Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 795

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

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EXHIBIT A Claim Chart For Staples, Inc Showing Infringement Of The ’985 Patent By Staples’ website* Claim Evidence from Staples’ website method for Users of Staples’ website (www.staples.com), the website itself, and/or the servers hosting that website an (and/or any combination thereof), operate in a hypermedia network environment that includes client application program workstations executing browsers which comprises a method for running an application program in a in distributed distributed hypermedia network environment, wherein the distributed hypermedia network environment hypermedia network comprises at least one client workstation and one remote network server coupled to the distributed environment, 36pre Claim Language hypermedia network environment, the method comprising of the following claim elements. In addition, A running a wherein the distributed Staples provides the infrastructure (e.g. servers, Staples’ websites, etc.), in addition to instructions to users, and causes them to use Staples’ websites in an infringing manner in its default and expected use. hypermedia network environment comprises at one least client workstation and one remote server the network coupled to distributed hypermedia network environment, the method comprising: 1 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/ 2 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 3 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: http://www.staples.com/ 4 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 5 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Visualware's Visual IP Trace 2009, http://www.visualiptrace.com/index.html 36a receiving, client at the Users of Staples’ website, the website itself and/or the servers hosting that website (and/or the workstation combination thereof), operate in a hypermedia network environment that includes client workstations 6 of 67 * Allegation not limited to the browser in use Claim Claim Language from the server Evidence from Staples’ website network over the executing browsers. Staples’ servers transmit a series of communications to client workstations in the distributed hypermedia network. Staples’ servers format the communications so that the client distributed workstation receives, from the network server over the distributed hypermedia network environment, at hypermedia network least one file containing information to enable a browser application to display at least a portion of a environment, at distributed hypermedia document within a browser-controlled window. In addition, Staples provides the file infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes them least one containing to use Staples’ website in an infringing manner in its default and expected use. information enable to a browser application to display at least a portion of a distributed hypermedia document within a browser-controlled window; 7 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.Staples.com/ 8 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 9 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: http://www.staples.com/ 10 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH <!DOCTYPE html PUBLIC "-//W3C//DTD XHTML 1.0 Transitional//EN" "http://www.w3.org/TR/xhtml1/DTD/xhtml1-transitional.dtd"> <html xmlns="http://www.w3.org/1999/xhtml" xml:lang="en" lang="en"> 11 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website <head> <script language='javascript' type='text/javascript'> <!-req_1_1308576537=new Image(); req_1_1308576537.src='/__ssobj/ard.png?5620293430795502737_1-1'+(10131*129165+5922); //--> </script> <title>Office Supplies, Printer Ink, Toner, Electronics, Computers, Printers & Office Furniture | Staples®</title> ... <script src="/sbd/js/jsprops.sjs" type="text/javascript"></script> <script src="/sbd/js/main.js" type="text/javascript"></script> ... </head> <body id="home" >  <script language="JavaScript" type="text/javascript"> ... <div id="home_box1" class="carousel c04"></div> <div id="home_box2" class="carousel c04"></div> 12 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website  <script type="text/javascript"> loadPersonalized('/office/supplies/carouselpersonalization?storeId=10001&langI d=-1&catalogId=10051&scheme=home_box1;home_box2&skuCount=16;16&pageId=' + resxPageId + '&pageType=' + parsedResxPageTitle); </script> ... </body> </html> Source: Lines 1-2974, Source code, HTML Document of webpage at URL http://www.staples.com/ 13 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/ 14 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 36b executing browser on the Users of Staples’ website, the website itself and/or the servers hosting that website (and/or the application combination thereof), operate in a hypermedia network environment that includes client workstations the client executing browsers. Staples’ servers transmit a series of communications to client workstations in the 15 of 67 * Allegation not limited to the browser in use Claim Claim Language workstation, the with browser Evidence from Staples’ website distributed hypermedia network. Staples’ servers format the communications so that the client workstation executes a browser application to respond to text formats to initiate processing specified by application: the text formats. In addition, Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in responding to text addition to instructions to users, and causes them to use Staples’ website in an infringing manner in its formats default and expected use. to initiate processing specified by the text formats; <!DOCTYPE html PUBLIC "-//W3C//DTD XHTML 1.0 Transitional//EN" "http://www.w3.org/TR/xhtml1/DTD/xhtml1-transitional.dtd"> <html xmlns="http://www.w3.org/1999/xhtml" xml:lang="en" lang="en"> <head> <script language='javascript' type='text/javascript'> <!-req_1_1308576537=new Image(); req_1_1308576537.src='/__ssobj/ard.png?5620293430795502737_1-1'+(10131*129165+5922); //--> </script> <title>Office Supplies, Printer Ink, Toner, Electronics, Computers, Printers & Office Furniture | Staples®</title> ... <script src="/sbd/js/jsprops.sjs" type="text/javascript"></script> <script src="/sbd/js/main.js" type="text/javascript"></script> ... </head> 16 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website <body id="home" >  <script language="JavaScript" type="text/javascript"> ... <div id="home_box1" class="carousel c04"></div> <div id="home_box2" class="carousel c04"></div>  <script type="text/javascript"> loadPersonalized('/office/supplies/carouselpersonalization?storeId=10001&langI d=-1&catalogId=10051&scheme=home_box1;home_box2&skuCount=16;16&pageId=' + resxPageId + '&pageType=' + parsedResxPageTitle); </script> ... </body> </html> Source: Lines 1-2974, Source code, HTML Document of webpage at URL http://www.staples.com/ 17 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.Staples.com/ 18 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 19 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.Staples.com/ 20 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 36c displaying at least a Users of Staples’ website, the website itself and/or the servers hosting that website (and/or the portion the combination thereof), operate in a hypermedia network environment that includes client workstations document within the executing browsers. Staples’ servers transmit a series of communications to client workstations in the browser-controlled distributed hypermedia network. of Staples’ servers format the communications so that the client 21 of 67 * Allegation not limited to the browser in use Claim Claim Language window; Evidence from Staples’ website workstation executes a browser application to display at least a portion of the document within the browser-controlled window. In addition, Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an infringing manner in its default and expected use. 22 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/ 23 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 36d identifying an Users of Staples’ website, the website itself and/or the servers hosting that website (and/or the embed text format combination thereof), operate in a hypermedia network environment that includes client workstations which executing browsers. Staples’ servers transmit a series of communications to client workstations in the corresponds to a first location in distributed hypermedia network. Staples’ servers format the communications so that the client 24 of 67 * Allegation not limited to the browser in use Claim Claim Language the where document, the Evidence from Staples’ website workstation executes a browser application to identify an embed text format which corresponds to a first embed location in the document, where the embed text format specifies the location of at least portion of an text format specifies object. In addition, Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition the location of at to instructions to users, and causes them to use Staples’ website in an infringing manner in its default least a portion of an and expected use. object; <!DOCTYPE html PUBLIC "-//W3C//DTD XHTML 1.0 Transitional//EN" "http://www.w3.org/TR/xhtml1/DTD/xhtml1-transitional.dtd"> <html xmlns="http://www.w3.org/1999/xhtml" xml:lang="en" lang="en"> <head> <script language='javascript' type='text/javascript'> <!-req_1_1308576537=new Image(); req_1_1308576537.src='/__ssobj/ard.png?5620293430795502737_1-1'+(10131*129165+5922); //--> </script> <title>Office Supplies, Printer Ink, Toner, Electronics, Computers, Printers & Office Furniture | Staples®</title> ... <script src="/sbd/js/jsprops.sjs" type="text/javascript"></script> <script src="/sbd/js/main.js" type="text/javascript"></script> ... </head> 25 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website <body id="home" >  <script language="JavaScript" type="text/javascript"> ... <div id="home_box1" class="carousel c04"></div> <div id="home_box2" class="carousel c04"></div>  <script type="text/javascript"> loadPersonalized('/office/supplies/carouselpersonalization?storeId=10001&langI d=-1&catalogId=10051&scheme=home_box1;home_box2&skuCount=16;16&pageId=' + resxPageId + '&pageType=' + parsedResxPageTitle); </script> ... </body> </html> Source: Lines 1-2974, Source code, HTML Document of webpage at URL http://www.staples.com/ 26 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website function loadPersonalized(a) { if (!personalizationLoaded) { personalizationUrlStr = a; document.write("<scr" + 'ipt src="/sbd/js/personalization.js" type="text/javascript"></scr' + "ipt>"); personalizationLoaded = true; } else { loadPersonalized_worker(a); } } Source: Lines 1087-1095, Source code, HTML Document of webpage at URL http://www.staples.com/sbd/js/main.js 27 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/ 28 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 36e identifying locating and Users of Staples’ website, the website itself and/or the servers hosting that website (and/or the an combination thereof), operate in a hypermedia network environment that includes client workstations executable executing browsers. Staples’ servers transmit a series of communications to client workstations in the application distributed hypermedia network. Staples’ servers format the communications so that the client 29 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website associated with the workstation executes a browser application that identifies and locates an executable application object; and associated with the object. In addition, Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an infringing manner in its default and expected use. <!DOCTYPE html PUBLIC "-//W3C//DTD XHTML 1.0 Transitional//EN" "http://www.w3.org/TR/xhtml1/DTD/xhtml1-transitional.dtd"> <html xmlns="http://www.w3.org/1999/xhtml" xml:lang="en" lang="en"> <head> <script language='javascript' type='text/javascript'> <!-req_1_1308576537=new Image(); req_1_1308576537.src='/__ssobj/ard.png?5620293430795502737_1-1'+(10131*129165+5922); //--> </script> <title>Office Supplies, Printer Ink, Toner, Electronics, Computers, Printers & Office Furniture | Staples®</title> ... <script src="/sbd/js/jsprops.sjs" type="text/javascript"></script> <script src="/sbd/js/main.js" type="text/javascript"></script> ... </head> <body id="home" > 30 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website  <script language="JavaScript" type="text/javascript"> ... <div id="home_box1" class="carousel c04"></div> <div id="home_box2" class="carousel c04"></div>  <script type="text/javascript"> loadPersonalized('/office/supplies/carouselpersonalization?storeId=10001&langI d=-1&catalogId=10051&scheme=home_box1;home_box2&skuCount=16;16&pageId=' + resxPageId + '&pageType=' + parsedResxPageTitle); </script> ... </body> </html> Source: Lines 1-2974, Source code, HTML Document of webpage at URL http://www.staples.com/ function loadPersonalized(a) { if (!personalizationLoaded) { personalizationUrlStr = a; 31 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website document.write("<scr" + 'ipt src="/sbd/js/personalization.js" type="text/javascript"></scr' + "ipt>"); personalizationLoaded = true; } else { loadPersonalized_worker(a); } } Source: Lines 1087-1095, Source code, HTML Document of webpage at URL http://www.staples.com/sbd/js/main.js 32 of 67 * Allegation not limited to the browser in use Claim 36f Claim Language Evidence from Staples’ website automatically Users of Staples’ website, the website itself and/or the servers hosting that website (and/or the invoking the executable combination thereof), operate in a hypermedia network environment that includes client workstations executing browsers. Staples’ servers transmit a series of communications to client workstations in the application, in distributed hypermedia network. Staples’ servers format the communications so that the client response to the workstation executes a browser application which automatically invokes the executable application, in identifying of the response to the identifying of the embed text format, in order to enable an end-user to directly interact embed text format, with the object, while the object is being displayed within a display area created at the first location in order to enable within the portion of the hypermedia document being displayed in the browser-controlled window. In an to addition, Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to directly interact with instructions to users, and causes them to use Staples’ website in an infringing manner in its default and the object, while the expected use. end-user object is displayed being within a display area created at the first location within the portion of the hypermedia document displayed being in the browser-controlled window, <!DOCTYPE html PUBLIC "-//W3C//DTD XHTML 1.0 Transitional//EN" "http://www.w3.org/TR/xhtml1/DTD/xhtml1-transitional.dtd"> <html xmlns="http://www.w3.org/1999/xhtml" xml:lang="en" lang="en"> <head> <script language='javascript' type='text/javascript'> <!-req_1_1308576537=new Image(); req_1_1308576537.src='/__ssobj/ard.png?5620293430795502737_1-1'+(10131*129165+5922); //--> </script> 33 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website <title>Office Supplies, Printer Ink, Toner, Electronics, Computers, Printers & Office Furniture | Staples®</title> ... <script src="/sbd/js/jsprops.sjs" type="text/javascript"></script> <script src="/sbd/js/main.js" type="text/javascript"></script> ... </head> <body id="home" >  <script language="JavaScript" type="text/javascript"> ... <div id="home_box1" class="carousel c04"></div> <div id="home_box2" class="carousel c04"></div>  <script type="text/javascript"> loadPersonalized('/office/supplies/carouselpersonalization?storeId=10001&langI d=-1&catalogId=10051&scheme=home_box1;home_box2&skuCount=16;16&pageId=' + resxPageId + '&pageType=' + parsedResxPageTitle); </script> 34 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website ... </body> </html> Source: Lines 1-2974, Source code, HTML Document of webpage at URL http://www.staples.com/ function loadPersonalized(a) { if (!personalizationLoaded) { personalizationUrlStr = a; document.write("<scr" + 'ipt src="/sbd/js/personalization.js" type="text/javascript"></scr' + "ipt>"); personalizationLoaded = true; } else { loadPersonalized_worker(a); } } Source: Lines 1087-1095, Source code, HTML Document of webpage at URL http://www.staples.com/sbd/js/main.js 35 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/ 36 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 37 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/ 38 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH GET /office/supplies/carouselpersonalization?storeId=10001&langId=1&catalogId=10051&scheme=home_box1;home_box2&skuCount=16;16&pageId=res11062018 27066429369456&pageType=Office%20Supplies%2C%20Printer%20Ink%2C%20Toner%2C%20E 39 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website lectronics%2C%20Computers%2C%20Printers%20%26%20Office%20Furniture HTTP/1.1 Host: www.staples.com User-Agent: Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.9.2.17) Gecko/20110420 Firefox/3.6.17 (.NET CLR 3.5.30729) Accept: application/xml, text/xml, */* Accept-Language: en-us,en;q=0.5 Accept-Encoding: gzip,deflate Accept-Charset: ISO-8859-1,utf-8;q=0.7,*;q=0.7 Keep-Alive: 115 Connection: keep-alive X-Requested-With: XMLHttpRequest Referer: http://www.staples.com/ Cookie: sslb=B; SSID=BQAanxsAAAAAUAAZS_9NkQQHBBlL_00BAAAAAAAAAAAAGUv_TQCQAAAAlgAAAIQAAABAAAAhQAAAJEAAAB7AAAAlQAAAHcAAAB4AAAAiwAAAI4AAACCAAAAjwAAAHYAAACIAAAAlAAAAIcAAA B8AAAAegAAAA; SSSC=1.G5620293430795502737.1|0.0; SSRT=GUv_TQE; SSPV=EMAAAAAAAAAAAAAAAAAAAAAAAAEAAAAAAAA; JSESSIONID=0000tN0vy5X4bZiJtKB7Bl8DL24:158g0khdc; HasSession=true; WC_SESSION_ESTABLISHED=true; WC_ACTIVEPOINTER=%2d1%2c10001; WC_USERACTIVITY_1002=%2d1002%2c10001%2cnull%2cnull%2cnull%2cnull%2cnull%2cnull%2cnull%2cnull%2 cv0xJGUE9kOBAwyjpe2hiJR42my%2fstZS3pWVGzG3jj4nizXBzkY4BIlRvIhY5cHctFBuVTcTKv8R n%0auyo291GhC%2fS7kaZDn660yv1KTpt9%2bVOlgcQzokqT9ivbYFE9FnZpiupElWYd6I4%3d; WC_GENERIC_ACTIVITYDATA=[180533561%3atrue%3afalse%3a0%3a1Mk63KNNO7P0%2bry5ZO6P 40 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website hfeJ1w8%3d][com.ibm.commerce.context.audit.AuditContext|null][com.ibm.commerce .store.facade.server.context.StoreGeoCodeContext|null%26null%26null%26null%26n ull%26null][CTXSETNAME|Store][com.ibm.commerce.context.globalization.Globaliza tionContext|%2d1%26USD%26%2d1%26USD][com.ibm.commerce.catalog.businesscontext. CatalogContext|10051%26null%26false%26false%26false][com.ibm.commerce.context. base.BaseContext|10001%26%2d1002%26%2d1002%26%2d1][com.ibm.commerce.context.ex periment.ExperimentContext|null][com.ibm.commerce.context.entitlement.Entitlem entContext|10002%2610002%26null%26%2d2000%26null%26null%26null]; stop_mobi=yes; RES_TRACKINGID=970376509022641; RES_SESSIONID=630241963928865; ResonanceSegment=2; mbox=check#true#1308576609|session#1308576548990978614#1308578409|PC#1308576548990-978614.18#1309786150; X21P=3NEznMCGw0GRe2eF00vSLfXtgFpa9uu-j-9JFpcCpGODn2fiPH6djZQ Pragma: no-cache Source: Request sent to http://www.staples.com/office/supplies/carouselpersonalization?storeId=10001&langId=1&catalogId=10051&scheme=home_box1;home_box2&skuCount=16;16&pageId=res11062018270664 29369456&pageType=Office%20Supplies%2C%20Printer%20Ink%2C%20Toner%2C%20Electronics%2 C%20Computers%2C%20Printers%20%26%20Office%20Furniture, captured using Fiddler debugging tool 41 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/ 42 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 36g wherein the Users of Staples’ website, the website itself and/or the servers hosting that website (and/or the executable combination thereof), operate in a hypermedia network environment that includes client workstations application is part of executing browsers. The executable application is part of a distributed application, and wherein at least a a portion of the distributed application is for execution on a remote network server coupled to the distributed 43 of 67 * Allegation not limited to the browser in use Claim Claim Language application, Evidence from Staples’ website and distributed hypermedia network environment. In addition, Staples provides the infrastructure (e.g. wherein at least a servers, Staples’ website, etc.), in addition to instructions to users, and causes them to use Staples’ portion website in an infringing manner in its default and expected use. of the distributed application is for execution on a remote network server the coupled to distributed hypermedia network environment. 44 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/ 45 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 46 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/ 47 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 48 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/ 49 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website Source: Webpage at URL http://www.staples.com/Staples-Multipurpose-Paper-8-1-2-x-14- Case/product_562784?cmArea=SEARCH 50 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website GET /office/supplies/carouselpersonalization?storeId=10001&langId=1&catalogId=10051&scheme=home_box1;home_box2&skuCount=16;16&pageId=res11062018 27066429369456&pageType=Office%20Supplies%2C%20Printer%20Ink%2C%20Toner%2C%20E lectronics%2C%20Computers%2C%20Printers%20%26%20Office%20Furniture HTTP/1.1 Host: www.staples.com User-Agent: Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.9.2.17) Gecko/20110420 Firefox/3.6.17 (.NET CLR 3.5.30729) Accept: application/xml, text/xml, */* Accept-Language: en-us,en;q=0.5 Accept-Encoding: gzip,deflate Accept-Charset: ISO-8859-1,utf-8;q=0.7,*;q=0.7 Keep-Alive: 115 Connection: keep-alive X-Requested-With: XMLHttpRequest Referer: http://www.staples.com/ Cookie: sslb=B; SSID=BQAanxsAAAAAUAAZS_9NkQQHBBlL_00BAAAAAAAAAAAAGUv_TQCQAAAAlgAAAIQAAABAAAAhQAAAJEAAAB7AAAAlQAAAHcAAAB4AAAAiwAAAI4AAACCAAAAjwAAAHYAAACIAAAAlAAAAIcAAA B8AAAAegAAAA; SSSC=1.G5620293430795502737.1|0.0; SSRT=GUv_TQE; SSPV=EMAAAAAAAAAAAAAAAAAAAAAAAAEAAAAAAAA; JSESSIONID=0000tN0vy5X4bZiJtKB7Bl8DL24:158g0khdc; HasSession=true; WC_SESSION_ESTABLISHED=true; WC_ACTIVEPOINTER=%2d1%2c10001; WC_USERACTIVITY_1002=%2d1002%2c10001%2cnull%2cnull%2cnull%2cnull%2cnull%2cnull%2cnull%2cnull%2 51 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website cv0xJGUE9kOBAwyjpe2hiJR42my%2fstZS3pWVGzG3jj4nizXBzkY4BIlRvIhY5cHctFBuVTcTKv8R n%0auyo291GhC%2fS7kaZDn660yv1KTpt9%2bVOlgcQzokqT9ivbYFE9FnZpiupElWYd6I4%3d; WC_GENERIC_ACTIVITYDATA=[180533561%3atrue%3afalse%3a0%3a1Mk63KNNO7P0%2bry5ZO6P hfeJ1w8%3d][com.ibm.commerce.context.audit.AuditContext|null][com.ibm.commerce .store.facade.server.context.StoreGeoCodeContext|null%26null%26null%26null%26n ull%26null][CTXSETNAME|Store][com.ibm.commerce.context.globalization.Globaliza tionContext|%2d1%26USD%26%2d1%26USD][com.ibm.commerce.catalog.businesscontext. CatalogContext|10051%26null%26false%26false%26false][com.ibm.commerce.context. base.BaseContext|10001%26%2d1002%26%2d1002%26%2d1][com.ibm.commerce.context.ex periment.ExperimentContext|null][com.ibm.commerce.context.entitlement.Entitlem entContext|10002%2610002%26null%26%2d2000%26null%26null%26null]; stop_mobi=yes; RES_TRACKINGID=970376509022641; RES_SESSIONID=630241963928865; ResonanceSegment=2; mbox=check#true#1308576609|session#1308576548990978614#1308578409|PC#1308576548990-978614.18#1309786150; X21P=3NEznMCGw0GRe2eF00vSLfXtgFpa9uu-j-9JFpcCpGODn2fiPH6djZQ Pragma: no-cache Source: Request sent to http://www.staples.com/office/supplies/carouselpersonalization?storeId=10001&langId=1&catalogId=10051&scheme=home_box1;home_box2&skuCount=16;16&pageId=res11062018270664 29369456&pageType=Office%20Supplies%2C%20Printer%20Ink%2C%20Toner%2C%20Electronics%2 C%20Computers%2C%20Printers%20%26%20Office%20Furniture, captured using Fiddler debugging tool 52 of 67 * Allegation not limited to the browser in use Claim Evidence from Staples’ website The method of claim Users of Staples’ website, the website itself and/or the servers hosting that website (and/or the 36 37 Claim Language the combination thereof) further comprises the method of claim 36 where: the information to enable to comprises text formats. In addition, Staples provides the infrastructure (e.g. servers, Staples’ website, comprises etc.), in addition to instructions to users, and causes them to use Staples’ website in an infringing where: information enable text formats. manner in its default and expected use. See the evidence and information cited for claim elements 36pre, 36a, and 36b supra which is expressly incorporated herein. 38 The method of claim Users of Staples’ website, the website itself and/or the servers hosting that website (and/or the 37 where: the text combination thereof) further comprises the method of claim 37 where: the text formats are HTML tags. formats In addition, Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to are HTML tags. instructions to users, and causes them to use Staples’ website in an infringing manner in its default and expected use. See the evidence and information cited for claim elements 36pre, 36a, and 36b supra which is expressly incorporated herein. 39 The method of claim Users of Staples’ website, the website itself and/or the servers hosting that website (and/or the 36 combination thereof) further comprises the method of claim 36 where: the information contained in the where: the information file received comprises at least one embed text format. In addition, Staples provides the infrastructure contained in the file (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes them to use received Staples’ website in an infringing manner in its default and expected use. comprises at least one embed 53 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website text format. See the evidence and information cited for claim elements 36pre, 36a, 36b and 36d supra which is expressly incorporated herein. 40pre A method of serving Staples’ website, and/or the servers hosting that website (and/or the combination thereof), operate in a digital information in hypermedia network environment that includes client workstations executing browsers which comprises a computer network a method of serving digital information in a computer network environment having a network server environment having coupled to said computer network environment, and where the network environment is distributed a server hypermedia network environment, the method comprising of the following claim elements. In addition, said Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to network coupled to computer network environment, users, and causes them to use Staples’ website in an infringing manner in its default and expected use. and where the network See the evidence and information cited for claim element 36pre supra which is expressly incorporated environment herein. is a distributed hypermedia network environment, the method comprising: 40a communicating via Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a the network server hypermedia network environment that includes client workstations executing browsers. Staples’ servers with one communicate over said computer network environment with at least one remote client workstation in client order to cause said client workstation to execute the following claim elements. In addition, Staples over provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and at least remote workstation 54 of 67 * Allegation not limited to the browser in use Claim Claim Language said Evidence from Staples’ website computer causes them to use Staples’ website in an infringing manner in its default and expected use. network environment in order to cause said client See the evidence and information cited for claim elements 36pre, 36a, 36e and 36g supra which is expressly incorporated herein. workstation to: 40b receive, over said Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a network hypermedia network environment that includes client workstations executing browsers. Staples’ servers from transmit a series of communications to client workstations in the distributed hypermedia network. the network server, Staples’ servers format the communications so that the client workstation receives, over said computer at network environment from the network server, at least one file containing information to enable a computer environment least one file browser application to display at least a portion of a distributed hypermedia document within a browser- containing to controlled window. In addition, Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), a browser in addition to instructions to users, and causes them to use Staples’ website in an infringing manner in application to information enable its default and expected use. display at least a portion of a distributed See the evidence and information cited for claim element 36a supra which is expressly incorporated herein. hypermedia document within a browser-controlled window; 55 of 67 * Allegation not limited to the browser in use Claim 40c Claim Language execute, at Evidence from Staples’ website said Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a client workstation, a hypermedia network environment that includes client workstations executing browsers. Staples’ servers browser application, transmit a series of communications to client workstations in the distributed hypermedia network. with Staples’ servers format the communications so that the client workstation executes at said client the browser application: workstation, a browser application, with the browser application responding to text formats to initiate responding to text processing specified by the text formats. In addition, Staples provides the infrastructure (e.g. servers, formats Staples’ website, etc.), in addition to instructions to users, and causes them to use Staples’ website in to initiate processing specified an infringing manner in its default and expected use. by the text formats; See the evidence and information cited for claim element 36b supra which is expressly incorporated herein. 40d displaying, on said Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a client workstation, hypermedia network environment that includes client workstations executing browsers. Staples’ servers at least a portion of transmit a series of communications to client workstations in the distributed hypermedia network. the document within Staples’ servers format the communications so that the client workstation executes at said client the workstation, a browser application, with the browser application displaying, on said client workstation, browser- controlled window; at least a portion of the document within the browser-controlled window. In addition, Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an infringing manner in its default and expected use. See the evidence and information cited for claim element 36c supra which is expressly incorporated herein. 56 of 67 * Allegation not limited to the browser in use Claim 40e Claim Language identifying Evidence from Staples’ website an Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a embed text format hypermedia network environment that includes client workstations executing browsers. Staples’ servers which corresponds transmit a series of communications to client workstations in the distributed hypermedia network. to a first location in Staples’ servers format the communications so that the client workstation executes at said client the workstation, a browser application, with the browser application identifying an embed text format which document, embed corresponds to a first location in the document, where the embed text format specifies the location of at text format specifies least a portion of an object. In addition, Staples provides the infrastructure (e.g. servers, Staples’ the location of at website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an least a portion of an infringing manner in its default and expected use. where the object; See the evidence and information cited for claim element 36d supra which is expressly incorporated herein. 40f identifying locating and Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a an hypermedia network environment that includes client workstations executing browsers. Staples’ servers executable transmit a series of communications to client workstations in the distributed hypermedia network. application Staples’ servers format the communications so that the client workstation executes at said client associated with the workstation, a browser application, with the browser application identifying and locating an executable object; and application associated with the object. In addition, Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an infringing manner in its default and expected use. See the evidence and information cited for claim element 36e supra which is expressly incorporated herein. 57 of 67 * Allegation not limited to the browser in use Claim 40g Claim Language Evidence from Staples’ website automatically Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a invoking the executable hypermedia network environment that includes client workstations executing browsers. Staples’ servers transmit a series of communications to client workstations in the distributed hypermedia network. in application, Staples’ servers format the communications so that the client workstation executes at said client response to the workstation, a browser application, with the browser application automatically invoking the executable identifying of the application in response to the identifying of the embed text format, in order to enable an end-user to embed text format, directly interact with the object while the object is being displayed within a display area created at the in order to enable first location within the portion of the hypermedia document being displayed in the browser-controlled an to window. In addition, Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition directly interact with to instructions to users, and causes them to use Staples’ website in an infringing manner in its default the object while the and expected use. end-user object is displayed being within a display area created See the evidence and information cited for claim element 36f supra which is expressly incorporated herein. at the first location within the portion of the hypermedia document displayed being in the browser-controlled window, 40h wherein the Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a executable hypermedia network environment that includes client workstations executing browsers. The executable application is part of application is part of a distributed application, and wherein at least a portion of the distributed 58 of 67 * Allegation not limited to the browser in use Claim Claim Language a distributed application, and wherein at least a portion of Evidence from Staples’ website application is for execution on the network server. In addition, Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an infringing manner in its default and expected use. the distributed See the evidence and information cited for claim element 36g supra which is expressly incorporated application is for execution on the herein. network server. 41 The method of claim Staples’ website and/or the servers hosting that website (and/or the combination thereof), 40 the comprises the method of claim 40 where: the information to enable comprises text formats. In addition, to Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to where: information enable comprises further users, and causes them to use Staples’ website in an infringing manner in its default and expected use. text formats. See the evidence and information cited for claim 37 supra which is expressly incorporated herein. 42 The method of Staples’ website and/or the servers hosting that website (and/or the combination thereof), further claim 41 where: the comprises the method of claim 41 where: the text formats are HTML tags. In addition, Staples provides text the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes formats are HTML tags. them to use Staples’ website in an infringing manner in its default and expected use. See the evidence and information cited for claim 38 supra which is expressly incorporated herein. 43 The method of claim Staples’ website and/or the servers hosting that website (and/or the combination thereof), 40 comprises the method of claim 40 where: the information contained in the file received comprises at where: the further 59 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website information least one embed text format. In addition, Staples provides the infrastructure (e.g. servers, Staples’ contained in the file website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an received infringing manner in its default and expected use. comprises at least one embed text format. 44pre A See the evidence and information cited for claim 39 supra which is expressly incorporated herein. method for Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a serving digital hypermedia network environment that includes client workstations executing browsers which comprises information in a a method for serving digital information in a computer network environment, said method comprising of network the following claim elements. In addition, Staples provides the infrastructure (e.g. servers, Staples’ computer environment, said method comprising: website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an infringing manner in its default and expected use. See the evidence and information cited for claim element 36pre supra which is expressly incorporated herein. 44a communicating via a Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a network server with hypermedia network environment where at least one remote client workstation communicates over the at least a remote computer network environment with a network server. In addition, Staples provides the infrastructure client (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes them to use workstation over the computer Staples’ website in an infringing manner in its default and expected use. network environment order to in See the evidence and information cited for claim elements 36pre and 40a supra which is expressly incorporated herein. 60 of 67 * Allegation not limited to the browser in use Claim 44b Claim Language receive from Evidence from Staples’ website commands Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a the client hypermedia network environment that includes client workstations executing browsers. Staples’ servers workstation, with receive commands from the client workstation, with the network server coupled to said computer the network server network environment, wherein said computer network environment has at least said client workstation coupled said and said network server coupled to the computer network environment, wherein the computer network network environment is a distributed hypermedia environment. In addition, Staples provides the infrastructure to computer environment, wherein (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes them to use said computer Staples’ website in an infringing manner in its default and expected use. network environment has at See the evidence and information cited for claim elements 36pre, 36a, 36e and 36g supra which is least expressly incorporated herein. said client workstation and said network coupled server to computer the network environment, wherein computer the network environment is a distributed hypermedia environment, 61 of 67 * Allegation not limited to the browser in use Claim 44c Claim Language wherein the client workstation receives, Evidence from Staples’ website Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a hypermedia network environment that includes client workstations executing browsers. Staples’ servers over the transmit a series of communications to client workstations in the distributed hypermedia network. network Staples’ servers format the communications so that the client workstation receives, over the computer from network environment from the server at least one file containing information to enable a browser the server, at least application to display, on the client workstation, at least a portion of a distributed hypermedia document one file containing within a browser-controlled window. In addition, Staples provides the infrastructure (e.g. servers, information Staples’ website, etc.), in addition to instructions to users, and causes them to use Staples’ website in computer environment enable to a browser application an infringing manner in its default and expected use. to display, client on the workstation, See the evidence and information cited for claim element 36a supra which is expressly incorporated herein. at least a portion of a distributed hypermedia document within a browser-controlled window, 44d wherein the client workstation executes Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a hypermedia network environment that includes client workstations executing browsers. Staples’ servers the transmit a series of communications to client workstations in the distributed hypermedia network. browser application, Staples’ servers format the communications so that the client workstation executes a browser to with respond to text formats to initiate processing specified by the text formats. In addition, Staples provides the browser 62 of 67 * Allegation not limited to the browser in use Claim Claim Language Evidence from Staples’ website application the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes responding to text them to use Staples’ website in an infringing manner in its default and expected use. formats to initiate processing specified by the text formats, herein. wherein at least said Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a portion the hypermedia network environment that includes client workstations executing browsers. Staples’ servers is transmit a series of communications to client workstations in the distributed hypermedia network. displayed within the Staples’ servers format the communications so that the client workstation executes a browser to display browser-controlled at least said portion of the document within the browser-controlled window. In addition, Staples window, 44e See the evidence and information cited for claim element 36b supra which is expressly incorporated provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and of document causes them to use Staples’ website in an infringing manner in its default and expected use. See the evidence and information cited for claim element 36c supra which is expressly incorporated herein. 44f wherein an embed Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a text which hypermedia network environment that includes client workstations executing browsers. Staples’ servers to a transmit a series of communications to client workstations in the distributed hypermedia network. first location in the Staples’ servers format the communications so that the client workstation executes a browser to identify document is an embed text format which corresponds to a first location in the document, wherein the embed text format corresponds identified by the format specifies the location of at least a portion of an object. In addition, Staples provides the browser, wherein infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes them 63 of 67 * Allegation not limited to the browser in use Claim Claim Language the embed text Evidence from Staples’ website to use Staples’ website in an infringing manner in its default and expected use. format specifies the location of at least a portion of an object, See the evidence and information cited for claim element 36d supra which is expressly incorporated herein. 44g wherein an Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a executable hypermedia network environment that includes client workstations executing browsers. Staples’ servers application transmit a series of communications to client workstations in the distributed hypermedia network. associated with the Staples’ servers format the communications so that the client workstation executes a browser to object is identified automatically invoke an executable application, in response to the identifying of the embed text format, and located by the to enable an end-user to directly interact with the object while the object is being displayed with in a browser, wherein display area created at the first location within the portion of the hypermedia document being displayed executable in the browser-controlled window. In addition, Staples provides the infrastructure (e.g. servers, Staples’ the application is infringing manner in its default and expected use. automatically invoked website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an by browser, the in response to the identifying of the embed text format, See the evidence and information cited for claim element 36f supra which is expressly incorporated herein. to enable an enduser interact to directly with the 64 of 67 * Allegation not limited to the browser in use Claim Claim Language object while object is displayed Evidence from Staples’ website the being within a display area created at the first location within the portion of the hypermedia document being displayed in the browser-controlled window, 44h wherein the Staples’ website and/or the servers hosting that website (and/or the combination thereof), operate in a executable hypermedia network environment that includes client workstations executing browsers. The executable application is part of application is part of a distributed application, and wherein at least a portion of the distributed a application is for execution on the network server. In addition, Staples provides the infrastructure (e.g. distributed application, and wherein at least a portion of servers, Staples’ website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an infringing manner in its default and expected use. the distributed application is for See the evidence and information cited for claim element 36g supra which is expressly incorporated execution on the herein. network server; 65 of 67 * Allegation not limited to the browser in use Claim 44i Claim Language executing one or Evidence from Staples’ website Staples’ website and/or the servers hosting that website (and/or the combination thereof), (and/or the more instructions in combination thereof) executes one or more instructions in response to the commands. In addition, response Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to to the commands; users, and causes them to use Staples’ website in an infringing manner in its default and expected use. See the evidence and information cited for claim elements 36pre, 36a, 36e and 36g supra which is expressly incorporated herein. 44j sending information Staples’ website and/or the servers hosting that website (and/or the combination thereof), to client combination thereof) sends information to the client workstation in response to the executed in instructions, to allow processing of the information at the client workstation to enable said end-user to the directly interact with said object. In addition, Staples provides the infrastructure (e.g. servers, Staples’ the workstation response to executed (and/or the website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an instructions, to infringing manner in its default and expected use. allow processing of the information the client workstation enable user interact at to said to See the evidence and information cited for claim elements 36pre, 36a, 36e and 36g supra which is expressly incorporated herein. enddirectly with said object. 66 of 67 * Allegation not limited to the browser in use Claim 45 Claim Language Evidence from Staples’ website The method of claim Staples’ website and/or the servers hosting that website (and/or the combination thereof), 44 the comprises the method of claim 44 where: the information to enable comprises text formats. In addition, to Staples provides the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to where: information enable comprises further users, and causes them to use Staples’ website in an infringing manner in its default and expected use. text formats. See the evidence and information cited for claim 37 supra which is expressly incorporated herein. 46 The method of claim Staples’ website and/or the servers hosting that website (and/or the combination thereof), 45 where: the text comprises the method of claim 45 where: the text formats are HTML tags. In addition, Staples provides formats the infrastructure (e.g. servers, Staples’ website, etc.), in addition to instructions to users, and causes are HTML tags. further them to use Staples’ website in an infringing manner in its default and expected use. See the evidence and information cited for claim 38 supra which is expressly incorporated herein. 47 The method of claim Staples’ website and/or the servers hosting that website (and/or the combination thereof), 44 comprises the method of claim 44 where: the information contained in the file received comprises at where: the further information least one embed text format. In addition, Staples provides the infrastructure (e.g. servers, Staples’ contained in the file website, etc.), in addition to instructions to users, and causes them to use Staples’ website in an received infringing manner in its default and expected use. comprises at least one embed text format. See the evidence and information cited for claim 39 supra which is expressly incorporated herein. 67 of 67 * Allegation not limited to the browser in use

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