Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 484

ANSWER to 460 Answer to Amended Complaint, Counterclaim by Eolas Technologies Incorporated. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(McKool, Mike)

Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Doc. 484 Att. 3

Exhibit C

Dockets.Justia.com

Claim Chart For CDW Showing Infringement Of The '985 Patent By CDW AutoSuggest*

Claim 36pre A

Claim Language method for an distributed

Evidence from www.cdw.com (AutoSuggest) Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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 CDW AutoSuggest application program runs inside of a Web browser as well as on Web server computers maintained by CDW. The application is automatically invoked while a browser loads and displays an HTML-based search page from a CDW server from a URL such as http://www.cdw.com. The browser running on the client workstation and remote CDW Web servers communicate via the World Wide Web, a distributed hypermedia network environment.

running in a

application program hypermedia network environment, wherein distributed hypermedia network environment comprises one remote server the at least client network coupled to distributed the the

workstation and one

The CDW AutoSuggest 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 CDW search form. The suggested search strings are shown as a menu below the search field. For example, for the search string "las", the CDW
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hypermedia network environment,

* Allegation not limited to the browser in use

Claim

Claim Language method comprising:

Evidence from www.cdw.com (AutoSuggest) AutoSuggest application provides the following output:

Source: www.cdw.com
2 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

The servers which host CDW AutoSuggest are located in the United States.

3 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

Source: Visual IP Trace.
4 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 36a receiving, client from server the at the Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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 browser-controlled window. A CDW 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 CDW search page. The received file, to enable a browser application to display at least a portion of a distributed hypermedia document within a browser-controlled window, is shown in the following screenshot of the CDW homepage, with the AutoSuggest functionality (as well as other pages of the CDW website which include the AutoSuggest feature), is received at the client workstation, from the network server over the distributed hypermedia network environment: at file to browser to of a workstation network the over

distributed hypermedia network environment, least one containing information enable a application portion distributed hypermedia document within a

display at least a

5 of 47 * Allegation not limited to the browser in use

Claim

Claim Language browser-controlled window;

Evidence from www.cdw.com (AutoSuggest)

Source: www.cdw.com. In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory
6 of 47 * Allegation not limited to the browser in use

Claim

Claim Language infringement.

Evidence from www.cdw.com (AutoSuggest) CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 36b executing browser on the application: responding to text formats to initiate The CDW homepage, with the AutoSuggest feature (as well as other pages of the CDW website which include the AutoSuggest 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 HTML 4.0 Transitional//EN'> <html lang='en'><head><title>CDW - IT Products and Services for Business</title> **** <body marginwidth='5' marginheight='5' topmargin='5' leftmargin='5' bgcolor='#FFFFFF' text='#000000' link='#000000' vlink='#000000' alink='#000000' > <div <div <div <div class='shadow1'> class='shadow2'> class='shadow3'> class='fullContainer'> 7 of 47 * Allegation not limited to the browser in use

the application client with browser

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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

workstation,

processing specified by the text formats;

Claim

Claim Language
<a name='Top'></a> <div id='c-container'>

Evidence from www.cdw.com (AutoSuggest)

<a href="#Content" accesskey="2" title="Skip to the main content (Access Key:2)"></a> <a href="#Footer" title="Skip to the Footer"></a> <a href="#AccessKeys" title="Skip to the AccessKey Listings"></a> **** <script language='javascript' type='text/javascript'> <!-cmSetProduction(); cmCreateTechPropsTag('CDW - IT Products and Services for Business', 'HOMEPAGE', '-_--_--_--_-_--_--_--_--_--_--_--_--_--_-'); //--> </script> </div> </div> </div> </div> </body> </html>

Source: www.cdw.com In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 36c displaying at least a portion of the document within the Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each operate in a hypermedia network environment that
8 of 47 * Allegation not limited to the browser in use

Claim

Claim Language browser-controlled window;

Evidence from www.cdw.com (AutoSuggest) includes client workstations executing browsers. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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. The following is an example of the CDW search page being displayed within a window controlled by a browser running on a client workstation:

9 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

Source: www.cdw.com

10 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest) In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

36d

identifying which the where

an

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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 language='javascript' type='text/javascript' src='/global/gui/javascript/AutoSuggest__2_11_0_25352.js'> </script>

embed text format corresponds document, the embed to a first location in

text format specifies the location of at least portion of an object;

Source: www.cdw.com Another example of an embed text format includes, but is not limited to, the following code:
<script> 11 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)
new actb('searchbox2', custom_array,'/AutoComplete.aspx?'); </script>

Source: www.cdw.com

Another example of an embed text format, includes, but is not limited to, the code shown below:
var suggesturl = ""; function actb(id, ca, url) { this.actb_suggesturl = url || (ca ? "" : suggesturl); this.actb_timeOut = -1; this.actb_response = 200; this.actb_lim = 10; **** http.open("GET", this.actb_suggesturl + "key=" + ot, true); **** toreturn += obj.offsetLeft; obj = obj.offsetParent } return toreturn };

Source: The JavaScript file containing the CDW AutoSuggest application. hhttp://www.cdw.com/global/gui/javascript/AutoSuggest__2_11_0_25352.js.

One URL for this file is Additional examples of

this are further contained in the source for the CDW home page, this file and other files accessed by the
12 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest) source code for the CDW home page.

In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 36e identifying locating executable application associated with the object; and and an Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW's servers format the communications so that the browser on the client workstation identifies and locates an executable application associated with the object.

A CDW server identifies the executable application by placing a URL of the AutoSuggest JavaScript file in a HTML <script> tag in a CDW Web page that makes use of the CDW AutoSuggest application. The following excerpt includes, but is not limited to, an example of this <script> tag:
13 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

<script language='javascript' type='text/javascript' src='/global/gui/javascript/AutoSuggest__2_11_0_25352.js'> </script>

Source: www.cdw.com The download and location processes for the executable application can also be observed with the Fiddler debugging tool:

14 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

Source: www.cdw.com (additional examples may be seen in the server-side code, which will be
15 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest) accessed during discovery). In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

16 of 47 * Allegation not limited to the browser in use

Claim 36f

Claim Language automatically invoking executable application, response identifying to of in the the the

Evidence from www.cdw.com (AutoSuggest) Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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.

embed text format, in order to enable an end-user to directly interact with the object, while the object displayed is being a within

The executable application is automatically invoked. An example of this is shown by the initialization code in the following code excerpt:
var suggesturl = ""; function actb(id, ca, url) { this.actb_suggesturl = url || (ca ? "" : suggesturl); this.actb_timeOut = -1; this.actb_response = 200; this.actb_lim = 10; this.actb_maxLim = false; this.actb_firstText = true; this.actb_firstMatch = false; this.actb_fullRefresh = false; this.actb_useIFrame = true; this.actb_useScroll = false; this.actb_mouse = true; this.actb_noDefault = true; this.actb_delimiter = new Array(); 17 of 47

display area created at the first location within the portion of the hypermedia being in the document displayed window,

browser-controlled

* Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)
this.actb_startcheck = 2; this.actb_selectedIndex = -1;

Source: The JavaScript file containing the CDW AutoSuggest application. hhttp://www.cdw.com/global/gui/javascript/AutoSuggest__2_11_0_25352.js. this are further contained in this file and other files.

One URL for this file is Additional examples of

In particular, the initialization code locates a display area. This display area is located on the screen immediately below the 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: this.actb_base_id = id; this.actb_curr = document.getElementById(id);

Source: The JavaScript file containing the CDW AutoSuggest application. hhttp://www.cdw.com/global/gui/javascript/AutoSuggest__2_11_0_25352.js. this are further contained in this file and other files.

One URL for this file is Additional examples of

18 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

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:

construct:

function() { this.actb_curr.actb = this; this.funcClick = this.actb_mouseclick; this.funcCheck = this.actb_checkkey; this.funcHighlight = this.actb_table_highlight; this.funcClear = this.callLater(this.actb_clear, this); this.funcPress = this.callLater(this.actb_keypress, this); this.funcUp = this.callLater(this.actb_goup, this); this.funcDown = this.callLater(this.actb_godown, this); this.funcFocus = this.callLater(this.actb_table_focus, this); this.funcUnfocus = this.callLater(this.actb_table_unfocus, this); addEvent(this.actb_curr, "focus", this.callLater(this.actb_setup, this)); return this

},

Source: The JavaScript file containing the CDW AutoSuggest application. hhttp://www.cdw.com/global/gui/javascript/AutoSuggest__2_11_0_25352.js. this are further contained in this file and other files.

One URL for this file is Additional examples of

An end-user can directly interact with menu of suggested search terms using a keyboard, mouse, and
19 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest) 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 CDW AutoSuggest 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 CDW AutoSuggest executable application will typically show the selected search term with a white highlight on the screen. This example screen shot shows how the user-interaction feature of the CDW AutoSuggest application is displayed on the screen.

20 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

An example of a JavaScript function which enables an end-user to interact with the object that contains the list of suggested search terms is shown in the following code excerpt:

21 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)
actb_checkkey: function(event) { event = event || window.event; var code = event.keyCode; var obj = getTargetElement(event).actb; obj.actb_caretmove = 0; var term = ""; if (obj.actb_toid) { clearTimeout(obj.actb_toid); obj.actb_toid = 0 } switch (code) { case 38: obj.actb_goup(); obj.actb_caretmove = 1; return false; break; case 40: if (!obj.actb_display) { obj.actb_toid = setTimeout(function() { obj.actb_tocomplete.call(obj, -1) }, 25) } else { obj.actb_godown(); obj.actb_caretmove = 1 } return false; break; case 33: for (var c = 0; c < obj.actb_lim; c++) { obj.actb_goup() } obj.actb_caretmove = 1; break; case 34: for (var c = 0; c < obj.actb_lim; c++) { obj.actb_godown() } obj.actb_caretmove = 1; break; case 27: term = obj.actb_curr.value; obj.actb_mouse_on_list = 0; obj.actb_removedisp(); break; case 13: 22 of 47

* Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)
if (obj.actb_display) { obj.actb_caretmove = 1; obj.actb_penter(); return false } break; case 9: if ((obj.actb_display && obj.actb_pos) || obj.actb_toid) { obj.actb_caretmove = 1; obj.actb_penter(); setTimeout(function() { obj.actb_curr.focus() }, 25); return false } break; default: obj.actb_caretmove = 0; obj.actb_toid = setTimeout(function() { obj.actb_tocomplete.call(obj, code) }, (obj.actb_response < 10 ? 10 : obj.actb_response)); break } if (term.length) { setTimeout(function() { obj.actb_curr.value = term }, 25) } return true },

Source: The JavaScript file containing the CDW AutoSuggest application. hhttp://www.cdw.com/global/gui/javascript/AutoSuggest__2_11_0_25352.js. this are further contained in this file and other files.

One URL for this file is Additional examples of

23 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

36g

wherein executable

the

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest feature), the websites themselves and/or the servers hosting those
24 of 47

* Allegation not limited to the browser in use

Claim

Claim Language application is part of a distributed and the is on for a application, portion distributed application execution remote server the of

Evidence from www.cdw.com (AutoSuggest) websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. CDW'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.

wherein at least a

network coupled to distributed

The CDW AutoSuggest executable application which runs on a client workstation communicates via the HTTP protocol with the CDW AutoSuggest server application running on one or more CDW servers. Together the CDW AutoSuggest executable application and CDW AutoSuggest server application are a distributed application coupled by a distributed hypermedia network environment. For example the CDW AutoSuggest executable application will send the following HTTP GET request to the CDW AutoSuggestserver application to receive a list of suggested search terms for the string "las":
GET http://www.cdw.com/AutoComplete.aspx?key=las HTTP/1.1 Host: www.cdw.com Connection: keep-alive User-Agent: Mozilla/5.0 (Windows; U; Windows NT 6.0; en-US) AppleWebKit/532.0 (KHTML, like Gecko) Chrome/3.0.195.38 Safari/532.0 Referer: http://www.cdw.com/ Accept: */* Accept-Encoding: gzip,deflate,sdch Cookie: ... Accept-Language: en-US,en;q=0.8 Accept-Charset: ISO-8859-1,utf-8;q=0.7,*;q=0.3

hypermedia network environment.

25 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

The CDW AutoSuggest server application will send an HTTP GET response with a list of suggested search terms represented as JavaScript code:
HTTP/1.1 200 OK Cache-Control: public, max-age=60 Content-Length: 113 Content-Type: text/xml; charset=utf-8 Expires: Tue, 22 Dec 2009 22:13:34 GMT Last-Modified: Tue, 22 Dec 2009 22:12:34 GMT Vary: * P3P: CP="CAO DSP DEVa TAIa OUR BUS UNI FIN COM NAV INT STA", X-Powered-By: ASP.NET Date: Tue, 22 Dec 2009 22:12:34 GMT Connection: keep-alive <listdata>Laser Printer Drums &amp; Fusers:P01:381|Laser Printer Toners:P0C:2502|Laser Printers:P1:379</listdata>

Source: www.cdw.com Web server The communications between the CDW AutoSuggest executable application and the CDW AutoSuggest server application can be observed using the Fiddler debugging tool as this example screen shot shows:

26 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW provides the infrastructure (e.g. the servers, the HTML code, the executable
27 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest) application, etc.) and documentation to users, and causes the users to use the CDW AutoSuggest feature in its default, intended, and infringing manner.

37

The method of claim 36 where: the to information enable text formats.

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

comprises

38

The method of claim 37 where: the text formats tags. are HTML

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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.
28 of 47

* Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 39 The method of claim 36 where: the information contained in the file received comprises 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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 40pre A method of serving digital information in a computer network environment having a network server Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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
29 of 47 * Allegation not limited to the browser in use

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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.

at least one embed text format.

Claim

Claim Language coupled computer to said and

Evidence from www.cdw.com (AutoSuggest) environment, and where the network environment is distributed hypermedia network environment, the method comprising the following claim elements. See the evidence and information cited for claim element 36pre supra which is expressly incorporated herein. In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW provides the infrastructure (e.g. the servers, the HTML code, the executable
30 of 47

network

environment, environment distributed

where the network is

hypermedia network environment, the method comprising: 40a communicating with at least via one client over computer in

the network server remote workstation said network environment client to: order to cause said workstation

CDW's servers communicate over said computer

network environment with at least one remote client workstation in order to cause said client

* Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest) application, etc.) and documentation to users, and causes the users to use the CDW AutoSuggest feature in its default, intended, and infringing manner.

40b

receive, computer

over

said from file to

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to
31 of 47

network

environment at least one

the network server, containing information enable a application portion distributed hypermedia document within a browser-controlled window; 40c execute at said client workstation, a browser application, with the browser of browser to a

display at least a

* Allegation not limited to the browser in use

Claim

Claim Language application: responding to text formats to initiate processing specified by the text formats;

Evidence from www.cdw.com (AutoSuggest) client workstations in the distributed hypermedia network. CDW'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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

40d

displaying, on said client workstation, at least a portion of the document within the browsercontrolled window;

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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.

32 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest) In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

40e

identifying which the where

an

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

embed text format corresponds document, the embed to a first location in

text format specifies the location of at least a portion of an object;

40f

identifying locating

and an

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest feature), the websites themselves and/or the servers hosting those
33 of 47

* Allegation not limited to the browser in use

Claim

Claim Language executable application associated with the object; and

Evidence from www.cdw.com (AutoSuggest) websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

40g

automatically invoking executable application response identifying to of in the the the

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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.
34 of 47

embed text format, in order to enable an end-user to

* Allegation not limited to the browser in use

Claim

Claim Language directly interact with the object while the object displayed is being a within

Evidence from www.cdw.com (AutoSuggest)

See the evidence and information cited for claim element 36f supra which is expressly incorporated herein. In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

display area created at the first location within the portion of the hypermedia being in the document displayed window, 40h wherein executable application is part of a distributed and the is on for the application, portion distributed application execution of the

browser-controlled Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW'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. See the evidence and information cited for claim element 36g supra which is expressly incorporated herein.
35 of 47 * Allegation not limited to the browser in use

wherein at least a

Claim

Claim Language network server.

Evidence from www.cdw.com (AutoSuggest)

In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 41 The method of claim 40 where: the to information enable text formats. See the evidence and information cited for claim 37 supra which is expressly incorporated herein. In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 42 The text method formats of are Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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 38 supra which is expressly incorporated herein.
36 of 47 * Allegation not limited to the browser in use

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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.

comprises

claim 41 where: the HTML tags.

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest)

In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 43 The method of claim 40 where: the information contained in the file received comprises See the evidence and information cited for claim 39 supra which is expressly incorporated herein. In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 44pre A method in for digital a said network Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. serving information computer environment, at least one embed text format. Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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.

method comprising:
37 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest) See the evidence and information cited for claim element 36pre supra which is expressly incorporated herein. In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

44a

communicating via a network server with at least a remote client network environment order to in workstation over the computer

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers communicate via a network server with at least a remote client workstation over the computer network environment to execute the following claim elements. 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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

44b

receive

commands

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned
38 of 47

* Allegation not limited to the browser in use

Claim

Claim Language from the client with said

Evidence from www.cdw.com (AutoSuggest) pages which use the AutoSuggest 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. CDW'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.

workstation, coupled computer wherein computer least network coupled computer wherein computer environment distributed hypermedia environment, 44c wherein the to said to

the network server network said network client

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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

environment has at workstation and said server the network the network is a

environment,

client

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned
39 of 47

* Allegation not limited to the browser in use

Claim

Claim Language workstation receives, computer environment over the from network

Evidence from www.cdw.com (AutoSuggest) pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

the server at least one file containing information enable display, client a a application on to browser to the

workstation, distributed

at least a portion of hypermedia document within a browser-controlled window, 44d wherein executes with the the client the browser

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW's servers format the communications
40 of 47

workstation browser application,

* Allegation not limited to the browser in use

Claim

Claim Language application: responding to text formats to initiate processing specified by the text formats,

Evidence from www.cdw.com (AutoSuggest) 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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

44e

wherein at least said portion document browser-controlled window, of the is

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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.

displayed within the

41 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest) In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

44f

wherein an embed text format which to a is by the text wherein corresponds document identified browser, the

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

first location in the

embed

format specifies the location of at least a portion of an object,

44g

wherein executable

an

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest feature), the websites themselves and/or the servers hosting those
42 of 47

* Allegation not limited to the browser in use

Claim

Claim Language application automatically invoked browser, response identifying to of by the in the the is

Evidence from www.cdw.com (AutoSuggest) websites (and/or the combination thereof) each operate in a hypermedia network environment that includes client workstations executing browsers. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. CDW'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 herein. In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

embed text format, to enable an enduser interact object object to directly with while is the the being

displayed with in a display area created at the first location within the portion of the hypermedia being in the document displayed window, 44h wherein the

browser-controlled Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned
43 of 47 * Allegation not limited to the browser in use

Claim

Claim Language executable application is part of a distributed and the is on for the application, portion distributed application execution of

Evidence from www.cdw.com (AutoSuggest) pages which use the AutoSuggest 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. CDW's servers transmit a series of communications to client workstations in the distributed hypermedia network. 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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. The executable application is part of a distributed application, and wherein at least a portion of the distributed application is for execution on

wherein at least a

network server;

44 i

executing response commands;

one to

or the

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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 the commands. See the evidence and information cited for claim elements 36pre, 36a, 36e and 36g supra which is expressly incorporated herein.

more instructions in

44 of 47 * Allegation not limited to the browser in use

Claim

Claim Language

Evidence from www.cdw.com (AutoSuggest) In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

44 j

sending information to the to client in the to workstation response executed instructions, the the workstation enable user interact object. said to with information allow processing of at to enddirectly said client

Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest 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. 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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each further comprises the method of claim 44 where: the information to enable comprises text formats.
45 of 47

45

The method of claim 44 where: the to information enable

comprises

* Allegation not limited to the browser in use

Claim

Claim Language text formats.

Evidence from www.cdw.com (AutoSuggest)

See the evidence and information cited for claim 37 supra which is expressly incorporated herein. In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 46 The method of claim 45 where: the text formats tags. are HTML Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each further comprises the method of claim 45 where: the text formats are HTML tags. See the evidence and information cited for claim 38 supra which is expressly incorporated herein. In addition to directly infringing this claim, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner. 47 The method of claim 44 where: the information contained in the file Users of CDW's AutoSuggest feature located on the website www.cdw.com (and other CDW owned pages which use the AutoSuggest feature), the websites themselves and/or the servers hosting those websites (and/or the combination thereof) each further comprises the method of claim 44 where: the information contained in the file received comprises at least one embed text format.
46 of 47 * Allegation not limited to the browser in use

Claim

Claim Language received comprises

Evidence from www.cdw.com (AutoSuggest)

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, CDW indirectly infringes, by inducement and/or contributory infringement. CDW 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 CDW AutoSuggest feature in its default, intended, and infringing manner.

47 of 47 * Allegation not limited to the browser in use