Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 425

Unopposed MOTION FOR LEAVE TO SUPPLEMENT ITS P.R. 3-1 INFRINGEMENT CONTENTIONS WITH RESPECT TO STAPLES NEWLY ADDED AUTOCOMPLETE FUNCTIONALITY by Eolas Technologies Incorporated. (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(McKool, Mike)

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Eolas Technologies Incorporated v. Adobe Systems Incorporated et al Doc. 425 Att. 1 EXHIBIT A Dockets.Justia.com Claim Chart For Staples Showing Infringement Of The '985 Patent By Staples AutoComplete* Claim for an Claim Language Evidence from www.staples.com (AutoComplete) Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers and comprise 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 the following claim elements. The Staples AutoComplete application program runs inside of a Web browser as well as on Web server computers maintained by Staples. The application is automatically invoked while a browser loads and displays an HTML-based search page from a Staples server from a URL such as http://www.staples.com. The browser running on the client workstation and remote Staples Web servers communicate via the World Wide Web, a distributed hypermedia network environment. 36pre A method running application program in a distributed hypermedia network the environment, wherein distributed hypermedia network least client environment comprises at one workstation and one to remote network server coupled the distributed hypermedia network the "Introduction 1 of 51 environment, * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) method comprising: Autocomplete an input field to enable users quickly finding and selecting some value, leveraging searching and filtering. By giving an autocompleted field focus or entering something into it, the plugin starts searching for matching entries and displays a list of values to choose from. By entering more characters, the user can filter down the list to better matches. This can be used to enter previous selected values, eg. for tags, to complete an address, eg. enter a city name and get the zip code, or maybe enter email addresses from an addressbook. Both local and remote data can be used: Local is good for small datasets (like an addressbook with 50 entries), remote is necessary for big datasets, like a database with hundreds or millions of entries to select from." Source: http://docs.jquery.com/Plugins/Autocomplete The Staples AutoComplete application provides to a user a list of suggested search terms as a user enters a search string into the search string field of the Staples search form. strings are shown as a menu below the search field. Staples AutoComplete application provides the following output: The suggested search For example, for the search string "laser", the 2 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) Source: www.staples.com The servers which host Staples AutoComplete are located in the United States. These servers run the IBM HTTP Server software. 3 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) 4 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) 5 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) Source: Visual IP Trace. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. the Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the client workstation receives, 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 browsercontrolled window. to A Staples server supplies to a browser application running on a client workstation an HTML file containing information such as HTML tags, text, script code, and style information which enable the browser to display at least a portion of the Staples search page. The received file, to enable a browser application to display at least a portion of a distributed hypermedia document within a browsercontrolled window, is shown in the following screenshot of the Staples homepage, with the 6 of 51 Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples 36a receiving, at client the workstation from the network server over distributed at file hypermedia network environment, least one containing information to a enable a browser application display at least a portion of distributed * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) AutoComplete functionality (as well as other pages of the Staples website which include the AutoComplete feature), is received at the client workstation, from the network server over the distributed hypermedia network environment: hypermedia document within a browser-controlled window; Source: www.staples.com. 7 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. the client with that includes client workstations executing browsers. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the client workstation executes a browser application to respond to text formats to initiate processing specified by the text formats. The Staples homepage, with the AutoComplete feature (as well as other pages of the Staples website which include the AutoComplete feature), comprise text formats, which the browser application responds to, to initiate the processing specified by the text formats. Examples of text formats include the following: <!DOCTYPE html PUBLIC "-//W3C//DTD XHTML 1.0 Transitional//EN" transitional.dtd"> <html xmlns="http://www.w3.org/1999/xhtml" xml:lang="en" lang="en"> "http://www.w3.org/TR/xhtml1/DTD/xhtml1- Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples 36b executing browser application on the workstation, the browser application: initiate responding to text formats to processing specified by the text formats; 8 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) <head> <title>Office Supplies, Printer Ink, Toner, Staples®</title> <link rel="canonical" href="/"/> **** <body id="home" > <div id="wrapall">   Electronics, Computers, Printers **** /************* DO NOT ALTER ANYTHING BELOW THIS LINE ! **************/ var s_code=s.t();if(s_code)document.write(s_code)//--></script>  </body> </html> & Office Furniture | Source: www.staples.com In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment 9 of 51 36c the displaying at least a portion of document within the * Allegation not limited to the browser in use Claim that includes client workstations executing browsers. Claim Language Evidence from www.staples.com (AutoComplete) Staples's servers transmit a series of browser-controlled window; document within the browser-controlled window. communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the browser on the client workstation displays at least a portion of the The following is an example of the Staples search page being displayed within a window controlled by a browser running on a client workstation: 10 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) 11 of 51 * Allegation not limited to the browser in use Claim Source: www.staples.com Claim Language Evidence from www.staples.com (AutoComplete) In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. an Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the browser on the client workstation identifies an embed text format which corresponds to a first location in the document, where the embed text format specifies the location of at least portion of an object. One example an embed text format includes, but is not limited to, the following code: <script type="text/javascript" src="/sbd/js/jquery.autocomplete.staples.js"> </script> Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples 36d identifying embed text format which corresponds to a first location in embed the document, where the text format specifies the location of at least portion of an object; Source: www.staples.com 12 of 51 * Allegation not limited to the browser in use Claim Another example of an embed text format includes, but is not limited to, the following code: <!-/* ================================================== Staples.com 6.0.7 main.js ================================================== */ ////////// // Browser check ////////// // Test for cookies **** var showSearchAutocomplete = (propertyValues.searchAutocomplete == 'ON') ? true : false; if (showSearchAutocomplete && cartclicky != 'overlay' && pageId != 'partner' && !isOverlay) { $("#searchkey").autocomplete('/autocomplete',{selectFirst: false,inputClass:"",loadingClass:""}) .result(function(e,item){setAutoSearch(item);}); } **** //wrapper for element tagging function tagElement(elementID, elementCategory, productID) { if (propertyValues.cmSwitch == "ON") { cmCreateProductElementTag(elementID, elementCategory, productID); } } // --> Claim Language Evidence from www.staples.com (AutoComplete) Source: JavaScript file http://www.staples.com/sbd/js/main.js which is loaded by the Staples home page and other Staples Web pages that use the Autocomplete feature. Another example of an embed text format, includes, but is not limited to, the code shown below: 13 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) (function(a) { a.fn.extend({ autocomplete: function(b, c) { var d = typeof b == "string"; c = a.extend({}, a.Autocompleter.defaults, { url: d ? b : null, data: d ? null : b, delay: d ? a.Autocompleter.defaults.delay : 10, max: c && !c.scroll ? 10 : 150 }, c); **** function f(z, B, y) { if (!g.matchCase) { z = z.toLowerCase(); } var A = m.load(z); if (A && A.length) { B(z, A); } else { if ((typeof g.url == "string") && (g.url.length > 0)) { var C = { timestamp: +new Date() }; a.each(g.extraParams, function(D, E) { C[D] = typeof E == "function" ? E() : E; }); a.ajax({ mode: "abort", port: "autocomplete" + l.name, dataType: g.dataType, url: g.url, data: a.extend({ q: i(z), limit: g.max }, C), success: function(E) { var D = g.parse && g.parse(E) || o(E); m.add(z, D); B(z, D); } }); 14 of 51 * Allegation not limited to the browser in use Claim } else { r.emptyList(); y(z); } } } **** if (g.selectionStart !== undefined) { return { start: g.selectionStart, end: g.selectionEnd }; } } }; })(jQuery); Claim Language Evidence from www.staples.com (AutoComplete) Source: The JavaScript file containing the Autocomplete application. One URL for this file is http://www.staples.com/sbd/js/jquery.autocomplete.staples.js. Additional examples of this are further contained in the source for the Staples home page, this file and other files accessed by the source code for the Staples home page. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. 15 of 51 * Allegation not limited to the browser in use Claim and an that includes client workstations executing browsers. Claim Language Evidence from www.staples.com (AutoComplete) Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the browser on the client workstation identifies and locates an executable application associated with the object. 36e identifying locating executable application associated with the object; and "Introduction Autocomplete an input field to enable users quickly finding and selecting some value, leveraging searching and filtering. By giving an autocompleted field focus or entering something into it, the plugin starts searching for matching entries and displays a list of values to choose from. By entering more characters, the user can filter down the list to better matches. This can be used to enter previous selected values, eg. for tags, to complete an address, eg. enter a city name and get the zip code, or maybe enter email addresses from an addressbook. Both local and remote data can be used: Local is good for small datasets (like an addressbook with 50 entries), remote is necessary for big datasets, like a database with hundreds or millions of entries to select from." 16 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) Source: http://docs.jquery.com/Plugins/Autocomplete A use of the Staples Autocomplete application. Staples server identifies the executable application by placing a URL of the jquery.autocomplete.staples.js JavaScript file in a HTML <script> tag in a Staples Web page that makes The following excerpt includes, but is not limited to, an example of this <script> tag: <script type="text/javascript" src="/sbd/js/jquery.autocomplete.staples.js"> </script> Source: www.staples.com The download and location processes for the executable application can also be observed with the Fiddler debugging tool: 17 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) Source: www.staples.com (additional examples may be seen in the server-side code, which will be 18 of 51 * Allegation not limited to the browser in use Claim accessed during discovery). Claim Language Evidence from www.staples.com (AutoComplete) In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples 19 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples 36f the in that includes client workstations executing browsers. the the of automatically invoking owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the browser on the client workstation automatically invokes 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 browser-controlled window. executable application, response to identifying embed text format, to in order to enable an end-user directly interact with being a the object, while the object is displayed within display area created "Introduction Autocomplete an input field to enable users quickly finding and selecting some value, leveraging searching and filtering. at the first location within the portion of being the hypermedia document displayed in By giving an autocompleted field focus or entering something into it, the plugin starts searching for matching entries and displays a list of values to choose from. By entering more characters, the user can filter down the the list to better matches. This can be used to enter previous selected values, eg. for tags, to complete an address, eg. enter a city name and get the zip code, or maybe enter email addresses from an addressbook. Both local and remote data can be used: Local is good for small datasets (like an addressbook with 50 20 of 51 browser-controlled window, * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) entries), remote is necessary for big datasets, like a database with hundreds or millions of entries to select from." Source: http://docs.jquery.com/Plugins/Autocomplete The executable application is automatically invoked. An example of this is shown by the initialization code in the following code excerpt: (function(a) { a.fn.extend({ autocomplete: function(b, c) { var d = typeof b == "string"; c = a.extend({}, a.Autocompleter.defaults, { url: d ? b : null, data: d ? null : b, delay: d ? a.Autocompleter.defaults.delay : 10, max: c && !c.scroll ? 10 : 150 }, c); c.highlight = c.highlight || function(e) { return e; }; c.formatMatch = c.formatMatch || c.formatItem; return this.each(function() { new a.Autocompleter(this, c); }); }, result: function(b) { return this.bind("result", b); }, search: function(b) { return this.trigger("search", [b]); }, flushCache: function() { return this.trigger("flushCache"); }, setOptions: function(b) { return this.trigger("setOptions", [b]); }, unautocomplete: function() { return this.trigger("unautocomplete"); 21 of 51 * Allegation not limited to the browser in use Claim } }); **** start: g.selectionStart, end: g.selectionEnd }; } } }; })(jQuery); Claim Language Evidence from www.staples.com (AutoComplete) Source: The JavaScript file containing the Autocomplete application. contained in this file and other files. . One URL for this file is http://www.staples.com/sbd/js/jquery.autocomplete.staples.js. Additional examples of this are further In particular, the initialization code creates a display area using dynamic HTML. This display area is located on the screen immediately below the Staples search box at the first location within the portion of the hypermedia document being displayed in the Web browser. The display area is kept hidden by the application until there are actual suggested search terms to be displayed. A portion of the code which creates the display area is shown in the following code excerpt: function n() { if (!s) { return; } 22 of 51 * Allegation not limited to the browser in use Claim c = a("<div/>").hide().addClass(e.resultsClass).css("position", "absolute").appendTo(document.body); Claim Language Evidence from www.staples.com (AutoComplete) Source: The JavaScript file containing the Autocomplete application. contained in this file and other files. . One URL for this file is http://www.staples.com/sbd/js/jquery.autocomplete.staples.js. Additional examples of this are further In addition, the initialization code installs handlers to respond to events from a user. An example that installs handlers is shown in the following code excerpt: o = a("<ul/>").appendTo(c).mouseover(function(t) { if (q(t).nodeName && q(t).nodeName.toUpperCase() == "LI") { f = a("li", o).removeClass(i.ACTIVE).index(q(t)); a(q(t)).addClass(i.ACTIVE); } }).click(function(t) { a(q(t)).addClass(i.ACTIVE); l(); j.focus(); return false; }).mousedown(function() { p.mouseDownOnSelect = true; }).mouseup(function() { p.mouseDownOnSelect = false; }); Source: The JavaScript file containing the Autocomplete application. One URL for this file is http://www.staples.com/sbd/js/jquery.autocomplete.staples.js. Additional examples of this are further 23 of 51 * Allegation not limited to the browser in use Claim contained in this file and other files. . Claim Language Evidence from www.staples.com (AutoComplete) An end-user can directly interact with menu of suggested search terms using a keyboard, mouse, and other input devices of the client computer. For example, by pressing the cursor down key on a keyboard one or more times, a particular search term from the list of suggested search terms can be selected. A search for the selected search term can then be initiated by hitting the enter key on the keyboard. Another method that an end-user can interact with the Staples AutoComplete application is with the mouse of the client computer. The mouse can be used to select a suggested search term and clicking the mouse button will instruct the executable application to search for the selected search term. The Staples AutoComplete executable application will typically show the selected search term with a blue highlight on the screen. This example screen shot shows how the user-interaction feature of the Staples AutoComplete application is displayed on the screen. 24 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) Some examples of JavaScript functions which enable an end-user to interact with the object that contains the list of suggested search terms are shown in the following code excerpts: b.bind((a.browser.opera ? "keypress" : "keydown") + ".autocomplete", function(y) { e = 1; u = y.keyCode; switch (y.keyCode) { 25 of 51 * Allegation not limited to the browser in use Claim case c.UP: y.preventDefault(); if (r.visible()) { r.prev(); } else { t(0, true); } break; case c.DOWN: y.preventDefault(); if (r.visible()) { r.next(); } else { t(0, true); } break; case c.PAGEUP: y.preventDefault(); if (r.visible()) { r.pageUp(); } else { t(0, true); } break; case c.PAGEDOWN: y.preventDefault(); if (r.visible()) { r.pageDown(); } else { t(0, true); } break; case g.multiple && a.trim(g.multipleSeparator) == "," && c.COMMA: case c.TAB: case c.RETURN: if (d()) { y.preventDefault(); w = true; return false; } break; case c.ESC: r.hide(); break; default: clearTimeout(j); Claim Language Evidence from www.staples.com (AutoComplete) 26 of 51 * Allegation not limited to the browser in use Claim j = setTimeout(t, g.delay); break; } Claim Language Evidence from www.staples.com (AutoComplete) Source: The JavaScript file containing the Autocomplete application. contained in this file and other files. One URL for this file is http://www.staples.com/sbd/js/jquery.autocomplete.staples.js. Additional examples of this are further In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. 36g wherein the Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting 27 of 51 executable * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. communications to client workstations in the distributed hypermedia network. Staples's servers transmit a series of The executable application is part of and the environment. is on to a for a distributed application, wherein at least a application is part of a distributed application, and wherein at least a portion of the distributed application is for execution on a remote network server coupled to the distributed hypermedia network portion of distributed application execution remote network server coupled "Introduction Autocomplete an input field to enable users quickly finding and selecting some value, leveraging searching and filtering. By giving an autocompleted field focus or entering something into it, the plugin starts searching for matching entries and displays a list of values to choose from. By entering more characters, the user can filter down the list to better matches. This can be used to enter previous selected values, eg. for tags, to complete an address, eg. enter a city name and get the zip code, or maybe enter email addresses from an addressbook. Both local and remote data can be used: Local is good for small datasets (like an addressbook with 50 entries), remote is necessary for big datasets, like a database with hundreds or millions of entries to select from." Source: http://docs.jquery.com/Plugins/Autocomplete 28 of 51 the distributed hypermedia network environment. * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) The Staples AutoComplete executable application which runs on a client workstation communicates via the HTTP protocol with the Staples AutoComplete server application running on one or more Staples servers. Together the Staples AutoComplete executable application and Staples AutoComplete server application are a distributed application coupled by a distributed hypermedia network environment. For example the Staples AutoComplete executable application will send the following HTTP GET request to the Staples AutoComplete server application to receive a list of suggested search terms for the string "laser": GET http://www.staples.com/autocomplete?q=laser&limit=10&timestamp=1279638640845 HTTP/1.1 Host: www.staples.com User-Agent: Mozilla/5.0 (Windows; U; Windows NT 6.0; en-US; rv:1.9.2.6) Gecko/20100625 Firefox/3.6.6 (.NET CLR 3.5.30729) Accept: */* Accept-Language: en-us,en;q=0.5 Accept-Encoding: gzip,deflate Accept-Charset: ISO-8859-1,utf-8;q=0.7,*;q=0.7 Keep-Alive: 115 Connection: keep-alive X-Requested-With: XMLHttpRequest Referer: http://www.staples.com/ Cookie: ... The Staples AutoComplete server application will send an HTTP GET response with a list of suggested search terms represented as JavaScript code: 29 of 51 * Allegation not limited to the browser in use Claim HTTP/1.1 200 OK Server: IBM_HTTP_Server Last-Modified: Tue, 13 Jul 2010 14:48:06 GMT ETag: "18379-76-48b45f4fbf580"-gzip Accept-Ranges: bytes Content-Length: 118 Content-Type: text/plain Date: Tue, 20 Jul 2010 15:10:52 GMT Connection: keep-alive Vary: Accept-Encoding ZipCodeDebug: Cookie=present_value=present ZipCodeCookie: 02653 Cache-Control: max-age=7200 Expires: Tue, 20 Jul 2010 17:10:52 GMT laser printer laser pointer color laser printer hp laser printer laser paper brother laser printer hp laserjet Claim Language Evidence from www.staples.com (AutoComplete) Source: www.staples.com Web server The communications between the Staples AutoComplete executable application and the Staples AutoComplete server application can be observed using the Fiddler debugging tool as this example screen shot shows: 30 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the 31 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each further comprises the method of claim 36 where: the information to enable comprises text formats. See the evidence and information cited for claim elements 36pre, 36a, and 36b supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each further comprises the method of claim 37 where: the text formats are HTML tags. See the evidence and information cited for claim elements 36pre, 36a, and 36b supra which is expressly incorporated herein. 32 of 51 37 the to The method of claim 36 where: information enable comprises text formats. 38 HTML The method of claim 37 where: the text formats are tags. * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each further comprises the method of claim 36 where: the information contained in the file received comprises at least one embed text format. See the evidence and information cited for claim elements 36pre, 36a, 36b and 36d supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers and comprise a method of serving digital information in a computer network environment having a network server coupled to said computer 33 of 51 Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples 39 the The method of claim 36 where: information contained in the file received comprises at least one embed text format. 40pre A method of serving digital information in a computer network server environment having a network * Allegation not limited to the browser in use Claim said environment, the method comprising the following claim elements. and Claim Language Evidence from www.staples.com (AutoComplete) network environment, and where the network environment is distributed hypermedia network coupled to computer network environment, is herein. where the network See the evidence and information cited for claim element 36pre supra which is expressly incorporated environment distributed In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. via one client over Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. workstation to execute the following claim elements. See the evidence and information cited for claim elements 36pre, 36a, 36e and 36g supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the 34 of 51 hypermedia network the environment, method comprising: 40a communicating the network server with at least remote Staples's servers communicate over said workstation computer network environment with at least one remote client workstation in order to cause said client said in computer network environment order to cause said client workstation to: * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. 40b from that includes client workstations executing browsers. file to to receive, over said Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the client workstation receives, 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 See the evidence and information cited for claim element 36a supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of 35 of 51 computer network environment the network server, at least one containing information enable a browser application a display at least a portion of distributed hypermedia document within a browser-controlled said window; 40c execute at client workstation, a browser application, with the browser * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the client workstation executes a browser application to respond to text formats to initiate processing specified by the text formats. See the evidence and information cited for claim element 36b supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the browser on the client workstation displays at least a portion of the document within the browser-controlled window. See the evidence and information cited for claim element 36c supra which is expressly incorporated herein. application: initiate responding to text formats to processing specified by the text formats; 40d displaying, on said client workstation, at least a portion of the document within the browser- controlled window; 36 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples 40e identifying an Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the browser on the client workstation identifies an embed text format which corresponds to a first location in the document, where the embed text format specifies the location of at least portion of an object. See the evidence and information cited for claim element 36d supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. embed text format which corresponds to a first location in embed the document, where the text format specifies the location of at least a portion of an object; 40f an identifying and Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting 37 of 51 locating * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the browser on the client workstation identifies and locates an executable application associated with the object. See the evidence and information cited for claim element 36e supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples executable application associated with the object; and 40g the in the the of automatically invoking owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the browser on the client workstation automatically invokes 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 browser-controlled 38 of 51 executable application response to identifying embed text format, to in order to enable an end-user * Allegation not limited to the browser in use Claim window. Claim Language Evidence from www.staples.com (AutoComplete) directly interact with being a herein. the object while the See the evidence and information cited for claim element 36f supra which is expressly incorporated object is displayed within display area created In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples at the first location within the portion of being the the hypermedia document displayed in browser-controlled the Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of The executable communications to client workstations in the distributed hypermedia network. window, 40h wherein executable application is part of and the the network server. is the for a distributed application, wherein at least a application is part of a distributed application, and wherein the executable application is part of a distributed application, and wherein at least a portion of the distributed application is for execution on portion of distributed application execution on See the evidence and information cited for claim element 36g supra which is expressly incorporated 39 of 51 * Allegation not limited to the browser in use Claim herein. Claim Language Evidence from www.staples.com (AutoComplete) network server. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each further comprises the method of claim 36 where: the information to enable comprises text formats. See the evidence and information cited for claim 37 supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. of are Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each further comprises the method of claim 37 where: the text formats are HTML tags. the to Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples 41 The method of claim 40 where: information enable comprises text formats. 42 The method claim 41 where: the text formats HTML tags. 40 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) See the evidence and information cited for claim 38 supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each further comprises the method of claim 36 where: the information contained in the file received comprises at least one embed text format. See the evidence and information cited for claim 39 supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples 43 the The method of claim 40 where: information contained in the file received comprises at least one embed text format. 44pre digital in said a A method for Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers and comprise a method for serving digital information in a computer network environment, said method comprising the following claim elements. 41 of 51 serving information computer network environment, * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) method comprising: See the evidence and information cited for claim element 36pre supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. following claim elements. in See the evidence and information cited for claim elements 36pre and 40a supra which are expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. 42 of 51 Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples 44a communicating via a network server with at least a remote client workstation Staples's servers communicate via a network over the computer server with at least a remote client workstation over the computer network environment to execute the network environment order to * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers receive commands from the client workstation over said computer network environment, wherein said computer network environment has at least said client workstation and said network server coupled to the computer network environment, wherein the computer network environment is a distributed hypermedia environment. See the evidence and information cited for claim elements 36pre, 36a, 36e and 36g supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. 44b client with said receive commands from the workstation, the network server coupled to computer said network environment, wherein computer client server the network environment has at least said workstation and said network coupled to computer the is a network environment, wherein computer network environment distributed hypermedia environment, 43 of 51 * Allegation not limited to the browser in use Claim client the that includes client workstations executing browsers. from Claim Language Evidence from www.staples.com (AutoComplete) Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the client workstation receives, over the computer network environment from the server at least one file containing information to enable a browser application to display, on the client workstation, at least a portion of a distributed hypermedia document within a browser-controlled window. See the evidence and information cited for claim element 40a supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of 44 of 51 44c wherein the workstation receives, over computer network environment the server at least to to the one file containing information enable a browser application display, on client workstation, at least a portion of a distributed hypermedia document within a browser-controlled client the window, 44d wherein the workstation executes browser application, * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the client workstation executes a browser application to respond to text formats to initiate processing specified by the text formats. See the evidence and information cited for claim element 36b supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the browser on the client workstation displays at least a portion of the document within the browser-controlled window. See the evidence and information cited for claim element 36c supra which is expressly incorporated herein. 45 of 51 with the browser application: initiate responding to text formats to processing specified by the text formats, 44e the is wherein at least said portion of document displayed within the browser-controlled window, * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the browser on the client workstation identifies an embed text format which corresponds to a first location in the document, where the embed text format specifies the location of at least portion of an object. See the evidence and information cited for claim element 36d supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. an Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples 46 of 51 Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples 44f which to is the text a wherein an embed text format corresponds first location in the document identified by browser, wherein the embed format specifies the location of at least a portion of an object, 44g wherein * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting executable is that includes client workstations executing browsers. the in the the window. of application those websites (and/or the combination thereof) each operate in a hypermedia network environment Staples's servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples's servers format the communications so that the browser on the client workstation automatically invokes 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 browser-controlled automatically invoked by browser, response to identifying embed text format, directly the the herein. being to enable an end- user to interact with See the evidence and information cited for claim element 36f supra which is expressly incorporated object while object contributory infringement. is displayed with in a In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. display area created at the first location within the portion of being the the hypermedia document displayed in browser-controlled window, 47 of 51 * Allegation not limited to the browser in use Claim the Claim Language Evidence from www.staples.com (AutoComplete) Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Staples's servers transmit a series of The executable communications to client workstations in the distributed hypermedia network. application is for execution on the network server. See the evidence and information cited for claim element 36g supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staples provides the infrastructure (e.g. the servers, the HTML code, the executable application, etc.) and documentation to users, and causes the users to use the Staples AutoComplete feature in its default, intended, and infringing manner. 44h wherein executable application is part of and the is the for a distributed application, wherein at least a application is part of a distributed application, and wherein at least a portion of the distributed portion of distributed application execution on network server; 44 i the the commands. executing one or Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each executes one or more instructions in response to more instructions in response to commands; See the evidence and information cited for claim elements 36pre, 36a, 36e and 36g supra which is expressly incorporated herein. 48 of 51 * Allegation not limited to the browser in use Claim Claim Language Evidence from www.staples.com (AutoComplete) In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. AutoComplete feature in its default, intended, and infringing manner. Users of Staples's AutoComplete feature located on the website www.staples.com (and other Staples owned pages which use the AutoComplete feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each sends information to the client workstation in response to the executed instructions, to allow processing of the information at the client workstation to enable said end-user to directly interact with said object. to See the evidence and information cited for claim elements 36pre, 36a, 36e and 36g supra which is expressly incorporated herein. In addition to directly infringing this claim, Staples indirectly infringes, by inducement and/or contributory infringement. Staple

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