Eolas Technologies Incorporated v. Adobe Systems Incorporated et al
Filing
426
Unopposed MOTION FOR LEAVE TO SUPPLEMENT ITS P.R. 3-1 INFRINGEMENT CONTENTIONS WITH RESPECT TO GOOGLE'S NEWLY ADDED GOOGLE INSTANT FUNCTIONALITY by Eolas Technologies Incorporated. (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(McKool, Mike)
Eolas Technologies Incorporated v. Adobe Systems Incorporated et al
Doc. 426 Att. 1
EXHIBIT A
Dockets.Justia.com
Claim Chart For Google Showing Infringement Of The '985 Patent By Google Instant Search*
Claim for an
Claim Language
Evidence from http://www.google.com (Instant Search) Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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 Google Instant Search application program runs inside of a Web browser as well as on Web server
36pre
A
method
running
application program
in
a
distributed
hypermedia network the
environment,
wherein
distributed
hypermedia network least client displays an HTML-based search computers maintained by Google. The application is automatically invoked while a browser loads and page from a Google server from a URL such as http://http://www.google.com. The browser running on the client workstation and remote Google Web servers communicate via the World Wide Web, a distributed hypermedia network environment. "Search: now faster than the speed of type
environment
comprises
at
one
workstation and one to
remote
network
server
coupled
the the
distributed
hypermedia network
environment,
1 of 62
* Allegation not limited to the browser in use
Claim 9/08/2010 09:51:00 AM
Claim Language
Evidence from http://www.google.com (Instant Search)
method comprising:
Search as you type. It's a simple and straightforward idea--people can get results as they type their queries. Imagining the future of search, the idea of being able to search for partial queries or provide some interactive feedback while searching has come up more than a few times. Along the way, we've even built quite a few demos (notably, Amit Patel in 1999 and Nikhil Bhatla in 2003). Our search-asyou-type demos were thought-provoking--fun, fast and interactive--but fundamentally flawed. Why? Because you don't really want search-as-you-type (no one wants search results for [bike h] in the process of searching for [bike helmets]). You really want search-before-you-type--that is, you want results for the most likely search given what you have already typed. As you can imagine, searching even before someone types isn't easy--which is why we are so excited today to be unveiling Google Instant. Google Instant is search-before-you-type. Instant takes what you have typed already, predicts the most likely completion and streams results in real-time for those predictions--yielding a smarter and faster search that is interactive, predictive and powerful. Here are a few of the core features in Google Instant: · · · Dynamic Results - Google dynamically displays relevant search results as you type so you can quickly interact and click through to the web content you need. Predictions - One of the key technologies in Google Instant is that we predict the rest of your query (in light gray text) before you finish typing. See what you need? Stop typing, look down and find what you're looking for. Scroll to search - Scroll through predictions and see results instantly for each as you arrow
2 of 62
* Allegation not limited to the browser in use
Claim down. ...
Claim Language
Evidence from http://www.google.com (Instant Search)
To bring Google Instant to life, we needed a host of new technologies including new caching systems, the ability to adaptively control the rate at which we show results pages and an optimization of pagerendering JavaScript to help web browsers keep up with the rest of the system. In the end, we needed to produce a system that was able to scale while searching as fast as people can type and think--all while maintaining the relevance and simplicity people expect from Google. The user benefits of Google Instant are many--but the primary one is time saved. Our testing has shown that Google Instant saves the average searcher two to five seconds per search. That may not seem like a lot at first, but it adds up. With Google Instant, we estimate that we'll save our users 11 hours with each passing second! As part of our current rollout, Google Instant will become the core search experience on Google.com for Chrome, Firefox, Safari and IE 8. We'll also be offering Google Instant to our users in France, Germany, Italy, Russia, Spain and the U.K. who are signed in and have Instant-capable browsers. Over the coming weeks and months, we'll work to roll out Google Instant to all geographies and platforms. We're very excited about today's announcement and hope that you are too. Give Google Instant a try and let us know what you think! Posted by Marissa Mayer, VP Search Products & User Experience" See http://googleblog.blogspot.com/2010/09/search-now-faster-than-speed-of-type.html The Google Instant Search application provides to a user a list of search results as they enter a search query in the search field.
3 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) The Google Instant Search application also provides to a user a list of suggested search terms as a user enters a search string into the search string field of the Google search form. strings are shown as a menu below the search field. For example, for the search string "bost", the Google Instant Search application provides the following output: The suggested search
4 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
5 of 62
* Allegation not limited to the browser in use
Claim Source: http://www.google.com
Claim Language
Evidence from http://www.google.com (Instant Search)
"As you can imagine, searching even before someone types isn't easy--which is why we are so excited today to be unveiling Google Instant. Google Instant is search-before-you-type. Instant takes what you have typed already, predicts the most likely completion and streams results in real-time for those predictions--yielding a smarter and faster search that is interactive, predictive and powerful." See http://googleblog.blogspot.com/2010/09/search-now-faster-than-speed-of-type.html. The servers which host Google Instant Search are located in the United States. These servers run the GWS (Google Web Server) software.
6 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
Source: Visual IP Trace.
7 of 62
* Allegation not limited to the browser in use
Claim In addition to directly infringing this claim, Google contributory infringement. Instant Search feature in its default, intended, and infringing manner. the Google
Claim Language
Evidence from http://www.google.com (Instant Search) indirectly infringes, by inducement and/or
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 Google Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google'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 Google 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 Google 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 Google homepage, with the Instant Search functionality (as well as other pages of the Google website which include the Instant Search feature), is received at the client workstation, from the network server over the distributed hypermedia network environment:
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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
hypermedia
document within a
browser-controlled
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
window;
9 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
10 of 62
* Allegation not limited to the browser in use
Claim Source: http://www.google.com. In addition to directly infringing this claim, Google contributory infringement. Instant Search feature in its default, intended, and infringing manner. the client with Google
Claim Language
Evidence from http://www.google.com (Instant Search)
indirectly infringes, by inducement and/or
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 Google
36b
executing
Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google'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 Google homepage, with the Instant Search feature (as well as other pages of the Google website which include the Instant Search 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:
browser
application
on
the
workstation,
the
browser
application: initiate
responding to text
formats
to
processing specified
by the text formats;
11 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
Google **** **** function l() {if(!google.timers.load.t)return;google.timers.load.t.ol=(new Date).getTime();google.timers.load.t.iml=f;google.kCSI.imc=d;google.kCSI.imn=b;google.kCSI.imp=e;google.timers .load.t.xjs&&google.report&&google.report(google.timers.load,google.kCSI)}if(window.addEventListener)window.ad dEventListener("load",l,false);else if(window.attachEvent)window.attachEvent("onload",l);google.timers.load.t.prt=(f=(new Date).getTime()); })();
Source: http://www.google.com In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google Instant Search feature in its default, intended, and infringing manner. Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google'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.
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36c the
displaying at least a
portion
of
document within the
browser-controlled
window;
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
The following is an example of the Google search page being displayed within a window controlled by a browser running on a client workstation:
13 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
Source: http://www.google.com
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* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or contributory infringement. Instant Search feature in its default, intended, and infringing manner. an Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google'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:
Claim Language
Evidence from http://www.google.com (Instant Search)
Source: http://www.google.com Another example of an embed text format includes, but is not limited to, the following code:
(function() { if (!google.nocsixjs && google.timers && google.timers.load.t) google.timers.load.t.xjses = (new Date).getTime(); })(); **** a a d b c b].join(""); I = "/complete/search" + c; **** google.timers.load.t.ol && google.report(google.timers.load, google.kCSI) } }, 0) }; })(); = = = = = Ia[X]; "&client=" + a; d ? "&ds=" + d : ""; W.allowPSuggest && e ? "&tok=" + encodeURIComponent(e) : ""; ["?hl=", google.kHL, a, hb(), d, "&sugexp=ldymls", (c ? "&pq=" + encodeURIComponent(c) : ""),
Source: The JavaScript file containing the Google Instant Search application which is downloaded from the http://www.google.com/extern_js/f directory by a Google search page. Additional examples of this are further contained in the source for the Google home page, this file and other files accessed by the source code for the Google home page.
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* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
Another example of an embed text format, includes, but is not limited to, the code shown below:
(function() { if (!google.nocsixjs && google.timers && google.timers.load.t) google.timers.load.t.xjses = (new Date).getTime(); })(); **** function Jb(a, b, d) { a = [a, "&xhr=t", "&", b, "=", encodeURIComponent(d), "&cp=" + R]; var c = google.enc; if (!c || !c.b64d) c = google; if (J && J.websafe_signing_key && c && c.b64d) { var e = c.b64d(J.websafe_signing_key); b = c.b64e(d); e = new c.HMAC(new c.MD5, e); e.update(d); d = c.b64e(e.digest()); a.push("&qe=" + b); a.push("&qesig=" + d); a.push("&pkc=" + J.pkc) } return a.join("") } function gc(a, b, d) { a = Jb(a, b, d); a = google.msg.send(16, [a], a); if (!a) return j; if (U._t() == 4) a = "http://clients1.google.com" + a; U._s(a); J && google.time() - J.ts > 828E5 && Kb(); return g } **** eb = function(a) { var b = a = a.replace(/[&\?]pq=[^&]*/, ""), 17 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
c = G(a); if (na(c)) { y.a.ra(c); y.a.Na(a); P(); return "" } o.hsa(y.g.Za(), h, h, e); var d = google.jesrstate; if (!d) return a; a = a.replace("/complete/search", "/s"); a = a.replace(/[&\?]client=[^&]*/, ""); d = d.substring(1); c = [a, "pf=p"]; a = O(a); var g = O(d), j = E("safe", window.location.href), l; if (l = j) { d = E("safe", d); d = d != f; l = !d } if (l) g.safe = j; for (var m in g) if (m != "pq" && a[m] === undefined) m == "num" ? c.push("num=10") : c.push(m + "=" + g[m]); m = c.join("&"); y.g.Fc(m); if (J._t() == 4) { J._s(m); return b + "&sclient=psy" } return m }, **** google.timers.load.t.ol && google.report(google.timers.load, google.kCSI) } }, 0) }; })();
18 of 62
* Allegation not limited to the browser in use
Claim Source:
Claim Language
Evidence from http://www.google.com (Instant Search) The JavaScript file containing the Google Instant application which is downloaded from the
http://www.google.com/extern_js/f directory by a Google search page. Additional examples of this are further contained in the source for the Google home page, this file and other files accessed by the source code for the Google home page.
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google Instant Search feature in its default, intended, and infringing manner. and an Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google's servers format the communications so that the browser on the client workstation identifies and locates an executable application associated with the object. "Search: now faster than the speed of type 9/08/2010 09:51:00 AM
36e
identifying
locating
executable
application
associated with the
object; and
19 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) Search as you type. It's a simple and straightforward idea--people can get results as they type their queries. Imagining the future of search, the idea of being able to search for partial queries or provide some interactive feedback while searching has come up more than a few times. Along the way, we've even built quite a few demos (notably, Amit Patel in 1999 and Nikhil Bhatla in 2003). Our search-asyou-type demos were thought-provoking--fun, fast and interactive--but fundamentally flawed. Why? Because you don't really want search-as-you-type (no one wants search results for [bike h] in the process of searching for [bike helmets]). You really want search-before-you-type--that is, you want results for the most likely search given what you have already typed. As you can imagine, searching even before someone types isn't easy--which is why we are so excited today to be unveiling Google Instant. Google Instant is search-before-you-type. Instant takes what you have typed already, predicts the most likely completion and streams results in real-time for those predictions--yielding a smarter and faster search that is interactive, predictive and powerful. Here are a few of the core features in Google Instant: · · · Dynamic Results - Google dynamically displays relevant search results as you type so you can quickly interact and click through to the web content you need. Predictions - One of the key technologies in Google Instant is that we predict the rest of your query (in light gray text) before you finish typing. See what you need? Stop typing, look down and find what you're looking for. Scroll to search - Scroll through predictions and see results instantly for each as you arrow down.
...
20 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) To bring Google Instant to life, we needed a host of new technologies including new caching systems, the ability to adaptively control the rate at which we show results pages and an optimization of pagerendering JavaScript to help web browsers keep up with the rest of the system. In the end, we needed to produce a system that was able to scale while searching as fast as people can type and think--all while maintaining the relevance and simplicity people expect from Google. The user benefits of Google Instant are many--but the primary one is time saved. Our testing has shown that Google Instant saves the average searcher two to five seconds per search. That may not seem like a lot at first, but it adds up. With Google Instant, we estimate that we'll save our users 11 hours with each passing second! As part of our current rollout, Google Instant will become the core search experience on Google.com for Chrome, Firefox, Safari and IE 8. We'll also be offering Google Instant to our users in France, Germany, Italy, Russia, Spain and the U.K. who are signed in and have Instant-capable browsers. Over the coming weeks and months, we'll work to roll out Google Instant to all geographies and platforms. We're very excited about today's announcement and hope that you are too. Give Google Instant a try and let us know what you think! Posted by Marissa Mayer, VP Search Products & User Experience" See http://googleblog.blogspot.com/2010/09/search-now-faster-than-speed-of-type.html A Google server identifies the executable application by placing a URL of the executable application in the JavaScript code. This code excerpt includes, but is not limited to, an example of this:
Source: http://www.google.com The JavaScript code, when processed by a browser will create an HTML
Claim Language
Evidence from http://www.google.com (Instant Search)
Source: www.google.com The download and location processes for the executable application can also be observed with the Fiddler debugging tool:
23 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
Source: http://www.google.com (additional examples may be seen in the server-side code, which will be accessed during discovery).
24 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or contributory infringement. Instant Search feature in its default, intended, and infringing manner. Google 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 Google
25 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) Users of Google's Instant Search feature located on the website http://www.google.com (and other
36f the in the the of
automatically
invoking
Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google'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. "Search: now faster than the speed of type 9/08/2010 09:51:00 AM Search as you type. It's a simple and straightforward idea--people can get results as they type their queries. Imagining the future of search, the idea of being able to search for partial queries or provide some interactive feedback while searching has come up more than a few times. Along the way, we've even built quite a few demos (notably, Amit Patel in 1999 and Nikhil Bhatla in 2003). Our search-asyou-type demos were thought-provoking--fun, fast and interactive--but fundamentally flawed. Why? Because you don't really want search-as-you-type (no one wants search results for [bike h] in the process of searching for [bike helmets]). You really want search-before-you-type--that is, you want results for the most likely search given what you have already typed.
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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
at the first location
within the portion of being the
the
hypermedia
document
displayed
in
browser-controlled
window,
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
As you can imagine, searching even before someone types isn't easy--which is why we are so excited today to be unveiling Google Instant. Google Instant is search-before-you-type. Instant takes what you have typed already, predicts the most likely completion and streams results in real-time for those predictions--yielding a smarter and faster search that is interactive, predictive and powerful. Here are a few of the core features in Google Instant: · · · Dynamic Results - Google dynamically displays relevant search results as you type so you can quickly interact and click through to the web content you need. Predictions - One of the key technologies in Google Instant is that we predict the rest of your query (in light gray text) before you finish typing. See what you need? Stop typing, look down and find what you're looking for. Scroll to search - Scroll through predictions and see results instantly for each as you arrow down.
... To bring Google Instant to life, we needed a host of new technologies including new caching systems, the ability to adaptively control the rate at which we show results pages and an optimization of pagerendering JavaScript to help web browsers keep up with the rest of the system. In the end, we needed to produce a system that was able to scale while searching as fast as people can type and think--all while maintaining the relevance and simplicity people expect from Google. The user benefits of Google Instant are many--but the primary one is time saved. Our testing has shown that Google Instant saves the average searcher two to five seconds per search. That may not seem like a lot at first, but it adds up. With Google Instant, we estimate that we'll save our users 11 hours with each passing second! As part of our current rollout, Google Instant will become the core search experience on Google.com for
27 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) Chrome, Firefox, Safari and IE 8. We'll also be offering Google Instant to our users in France, Germany, Italy, Russia, Spain and the U.K. who are signed in and have Instant-capable browsers. Over the coming weeks and months, we'll work to roll out Google Instant to all geographies and platforms. We're very excited about today's announcement and hope that you are too. Give Google Instant a try and let us know what you think! Posted by Marissa Mayer, VP Search Products & User Experience" See http://googleblog.blogspot.com/2010/09/search-now-faster-than-speed-of-type.html The executable application is automatically invoked. An example of this is shown by the initialization code in the following code excerpt:
(function() { if (!google.nocsixjs && google.timers && google.timers.load.t) google.timers.load.t.xjses = (new Date).getTime(); })(); (function() { var e = {}, f = google.j && google.j.b, g = function(a) { if (google.mc) { if (f) { f = false; return g("bookmarkInit") } for (var b = 0, h = google.mc.length; b < h; b++) { var c = a == "dispose" ? h - b - 1 : b; try { var d = e[google.mc[c][0]]; d && d[a] && d[a](google.mc[c][1]) } catch (i) { google.ml(i, false, { cause: "m" + a, index: c, mid: google.mc[c] && google.mc[c][0] 28 of 62
* Allegation not limited to the browser in use
Claim
}) } } if (a == "dispose") google.mc = null } }; google.med = g; google.register = function(a, b) { e[a] = b }; })(); (function() { var g = true, h = false; google.browser = {}; google.browser.engine = { IE: h, GECKO: h, WEBKIT: h, OPERA: h }; **** google.timers.load.t.ol && google.report(google.timers.load, google.kCSI) } }, 0) }; })();
Claim Language
Evidence from http://www.google.com (Instant Search)
Source: The JavaScript file containing the Google Instant Search application which is downloaded from the http://www.google.com/extern_js/f directory by a Google search page.. Additional examples of this are further contained in this file and other files. Additional initialization code can be found in the JavaScript function "Ya". This function is shown in the following code excerpt:
function Ya(a, b, d, c, e, f) { if (!b) { 29 of 62
* Allegation not limited to the browser in use
Claim
a = document.f || document.gs; b = a.q } if (!(!google.msg.send(13, [b]) && y)) { Wa(d, c); Za(); f && $a(f); ab(); x = a; y = b; q = s = p = y.value; if (!b.init) { ua = document.getElementsByTagName("head")[0]; google.bind(x, "submit", bb); google.bind(y, "paste", function(i) { return cb(i) }); google.bind(y, "cut", function(i) { return cb(i) }); y.setAttribute("autocomplete", "off"); if (W.allowHideSuggestions) { google.bind(y, "blur", Y); } google.bind(y, "keydown", db); y.onkeyup = eb; y.setAttribute("spellcheck", j); **** I = "/complete/search" + c; va = "/complete/deleteitems" + c; R = ib(); kb(); e = la || e && e.length || "https:" == document.location.protocol; ma = ["http", e ? "s" : "", "://"].join(""); e && Ra() }
Claim Language
Evidence from http://www.google.com (Instant Search)
Source: The JavaScript file containing the Google Instant Search application which is downloaded from the http://www.google.com/extern_js/f directory by a Google search page. Additional examples of this
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* Allegation not limited to the browser in use
Claim are further contained in this file and other files.
Claim Language
Evidence from http://www.google.com (Instant Search)
In addition, the "Ya" function calls the function google.bind to install handlers to respond to events from a user. excerpts:
google.bind(x, "submit", bb); google.bind(y, "paste", function(i) { return cb(i) }); google.bind(y, "cut", function(i) { return cb(i) if (W.allowHideSuggestions) { google.bind(y, "blur", Y); } google.bind(y, "keydown", db);
An example of code calling google.bind to install handlers is shown in the following code
Source: The JavaScript file containing the Google Instant Search application which is downloaded from the http://www.google.com/extern_js/f directory by a Google search page. Additional examples of this are further contained in this file and other files. An end-user can directly interact with the Instant Search application using a keyboard, mouse, and other input devices of the client computer to enter a search query in the search field. As a search query is entered in the search field, the Instant Search application will automatically display search results within a display area created at the first location within the portion of the hypermedia document being displayed in the browser-controlled window.
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* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) For example, the following screen shot shows the instant search results for the phrase "Boston" after a user has typed in the search string "bost":
32 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
Source: www.google.com The following is an example of a function in the Google Instant Search application which is used to
33 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) display the instant search results at the first location within the portion of the hypermedia document being displayed in the browser-controlled window:
(function() { if (!google.nocsixjs && google.timers && google.timers.load.t) google.timers.load.t.xjses = (new Date).getTime(); })(); **** function _p(a, c, b, d, e) { if (t == 1 || V(d)) { if (!google.msg.send(6, [c, a])) return i; try { e || W("p", [c, b, 0]); if ((c == "sdb" || c == "taw") && P) { document.body.style.height = document.body.offsetHeight + 4 + "px"; X(D); window.scroll(0, 0); P=i } var f = document.getElementById(c); try { f.innerHTML = b; Ma(b) } catch (j) { var k = f.cloneNode(i); k.innerHTML = b; f.parentNode.replaceChild(k, f) } if (c == "main") { var p = Y("q", a) || Y("as_q", a); p = google.msg.send(4, [p, g], p, h); if (p != h) { a = 0; for (var y; y = ["gs", "bgs", "f"][a++];) if (document[y] && document[y].q.value != p) document[y].q.value = p } } document.getElementById(c).style.visibility = "visible" } catch (u) { K("P", { id: c 34 of 62
* Allegation not limited to the browser in use
Claim
}, u) } I = 21; if (!google.msg.send(18, [c])) return i } } l.p = _p; **** google.timers.load.t.ol && google.report(google.timers.load, google.kCSI) } }, 0) }; })();
Claim Language
Evidence from http://www.google.com (Instant Search)
Source: The JavaScript file containing the Google Instant Search application which is downloaded from the http://www.google.com/extern_js/f directory by a Google search page. Additional examples of this are further contained in this file and other files. An end-user can also 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 Google Instant Search 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.
35 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) The Google Instant Search executable application will typically show the selected search term with a blue highlight on the screen.
Some examples of JavaScript functions which enable an end-user to interact with the object that contains the instant search results and the list of suggested search terms are shown in the following code excerpts:
function db(a) { var b = a.keyCode; ca = j; if (!lb(a, b)) return j; if (b == 27 && nb()) return ob(a, g); if (b == 13) return ob(a); if (pb(b, a)) { L++; L % 3 == 1 && jb(b, a); a.cancelBubble = g; a.returnValue = j; return j } W.useKeyDown && window.setTimeout(function() { jb(b, a) }, 0) } function kb() { fc(); for (var a = 100, b = 1; b <= (K - 2) / 2; ++b) a *= 2; a += 50; oa = window.setTimeout(kb, a) } function fc() { if (!(xa >= 3)) { if (s != q) if (google.msg.send(10, [q]) && q) { gc(I, "q", q) && K++; 36 of 62
* Allegation not limited to the browser in use
Claim
y.focus() } s=q } } function gc(a, b, d) { a = Jb(a, b, d); a = google.msg.send(16, [a], a); if (!a) return j; if (U._t() == 4) a = "http://clients1.google.com" + a; U._s(a); J && google.time() - J.ts > 828E5 && Kb(); return g }
Claim Language
Evidence from http://www.google.com (Instant Search)
Source: The JavaScript file containing the Google Instant Search application which is downloaded from the http://www.google.com/extern_js/f directory by a Google search page. Additional examples of this are further contained in this file and other files.
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google Instant Search feature in its default, intended, and infringing manner.
36g
wherein
the
Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search feature), the websites themselves and/or the servers
37 of 62
executable
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. The executable 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 environment.
application is part of and the is on "Search: now faster than the speed of type 9/08/2010 09:51:00 AM to a for
a
distributed
application,
wherein at least a
portion
of
distributed
application
execution
remote
network
server
coupled
the
distributed
hypermedia network
Search as you type. It's a simple and straightforward idea--people can get results as they type their queries. Imagining the future of search, the idea of being able to search for partial queries or provide some interactive feedback while searching has come up more than a few times. Along the way, we've even built quite a few demos (notably, Amit Patel in 1999 and Nikhil Bhatla in 2003). Our search-asyou-type demos were thought-provoking--fun, fast and interactive--but fundamentally flawed. Why? Because you don't really want search-as-you-type (no one wants search results for [bike h] in the process of searching for [bike helmets]). You really want search-before-you-type--that is, you want results for the most likely search given what you have already typed. As you can imagine, searching even before someone types isn't easy--which is why we are so excited today to be unveiling Google Instant. Google Instant is search-before-you-type. Instant takes what you have typed already, predicts the most likely completion and streams results in real-time for those
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environment.
* Allegation not limited to the browser in use
Claim predictions--yielding a smarter and faster search that is interactive, predictive and powerful. Here are a few of the core features in Google Instant: · · ·
Claim Language
Evidence from http://www.google.com (Instant Search)
Dynamic Results - Google dynamically displays relevant search results as you type so you can quickly interact and click through to the web content you need. Predictions - One of the key technologies in Google Instant is that we predict the rest of your query (in light gray text) before you finish typing. See what you need? Stop typing, look down and find what you're looking for. Scroll to search - Scroll through predictions and see results instantly for each as you arrow down.
... To bring Google Instant to life, we needed a host of new technologies including new caching systems, the ability to adaptively control the rate at which we show results pages and an optimization of pagerendering JavaScript to help web browsers keep up with the rest of the system. In the end, we needed to produce a system that was able to scale while searching as fast as people can type and think--all while maintaining the relevance and simplicity people expect from Google. The user benefits of Google Instant are many--but the primary one is time saved. Our testing has shown that Google Instant saves the average searcher two to five seconds per search. That may not seem like a lot at first, but it adds up. With Google Instant, we estimate that we'll save our users 11 hours with each passing second! As part of our current rollout, Google Instant will become the core search experience on Google.com for Chrome, Firefox, Safari and IE 8. We'll also be offering Google Instant to our users in France, Germany, Italy, Russia, Spain and the U.K. who are signed in and have Instant-capable browsers. Over the coming weeks and months, we'll work to roll out Google Instant to all geographies and platforms. We're very excited about today's announcement and hope that you are too. Give Google Instant a try
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* Allegation not limited to the browser in use
Claim and let us know what you think! Posted by Marissa Mayer, VP Search Products & User Experience" See http://googleblog.blogspot.com/2010/09/search-now-faster-than-speed-of-type.html
Claim Language
Evidence from http://www.google.com (Instant Search)
The Google Instant Search executable application which runs on a client workstation communicates via the HTTP protocol with the Google Instant Search server application running on one or more Google servers. Together the Google Instant Search executable application and Google Instant Search server application are a distributed application coupled by a distributed hypermedia network environment. For example the Google Instant Search executable application will send the following HTTP GET request to the Google Instant Searchserver application to receive a list of suggested search terms and instant search results for the string "bos":
GET http://www.google.com/s?hl=en&expIds=25900,26446,26515&sugexp=ldymls&xhr=t&q=bos&cp=3&pf=p&sclient=psy&site=&s ource=hp&aq=f&aqi=&aql=&oq=bos&gs_rfai=&pbx=1&fp=ab5cdb1806fef4aa&tch=1&ech=3&psi=c_uLTN3WB6iCyAXq2ZCWCQ128424 22933990 HTTP/1.1 Host: www.google.com Connection: keep-alive Referer: http://www.google.com/ Accept: */* User-Agent: Mozilla/5.0 (Windows; U; Windows NT 6.0; en-US) AppleWebKit/534.3 (KHTML, like Gecko) Chrome/6.0.472.55 Safari/534.3 Accept-Encoding: gzip,deflate,sdch Accept-Language: en-US,en;q=0.8 Accept-Charset: ISO-8859-1,utf-8;q=0.7,*;q=0.3 Cookie: ...
40 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) The Google Instant Search server application will send an HTTP GET response with a list of suggested search terms and instant search results represented as JavaScript code:
HTTP/1.1 200 OK Date: Sat, 11 Sep 2010 21:58:33 GMT Expires: -1 Cache-Control: no-cache, must-revalidate Content-Type: application/json Pragma: no-cache Server: gws X-XSS-Protection: 1; mode=block Content-Length: 92147 {e:"ifuLTL6AN8b_lgelsbRg",c:1,u:"http://www.google.com/s?hl\x3den\x26expIds **** d:"[\x22bos\x22,[[\x22bos\\u003Cb\\u003Eton\\u003C\\/b\\u003E\x22,0,\x220\x22],[\x22bos\\u003Cb\\u003Eton market\\u003C\\/b\\u003E **** if(je.zz)je.zz(_loc,_ss);\x3c/script\x3e"}/*""*/
Source: www.google.com Web server The communications between the Google Instant Search executable application and the Google Instant Search server application can be observed using the Fiddler debugging tool as this example screen shot shows:
41 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google Instant Search feature in its default, intended, and infringing manner.
42 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google Instant Search feature in its default, intended, and infringing manner. Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or contributory infringement. Google provides the infrastructure (e.g. the servers, the HTML code, the
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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 http://www.google.com (Instant Search) executable application, etc.) and documentation to users, and causes the users to use the Google Instant Search feature in its default, intended, and infringing manner. Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google Instant Search feature in its default, intended, and infringing manner. Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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 network environment, and where the network environment is distributed hypermedia network environment, the method comprising the following claim elements.
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 said and
environment having
a
network
coupled
to
computer
network
environment,
44 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) See the evidence and information cited for claim element 36pre supra which is expressly incorporated herein. In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or contributory infringement. Instant Search feature in its default, intended, and infringing manner. Google 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 Google Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. Google's servers communicate over said computer network environment with at least one remote client workstation in order to cause said client 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, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google Instant Search feature in its default, intended, and infringing manner.
where the network is
environment
distributed the
hypermedia network
environment,
method comprising: via one client over
40a
communicating
the network server
with
at
least
remote
workstation
said in
computer
network
environment
order to cause said
client
workstation
to:
40b
receive,
over
said
Users of Google's Instant Search feature located on the website http://www.google.com (and other
45 of 62
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google'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, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google Instant Search feature in its default, intended, and infringing manner. Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google'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.
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computer from file to to a
network
environment
the network server,
at
least
one
containing
information
enable
a
browser
application
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
application: initiate
responding to text
formats
to
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search)
processing specified See the evidence and information cited for claim element 36b supra which is expressly incorporated herein. In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or contributory infringement. Instant Search feature in its default, intended, and infringing manner. Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google'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. In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google
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by the text formats;
Google 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 Google
40d
displaying, on said
client
workstation,
at least a portion of
the document within
the
browser-
controlled window;
* Allegation not limited to the browser in use
Claim Instant Search feature in its default, intended, and infringing manner. an
Claim Language
Evidence from http://www.google.com (Instant Search)
40e
identifying
Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google'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, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google Instant Search 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 Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google's servers format
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locating
executable
application
associated with the
* Allegation not limited to the browser in use
Claim
Claim Language
Evidence from http://www.google.com (Instant Search) 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, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google Instant Search feature in its default, intended, and infringing manner. Users of Google's Instant Search feature located on the website http://www.google.com (and other
object; and
40g the in the the of
automatically
invoking
Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. Google'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. See the evidence and information cited for claim element 36f supra which is expressly incorporated
49 of 62
executable
application
response
to
identifying
embed text format, to
in order to enable
an
end-user
directly interact with being
the object while the
object
is
* Allegation not limited to the browser in use
Claim a herein.
Claim Language
Evidence from http://www.google.com (Instant Search)
displayed
within
display area created In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or contributory infringement. Instant Search feature in its default, intended, and infringing manner. Google 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 Google
at the first location
within the portion of being the
the
hypermedia
document
displayed
in
browser-controlled the Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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. Google's servers transmit a series of communications to client workstations in the distributed hypermedia network. The executable 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 the network server. is the herein. In addition to directly infringing this claim, Google indirectly infringes, by inducement and/or
50 of 62
window,
40h
wherein
executable
application is part of and the for
a
distributed
application,
wherein at least a
portion
of
distributed
application
execution
on
See the evidence and information cited for claim element 36g supra which is expressly incorporated
network server.
* Allegation not limited to the browser in use
Claim contributory infringement. Instant Search feature in its default, intended, and infringing manner.
Claim Language
Evidence from http://www.google.com (Instant Search) Google 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 Google Users of Google's Instant Search feature located on the website http://www.google.com (and other Google owned pages which use the Instant Search 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, Google indirectly infringes, by inducement and/or contributory infringement. Google 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 Google Instant Search feature in its default, intended, and infringing manner. of are Users of Google's Instant Search feature located on the website ht
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