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose ongoing
inter-process communications. See, e.g., :
13

Claim Text from ’906 Patent
communications to interactively control said
controllable application continue to be exchanged
between the controllable application and the
browser even after the controllable application
program has been launched.

906-6.a:
A computer program product for use in a system
having at least one client workstation and one
network server coupled to said network

Mosaic, HTML+, and Bill Janssen's postings and testimony
With further reference to the example in which XV is an executable
application interoperating with the browser, Bill Janssen explained:
11 Q.
In Janssen Exhibit 11, what you have
12 described as program B, could that be a separate
13 stand-alone program such as the graphics program XV?
14 A.
It could.
15 Q.
And you have some lines going back and
16 forth between A and B. Does that indicate
17 inter-process communications between program A and
18 program B?
19 A.
It does.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an
application program in a computer network environment. See evidence recited
for 906-1.a.

14

Claim Text from ’906 Patent
environment, wherein said network environment is
a distributed hypermedia environment, the
computer program product comprising:

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony also disclose a client
workstation and a network server in a distributed hypermedia environment. See
evidence recited for 906-1.b.

906-6.b:
a computer usable medium having computer
readable program code physically embodied
therein, said computer program product further
comprising:

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose computer
code physically embodied on a medium. See, e.g., :

906-6.c:
computer readable program code for causing said
client workstation to execute a browser application
to parse a first distributed hypermedia document to
identify text formats included in said distributed
hypermedia document and to respond to
predetermined text formats to initiate processes
specified by said text formats;
906-6.d:
computer readable program code for causing said
client workstation to utilize said browser to
display, on said client workstation, at least a
portion of a first hypermedia document received
over said network from said server,
906-6.e:
wherein the portion of said first hypermedia
document is displayed within a first browsercontrolled window on said client workstation,
906-6.f:

Release of machine readable source code of Mosaic 0.5 at access path:
file://tip.ncsa.uiuc.edu/Web/xmosaic/xmosaic-0.5.tar.Z disclosed in
[Andreessen93a]. A listing of current capabilities was disclosed in the
same document as well as machines it was known to compile on.
See also Mosaic Source Code.
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application that parses a hypermedia document with text formats. See evidence
recited for 906-1.c.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a
hypermedia document received from a server and a browser that displays the
hypermedia document. See evidence recited for 906-1.d.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
hypermedia document is displayed in a browser window. See evidence recited
for 906-1.e.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an embed

15

Claim Text from ’906 Patent
wherein said first distributed hypermedia
document includes an embed text format, located
at a first location in said first distributed
hypermedia document, that specifies the location
of at least a portion of an object external to the first
distributed hypermedia document,
906-6.g:
wherein said object has type information
associated with it utilized by said browser to
identify and locate an executable application
external to the first distributed hypermedia
document, and
906-6.h:
wherein said embed text format is parsed by said
browser to automatically invoke said executable
application to execute on said client workstation in
order to display said object and enable an end-user
to directly interact with said object within a
display area created at said first location within the
portion of said first distributed hypermedia
document being displayed in said first browsercontrolled window.

Mosaic, HTML+, and Bill Janssen's postings and testimony
text format at a first location in a hypermedia document; that the embed text
format specifies the location of an object; and that the object is external to the
hypermedia document. See evidence recited for 906-1.f.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
object has associated type information, that the browser uses the type
information to identify and locate an executable application, and that the
executable application is external to the hypermedia document. See evidence
recited for 906-1.g.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
browser parses the embed text format; that the browser automatically invokes the
executable application; that the executable application displays the object and
enables an end-user to directly interact with it; and that interaction with the
object is at a first location in the hypermedia document. See evidence recited for
906-1.h.

906-7.a:
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose interactive
The computer program product of claim 6, wherein control via inter-process communications between a browser and an application.
said executable application is a controllable
See evidence recited for 906-2.a.
application and further comprising:
computer readable program code for causing said
client workstation to interactively control said
controllable application on said client workstation
via inter-process communications between said
browser and said controllable application.

16

Claim Text from ’906 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony

906-8.a:
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose ongoing
The computer program product of claim 7, wherein inter-process communications. See evidence recited for 906-3.a.
the communications to interactively control said
controllable application continue to be exchanged
between the controllable application and the
browser even after the controllable application
program has been launched.
906-11.a:
The method of claim 3, wherein additional
instructions for controlling said controllable
application reside on said network server, wherein
said step of interactively controlling said
controllable application includes the following
substeps:

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose additional
instructions on the server. See, e.g., :
Dave Raggett disclosed in connection with his EMBED tag that
"[b]rowsers can then be upgraded to display new formats without
changing their code at all." (Janssen Dep. Ex. 9) Thus, Mosaic could
interoperate with external applications, including distributed applications,
without any change to Mosaic.
In addition, as Bill Jannssen disclosed in connection with Dave Raggett's
EMBED tag, a browser could create and manage an X sub-window over
an area where an object is to be displayed. (Janssen Dep. Ex. 10.) Bill
Janssen further discussed that one could achieve this by passing a window
ID to an executable application as to allow that executable application to
paint its output in an X sub-window where an object is to be displayed.
(Janssen Dep. Ex. 8.) The mechanism of passing a window ID to an
executable application to allow that application to paint its output in an X
sub-window was extensible, in that any application could be used. As one
example, Bill Janssen disclosed the use of XV in this capacity. (Janssen
Dep. Ex. 8.) However, any application, including a distributed
application, could also be used.
One example of a distributed application is the Collage application: “in a
networked environment, this tool provides the capability to distribute most
of these data analysis and visualization functions synchronously among a

17

Claim Text from ’906 Patent

906-11.b:
issuing, from the client workstation, one or more
commands to the network server;

Mosaic, HTML+, and Bill Janssen's postings and testimony
number of users. This is the foundation for the collaborative aspects of this
tool’s functionality.” [Collage92]
From [Andreessen93b], Mosaic interoperated with Collage.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
client issues commands to the server. See, e.g., :
Dave Raggett disclosed in connection with his EMBED tag that
"[b]rowsers can then be upgraded to display new formats without
changing their code at all." (Janssen Dep. Ex. 9) Thus, Mosaic could
interoperate with external applications, including distributed applications,
without any change to Mosaic.
In addition, as Bill Jannssen disclosed in connection with Dave Raggett's
EMBED tag, a browser could create and manage an X sub-window over
an area where an object is to be displayed. (Janssen Dep. Ex. 10.) Bill
Janssen further discussed that one could achieve this by passing a window
ID to an executable application as to allow that executable application to
paint its output in an X sub-window where an object is to be displayed.
(Janssen Dep. Ex. 8.) The mechanism of passing a window ID to an
executable application to allow that application to paint its output in an X
sub-window was extensible, in that any application could be used. As one
example, Bill Janssen disclosed the use of XV in this capacity. (Janssen
Dep. Ex. 8.) However, any application, including a distributed
application, could also be used.
One example of a distributed application is the Collage application: “in a
networked environment, this tool provides the capability to distribute most
of these data analysis and visualization functions synchronously among a
number of users. This is the foundation for the collaborative aspects of this
tool’s functionality.” [Collage92]

906-11.c:

From [Andreessen93b], Mosaic interoperated with Collage.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the

18

Claim Text from ’906 Patent
executing, on the network server, one or more
instructions in response to said commands;

Mosaic, HTML+, and Bill Janssen's postings and testimony
server executes instructions in response to client commands. See, e.g., :
Dave Raggett disclosed in connection with his EMBED tag that
"[b]rowsers can then be upgraded to display new formats without
changing their code at all." (Janssen Dep. Ex. 9) Thus, Mosaic could
interoperate with external applications, including distributed applications,
without any change to Mosaic.
In addition, as Bill Jannssen disclosed in connection with Dave Raggett's
EMBED tag, a browser could create and manage an X sub-window over
an area where an object is to be displayed. (Janssen Dep. Ex. 10.) Bill
Janssen further discussed that one could achieve this by passing a window
ID to an executable application as to allow that executable application to
paint its output in an X sub-window where an object is to be displayed.
(Janssen Dep. Ex. 8.) The mechanism of passing a window ID to an
executable application to allow that application to paint its output in an X
sub-window was extensible, in that any application could be used. As one
example, Bill Janssen disclosed the use of XV in this capacity. (Janssen
Dep. Ex. 8.) However, any application, including a distributed
application, could also be used.
One example of a distributed application is the Collage application: “in a
networked environment, this tool provides the capability to distribute most
of these data analysis and visualization functions synchronously among a
number of users. This is the foundation for the collaborative aspects of this
tool’s functionality.” [Collage92]

906-11.d:
sending information from said network server to
said client workstation in response to said executed
instructions; and

From [Andreessen93b], Mosaic interoperated with Collage.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
server responds with information to the client. See, e.g., :
Dave Raggett disclosed in connection with his EMBED tag that
"[b]rowsers can then be upgraded to display new formats without
changing their code at all." (Janssen Dep. Ex. 9) Thus, Mosaic could

19

Claim Text from ’906 Patent

906-11.e:
processing said information at the client
workstation to interactively control said
controllable application.

Mosaic, HTML+, and Bill Janssen's postings and testimony
interoperate with external applications, including distributed applications,
without any change to Mosaic.
In addition, as Bill Jannssen disclosed in connection with Dave Raggett's
EMBED tag, a browser could create and manage an X sub-window over
an area where an object is to be displayed. (Janssen Dep. Ex. 10.) Bill
Janssen further discussed that one could achieve this by passing a window
ID to an executable application as to allow that executable application to
paint its output in an X sub-window where an object is to be displayed.
(Janssen Dep. Ex. 8.) The mechanism of passing a window ID to an
executable application to allow that application to paint its output in an X
sub-window was extensible, in that any application could be used. As one
example, Bill Janssen disclosed the use of XV in this capacity. (Janssen
Dep. Ex. 8.) However, any application, including a distributed
application, could also be used.
One example of a distributed application is the Collage application: “in a
networked environment, this tool provides the capability to distribute most
of these data analysis and visualization functions synchronously among a
number of users. This is the foundation for the collaborative aspects of this
tool’s functionality.” [Collage92]
From [Andreessen93b], Mosaic interoperated with Collage.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
client uses information from the server to interactively control the application.
See, e.g., :
Dave Raggett disclosed in connection with his EMBED tag that
"[b]rowsers can then be upgraded to display new formats without
changing their code at all." (Janssen Dep. Ex. 9) Thus, Mosaic could
interoperate with external applications, including distributed applications,
without any change to Mosaic.
In addition, as Bill Jannssen disclosed in connection with Dave Raggett's
EMBED tag, a browser could create and manage an X sub-window over

20

Claim Text from ’906 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
an area where an object is to be displayed. (Janssen Dep. Ex. 10.) Bill
Janssen further discussed that one could achieve this by passing a window
ID to an executable application as to allow that executable application to
paint its output in an X sub-window where an object is to be displayed.
(Janssen Dep. Ex. 8.) The mechanism of passing a window ID to an
executable application to allow that application to paint its output in an X
sub-window was extensible, in that any application could be used. As one
example, Bill Janssen disclosed the use of XV in this capacity. (Janssen
Dep. Ex. 8.) However, any application, including a distributed
application, could also be used.
One example of a distributed application is the Collage application: “in a
networked environment, this tool provides the capability to distribute most
of these data analysis and visualization functions synchronously among a
number of users. This is the foundation for the collaborative aspects of this
tool’s functionality.” [Collage92]
From [Andreessen93b], Mosaic interoperated with Collage.

906-13.a:
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose additional
The computer program product of claim 8, wherein instructions on the server See evidence recited for 906-11.a.
additional instructions for controlling said
controllable application reside on said network
server, wherein said computer readable program
code for causing said client workstation to
interactively control said controllable application
on said client workstation includes:
906-13.b:
computer readable program code for causing said
client workstation to issue from the client
workstation, one or more commands to the
network server;

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
client issues commands to the server. See evidence recited for 906-11.b.

21

Claim Text from ’906 Patent
906-13.c:
computer readable program code for causing said
network server to execute one or more instructions
in response to said commands;
906-13.d:
computer readable program code for causing said
network sever to send information to said client
workstation in response to said executed
instructions; and
906-13.e:
computer readable program code for causing said
client workstation to process said information at
the client workstation to interactively control said
controllable application.

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
server executes instructions in response to client commands. See evidence
recited for 906-11.c.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
server responds with information to the client. See evidence recited for 90611.d.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
client uses information from the server to interactively control the application.
See evidence recited for 906-11.e.

22

INVALIDITY CLAIM CHART FOR U.S. PATENT NO. 7,599,985







“NCSA MOSAIC FOR X 2.0 AVAILABLE”, WWW-TALK, OCT-DEC, 1993 [PA-00292659] [ANDREESSEN93A],
NCSA MOSAIC TECHNICAL SUMMARY [PA-00292824] [ANDREESSEN 93B],
NCSA COLLAGE FOR THE MACINTOSH VERSION 1.0, OCTOBER 1992 [PA-00292677] [COLLAGE92],
MOSAIC SOFTWAR(E.G., THE CODEBASES FOUND AT [PA-NAT-00000044] – [PA-NAT-00000046])
MMY PERSONAL EXPERIENCE WITH THE MOSAIC BROWSER,
VIDEO: THE NATIONAL CENTER FOR SUPERCOMPUTING APPLICATIONS SOFTWARE DEVELOPMENT GROUP PRESENTS
NCSA MOSAIC [HARDIN 93]
 “HTML+ (HYPERTEXT MARKUP LANGUAGE), HEWLETT-PACKARD, 1993 [RAGGETT93A] [PA-00321233]
 DEPOSITION OF WILLIAM JANSSEN (MAY 11, 2011) [JANSSEN DEP.]
o EXHIBITS TO [JANSSEN DEP.], INCLUDING EXHIBIT 6 [PH_001_0000598210], EXHIBIT 8 [PH_001_0000598248],
EXHIBIT 9 [PA-00306624], EXHIBIT 10 [PH_001_0000588858]; EXHIBIT 11
(“MOSAIC, HTML+, AND BILL JANSSEN'S POSTINGS AND TESTIMONY”)
Claim Text from ’985 Patent
985-1.a:
A method for running an application program in a
distributed hypermedia network environment,
wherein the network environment comprises at
least one client workstation and one network
server coupled to the network environment, the
method comprising:

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an
application program. See, e.g., :
Compilation of code from the archive:
file://tip.ncsa.uiuc.edu/Web/xmosaic/xmosaic-0.5.tar.Z produced an
application program.
Other examples of prior art Mosaic distributions that operated as
application programs include the Mosaic Source Code identified above.
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a computer
network environment. See, e.g., :
From [Andreessen93b], “NCSA Mosaic provides extensive distributed
hypermedia capabilities that take advantage of the information base on the
global Internet.”
See generally [Hardin93] video.
23

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a client
workstation. See, e.g., :
From [Andreessen93a], Mosaic was supported on the following client
workstations:
SGI (IRIX 4.0.2)
IBM (AIX 3.2)
Sun 4 (SunOS 4.1.2 with stock X11R4 and Motif 1.1
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a network
server. See, e.g., :
From [Andreessen93b], “NCSA Data Transfer Mechanism
communications support_ for integration with NCSA Collage and other
network_based DTM clients and information servers. . . . The scheme that
NCSA Mosaic uses to name information resources on the global network
is the Uniform Resource Locator mechanism . . . . Uniform Resource
Locators can point to documents residing on FTP or HTTP servers . . . . ”
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a
distributed hypermedia environment. See, e.g., :

985-1.b:
receiving, at the client workstation from the

From [Andreessen93b], “NCSA Mosaic provides extensive distributed
hypermedia capabilities that take advantage of the information base on the
global Internet.”
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application. See, e.g., :

24

Claim Text from ’985 Patent
network server over the network environment, at
least one file containing information to enable a
browser application to display at least a portion of
a distributed hypermedia document within a
browser-controlled window;

Mosaic, HTML+, and Bill Janssen's postings and testimony
Compilation of code from the archive file
://tip.ncsa.uiuc.edu/Web/xmosaic/xmosaic-0.5.tar.Z produced an
executable browser application.
Other examples of prior art Mosaic distributions that operated as
application programs include the Mosaic Source Code identified above.
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a file
containing enabling information. See, e.g., :
From [Andreessen93a], Mosaic parsed HTML files containing enabling in
formation in the from of HTML markup tags. In addition, from
[Andreessen93a], Mosaic parsed files that contained enabling information
in the form of HTML+ tags, including tags for embedded, interactive fillout forms.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the file
is received at the client workstation from the network server. See, e.g., :
From [Andreessen93b], “NCSA Mosaic provides extensive distributed
hypermedia capabilities that take advantage of the information base on the
global Internet.” Hypermedia document is a file received from server
described above.
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
browser displays at least a portion of a distributed hypermedia document. See,
e.g., :
From [Andreessen93b], “NCSA Mosaic provides extensive distributed
hypermedia capabilities that take advantage of the information base on the

25

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
global Internet.”
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that at least
a portion of a hypermedia document is displayed in a browser-controlled
window. See, e.g., :
From [Andreessen93b], “A screen snapshot of NCSA Mosaic for X
viewing the Mosaic home page _ the document that is retrieved and
displayed when Mosaic is launched_ is in Figure 1.” The figure is shown
here:

26

Claim Text from ’985 Patent

985-1.c:
executing the browser application on the client
workstation, with the browser application:

Mosaic, HTML+, and Bill Janssen's postings and testimony

See also generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application executing on the client workstation. See, e.g., :
Compilation of code from the archive file
://tip.ncsa.uiuc.edu/Web/xmosaic/xmosaic-0.5.tar.Z produced an

27

Claim Text from ’985 Patent

985-1.d:
responding to text formats to initiate processing
specified by the text formats;

Mosaic, HTML+, and Bill Janssen's postings and testimony
executable browser application.
Other examples of prior art Mosaic distributions that operated as
application programs include the Mosaic Source Code identified above.
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose responding
to text formats to initiate processing specified by the text formats, i.e., parsing
text formats. See, e.g., :
Mosaic parsed a file to discover tags. From [Andreessen93a], Mosaic
parsed HTML files to identify HTML markup tags and HTML+ tags,
including tags for embedded, interactive fill-out forms.

985-1.e:
displaying at least a portion of the document
within the browser-controlled window;

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
browser displays a hypermedia document. See, e.g., :
From [Andreessen93b], “NCSA Mosaic provides extensive distributed
hypermedia capabilities that take advantage of the information base on the
global Internet.”
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that a
hypermedia document is displayed in a browser window. See, e.g., :
From [Andreessen93b], “A screen snapshot of NCSA Mosaic for X
viewing the Mosaic home page _ the document that is retrieved and
displayed when Mosaic is launched_ is in Figure 1.” The figure is shown
here:

28

Claim Text from ’985 Patent

985-1.f:
identifying an embed text format which
corresponds to a first location in the document,
where the embed text format specifies the location
of at least a portion of an object external to the file,

Mosaic, HTML+, and Bill Janssen's postings and testimony

See also generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose identifying
an embed text format. See, e.g., :
Mosaic parsed enabling information to identify text formats in the form of
HTML and HTML+ tags. [Andreessen93a]. It would have been obvious

29

Claim Text from ’985 Patent
where the object has type information associated
with it;

Mosaic, HTML+, and Bill Janssen's postings and testimony
for Mosaic to process other HTML+ tags, including the EMBED tag
disclosed in [Raggett93a].
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
The result is that an equation would appear in the browser window at a
location corresponding to the location of the EMBED tag.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
embed text format corresponds to a first location in the hypermedia document.
See, e.g., :
Mosaic parsed enabling information to identify text formats in the form of
HTML and HTML+ tags. [Andreessen93a]. It would have been obvious
for Mosaic to process other HTML+ tags, including the EMBED tag
disclosed in [Raggett93a].
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
The result is that an equation would appear in the browser window at a
location corresponding to the location of the EMBED tag.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
embed text format specifies the location of an object. See, e.g., :
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
It would have been obvious for the EMBED tag to specify the location of
an object, such as its filepath location. Other HTML embed tags, such as
the IMG tag, specified the location of an object using a filepath location.
In reference to the EMBED tag disclosed above, Dave Raggett also
disclosed that the EMBED text format could specify the location of an
object: "you can also put the foreign data in a separate file referenced by a
URL." (Janssen Dep. Ex. 9).

30

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
object is external to the file containing enabling information. See, e.g., :
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
This displayed an equation object that was internal to the hypermedia
document.
However, Dave Raggett disclosed that the EMBED text format could also
specify the location of an object external to the file containing enabling
information: "you can also put the foreign data in a separate file
referenced by a URL." (Janssen Dep. Ex. 9).
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
object has associated type information. See, e.g., :

The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
The tag provided for a "type" attribute that, in this example, was specified
as "application/eqn." Thus, this equation object has type information
associated with it.
As Dave Raggett disclosed, "[t]he browser identifies the format of the
embedded data from the 'type' attribute, specified as a MIME content
type." (Jannssen Dep. Ex. 9)
985-1.g:
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
utilizing the type information to identify and locate browser uses type information to identify and locate an executable application.
an executable application external to the file; and
See, e.g., :
As Dave Raggett disclosed, "[t]he browser identifies the format of the
embedded data from the 'type' attribute, specified as a MIME content
type." (Jannssen Dep. Ex. 9)
Raggett further disclosed that "[t]he functions could be implemented as

31

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
separate programs driven via pipes… ."
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
executable application is external to the file containing enabling information.
See, e.g., :

985-1.h:
automatically invoking the executable application,
in response to the identifying of the embed text
format, to execute on the client workstation in
order to display the object and enable an end-user
to directly interact with the object while the object
is being displayed within a display area created at
the first location within the portion of the
hypermedia document being displayed in the
browser-controlled window.

As Dave Raggett disclosed, "[t]he browser identifies the format of the
embedded data from the 'type' attribute, specified as a MIME content
type." (Jannssen Dep. Ex. 9)
Raggett further disclosed that "[t]he functions could be implemented as
separate programs driven via pipes… ."
One mechanism Raggett disclosed for identifying and launching the
executable application was the use of X resources: "binding the MIME
content type to the function name for that format, e.g. via X resource… ."
(Janssen Dep. Ex. 9)
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
browser parses the embed text format. See, e.g., :
Mosaic parsed text formats in the form of HTML and HTML+ tags.
[Andreessen93a]. It would have been obvious for Mosaic to process other
HTML+ tags, including the EMBED tag disclosed in [Raggett93a].
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
The result is that an equation would appear in the browser window at a
location corresponding to the location of the EMBED tag.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose automatic
invocation of the executable application. See, e.g., :
In prior art Mosaic 2.4, helper applications display the hypermedia object
and the applications are invoked by the user, not automatically.
However, it was obvious and widely known to persons of ordinary skill at

32

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
the time how to automatically initiate invocation of an executable
application. The earlier discussion of inline embedding involved a
determination of the type of external application to be invoked and the
location of an external dataset to be accessed. The default invocation
would normally be automatic.
Dave Raggett disclosed automatic invocation of an executable application
through "binding the MIME content type to the function name for that
format, e.g. via X resources. …. The functions could be implemented as
separate programs … ." (Janssen Dep. Ex. 9) If the "type=" attribute were
bound in that fashion to separate programs, those programs would be
invoked automatically upon parsing of the "type=" attribute.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
executable application displays the object. See, e.g., :
Dave Raggett disclosed in connection with his EMBED tag that
"[b]rowsers can then be upgraded to display new formats without
changing their code at all."
As Bill Jannssen disclosed in connection with Dave Raggett's EMBED
tag, a browser could create and manage an X sub-window over an area
where an object is to be displayed. (Janssen Dep. Ex. 10.)
Bill Janssen further discussed that one could achieve this by passing a
window ID to an executable application as to allow that executable
application to paint its output in an X sub-window where an object is to be
displayed. (Janssen Dep. Ex. 8.)
The mechanism of passing a window ID to an executable application to
allow that application to paint its output in an X sub-window was
extensible, in that any application could be used. As one example, Bill
Janssen disclosed the use of XV in this capacity. (Janssen Dep. Ex. 8.) In
that scenario, XV would display an image object.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the

33

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
executable application enables direct interaction with the object. See, e.g., :
For example, Bill Janssen disclosed embedded "insets" that provide
control panels. (Janssen Dep. Ex. 6.)
Bill Janssen also disclosed in connection with the EMBED tag that the
external program "is to handle all events and refresh on the sub-window…
." (Janssen Dep. Ex. 10.) By events, Janssen inherently disclosed user
interaction X events, as I discuss in the X Windows section of my report.
This was explained further by Janssen during the Janssen deposition:
The
21 idea is that -- this is basically a restatement of
22 an idea that I came up with back in 1987, I believe,
23 where you have one perim which creates an X window
24 which it does not want to manage itself for various
25 reasons. But it does want to control the placement
0041
1 of the window inside some larger user interface
2 context and wants to control the size of the window.
3 So it operates as the window's manager, what we call
4 it in X11 terminology. But it passes off control of
5 the inside of the window responding to mouse or
6 keyboard events and redrawing the window.
7
The reference to "refresh" there, "refresh
8 on the sub-window," is actually referring to the act
9 of repainting the window when part of it needs to be
10 repainted. And then the surrounding program, the
11 larger user interface context gets to handle the
12 configuration and the window movement.
The mechanism of passing a window ID to an executable application to
allow that application to paint its output in an X sub-window was
extensible, in that any application could be used. As one example, Bill
Janssen disclosed the use of XV in this capacity. (Janssen Dep. Ex. 8.) In

34

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
that scenario, XV would display an image object. XV was an application
program that enabled direct interaction with an object. For example, with
XV, a user could apply various special effects or scaling factors to a
displayed image object.
Bill Janssen further elaborated during the Janssen Deposition:
2 Q.
And using X11, if I understood your
3 explanation of what was being discussed on www-talk
4 on April 29th, 1993, you could have the browser pass
5 the window ID to XV, and then XV would allow a user
6 to manipulate an image directly with inline of the
7 Web page?
8 A.
That's a pretty good summary, yeah.
9 Q.
In 1993 did you believe that having
10 browsers and external viewers cooperate with each
11 other was an easy project?
12 A.
I'd call it straightforward, because I'd
13 certainly already done it several times in different
14 kinds of browsers. And I knew other people who had
15 done it. For example, the Andrew project at CMU,
16 the Slate project referred to apparently did it,
17 although I don't remember the Slate project. So
18 yes. I would say straightforward, not easy.
(Janssen Dep. at 30.)
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that
interaction with the object is at a first location in the hypermedia document. See,
e.g., :
Bill Janssen disclosed in connection with the EMBED tag that the external
program "is to handle all events and refresh on the sub-window… ."
(Janssen Dep. Ex. 10.) By events, Janssen inherently disclosed user
interaction X events such as mouse events that occur on the sub-window,

35

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
of the type that I discuss in the X Windows section of my report.
This was explained further by Janssen during the Janssen deposition:
The
21 idea is that -- this is basically a restatement of
22 an idea that I came up with back in 1987, I believe,
23 where you have one perim which creates an X window
24 which it does not want to manage itself for various
25 reasons. But it does want to control the placement
0041
1 of the window inside some larger user interface
2 context and wants to control the size of the window.
3 So it operates as the window's manager, what we call
4 it in X11 terminology. But it passes off control of
5 the inside of the window responding to mouse or
6 keyboard events and redrawing the window.
7
The reference to "refresh" there, "refresh
8 on the sub-window," is actually referring to the act
9 of repainting the window when part of it needs to be
10 repainted. And then the surrounding program, the
11 larger user interface context gets to handle the
12 configuration and the window movement.
Also, as explained by Bill Janssen during the Janssen Deposition:
2 Q.
And using X11, if I understood your
3 explanation of what was being discussed on www-talk
4 on April 29th, 1993, you could have the browser pass
5 the window ID to XV, and then XV would allow a user
6 to manipulate an image directly with inline of the
7 Web page?
8 A.
That's a pretty good summary, yeah.
9 Q.
In 1993 did you believe that having
10 browsers and external viewers cooperate with each
11 other was an easy project?

36

Claim Text from ’985 Patent

985-2.a:
The method of claim 1 where: the information to
enable comprises text formats.

Mosaic, HTML+, and Bill Janssen's postings and testimony
12 A.
I'd call it straightforward, because I'd
13 certainly already done it several times in different
14 kinds of browsers. And I knew other people who had
15 done it. For example, the Andrew project at CMU,
16 the Slate project referred to apparently did it,
17 although I don't remember the Slate project. So
18 yes. I would say straightforward, not easy.
(Janssen Dep. at 30.)
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file is text formats. See, e.g., :
Mosaic parses a file to discover tags. From [Andreessen93a], Mosaic
parsed HTML files containing enabling in formation in the from of HTML
markup tags. In addition, from [Andreessen93a], Mosaic parsed files that
contained enabling information in the form of HTML+ tags, including tags
for embedded, interactive fill-out forms.

985-3.a:
The method of claim 2 where the text formats are
HTML tags.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the text
formats are HTML tags. See, e.g., :
Mosaic parses a file to discover tags, including HTML tags.
[Andreessen93a].

985-4.a:
The method of claim 1 where the information
contained in the file received comprises at least
one embed text format.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file includes an embed text format. See, e.g., :
Mosaic processed enabling information in the form of HTML and
HTML+ tags. [Andreessen93a]. It would have been obvious for Mosaic
to process other HTML+ tags, including the EMBED tag disclosed in
[Raggett93a].
The EMBED tag disclosed in [Raggett93a] took the form:

37

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
<embed type="application/eqn"> [equation] </embed>
The result is that an equation would appear in the browser window at a
location corresponding to the location of the EMBED tag.

985-5.a:
The method of claim 1 where the step of
identifying an embed text format comprises:
parsing the received file to identify text formats
included in the received file.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
embed text format is identified by parsing the file containing enabling
information. See, e.g., :

985-6.a:
The method of claim 5 where the parsing is by a
parser in the browser.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
parser is in the browser See, e.g., :

Mosaic parsed enabling information to identify text formats in the form of
HTML and HTML+ tags. [Andreessen93a]. It would have been obvious
for Mosaic to process other HTML+ tags, including the EMBED tag
disclosed in [Raggett93a].
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
The result is that an equation would appear in the browser window at a
location corresponding to the location of the EMBED tag.

Mosaic included a parser to discover tags, including HTML or HTML+
tags. [Andreessen93a].
985-7.a:
The method of claim 1 where the processing
specified by the text formats is specified directly.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the text
formats directly specify the processing. See, e.g., :
Mosaic parses a file to discover tags. These tags include HTML and
HTML+ tags. [Andreessen93a]. The tags directly specify processing,
such as text that should be formatted in certain ways or objects that should
be processed in certain ways. By way of example, [Raggett93a] provides
a host of tags that directly specify processing, including tags that specify
whether text should appear in a certain style (bold, italics, etc.) or that

38

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
specify objects to be embedded within the browser window.

985-8.a:
The method of claim 1 where the correspondence
is implied by the order of the text format in a set of
all of the text formats.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
correspondence is implied by the order of text formats. See, e.g., :

985-9.a:
The method of claim 1 where the embed text
format specifies the location of at least a portion of
an object directly.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
embed text format specifies the location of the object directly. See, e.g., :

985-10.a:
The method of claim 1 where having type
information associated is by including type
information in the embed text format.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the type
information is in the embed text format. See, e.g., :

Mosaic parses a file to discover tags.
Text and objects were rendered in the browser window based on the order
in which corresponding tags were parsed, so the correspondence was
implied by the order of text formats.

The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
It would have been obvious for the EMBED tag to specify the location of
an object, such as its filepath location. Other HTML embed tags, such as
the IMG tag, specified the location of an object directly using a filepath
location. In reference to the EMBED tag disclosed above, Dave Raggett
also disclosed that the EMBED text format could specify the location of
an object directly: "you can also put the foreign data in a separate file
referenced by a URL." (Janssen Dep. Ex. 9).

The "type=" attribute in the EMBED tag disclosed in [Raggett93a] was in
the embed text format:
<embed type="application/eqn"> [equation] </embed>
As Dave Raggett disclosed, "[t]he browser identifies the format of the
embedded data from the 'type' attribute, specified as a MIME content
type." (Jannssen Dep. Ex. 9)

39

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony

985-11.a:
The method of claim 1 where automatically
invoking does not require interactive action by the
user.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that
automatic invocation does not require interactive action by the user. See, e.g., :

985-16.a:
One or more computer readable media encoded
with software comprising computer executable
instructions, for use in a distributed hypermedia
network environment, wherein the network
environment comprises at least one client
workstation and one network server coupled to the
network environment, and when the software is
executed operable to:

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose computer
code physically embodied on a medium. See, e.g., :

In prior art Mosaic 2.4, helper applications display the hypermedia object
and the applications are invoked by the user, not automatically.
However, it was obvious and widely known to persons of ordinary skill at
the time how to automatically initiate invocation of an executable
application. The earlier discussion of inline embedding involved a
determination of the type of external application to be invoked and the
location of an external dataset to be accessed. The default invocation
would normally be automatic.
Dave Raggett disclosed automatic invocation of an executable application
through "binding the MIME content type to the function name fro that
format, e.g. via X resources. …. The functions could be implemented as
separate programs … ." (Janssen Dep. Ex. 9) If the "type=" attribute were
bound in that fashion to separate programs, those programs would be
invoked automatically upon parsing of the "type=" attribute. No
interactive action by a user would be required.

Release of machine readable source code of Mosaic 0.5at access path:
file://tip.ncsa.uiuc.edu/Web/xmosaic/xmosaic-0.5.tar.Z disclosed in
[Andreessen93a]. A listing of current capabilities was disclosed in the
same document as well as machines it was known to compile on.
See also Mosaic Source Code.
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a client
workstation and a network server in a distributed hypermedia environment. See

40

Claim Text from ’985 Patent
985-16.b:
receive, at the client workstation from the network
server over the network environment, at least one
file containing information to enable a browser
application to display at least a portion of a
distributed hypermedia document within a
browser-controlled window;
985-16.c:
cause the client workstation to utilize the browser
to:
985-16.d:
respond to text formats to initiate processing
specified by the text formats;
985-16.e:
display at least a portion of the document within
the browser-controlled window;
985-16.f:
identify an embed text format corresponding to a
first location in the document, the embed text
format specifying the location of at least a portion
of an object external to the file, with the object
having type information associated with it;
985-16.g:
utilize the type information to identify and locate
an executable application external to the file; and
985-16.h:
automatically invoke the executable application, in
response to the identifying of the embed text
format, to execute on the client workstation in
order to display the object and enable an end-user
to directly interact with the object while the object

Mosaic, HTML+, and Bill Janssen's postings and testimony
evidence recited for 985-1.a.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application; a file containing enabling information received from a server; that
the browser displays at least a portion of a distributed hypermedia document; and
that the display is in a browser-controlled window. See evidence recited for 9851.b.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application executing on the client workstation. See evidence recited for 9851.c.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose parsing text
formats. See evidence recited for 985-1.d.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose displaying
at least a portion of the document within the browser-controlled window. See
evidence recited for 985-1.e.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose identifying
an embed text format; that the embed text format corresponds to a first location
in a hypermedia document; that the embed text format specifies the location of at
least a portion of an object external to the file containing enabling information;
and that the object has associated type information. See evidence recited for
985-1.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose using type
information to identify and locate an executable application external to the file.
See evidence recited for 985-1.g.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose
automatically invoking the executable application; that the executable
application displays the object and enables an end-user to directly interact with
it; and that the interaction with the object is at a first location in a hypermedia
document. See evidence recited for 985-1.h.

41

Claim Text from ’985 Patent
is being displayed within a display area created at
the first location within the portion of the
hypermedia document being displayed in the
browser-controlled window.

Mosaic, HTML+, and Bill Janssen's postings and testimony

985-17.a:
The computer readable media of claim 16 where:
the information to enable comprises text formats.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file is text formats. See evidence recited for 985-2.a.

985-18.a:
The computer readable media of claim 17 where:
the text formats are HTML tags.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the text
formats are HTML tags. See evidence recited for 985-3.a.

985-19.a:
The computer readable media of claim 16 where:
the information contained in the file received
comprises at least one embed text format.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file includes an embed text format. See evidence
recited for 985-4.a.

985-20.a:
A method of serving digital information in a
computer network environment having a network
server coupled the network environment, and
where the network environment is a distributed
hypermedia environment, the method comprising:

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose digital
information. See, e.g., :
From [Andreessen93b], “The initial versions of the NCSA Mosaic clients
have the following functionality . . . Graphical display of plain text, rich
(formatted) text, and hypertext, as well as inlined access to graphs,
images, audio clips, video sequences, and scientific data in multimedia
and hypermedia documents.” All that information is digital.
See generally [Hardin93] video.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a network
server in a distributed hypermedia environment. See evidence recited for 9851.a.

42

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
985-20.b:
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a client
communicating via the network server with at least workstation. See evidence recited for 985-1.a.
one client workstation over said network in order
to cause said client workstation to:
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose
communicating via network server in order to cause the client workstation to act.
See, e.g., :

985-20.c:
receive, over said network environment from said

Dave Raggett disclosed in connection with his EMBED tag that
"[b]rowsers can then be upgraded to display new formats without
changing their code at all." (Janssen Dep. Ex. 9) Thus, Mosaic could
interoperate with external applications, including distributed applications,
without any change to Mosaic.
In addition, as Bill Jannssen disclosed in connection with Dave Raggett's
EMBED tag, a browser could create and manage an X sub-window over
an area where an object is to be displayed. (Janssen Dep. Ex. 10.) Bill
Janssen further discussed that one could achieve this by passing a window
ID to an executable application as to allow that executable application to
paint its output in an X sub-window where an object is to be displayed.
(Janssen Dep. Ex. 8.) The mechanism of passing a window ID to an
executable application to allow that application to paint its output in an X
sub-window was extensible, in that any application could be used. As one
example, Bill Janssen disclosed the use of XV in this capacity. (Janssen
Dep. Ex. 8.) However, any application, including a distributed
application, could also be used.
One example of a distributed application is the Collage application: “in a
networked environment, this tool provides the capability to distribute most
of these data analysis and visualization functions synchronously among a
number of users. This is the foundation for the collaborative aspects of this
tool’s functionality.” [Collage92]
From [Andreessen93b], Mosaic interoperated with Collage.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application; a file containing enabling information received from a server; that

43

Claim Text from ’985 Patent
server, at least one file containing information to
enable a browser application to display at least a
portion of a distributed hypermedia document
within a browser-controlled window;
985-20.d:
execute, at said client workstation, a browser
application, with the browser application:
985-20.e:
responding to text formats to initiate processing
specified by the text formats;
985-20.f:
displaying, on said client workstation, at least a
portion of the document within the browsercontrolled window;
985-20.g:
identifying an embed text format which
corresponds to a first location in the document,
where the embed text format specifies the location
of at least a portion of an object external to the file,
where the object has type information associated
with it;
985-20.h:
utilizing the type information to identify and locate
an executable application external to the file; and
985-20.i:
automatically invoking the executable application,
in response to the identifying of the embed text
format, to execute on the client workstation in
order to display the object and enable an end-user
to directly interact with the object while the object
is being displayed within a display area created at
the first location within the portion of the

Mosaic, HTML+, and Bill Janssen's postings and testimony
the browser displays at least a portion of a distributed hypermedia document; and
that the display is in a browser-controlled window. See evidence recited for 9851.b.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application executing on the client workstation. See evidence recited for 9851.c.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose parsing text
formats. See evidence recited for 985-1.d.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose displaying
at least a portion of the document within the browser-controlled window. See
evidence recited for 985-1.e.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose identifying
an embed text format; that the embed text format corresponds to a first location
in a hypermedia document; that the embed text format specifies the location of at
least a portion of an object external to the file containing enabling information;
and that the object has associated type information. See evidence recited for
985-1.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose using type
information to identify and locate an executable application external to the file.
See evidence recited for 985-1.g.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose
automatically invoking the executable application; that the executable
application displays the object and enables an end-user to directly interact with
it; and that the interaction with the object is at a first location in a hypermedia
document. See evidence recited for 985-1.h.

44

Claim Text from ’985 Patent
hypermedia document being displayed in the
browser-controlled window.

Mosaic, HTML+, and Bill Janssen's postings and testimony

985-21.a:
The method of claim 20 where: the information to
enable comprises text formats.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file is text formats. See evidence recited for 985-2.a.

985-22.a:
The method of claim 21 where: the text formats
are HTML tags.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the text
formats are HTML tags. See evidence recited for 985-3.a.

985-23.a:
The method of claim 20 where: the information
contained in the file received comprises at least
one embed text format.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file includes an embed text format. See evidence
recited for 985-4.a.

985-24.a:
A method for running an executable application in
a computer network environment, wherein said
network environment has at least one client
workstation and one network server coupled to a
network environment, the method comprising:
985-24.b:
enabling an end-user to directly interact with an
object by utilizing said executable application to
interactively process said object while the object is
being displayed within a display area created at a
first location within a portion of a hypermedia
document being displayed in a browser-controlled
window,

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a client
workstation and a network server in a network environment. See evidence
recited for 985-1.a.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an
executable application. See evidence recited for 985-1.g.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose displaying
at least a portion of the document within the browser-controlled window. See
evidence recited for 985-1.e.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an object
external to a file containing enabling information. See evidence recited for 9851.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that there is
enabling of an end-user to directly interact with the object. See, e.g., :
45

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
For example, Bill Janssen disclosed embedded "insets" that provide
control panels. (Janssen Dep. Ex. 6.)
Bill Janssen also disclosed in connection with the EMBED tag that the
external program "is to handle all events and refresh on the sub-window…
." (Janssen Dep. Ex. 10.) By events, Janssen inherently disclosed user
interaction X events, as I discuss in the X Windows section of my report.
This was explained further by Janssen during the Janssen deposition:
The
21 idea is that -- this is basically a restatement of
22 an idea that I came up with back in 1987, I believe,
23 where you have one perim which creates an X window
24 which it does not want to manage itself for various
25 reasons. But it does want to control the placement
0041
1 of the window inside some larger user interface
2 context and wants to control the size of the window.
3 So it operates as the window's manager, what we call
4 it in X11 terminology. But it passes off control of
5 the inside of the window responding to mouse or
6 keyboard events and redrawing the window.
7
The reference to "refresh" there, "refresh
8 on the sub-window," is actually referring to the act
9 of repainting the window when part of it needs to be
10 repainted. And then the surrounding program, the
11 larger user interface context gets to handle the
12 configuration and the window movement.
The mechanism of passing a window ID to an executable application to
allow that application to paint its output in an X sub-window was
extensible, in that any application could be used. As one example, Bill
Janssen disclosed the use of XV in this capacity. (Janssen Dep. Ex. 8.) In
that scenario, XV would display an image object. XV was an application

46

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
program that enabled direct interaction with an object. For example, with
XV, a user could apply various special effects or scaling factors to a
displayed image object.
Also, as explained by Bill Janssen during the Janssen Deposition:
2 Q.
And using X11, if I understood your
3 explanation of what was being discussed on www-talk
4 on April 29th, 1993, you could have the browser pass
5 the window ID to XV, and then XV would allow a user
6 to manipulate an image directly with inline of the
7 Web page?
8 A.
That's a pretty good summary, yeah.
9 Q.
In 1993 did you believe that having
10 browsers and external viewers cooperate with each
11 other was an easy project?
12 A.
I'd call it straightforward, because I'd
13 certainly already done it several times in different
14 kinds of browsers. And I knew other people who had
15 done it. For example, the Andrew project at CMU,
16 the Slate project referred to apparently did it,
17 although I don't remember the Slate project. So
18 yes. I would say straightforward, not easy.
(Janssen Dep. at 30.)
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
interaction with the object is at a first location in a hypermedia document. See
evidence recited for 985-1.h.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
object is displayed at a first location within a portion of the hypermedia
document being displayed. See, e.g., :
Mosaic parsed text formats in the form of HTML and HTML+ tags.

47

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
[Andreessen93a]. For prior art Mosaic 2.4, only media of type XBM and
GIF are embedded inline, by the HTML IMG tag, at the first location in
the hypermedia document.
However, it was obvious and widely known to persons of ordinary skill at
the time how to cause the object to be displayed at the first location in a
hypermedia document. There were numerous posts to the www-talk
interest group in mid-1993 about the subject. The issue was often referred
to as “inlining” or “embedding” and the EMBED tag was proposed in the
HTML+ standard [Raggett93a] to handle that situation. That means that
when the presence of a hypermedia object was discovered during parsing,
its representation was displayed in the browser window at the page
position where it was parsed. Among many possibilities, the hypermedia
object could be video, mathematical equations and running applications.
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
The EMBED tag was at a first location in the hypermedia document, and
the result is that an equation would appear in the browser window also at a
first location, corresponding to the location of the EMBED tag.
In addition, Bill Janssen disclosed in connection with Dave Raggett's
EMBED tag that a browser could create and manage an X sub-window
over an area where an object is to be displayed. (Janssen Dep. Ex. 10.)
Bill Janssen further discussed that one could achieve this by passing a
window ID to an executable application as to allow that executable
application to paint its output in an X sub-window where an object is to be
displayed. (Janssen Dep. Ex. 8.)
This was elaborated on by Bill Janssen during the Janssen Deposition:
9
MR. CHANDLER: Q. Let me try again. Does
10 the combination of a www-talk postings on June 14th,
11 1993, and the HTML+ standard dated July 23rd, 1993,
12 describe a technique of how a browser can parse an
13 EMBED tag and then automatically invoke a different
14 stand-alone program to display an image in a sub

48

Claim Text from ’985 Patent

985-24.c:
wherein said network environment is a distributed
hypermedia environment,
985-24.d:
wherein said client workstation receives, over said
network environment from said server, at least one
file containing information to enable said browser
application to display, on said client workstation,
at least said portion of said distributed hypermedia
document within said browser-controlled window,
985-24.e:
wherein said executable application is external to
said file,
985-24.f:
wherein said client workstation executes the
browser application, with the browser application
responding to text formats to initiate processing
specified by the text formats,
985-24.g:
wherein at least said portion of the document is
displayed within the browser-controlled window,
985-24.h:
wherein an embed text format which corresponds
to said first location in the document is identified
by the browser,

Mosaic, HTML+, and Bill Janssen's postings and testimony
15 window that appears within the larger browser window
16 and enables an end user to interact with that image
17 at the same location as where the EMBED tag was in
18 the HTML file?
19
MR. CAMPBELL: Objection; form.
20
THE WITNESS: In my opinion, yes.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a client
workstation and a network server in a distributed hypermedia environment. See
evidence recited for 985-1.a.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application; a file containing enabling information received from a server; that
the browser displays at least a portion of a distributed hypermedia document; and
that the display is in a browser-controlled window. See evidence recited for 9851.b.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an
executable application external to the file. See evidence recited for 985-1.g.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application executing on the client workstation. See evidence recited for 9851.c.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose parsing text
formats. See evidence recited for 985-1.d.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose displaying
at least a portion of the document within the browser-controlled window. See
evidence recited for 985-1.e.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose identifying
an embed text format and that the embed text format corresponds to a first
location in a hypermedia document. See evidence recited for 985-1.f.

49

Claim Text from ’985 Patent
985-24.i:
wherein the embed text format specifies the
location of at least a portion of said object external
to the file,
985-24.j:
wherein the object has type information associated
with it,
985-24.k:
wherein the type information is utilized by the
browser to identify and locate said executable
application, and
985-24.l:
wherein the executable application is automatically
invoked by the browser, in response to the
identifying of the embed text format.

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
embed text format specifies the location of at least a portion of an object external
to the file containing enabling information. See evidence recited for 985-1.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
object has associated type information. See evidence recited for 985-1.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose using type
information to identify and locate an executable application external to the file.
See evidence recited for 985-1.g.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose
automatically invoking the executable application. See evidence recited for 9851.h.

985-25.a:
The method of claim 24 where: the information to
enable comprises text formats.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file is text formats. See evidence recited for 985-2.a.

985-26.a:
The method of claim 25 where: the text formats
are HTML tags.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the text
formats are HTML tags. See evidence recited for 985-3.a.

985-27.a:
The method of claim 24 where: the information
contained in the file received comprises at least
one embed text format.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file includes an embed text format. See evidence
recited for 985-4.a.

985-28.a:
One or more computer readable media encoded
with software comprising an executable

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose computer
code physically embodied on a medium. See evidence recited for 985-16.a.

50

Claim Text from ’985 Patent
application for use in a system having at least one
client workstation and one network server coupled
to a network environment, operable to:

985-28.b:
cause the client workstation to display an object
and enable an end-user to directly interact with
said object while the object is being displayed
within a display area created at a first location
within a portion of a hypermedia document being
displayed in a browser-controlled window,

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a client
workstation and a network server in a network environment. See evidence
recited for 985-1.a.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an
executable application. See evidence recited for 985-1.g.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose displaying
at least a portion of the document within the browser-controlled window. See
evidence recited for 985-1.e.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an object
external to a file containing enabling information. See evidence recited for 9851.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that there is
enabling of an end-user to directly interact with the object. See evidence recited
for 985-24.b.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
interaction with the object is at a first location in a hypermedia document. See
evidence recited for 985-1.h.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
object is displayed within a display area created at the first location.. See, e.g., :
Mosaic parsed text formats in the form of HTML and HTML+ tags.
[Andreessen93a]. For prior art Mosaic 2.4, only media of type XBM and
GIF are embedded inline, by the HTML IMG tag, at the first location in
the hypermedia document.
However, it was obvious and widely known to persons of ordinary skill at
the time how to cause the object to be displayed at the first location in a
hypermedia document. There were numerous posts to the www-talk

51

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
interest group in mid-1993 about the subject. The issue was often referred
to as “inlining” or “embedding” and the EMBED tag was proposed in the
HTML+ standard [Raggett93a] to handle that situation. That means that
when the presence of a hypermedia object was discovered during parsing,
its representation was displayed in the browser window at the page
position where it was parsed. Among many possibilities, the hypermedia
object could be video, mathematical equations and running applications.
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
The EMBED tag was at a first location in the hypermedia document, and
the result is that an equation would appear in the browser window also at a
first location, corresponding to the location of the EMBED tag.
In addition, Bill Jannssen disclosed in connection with Dave Raggett's
EMBED tag that a browser could create and manage an X sub-window
over an area where an object is to be displayed. (Janssen Dep. Ex. 10.)
Bill Janssen further discussed that one could achieve this by passing a
window ID to an executable application as to allow that executable
application to paint its output in an X sub-window where an object is to be
displayed. (Janssen Dep. Ex. 8.)
This was elaborated on by Bill Janssen during the Janssen Deposition:
9
MR. CHANDLER: Q. Let me try again. Does
10 the combination of a www-talk postings on June 14th,
11 1993, and the HTML+ standard dated July 23rd, 1993,
12 describe a technique of how a browser can parse an
13 EMBED tag and then automatically invoke a different
14 stand-alone program to display an image in a sub
15 window that appears within the larger browser window
16 and enables an end user to interact with that image
17 at the same location as where the EMBED tag was in
18 the HTML file?
19
MR. CAMPBELL: Objection; form.
20
THE WITNESS: In my opinion, yes.

52

Claim Text from ’985 Patent
985-28.c:
wherein said network environment is a distributed
hypermedia environment,
985-28.d:
wherein said client workstation receives, over said
network environment from said server, at least one
file containing information to enable said browser
application to display, on said client workstation,
at least said portion of said distributed hypermedia
document within said browser-controlled window,
985-28.e:
wherein said executable application is external to
said file,
985-28.f:
wherein said client workstation executes said
browser application, with the browser application
responding to text formats to initiate processing
specified by the text formats,
985-28.g:
wherein at least said portion of the document is
displayed within the browser-controlled window,
985-28.h:
wherein an embed text format which corresponds
to said first location in the document is identified
by the browser,
985-28.i:
wherein the embed text format specifies the
location of at least a portion of said object external
to the file,
985-28.j:
wherein the object has type information associated

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a client
workstation and a network server in a distributed hypermedia environment. See
evidence recited for 985-1.a.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application; a file containing enabling information received from a server; that
the browser displays at least a portion of a distributed hypermedia document; and
that the display is in a browser-controlled window. See evidence recited for 9851.b.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an
executable application external to the file. See evidence recited for 985-1.g.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application executing on the client workstation. See evidence recited for 9851.c.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose parsing text
formats. See evidence recited for 985-1.d.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose displaying
at least a portion of the document within the browser-controlled window. See
evidence recited for 985-1.e.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose identifying
an embed text format and that the embed text format corresponds to a first
location in a hypermedia document. See evidence recited for 985-1.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
embed text format specifies the location of at least a portion of an object external
to the file containing enabling information. See evidence recited for 985-1.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
object has associated type information. See evidence recited for 985-1.f.

53

Claim Text from ’985 Patent
with it,
985-28.k:
wherein the type information is utilized by the
browser to identify and locate said executable
application, and
985-28.l:
wherein the executable application is automatically
invoked by the browser, in response to the
identifying of the embed text format.
985-36.a:
A method for running an application program in a
distributed hypermedia network environment,
wherein the distributed hypermedia network
environment comprises at least one client
workstation and one remote network server
coupled to the distributed hypermedia network
environment, the method comprising:
985-36.b:
receiving, at the client workstation from the
network server over the distributed hypermedia
network environment, at least one file containing
information to enable a browser application to
display at least a portion of a distributed
hypermedia document within a browser-controlled
window;
985-36.c:
executing the browser application on the client
workstation, with the browser application:
985-36.d:
responding to text formats to initiate processing
specified by the text formats;

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose using type
information to identify and locate an executable application external to the file.
See evidence recited for 985-1.g.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose
automatically invoking the executable application. See evidence recited for 9851.h.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an
application program in a distributed hypermedia environment comprising at least
client workstation and network server. See evidence recited for 985-1.a.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application; a file containing enabling information; that the file is received at the
client workstation from the network server; that the browser displays at least a
portion of a distributed hypermedia document; and that at least a portion of a
hypermedia document is displayed in a browser-controlled window. See
evidence recited for 985-1.b.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application executing on the client workstation. See evidence recited for 9851.c.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose parsing text
formats. See evidence recited for 985-1.d.

54

Claim Text from ’985 Patent
985-36.e:
displaying at least a portion of the document
within the browser-controlled window;
985-36.f:
identifying an embed text format which
corresponds to a first location in the document,
where the embed text format specifies the location
of at least a portion of an object;

985-36.g:
identifying and locating an executable application
associated with the object; and

985-36.h:
automatically invoking the executable application,
in response to the identifying of the embed text
format, in order to enable an end-user to directly

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose displaying
at least a portion of the document within the browser-controlled window. See
evidence recited for 985-1.e.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an object.
See, e.g., :
The EMBED tag disclosed in [Raggett93a] took the form:
<embed type="application/eqn"> [equation] </embed>
The result is that an equation object would appear in the browser window
at a location corresponding to the location of the EMBED tag.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose identifying
an embed text format; that the embed text format corresponds to a first location
in the hypermedia document; and that the embed text format specifies the
location of an object. See evidence recited for 985-1.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
browser identifies and locates an executable application associated with the
object. See, e.g.,
As Dave Raggett disclosed, "[t]he browser identifies the format of the
embedded data from the 'type' attribute, specified as a MIME content
type." (Jannssen Dep. Ex. 9)
Raggett further disclosed that "[t]he functions could be implemented as
separate programs driven via pipes… ." (Janssen Dep. Ex. 9)
One mechanism Raggett disclosed for identifying and launching the
executable application was the use of X resources: "binding the MIME
content type to the function name for that format, e.g. via X resource… ."
(Janssen Dep. Ex. 9)
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose identifying
an embed text format. See evidence recited in 985-1.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose automatic

55

Claim Text from ’985 Patent
interact with the object, while the object is being
displayed within a display area created at the first
location within the portion of the hypermedia
document being displayed in the browsercontrolled window,

Mosaic, HTML+, and Bill Janssen's postings and testimony
invocation of the executable application; that the executable application displays
the object; that the executable application enables direct interaction with the
object; and that interaction with the object is at a first location in the hypermedia
document. See evidence recited in 985-1.h.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
object is displayed at a first location within a portion of the hypermedia
document being displayed. See evidence recited at 985-24.b.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that a
hypermedia document is displayed in a browser window. See, e.g., evidence
recited for 985-1.e.

985-36.i:
wherein the executable application is part of a
distributed application, and

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a
distributed application. See, e.g., :
Dave Raggett disclosed in connection with his EMBED tag that
"[b]rowsers can then be upgraded to display new formats without
changing their code at all." (Janssen Dep. Ex. 9) Thus, Mosaic could
interoperate with external applications, including distributed applications,
without any change to Mosaic.
In addition, as Bill Jannssen disclosed in connection with Dave Raggett's
EMBED tag, a browser could create and manage an X sub-window over
an area where an object is to be displayed. (Janssen Dep. Ex. 10.) Bill
Janssen further discussed that one could achieve this by passing a window
ID to an executable application as to allow that executable application to
paint its output in an X sub-window where an object is to be displayed.
(Janssen Dep. Ex. 8.) The mechanism of passing a window ID to an
executable application to allow that application to paint its output in an X
sub-window was extensible, in that any application could be used. As one
example, Bill Janssen disclosed the use of XV in this capacity. (Janssen

56

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
Dep. Ex. 8.) However, any application, including a distributed
application, could also be used.
One example of a distributed application is the Collage application: “in a
networked environment, this tool provides the capability to distribute most
of these data analysis and visualization functions synchronously among a
number of users. This is the foundation for the collaborative aspects of this
tool’s functionality.” [Collage92]
From [Andreessen93b], Mosaic interoperated with Collage.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
executable application is part of a distributed application. See, e.g., :
Dave Raggett disclosed in connection with his EMBED tag that
"[b]rowsers can then be upgraded to display new formats without
changing their code at all." (Janssen Dep. Ex. 9) Thus, Mosaic could
interoperate with external applications, including distributed applications,
without any change to Mosaic.
In addition, as Bill Jannssen disclosed in connection with Dave Raggett's
EMBED tag, a browser could create and manage an X sub-window over
an area where an object is to be displayed. (Janssen Dep. Ex. 10.) Bill
Janssen further discussed that one could achieve this by passing a window
ID to an executable application as to allow that executable application to
paint its output in an X sub-window where an object is to be displayed.
(Janssen Dep. Ex. 8.) The mechanism of passing a window ID to an
executable application to allow that application to paint its output in an X
sub-window was extensible, in that any application could be used. As one
example, Bill Janssen disclosed the use of XV in this capacity. (Janssen
Dep. Ex. 8.) However, any application, including a distributed
application, could also be used.
One example of a distributed application is the Collage application: “in a
networked environment, this tool provides the capability to distribute most
of these data analysis and visualization functions synchronously among a

57

Claim Text from ’985 Patent

985-36.j:
wherein at least a portion of the distributed
application is for execution on a remote network
server coupled to the distributed hypermedia
network environment.

985-37.a:
The method of claim 36 where: the information to

Mosaic, HTML+, and Bill Janssen's postings and testimony
number of users. This is the foundation for the collaborative aspects of this
tool’s functionality.” [Collage92]
From [Andreessen93b], Mosaic interoperated with Collage.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
distributed application executes at least partially on a network server. See, e.g., :
Dave Raggett disclosed in connection with his EMBED tag that
"[b]rowsers can then be upgraded to display new formats without
changing their code at all." (Janssen Dep. Ex. 9) Thus, Mosaic could
interoperate with external applications, including distributed applications,
without any change to Mosaic.
In addition, as Bill Jannssen disclosed in connection with Dave Raggett's
EMBED tag, a browser could create and manage an X sub-window over
an area where an object is to be displayed. (Janssen Dep. Ex. 10.) Bill
Janssen further discussed that one could achieve this by passing a window
ID to an executable application as to allow that executable application to
paint its output in an X sub-window where an object is to be displayed.
(Janssen Dep. Ex. 8.) The mechanism of passing a window ID to an
executable application to allow that application to paint its output in an X
sub-window was extensible, in that any application could be used. As one
example, Bill Janssen disclosed the use of XV in this capacity. (Janssen
Dep. Ex. 8.) However, any application, including a distributed
application, could also be used.
One example of a distributed application is the Collage application: “in a
networked environment, this tool provides the capability to distribute most
of these data analysis and visualization functions synchronously among a
number of users. This is the foundation for the collaborative aspects of this
tool’s functionality.” [Collage92]
From [Andreessen93b], Mosaic interoperated with Collage.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file is text formats. See evidence recited for 985-2.a.

58

Claim Text from ’985 Patent
enable comprises text formats.

Mosaic, HTML+, and Bill Janssen's postings and testimony

985-38.a:
The method of claim 37 where: the text formats
are HTML tags.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the text
formats are HTML tags. See evidence recited for 985-3.a.

985-39.a:
The method of claim 36 where: the information
contained in the file received comprises at least
one embed text format.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file includes an embed text format. See evidence
recited for 985-4.a.

985-40.a:
A method of serving digital information in a
computer network environment having a network
server coupled to said computer network
environment, and where the network environment
is a distributed hypermedia network environment,
the method comprising:
985-40.b:
communicating via the network server with at least
one remote client workstation over said computer
network environment in order to cause said client
workstation to:

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose digital
information. See evidence recited for 985-20.a.

985-40.c:
receive, over said computer network environment
from the network server, at least one file
containing information to enable a browser
application to display at least a portion of a
distributed hypermedia document within a
browser-controlled window;
985-40.d:

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a network
server in a distributed hypermedia environment. See evidence recited for 9851.a.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a client
workstation. See evidence recited for 985-1.a.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose
communicating via network server in order to cause the client workstation to act.
See evidence recited for 985-20.b.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
application; a file containing enabling information received from a server; that
the browser displays at least a portion of a distributed hypermedia document; and
that the display is in a browser-controlled window. See evidence recited for 9851.b.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose a browser
59

Claim Text from ’985 Patent
execute, at said client workstation, a browser
application, with the browser application:
985-40.e:
responding to text formats to initiate processing
specified by the text formats;
985-40.f:
displaying, on said client workstation, at least a
portion of the document within the browsercontrolled window;
985-40.g:
identifying an embed text format which
corresponds to a first location in the document,
where the embed text format specifies the location
of at least a portion of an object;
985-40.h:
identifying and locating an executable application
associated with the object; and
985-40.i:
automatically invoking the executable application,
in response to the identifying of the embed text
format, in order to enable an end-user to directly
interact with the object while the object is being
displayed within a display area created at the first
location within the portion of the hypermedia
document being displayed in the browsercontrolled window,

Mosaic, HTML+, and Bill Janssen's postings and testimony
application executing on the client workstation. See evidence recited for 9851.c.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose parsing text
formats. See evidence recited for 985-1.d.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose displaying
at least a portion of the document within the browser-controlled window. See
evidence recited for 985-1.e.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose an object.
See evidence recited for 985-36.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose identifying
an embed text format; that the embed text format corresponds to a first location
in the hypermedia document; and that the embed text format specifies the
location of an object. See evidence recited for 985-1.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
browser identifies and locates an executable application associated with the
object. See evidence recited for 985-36.g.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose identifying
an embed text format. See evidence recited in 985-1.f.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose automatic
invocation of the executable application; that the executable application displays
the object; that the executable application enables direct interaction with the
object; and that interaction with the object is at a first location in the hypermedia
document. See evidence recited in 985-1.h.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
object is displayed at a first location within a portion of the hypermedia
document being displayed. See evidence recited for 985-24.b.

60

Claim Text from ’985 Patent

Mosaic, HTML+, and Bill Janssen's postings and testimony
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that a
hypermedia document is displayed in a browser window. See, e.g., evidence
recited for 985-1.e.

985-40.j:
wherein the executable application is part of a
distributed application, and
985-40.k:
wherein at least a portion of the distributed
application is for execution on the network server.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
executable application is part of a distributed application. See evidence recited
in 985-36.i.
Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
distributed application executes at least partially on a network server. See
evidence recited for 985-36.j.

985-41.a:
The method of claim 40 where: the information to
enable comprises text formats.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file is text formats. See evidence recited for 985-2.a.

985-42.a:
The method of claim 41 where: the text formats
are HTML tags.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the text
formats are HTML tags. See evidence recited for 985-3.a.

985-43.a:
The method of claim 40 where: the information
contained in the file received comprises at least
one embed text format.

Mosaic, HTML+, and Bill Janssen's postings and testimony disclose that the
enabling information in the file includes an embed text format. See evidence
recited for 985-4.a.

61