Apple, Inc. v. Motorola, Inc. et al

Filing 93

Declaration of Christine Saunders Haskett filed by Plaintiffs Apple, Inc., NEXT SOFTWARE, INC. re: 90 Motion Requesting Claims Construction (Attachments: # 1 Ex. 21 IEEE Dictionary, # 2 Ex. 22 '575 file history, # 3 Ex. 23 '486 file history, # 4 Ex. 24 Order No. 18, # 5 Ex. 25 '705 file history, # 6 Ex. 26 '647 file history, # 7 Ex. 27 Brad Cox, # 8 Ex. 28 Microsoft Press Dictionary, # 9 Ex. 29 '002 file history, # 10 Ex. 30 Dictionary of Computer Words, # 11 Ex. 31 Computer Dictionary, # 12 Ex. 32 Academic Press Dictionary, # 13 Ex. 33 IBM Dictionary, # 14 Ex. 34 Black's Law Dictionary, # 15 Ex. 35 About 3GPP, # 16 Ex. 36 '919 patent, # 17 Ex. 37 '713 provisional application) (Haslam, Robert)

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EXHIBIT 23 THE UNITED STATES IN AND TRADEMARK PATENT APPLICANT Michael NO APPLICATION cC 10/408789 DATE FILING Cleron OFFICE April3 TITLE 2003 .EXAItINERi St John NETWORK COMPONENT REPLACEABLE EXTENSIBLE EIVED ID Courtenay 62004 Jul GROUP ART UNIT 2126 Afl DKT NO 18602-07124 Technology CERTIFICATE hereby cntfr that to envetopraddreued the date shown below is eoncspondeacc this Mail Ameodmait Stop the tr being Express Mail Convtalona Nunther MaSing For Is United Patents flied In Postal States P.O below ServIce Boa 1450 then this as Class First VA Meatandtia Is correspondence LA 2OD9 NUMBER MAIL MAILING In being at on deposited By Rimma EXPRESS Mall 22313-1450 1.10 wIththeUtfitsdsweePontaseeEtpreUMlPOntOneetoAddrtSneeserVitePWnualttto37CPR Dated 2100 OF MAILING with the deposited Center Budnitskaya Reg No.48237 EL5999075171JS STOP AMENDMENT COMIvUSSIONER FOR PATENTS MAIL P.O BOX 1450 VA AISEXAIIDRIA 22313-1450 AMENDMENT iO/01J2004 00004004 hItHER 10400789 192555 SIR 54.00 FC1202 05 04 Tha Amendment Action dated March 17/13/200411900110111 It FC 00000057 begin 92555 the patent application identified above is in response to the 0111cc 92004 Amendments Remarks fbr to the on Claims begin page of this on page of this paper paper 104091119 110.19 IlaOzatltZd/5F/StflOOtJ 486 RE 101 WI-App1e0002281 PATENT AMENDMENTS Please amend 1. the claims An Original arrangement on residing TO THE CLAIMS follows as and extensible computer coupled replaceable to layered the network computer computing component arrangement layered comprising software architecture component control the component layer services provide layer includes first class for navigation available on coupled to the the to the application computer computer network network among wherein the the computing that components network the component and different architecture component and interfaces programming to architecture component navigation interfaces that represents object software network system operating software components programming conununication facilitate computer developing directed in the the of computing application included network the plurality layer defining network of operations with an layer interfacing to construct network network first resources component layer in integrating and network layer relation to navigation components. 2. Original are components 3. navigation interfaces object computing arrangement of claim wherein the network The computing arrangement of claim wherein the application navigation objects. Original programming The further data representing second comprise stream class second for constructing for transferring information among network objects of the arrangement. 4. navigation Original object is The an Item computing object and the arrangement second of claim network wherein navigation the object first is network Stream object 186021011241SE15122004.3 486 RE 102 WI-App1e0002282 PATENT and wherein Item that the resource the tem object object additional representing component components further interfaces architecture and arrangement computing for providing arrangement to provided from information wherein claim computing navigation the network the application network third for constructing of components between communication enable the the navigation software computing components An Original third class comprise to thereby layer of arrangement behaviors network the to obtain object represents The computing Original programming Stream the spawns object and extensible services replaceable to information directed component layered computing on computer available the networks comprising processor an system operating software architecture component operations of defining plurality network the and network obtain ensure is network available integrally navigation the computer on coupled communication to the among the the layer network the different network architecture and network and interfaces that represents wherein to the networks programming component computing configured components computer component software the and application network architecture navigation on available to control system operating component components layer includes component resources layer of computing information for constructing means software layer for creating component search the processor to the coupled layer component layer to navigation components Original component components layer and within The computing software one another component to form arrangement of claim architecture layer compound wherein comprise document having the means mixed network for embedding data types and formats 18602107124/5F1$122004.3 486 RE 103 WI-App1e0002283 PATENT The Original 8. programming interfaces implements computing arrangement means arrangement means wherein claim for constructing The computing of network for constructing the application that protocol. Original 9. programming among the flinctionatity to existing The computing Original comprises component computing computing functions component coupled to to the 13. screen networks Original component navigation of the the wherein claim network application that component navigation communication to enable components The computing Currently the over computing claim 10 of data of the computing content. wherein remotely screen the the computing onto log computing another arrangement. 10 claim wherein the network 10 wherein the network component. arrangement component and networks arrangement browsing editor of and view images on wherein claim for of claim one of text displaying and movies displaying arrangement. Cancelled. 15. of viewing arrangement files The computing comprises 14. having part transfer comprises component navigation one of Original 12. arrangement The computing Original 11. computer comprise of component navigation components. 10. on interfaces additional provides comprise object navigation 16. navigation 17. navigation is adapted Currently object is is to Amended adapted Currently object Amended The adapted browse the The layered to display Amended to layered The display text computer on layered of claim arrangement the network network. arrangement computer arrangement images on wherein 12 of claim 12 44 wherein the network wherein the network display. of claim computer j.Q 4.4 display. 18602/0712415F5122004.3 486 RE 104 WI-App1e0002284 PATENT The 18 Currently Amended navigation object includes between information on residing in the objects 19 Original An computer commands software and extensible adapted replaceable be coupled to for creating component layered computing network the arrangement component computing the network computer wherein for transferring datastream layered on i4-4 of claim arrangement layered arrangement arrangement layered comprising software architecture component control the layer defining network layer of least that represents 20 Original network navigation location on the computer navigation components of component abstract class to coupled the software among in the the computer navigation the network navigation and programming architecture component network the interface application network navigation network programming application the one network computer for defining on available least to the included one object network layer component to and at component arrangement that represents object 21 Original network layered at to directed abstract one computing The be coupled classes architecture component components an communication facilitate to service resource layer component least of computing to system operating software layer including interconnected at the computer adapted component interface the that provides component number plurality component network of operations with an layer interfacing of claim method 19 wherein of downloading the abstract class from information defines remote network The object layered that arrangement represents of claim additional 19 wherein behaviors the abstract provided to the layer for integrating with class defines computing layer 22 lions the software Currently component Amended architecture computer which when executed by readable prococcor medium hnving inn computer erm-mne operations oyetein of otorod the network thereon adapted to computer ho coupled to pronram_ 186021071 2415F151 220043 486 RE 105 WI-App1e0002285 PATENT p4jct for pter providing network the networks computer containing comnuter network constructing of computer 23 object is adapted 24 object is object between New New includes system to browse the to text on images on The computer program software commands the product at meditia computer-readable on at least one abstract class from and class least enable to interaction one computing with an of operations of to the in component operating system on computer ihc software system 22 wherein claim between the network the navigation network product computer The computer program classes and system coupled computer operations based layer interfacing program computer the abstract control The computer program to display the object architecture The computer to display adapted 26 object New adapted 25 is New with of user comprising object abstract navigation component oroduct navigation associated network to foerforming interconnected methods using services program code program set information 22 wherein the network navigation 22 wherein the network navigation 22 the network navigation claim display product computer product for creating of of claim display of claim datastream wherein for transferring information objects 1860V01124/5F15122004.3 486 RE 106 WI-App1e0002286 REMARKS Claims 15-18 and claims was without of as to U.S Serial No of inaccessibility the third In C.F.R U.S Patent not which upon under 37 Certificate of the 23-26 claims have Examiner Action offer Office that to surrender In patent 14 been been has original reissue or patent an Affidavit submit Applicants response cancelled added that the indicated the identifies it 3.73 Examiner Action reissue present C.F.R Office the original the in proper new claim response or original Bl 6212575 paragraph is 3.73 the In rejected and the required Declaration Patent stand amended paragraph filed and pending 22 have been second In the application were 1-22 the present correctly reissue based is application indicated identifying of instead application Patent under 37 Certificate Applicants submit U.S the that the the requisite No Serial 62 12575B1 In Reissue Michael that adequately Cleron and filed petition Decision In U.S.C 251 based from In the an improper broadened limitation Office the U.S in claim No Serial have 22 subject paragraph eleven first the patent class however matter claim upon as is claims rejected subject cancelled matter of with included did the 62l2575Bl Examiner the of of Office the by Fisher 1.47a The in the submitted 14-18 and 22 under during present and amended 14 Reissue inventors 37 C.F.R indicated suffendered which as error original signed Stephen of which copy Examiner is under Petition inventor nonsigning one corrected Declaration the that 1.47 Action recapture The error least at claims 35 the reissue 15-18 application to depend 19 claim of recapture Action Office submit Applicants that the indicated identi adequately and Trademark Patent 37 C.F.R Applicants claim to respect of the Patent response Indeed of being improper independent With patent as of prosecution is nine paragraph the Examiner Action submit of States Under Status According not one least at behalf United Office response Applicants on 52003 the does it In identifies the by granted because Timo Bruck on September was of eight al 1.175 by 37 C.F.R Declaration through defective is Declaration required was four paragraphs not provided surrendered the Office new reissue in the Examiner haa Action details the how claim 22 of 14 that has eliminates claim 22 the Nowhere interfaces.. how new independent being is the original stated claim programming on prosecution Examiner independent application indicate during any is in the an improper 18602107124/5Ff5122004.3 486 RE 107 WI-App1e0002287 PATENT of recapture surrendered 22 to claim In respect paragraph matter subject Examiner is If Examiner invited respectfully continues maintain to further to provide his details with position of in support his position defective upon reissue respectfully l3 In the 103a Byte October being 1991 of information services performing the methods at least claimed invention between component component-based the is Smarts edition traversed respectfully network for providing product program With Primer Stanley rejection the system.. computer program on with of the for product one interconnected least at abstract approach layer object The browsing application-based with an the to control directed to computer at least at least invention retrieving approach of one with abstract the beneficially prior browsing product claimed class abstract one computing network-oriented program The system computer on associated and claimed and is of based methods uses navigation layer to object and object Emphasis added 22 user enable software system system to to interfacing in claim navigation in computer services network class navigation component the as recited architecture abstract network computer advantageously monolithic the the architecture system on network the based object of set one computing information also navigation between invention network constructs to computer Network U.S.C 35 and operations opposed alia computer associated operating software inter 251 and Llppman claim 22 under The Applicants U.S.C 35 Reinhardt of Reinhardt This Therefore under rejected Lippman Lippman from class component interaction to of interaction claimed Reinhardt Andy error 1-22 View in Examiner of network classes using invention 103a view one least at being based as Applicants submit response to claims rejection Action in In 1-22 operations abstract for providing Office recites user constructing The the 394-394 pages to the 1-64 claim 22 Amended identifies claim rejected 251 U.S.C 35 adequately unpatentable 1994 pages Addison-Wesley under remove to Examiner Action Under 35 USC paragraph as allegedly Office that Rejection to the declaration Examiner request esponse of Declaration Reissue corrected twelve The class to enable in component employs information as systems 86021071241SF/5 122004.3 486 RE 108 WI-App1e0002288 PATENT Reinhardt that discusses does intelligent networks discloses muting hehall Reinhardt does Line not altehiative with Lippman classes Since the layer interfacing claimed invention. Reinhardt and does their patentable not an abstract does with an operating would depend the not of deficiency base operating of usage class disclose nor Lippman Accordingly from claim 22 is as agents is is Lippman class software computer mentioned layer Reinhardt merely Although language. as at an are architecture over patentable and claimed. architecture standard the object component or suggest system on navigation layer Reinhardt. designed to this getwork software the corollary network the employing from which other component to control system the system. Reinhardt with an the and programming Lippman computer cure the object-oriented not Accordingly system. As to respect users the on system of operating system. that col. agents page 395 and Lippman their patentability and col. network at Claims 23-26 64 an architecture component to the features neither between modular layer interfacing of operations interaction the operating can be derived architecture computer software page at the discloses Lippman the services similarly tutorial describing of with on-line respect with an interfacing in interfacing layer with network the or services Reinhardt in publication Reinhardt Although information disclosure is move around that proxies out seeking no Reinhardt technology. or agents is operations or suggest suggests to monolithic by Reinhardt the component Reinhardt Although there invention. agent-based and user architecture disclose computing utilize sofiware to col. software to control system Reinhardt sent 51 page that to host claimed the or suggest networks messages component-based computer disclose designed or filtering least not not either disclose system combination person of ordinary find the directly independent claimed of the invention from which references in the skill or indirectly claim software component-based art not produce the considering the teachings of obvious. from independent they does architecture depend claim in addition 22 and derive to reciting features. 1860 2/071245 F/i 122004.3 486 RE 109 WI-App1e0002289 For 13 and these 15-26 reasons are allowable Applicants over the submits respectfully cited art of that and record all the pending that request the claims Examiner claims allow 1- the case submitted Respectfully MICHAEL Dated OO CLERON et By_________________________ Rinuna Rudnitskaya Attorney for Fenwick Silicon 801 West Valley California Mountain Tel Fax No 48237 LLP Center Street View CA 415 Reg Applicant 94041 875-2401 415281-1350 8602/07142/SF/5122004 10 86O2/O7l24/SF$l22OO4.3 486 RE 110 WI-App1e0002290

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