Gary B. Rohrabaugh and Scott A. Sherman Patent

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

In re: Gary B. Rohrabaugh and ) ) Scott A. Sherman ) Examiner: Unassigned ) Patent No.: 7,831,926 ) Group Art Unit: Unassigned ) Issued: November 9, 2010 ) Tuesday, October 02, 2012 ) For: Scalable Display of ) ) Internet Content on Mobile Devices )

PETITION FOR INTER PARTES REVIEW OF

U.S. PATENT NO. 7,831,926

Sir:

Pursuant to 35 U.S.C. § 311 et seq. and 37 C.F.R. § 42.1 et seq., Kyocera

Corporation (“Petitioner”) hereby petitions for an Inter Partes Review (the

“Petition”) of U.S. Patent No. 7,831,926 (the “‘926 Patent”). As a point of information, Petitioner has also filed a petition for Inter Partes Review of U.S.

Patent No. 7,461,353 (the “‘353 Patent”), which claims common priority patent applications. The undersigned is authorized to act in a representative capacity for

Petitioner.

TABLE OF CONTENTS

I. Introduction...... 1

II. Inter Partes Review Under 37 CFR §§ 42.101 – 103...... 2

III. Petition Requirements Under 37 CFR § 42.104...... 3

IV. The ‘926 Patent...... 6

A. Priority Date of ‘926 Patent ...... 6

B. The Written Specification and Figures ...... 6

C. Prosecution History ...... 10

V. Statements Showing a Reasonable Likelihood That Petitioner Will Prevail With Respect to at Least One Claim of the ‘926 Patent ...... 12

A. Expert Declarations ...... 12

B. State of the Art ...... 14

C. Scope and Content of the Prior Art Forming the Basis for the Proposed Rejections Under and 35 U.S.C. § 103 ...... 15

1. Nokia 9000 Communicator (“Nokia”) (Exhibit PX1003)...... 15

2. Sharp Zaurus (“Zaurus”) (Exhibit PX1004) ...... 16

3. Japanese Application No. H10-21224 to Tsutsumitake et al. (“Tsutsumitake”) (Exhibit PX1005) ...... 16

4. Pad++ (“Pad++”) (Exhibit PX1006)...... 17

5. W3C Scalable Vector Graphics Requirements (SVG) (Exhibit PX1007) ...... 17

6. Japanese Application Publication H10-326169 to Masao Hara (“Hara”) (Exhibit PX1008) ...... 18

7. Specification for the Simple Vector Format (SVF) v 1.1, (the “SVF References”) (Exhibit PX1009)...... 18

- i -

8. Matthews, et al., Vector Markup Language (“VML”) (Exhibit PX1010) ...... 19

D. Summary of Invalidity Arguments...... 19

E. Listing of RLPs ...... 21

1. RLP Issue # 1:...... 21

2. RLP Issue # 2:...... 34

3. RLP Issue # 3:...... 38

4. RLP Issue # 4:...... 42

5. RLP Issue # 5:...... 46

VI. Conclusion ...... 58

- ii -

TABLE OF EXHIBITS

EXHIBIT DESCRIPTION RELEVANT PATENT MATERIALS **** PX 1001 U.S. Patent No. 7,461,353 (“the ‘353 Patent”) PX 1002 Prosecution History for the ‘353 Patent PRIOR ART **** Nokia Unveils World’s First All-In-One Communicator for the PX 1003 Americas, Nokia Press Release, September 19, 1996 (“Nokia”) Watanabe, Mituyoshi, How to Make the Most of the Power Zaurus, Computing Communication Multimedia Mobile - Computing Communication Multimedia, April 14, 1998 (“Zaurus_1”) (including partial English translation) Power Zaurus Specifications: User Manual - Mobile Business Tool – Model MI-106 / MI-106M / MI-110M, November 1997 (“Zaurus_2”) PX 1004 (including partial English translation) Power Zaurus MI-110 / M106 / M106 Brochure, December 1997 (“Zaurus_3”) Power Zaurus MI-610/DC Brochure, June 1998 (“Zaurus_4”) Power Zaurus MI-504/ MI-506/ MI-506DC Brochure, July 1997 (“Zaurus_5”) Power Zaurus Article, PCWatch, November 18, 1997 (“Zaurus_6”) Japanese Application No. H10-21224 to Tsutsumitake et al., January PX 1005 23, 1998 (“Tsutsumitake”) (including English translation) Bederson, Benjamin B. and Hollan James D., Pad++: A Zoomable PX 1006 Graphical Interface System, CHI ‘95 Mosaic of Creativity, May 1995 (“Bederson-1”) Bederson, Benjamin B. and Furnas, George W, Space-Scale Diagrams: Understanding Multiscale Interfaces, CHI ‘95 Proceedings, 1995 (“Bederson-2”) Bederson, Benjamin B., et al, A Zooming Web Browser, SPIE, Vol. 2667, 260-271, May 1996 (“Bederson-3”) Bederson, Ben and Meyer, Jon, Implementing a Zooming User Interface: Experience Building Pad ++, Software-Practice and Experience, Vol. 28(1), 1101-1135, August 1998 (“Bederson-4”)

- iii -

EXHIBIT DESCRIPTION Bederson, Benjamin B., et al., Pad++: A Zoomable Graphical Sketchpad for Exploring Alternate Interface Physics, Journal of Visual Languages and Computing, Vol. 7, 3-31, 1996 (“Bederson-5”) Pad++ Reference Manual Version 0.2.7, published July 9, 1996 (“Reference Manual”)

Pad++ Programmer’s Guide Version 0.2.7, published June 10, 1996 (“Programmer’s Guide”)

Ferraiolo, Jon, Scalable Vector Graphics Requirements: W3C Working PX 1007 Draft, October 29, 1998 (“SVG”) Japanese Application Publication H10-326169 to Masao Hara, PX 1008 December 8, 1998 (“Hara”) (including English translation) Specification for the Simple Vector Format v. 1.1, January 16, 1995 (“SVF”) “New CAD System Works With AutoCAD Drawings Without Translation,” June 17, 1996, retrieved from: http://web.archive.org/webI19961019052917/http://soft:source.cominet PX 1009 news.html, (“SVF Press 1”) “Bring New CAD Viewing Power to the Internet,” March 4, 1996, retrieved from: http://web.archive.org/webI19961019052917/http://softsource.cominet news.html, (“SVF Press 2”) Matthews, et al., Vector Markup Language, World Wide Web Consortium Note, Note-VML-19980513, May 13, 1998, retrieved PX 1010 from: http://www.w3.org/TRl1998/Note-VML 19980513 (“VML”) Gessler, S., Kotulla, A., “PDAs as mobile WWW browsers.” Proc. of PX 1011 Mosaic and the Web Conference, Chicago, October 1994 Lauff, Markus, and Gellersen, Hans-Werner, “Multimedia client PX 1012 implementation on Personal Digital Assistants”, Interactive Distributed Multimedia Systems and Telecommunication Services, 1997 “NetHopper 2.0 First true Web browser for Newton”. PenComputing PX 1013 Magazine, 1996, retrieved from: http://www.pencomputing.com/archive/PCM_11/nethopper.html

- iv -

EXHIBIT DESCRIPTION Kamada, Compact HTML for Small Information Appliances, February PX 1014 9, 1998, retrieved from: http://www.w3.org/TR/1998/NOTE- compactHTML-19980209/ OTHER MATERIALS **** PX 1015 Power of Attorney, dated September 21, 2012 Complaint for Patent Infringement filed May 10, 2010 in the case of PX 1016 SoftView LLC v. Apple Inc., and AT&T Mobility LLC, Case No. 10- 389-LPS in the United States District court for the District of Delaware First Amended Complaint filed December 3, 2010 in the case of PX 1017 SoftView LLC v. Apple Inc., and AT&T Mobility LLC, Case No. 10- 389-LPS in the United States District court for the District of Delaware Second Amended Complaint filed September 30, 2011 in the case of PX 1018 SoftView LLC v. Apple Inc., and AT&T Mobility LLC, Case No. 10- 389-LPS in the United States District court for the District of Delaware Joint Claim Construction Chart (Volume 1 of 2) filed August 31, 2012 in the case of SoftView LLC v. Apple Inc., and AT&T Mobility LLC, PX 1019a Case No. 10-389-LPS in the United States District court for the District of Delaware Joint Claim Construction Chart (Volume 2 of 2) filed August 31, 2012 in the case of SoftView LLC v. Apple Inc., and AT&T Mobility LLC, PX 1019b Case No. 10-389-LPS in the United States District court for the District of Delaware SoftView LLC’s Opening Claim Construction Brief filed September 21, 2012 in the case of SoftView LLC v. Apple Inc., and AT&T Mobility PX 1020 LLC, Case No. 10-389-LPS in the United States District court for the District of Delaware January 20, 2012 Declaration of Jack D, Grimes, Ph.D., submitted by PX 1021 Third Party Requester Apple in Inter Partes Reexamination Nos. 95/000,634 and 95/000,635 (“Grimes-I”) April 2, 2012 Declaration of Jack D, Grimes, Ph.D., submitted by Third PX 1022 Party Requester Apple in Inter Partes Reexamination No. 95/000,634 and 95/000,635 (“Grimes-2”)

- v -

EXHIBIT DESCRIPTION Declaration Of Craig Johnson In Support Of Plaintiff SoftView LLC's Opening Claim Construction Brief (including Exhibits 1-14) filed PX 1023 September 21, 2012 in the case of SoftView LLC v. Apple Inc., and AT&T Mobility LLC, Case No. 10-389-LPS in the United States District court for the District of Delaware Declaration Of Glenn Reinman In Support Of Plaintiff SoftView LLC's Opening Claim Construction Brief (including Exhibits A-D) filed PX 1024 September 21, 2012 in the case of SoftView LLC v. Apple Inc., and AT&T Mobility LLC, Case No. 10-389-LPS in the United States District court for the District of Delaware Plaintiff SoftView LLC's Technology Tutorial filed September 21, 2012 in the case of SoftView LLC v. Apple Inc., and AT&T Mobility PX 1025 LLC, Case No. 10-389-LPS in the United States District court for the District of Delaware Defendants’ Opening Claim Construction Brief (including Exhibits A- J) filed September 21, 2012 in the case of SoftView LLC v. Apple Inc., PX 1026 and AT&T Mobility LLC, Case No. 10-389-LPS in the United States District court for the District of Delaware Softview LLC's Responses To Kyocera Corp. And Kyocera Wireless Corp.'S First Set Of Interrogatories (NO. 1) with Exhibits, filed July 23, PX 1028 2012 in the case of SoftView LLC v. Apple Inc., and AT&T Mobility LLC, Case No. 10-389-LPS in the United States District court for the District of Delaware PX 1029 Declaration of Hidekazu Takahashi, dated September 25, 2012. PX 1030 Declaration of Manabu Toda, dated September 28, 2012.

- vi -

I. INTRODUCTION This petition for Inter Partes Review demonstrates a reasonable likelihood that the Petitioner will prevail (“RLP”) with respect to at least one of claims 30, 31,

40, 41, 43, 52, 55, 59, 72, and 75 (“Subject Claims”) challenged in this petition. 35

U.S.C. § 314(a). This Petition meets this threshold. Petitioner asserts that the

Subject Claims are obvious over the asserted prior art, and should be found

unpatentable and cancelled.

Real Party-In-Interest: 37 CFR 42.8(b)(1). Pursuant to 35 U.S.C.

312(a)(2), the real party-in-interest is Kyocera Corporation, a Japanese Corporation

located in Kyoto, Japan.

Related Matters: 37 CFR 42.8(b)(2). In 2010, SoftView LLC, the patent

owner, sued Apple, Inc. and ATT Mobility for infringement of the ‘353 Patent and

‘926 Patent (the “Patents-in-Suit”).1 On September 30, 2011, SoftView filed an amended complaint,2 which, for the first time alleged that Petitioner and 16 new

defendants infringed the ‘926 Patent and the ‘353 Patent. A copy of SoftView’s

Second Amended Complaint is attached as Exhibit PX1018. Petitioner was not

served with the complaint. See note 3, infra.

1 SoftView LLC v. Apple Inc., and AT&T Mobility LLC, Case No. 10-389-LPS (D. DE) (“the Underlying Litigation”). 2 See Plaintiff SoftView LLC’s Second Amended Complaint for Patent Infringement dated September 30, 2011, Case 1:10-cv-00389-LPS, Doc. 108-3 (Exhibit PX1018).

The ‘926 Patent is subject to three reexamination proceedings (the “Prior

Reexaminations”). The three pending reexaminations include: (i) Inter Partes

Reexamination No. 95/000,635; (ii) Ex Parte Reexamination No. 90/009,995; and

(iii) Inter Partes Reexamination No. 95/002,126. Neither Petitioner nor any party

in privity with Petitioner filed the requests for the Prior Reexaminations.

Lead and Back-up Counsel (37 CFR 42.8(b)(3)) SoftView (Patent Owner) Kyocera (Petitioner) Morgan Chu / Samuel K. Lu Richard Bauer (Lead) / Michael Tomsa Irell & Manella LLP Katten Muchin Rosenman LLP 1800 Avenue of the Stars, Suite 900 2900 K Street NW - Suite 200 Los Angeles, CA 90067-4276 Washington, DC 20007-5118

Service Information: 37 CFR 42.8(b)(4) SoftView (Patent Owner) Kyocera (Petitioner) Morgan Chu Richard P. Bauer Irell & Manella LLP Katten Muchin Rosenman LLP 1800 Avenue of the Stars, Suite 900 2900 K Street NW - Suite 200 Los Angeles, CA 90067-4276 Washington, DC 20007-5118

II. INTER PARTES REVIEW UNDER 37 CFR §§ 42.101 – 103 Pursuant to 37 CFR § 42.101, Petitioner has not filed a civil action challenging the validity of a claim of the ‘926 Patent. Petitioner was first named as a defendant in the Underlying Litigation on September 30, 2011 (See PX1018).

Thus, this petition is within one year from the date on which the complaint was

- 2 -

filed.3 Petitioner is not estopped from challenging the claims on the grounds identified in the Petition. Pursuant to 37 CFR § 42.102(a), the timing for this

Petition is proper. The ‘926 Patent was granted on November 9, 2010, which is more than nine months ago and, as of the present filing, a post-grant review has not been initiated.

Pursuant to 37 CFR § 42.103, the Patent Office is authorized to charge

Deposit Account No. 50-1214 the $27,200 review fee set forth in § 42.15(a).

Further, Petitioner authorizes a debit from Deposit Account No. 50-1214 for whatever additional payment is necessary in granting this Petition.

III. PETITION REQUIREMENTS UNDER 37 CFR § 42.104 Standing. Petitioner certifies that the patent for which review is sought is

available for Inter Partes Review and that the Petitioner is not barred or estopped

from requesting an Inter Partes Review challenging the patent claims on the

grounds identified in the Petition. 37 CFR § 42.104(a).

Claims challenged, 37 CFR § 42.104(b)(1). Petitioner petitions for review

of claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75 (“Subject Claims”), of the ‘926

Patent.

3 Kyocera Corporation agreed to waive service of SoftView LLC’s Second Amended Complaint on October 26, 2011, which constitutes effective service. See Joint Stipulation And Proposed Order Extending Time To Respond To Complaint filed May 10, 2010 in the case of SoftView LLC v. Apple Inc., and AT&T Mobility LLC, Case No. 10-389-LPS Dkt. No. 125

- 3 -

Specific Statutory Grounds: 37 CFR § 42.104(b)(2). Petitioner submits

that the Subject Claims are obvious under 35 U.S.C. § 103 in view of the cited

prior art. A statement pointing out each showing of a reasonable likelihood that

Petitioner will prevail (“RLP”) with respect to at least one claim of the ‘926 Patent

can be found below at Section V(E).

Claim Construction: 37 CFR § 42.104(b)(3). For purposes of this review,

a claim in an unexpired patent shall be given its broadest reasonable construction

in light of the specification of the patent in which it appears. See 37 CFR

42.100(b). While the Examiner will construe the claim terms in accordance with

Patent Office guidelines, Petitioner submits SoftView’s proposed construction in

the Underlying Litigation for purposes of completeness of disclosure only. See

Exhibits PX1019a, 1019b and 1020, which are reproduced below in part.

Claim Term SoftView’s Claim Construction “graphic content capable of being rendered at multiple scalable content zoom levels” “capable of being rendered at multiple zoom levels / scalable / scaling / rendering at multiple zoom levels / rendered at multiple scaled zoom levels” processing [the] HTML-based Web “processing [the] HTML-based Web content to produce content to produce content capable of being zoomed in or out” scalable content vector-based content “graphic content that includes one or more vectors”

- 4 -

Claim Term SoftView’s Claim Construction “‘scalable vector-based content’: graphic content that (1) scalable vector-based is capable of being rendered at multiple zoom levels and content (2) includes one or more vectors” “A mathematical expression representing a length and a direction in a two dimensional space. In an X, Y vector coordinate system, a vector is represented by a value X2, Y2 relative to an origin point, represented by X1, Y1.” primary datum “an origin point defined at an X,Y coordinate” object datum “reference point for an object” “one or more points corresponding to the location of the layout location datum object” enabling the user to “enabling the user to zoom and move around the Web zoom and pan a view page” of the Web page “The machine-readable medium may include, but is not limited to, floppy diskettes, optical disks, ROMs, RAMs, machine-readable EPROMs, EEPROMs, magnetic or optical cards, flash medium memory, or other type of media/machine-readable medium suitable for storing electronic instructions.”

Petitioner is neither admitting nor acquiescing as to the correctness and/or

reasonableness of SoftView’s proffered claim construction and arguments in the

litigation and/or as otherwise set forth herein. However, by SoftView’s admissions,

it would not be unreasonable for the Patent Trial and Appeal Board (“PTAB”) to

adopt the same constructions.

- 5 -

Invalidity under 37 CFR § 42.104(b)(4)-(5). For the reasons set forth in

detail below in Section V(E), a reasonable likelihood that Petitioner will prevail

exists with respect to each of the Subject Claims based on obviousness under 35

U.S.C. § 103 in view of the various combinations of prior art. A complete copy of every patent and printed publication relied upon in this Petition is attached and discussed in Section V(C).

IV. THE ‘926 PATENT

A. Priority Date of ‘926 Patent The ‘926 Patent is a Continuation of U.S. Patent No. 7,210,099, which is a

continuation-in-part of abandoned U.S. Patent Application Serial No. 09/828,511,

which claims Priority from Provisional Applications 60/217,345, filed 07-11-2000,

and 60/211,019, filed 06-12-2000. Thus, the effective filing date for purposes of 35

U.S.C. §§ 102(a) and 102(b) would appear to be June 12, 2000.

B. The Written Specification and Figures The ‘926 Patent was filed on April 21, 2007, and issued on November 9,

2010. The named inventors are Gary B. Rohrabaugh and Scott A. Sherman. The

‘926 Patent is assigned to SoftView LLC. The ‘926 Patent is subject to a terminal

disclaimer, and the term of the patent is adjusted by 799 days.

The ‘926 Patent relates generally to a system and method for translating web

pages from a native file format—typically HTML—into a “scalable vector

- 6 -

representation,” also referred to as “vectorized content,” or “scalable content.” See

the ’926 Patent at 1:52-60, 2:4-8, 2:32-43, 6:53-56, 7:27-33, 7:45-8:7, 8:47-52,

8:64-67, 12:7-9, Abstract. According to the ‘926 Patent, it was familiar in the prior

art Computer Aided Design (“CAD”) field for graphics in a “vector” format to be

magnified and moved around in real time. Id. at 4:56-5:15. Likewise, in

accordance with the “present invention,” the specification alleges that scale factors

and offsets may be applied to the translated web content to simplify zooming and

panning of the web page, or to more easily scale a page designed for a single,

target resolution (typically, a desktop monitor) for display at different sizes or resolutions, such as a small PDA or a large, “billboard”-style display. Id. at 2:14-

36, 4:56-5:15, 4:62-5:15, 8:58-9:3, 17:42-45, 20:49-67, Figs. 7A-9B.

According to the ‘926 Patent, translating web content from HTML into a scalable vector representation or scalable content includes a “pre-rendering”

- 7 -

process that was performed by prior art web browsers. Id. at 17:31-34. In the prior art, and still today, the layout of a HTML web page is not typically defined by designating specific coordinate locations for objects on a web page; instead,

HTML usually defines layout by spatial relationships between objects (e.g., requiring text to be placed below an image). Id. at 16:55-58. In a prior art “layout” process, browsers would retrieve, parse (i.e., separate and identify the constituent parts of the page), and process the HTML to define a page layout based on the location of a “bounding box” for each object on the page. Id. at 15:43-16:38,

17:16-30, Fig. 5 (blocks 150-154). In prior art browsers, such as those using the

“Mozilla” rendering engine, a data structure called a “render tree” would store, for each object on the page, the X,Y location of the object relative to a previously- defined object, called a “container.” Id. at 17:16-41; Ex. A, U.S. App. No.

11/868,124, Applicant Remarks at 26-30 (Nov. 24, 2010). The ‘926 Patent refer to this process as “pre-rendering.” Id. at 15:43-17:41, Fig. 5 (blocks 150-154). Such prior art browsers would calculate the X,Y location of an object relative to the top- left corner of the page by “walking the render tree,” or adding together the stored

X,Y coordinates in the render tree for the object, its container, its container’s container, and so forth. See PX1026 at Ex. A pp. 27, 29-30; see also ’926 patent at

17:53-56.

- 8 -

Generating a scalable vector representation from the pre-rendered layout information begins by defining a datum point for the entire page and additional datum points for each object on the page. See ’926 patent at 17:42-18:32, Fig. 5

(blocks 156-160). The page datum for the entire page, or “primary datum,” may be at any point on the page, so long as that point is used consistently in calculating the coordinates of objects on the page. Id. at 17:47-56, Fig. 4C (item 262), claim 5.

Likewise, the “object datum” may be at any point on an object (e.g., the top-left corner of the bounding box for the object), so long as that location is used consistently across all objects. Id. at 17:57-64, Fig. 4C (items ending in “C”).

After datum points are defined, a “vector” for each object is generated from the page datum to each object datum. Id. at 17:65-67, Fig. 5 (block 158), Fig. 4C

(items ending in “D”). If the page datum is chosen to be at coordinate 0,0, the vector for an object may simply be stored as the X,Y value of that object’s datum

- 9 -

point. Id. at 17:67-18:8, Fig. 4D. The scalable vector representation is completed by creating a reference that associates an object’s content and attributes to its vector. Id. at 18:17-26, Fig. 5 (block 160).

The scalable vector representation can then be used to scale the web page for displays of various sizes and resolutions and to zoom and pan the page at various user-selectable scaled resolutions and pan offsets. Id. at 4-62-5:15, 8:58-9:3, 18:47-

19:3. According to the ‘926 Patent, a page can be scaled simply by manipulating the vectors and resizing the bounding boxes for each object to be displayed, and then scaling the content. Id. at 19:32-56, 20:18-32, Fig. 6. More specifically, for each object to be zoomed or panned, the vector is offset and has a scale factor applied to it, and the bounding box is scaled by the same scale factor, as shown in

Figure 4G of the Patents. Id. at 19:57-20:17. Thus, for example, zooming the web page in Figure 4A into the broken rectangle in Figure 4F results in the page displayed in Figure 4E. Id. at 3:21-39.

C. Prosecution History The ‘926 Patent was filed on April 21, 2007, and was assigned serial application No. 11/738,486 (“the ‘486 application”). On November 28, 2009, the

Applicants filed a Preliminary Amendment. The Preliminary Amendment included amendments to the specifications and replacement Figures 2A-2C.

- 10 -

On April 1, 2010, the Patent Office issued a Non-Final Office Action. The

Examiner objected to certain informalities in the specification, as amended by the

Preliminary Amendment. Claims 1, 11, 13, 15-16, 25, 27, 29, 35, 37, 39, 40, 49,

56, 61, 63, 65, 66, 75, 84, 86, and 87 were rejected under 35 U.S.C. §112, second paragraph as being indefinite. The Examiner also issued a double-patenting rejection of claims 1-88 as being anticipated by or obvious in view of U.S. patent no. 7,210,099 and U.S. patent no. 7,461,353. The Examiner recited that claims 1-

88 would be allowable if a terminal disclaimer was filed, the claims were rewritten to overcome the 35 U.S.C. §112 rejection, and the objections to the specification were addressed.

On April 21, 2010, a terminal disclaimer was filed, and the Applicant submitted a response to the Non-Final application. The Applicant amended the claims to clarify the subject matter. Claims 14, 17, 18, 23, 38, 41, 42, and 64 were canceled, and new claims 89-96 were added. On June 2, 2010, the Examiner and the Applicant’s representative conducted a telephone interview, and an Examiner’s amendment was authorized in regard to claims 1, 27, 51, 79, and 90. On June 9,

2010, an Examiner Interview Summary and Notice of Allowance were mailed.

On September 9, 2010, the Applicant submitted Comments on the Statement of Reasons for Allowance. In its comments, the Applicant specifically recited that the while the Examiner agreed that the claimed subject matter is patentable, the

- 11 -

Applicant identified the specific claim elements it found patentable - namely

“scalable resolution-independent representation of the HTML-based content” and

“scalable content.” The Applicant further elaborated on the Examiner’s

amendment of “‘preserving the original page layout, functionality, and design’ of

the HTML-based Web content.” Applicant’s Comments to Notice of Allowance, p.

6. The Applicant paid the issue fees on September 9, 2010, and the Patent Office

issued the ‘926 patent on November 9, 2010 subject to a terminal disclaimer

adjusting the patent term by 799 days.

V. STATEMENTS SHOWING A REASONABLE LIKELIHOOD THAT PETITIONER WILL PREVAIL WITH RESPECT TO AT LEAST ONE CLAIM OF THE ‘926 PATENT The prior art references cited herein constitute effective prior art and

establish a reasonable likelihood that Petitioner will prevail with respect to at least

one claim of the ‘926 Patent under 35 U.S.C. § 103.

A. Expert Declarations Petitioner hereby submits the January 20, 2012 (“Grimes-1”) and April 2,

2012 (“Grimes-2”) Declarations of Jack D. Grimes, Ph.D., which were also submitted by Apple in the Apple Inter Partes request and explain that Pad++ teaches scalable vectors, as claimed. For example, as stated by Dr. Grimes, “the

Pad++ references define object[s] and the transformation of objects with respect to a coordinate system (e.g., using XY coordinates relative to an origin, which gives

- 12 -

the magnitude and direction that defines vectors).” Grimes-1, ¶ 29. Moreover,

“Pad++ describes the default origin as the center of the screen. [Bederson-4, p.

1129; See also, p. 4, Pad++; Programmer’s Guide]. However, in other examples,

Pad ++ describes the origin elsewhere: ‘0.0 [the origin (0, 0)] represents the left or bottom side of the window.’ [p. 22, Reference Manual].” Grimes-1, ¶ 26. “All locations or ‘places’ of objects are the locations of the anchor for each object, relative to this origin.” Grimes-1, ¶¶11-46. Additionally, Dr. Grimes states “[w]e know that the vector is stored by Pad++ for the rectangle called “rect2” because there is another command that can be used to determine the location of the rectangle “rect2.” Grimes-1, ¶¶ 55-56. Adding that “[w]e know that a “vector” for each object is generated and stored because otherwise, the -place command would not return a resulting location for the object relative to the primary datum. A -place of X, Y only makes sense if the coordinate X, Y is known to be relative to a known reference point, i.e., the origin at the center of the Pad++ surface. Since we have an origin and a place, then we have necessarily defined a vector. Using the common shorthand used in the ‘353 and ‘926 Patents, one of ordinary skill in the art would understand that this vector in Pad++ is from the known origin of the Pad++ surface to the “-anchor” of the object.” Id.

- 13 -

B. State of the Art At the time of the ‘926 Patent’s filing (i.e., 1999-2000 era),

Internet-equipped portable communicators, personal digital assistants (“PDAs”),

and the like, were rapidly growing in popularity. Such devices include, for

example, the Nokia 9000 Communicator, which enables users to send and receive

faxes, e- mail/short messages, access Internet services and voice calls.4

Mobile Internet and Browsers. Mobile browsers optimize the display for presenting Web content on a portable device’s small screen. The Apple Newton’s

PocketWeb, an early mobile browser, was created at TecO in 1994.5 The

PocketWeb was followed by the first commercial product, NetHopper, which was released in August 1996.6 With time, other browsers were developed and multiple companies offered browsers for the Palm OS platform. Released in 1997, the first

HTML browser was HandWeb by Smartcode. In February of 1996, Access Co.

Ltd. of Tokyo, Japan (“Access”) introduced NetFront software for Internet

browsing, which was initially installed in Internet TVs, word processors and, in

4 See e.g.,“Nokia Unveils World¬s First All-In-One Communicator For The Americas,” September 19, 1996 (Exhibit PX1003) 5 See e.g., Gessler, S., Kotulla, A., “PDAs as mobile WWW browsers.” Proc. of Mosaic and the Web Conference, Chicago, October 1994 (Exhibit PX1011) & Markus Lauff, Markus, and Gellersen, Hans-Werner, “Multimedia client implementation on Personal Digital Assistants,” Interactive Distributed Multimedia Systems and Telecommunication Services, 1997 (Exhibit PX1012). 6 “NetHopper 2.0 First true Web browser for Newton,” PenComputing Magazine, 1996, Retrieved September 21, 2012. (Exhibit PX1013)

- 14 -

February 1998, for mobile phones.7 Thus, it is clear that, at the time of the alleged

invention, multiple companies were offering Web browsers for devices with small

displays.

Scalable Vector Graphics. Scalable Vector Graphics are a family of

specifications of a file format for two-dimensional vector graphics, both static and

dynamic (i.e., interactive or animated). The specification is an open standard that

has been under development by the World Wide Web Consortium (“W3C”) since

1999.

Zooming. Pad++ is an ongoing effort to create a zooming user interface or

zoomable user interface (“ZUI”). In Pad++, the zooming functionality means that

lines can be of nearly any size. Making the level of noise proportional to the length

of the line keeps the informality uniform at all sizes.

C. Scope and Content of the Prior Art Forming the Basis for the Proposed Rejections Under and 35 U.S.C. § 103 As described in Section V(E), the following prior art references teach each

of the ‘926 Patent’s claimed elements.

1. Nokia 9000 Communicator (“Nokia”) (Exhibit PX1003)

Nokia discusses the Nokia 9000 Communicator, which enables users to send

and receive faxes, e-mail and short messages, access Internet services and voice

7 See id. at p. 2

- 15 -

calls. The motivation to combine Pad++, Tsutsumitake, SVG, SVF References and

VML with Nokia is clear, as it describes a mobile device that can access the internet, and thereby access Web content. Nokia was published September 19,

1996 and is prior art to the ‘926 Patent under 35 U.S.C. § 102(b).

2. Sharp Zaurus (“Zaurus”) (Exhibit PX1004) Zaurus (Zaurus_1 - Zaurus_6, collectively, “Zaurus”) teaches an early PDA made by Sharp Corporation. In the 1990’s, the Zaurus was a popular touch screen

PDA marketed in Japan. Using the highly portable Zaurus, Web browsing could be facilitated by accessing the Internet through either a wired or cellular connection.

In addition, Zaurus’ fully functional browser could render HTML web pages and

included a zooming functionality. Each of the Zaurus references was published

between 1997 and 1998 and is prior art to the ‘926 Patent under 35 U.S.C. §

102(b).

3. Japanese Application No. H10-21224 to Tsutsumitake et al. (“Tsutsumitake”) (Exhibit PX1005) Tsutsumitake teaches: (1) translating from HTML content to vector-based

format/representation; (2) grouping selected content into objects; (3) generating a

bounding box for each object; and (4) using the bounding boxes to display an

image / text layout. Tsutsumitake was published January 23, 1998 and is prior art to the ‘926 Patent under 35 U.S.C. § 102(b).

- 16 -

4. Pad++ (“Pad++”) (Exhibit PX1006) Pad++ (Bederson-1 - Bederson-5, Reference Manual¸ Programmer’s Guide, and Tour, collectively, “Pad++”) teaches a graphical interface system based on zooming, as an alternative to traditional window and icon-based approaches.

Pad++ renders Web pages for display in a resolution-independent scaleable format

that enables zooming and panning and preserves the layout, design, and function of

the Web page. According to Pad++, objects can be placed in the graphical

workspace at any size, and zooming is the fundamental navigational technique. An

objective of Pad++ is to provide simple methods for visually navigating complex information spaces that ease the burden of locating information while maintaining an intuitive sense of location and of relationship between information objects. As noted by Dr. Grimes, a “vector” for each object is generated and stored. Pad++ also employs internet links. Figure 5 shows a snapshot where several hypertext links have been followed. See Bederson-5 at 12. As discussed in the Prior

Reexaminations, each of the Pad++ References was published between 1995 and

1998 and is prior art to the ‘926 Patent under 35 U.S.C. § 102(b).

5. W3C Scalable Vector Graphics Requirements (SVG) (Exhibit PX1007) SVG discloses a family of specifications of an XML-based file format for

two-dimensional vector graphics, both static and dynamic (i.e., interactive or

animated). The SVG specification is an open standard that has been under

- 17 -

development by the World Wide Web Consortium (“W3C”) since 1999. SVG also teaches scalable vector-based content, including zooming, panning, hyperlinks,

HTML functionality, and Cascading Style Sheet (CSS). SVG was published

October 29, 1998, and is prior art to the ‘926 Patent under 35 U.S.C. § 102(b).

6. Japanese Application Publication H10-326169 to Masao Hara (“Hara”) (Exhibit PX1008) Hara teaches a protocol for modifying the display size of image data in

accordance with a resolution of a display screen, to display at a size that can be

recognized by a user. Along with identifying the resolution of a display screen of a

display device when obtaining data from a server, the resolution of image data that

exists within that data is identified. The resolution of the image data is converted

into a size that is in accordance with the resolution of the display screen, based on

the resolution of the display screen and on the resolution of the image data, and the

image data after the conversion is displayed on the display screen of the display

device 16. Hara was published December 8, 1998, and prior art to the ‘926 Patent

under 35 U.S.C. § 102(b).

7. Specification for the Simple Vector Format (SVF) v 1.1, (the “SVF References”) (Exhibit PX1009) The SVF References relate to the Simple Vector Format for describing Web

page content, which uses a base set of coordinates (0, 0) and describes vectors

according to their end points (X, Y) in relation to that base set of coordinates. The

SVF References disclose plug-ins that work with Web browsers and include

- 18 -

scaleable vector graphics, permit zooming and panning of a displayed Web page, and preserve Web page functionality, such as hyperlinks. Each of the SVF

References were published between 1995 and 1998 and is prior art to the ‘926

Patent under 35 U.S.C. § 102(b).

8. Matthews, et al., Vector Markup Language (“VML”) (Exhibit PX1010) VML discloses a format for storing and encoding information about objects on Web pages in terms of X, Y coordinates relative to an origin set of coordinates

(0, 0), i.e., encoding information in vector form about how Web page content can be displayed. Hara would have been understood by one of ordinary skill to disclose the elements of the alleged invention disclosed in the ‘926 Patent. Hara, in

combination with Zaurus, Pad++, the SVF References, and/or VML, renders all

requested claims of the ‘926 Patent unpatentably obvious. VML was published

May 13, 1998, and is prior art to the ‘926 Patent under 35 U.S.C. § 102(b).

D. Summary of Invalidity Arguments As discussed above, the ‘926 patent claims are directed to mobile devices

that translate HTML-based Web content into a scalable, resolution-independent

format that allows the content to be rendered, zoomed and panned, while

preserving the original layout, functionality and design of the original Web page.

The ‘926 patent claims further clarifies that the zooming, or “scaling”, may be

accomplished using scalable vectors. As will be discussed in greater detail below,

- 19 -

Zaurus plainly teaches a majority of the claimed elements. Specifically, Zaurus teaches each of the hardware claim limitations and a fully functional web browser that includes both zooming and panning functionality. While Zaurus doesn’t disclose the technological methods used to facilitate zooming and panning, the remaining prior art references each teach the translation of HTML-based Web content into a scalable format and, more specifically, scalable vectors.

Thus, it would have been obvious to one of skill in the art at the time of the purported invention to take the known HTML translation and vector zooming techniques taught by Pad++, Tsutsumitake, SVG, SVF References and VML and to apply it to Zaurus, which clearly teaches a browser having zooming capability.

The motivation to combine Pad++, Tsutsumitake, SVG, SVF References and VML with Zaurus is clear, as Zaurus describes a mobile device that can access the internet, and thereby access Web content. In fact, one of the inventors admits that insights “acquired while working in the CAD field formed the basis for the web browser technologies.” See Exhibit PX1025, pp. 10-11, 14. Noting that “CAD

drawings, like web pages, are viewed by multiple users who may operate

computers having different size and resolution displays.” Id. at 11.

- 20 -

E. Listing of RLPs Pursuant to 37 CFR § 42.108, a party is required to show a reasonable

likelihood that at least one of the claims challenged in the petition is unpatentable.

The references of Section V(C) will be used as a basis for the following RLPs.

1. RLP Issue # 1: Claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75 are obvious under 35

U.S.C. § 103(a) as being unpatentable over Zaurus in view of Pad++. This RLP is

new because neither the original Examiner nor the Examiners in the Prior

Reexaminations considered the newly cited Zaurus and Pad++ combination of references.

•Claim 30 [A]: A mobile phone, comprising: a processor,

[Zaurus_2, p. 195]; See also, Zaurus_1, p. 167. •Claim 30[B]: wireless communications means operatively coupled to the processor, to facilitate communication with a mobile service provider network via which Web content may be accessed; “The Power Zaurus offers Internet access via its “ZaurusNet” feature, which can be achieved by using its built-in modem or an external modem, PHS, or a mobile phone.”[Zaurus_1, p. 19]

“With a CE-DA5, CE-DA4, CE-DA3, or CE-DA2, data communication and G3 compatible fax transmission/receiving can be carried out by using a digital cellular phone.” [Zaurus_2, p. 176] See also, Zaurus_2, pp. 26, 176; Zaurus_1, pp. 40. Moreover, integrating voice communication was well known prior to the filing of the ‘726 patent. For example, the Nokia 9000 Communicator, which was announced in 1996, enables users to access Internet services and

- 21 -

facilitates voice calls (See PX1003). •Claim 30 [C]: a touch sensitive display;

[Zaurus_2, p. 33]; See also, Zaurus_1, pp. 29, 44, 66; Zaurus_2, pp. 33, 36. • Claim 30 [D]: a memory, operatively coupled to the processor “The Zaurus main memory size [...]” [Zaurus_1, p. 40] “[...] the data stored in a compact flash memory card [...]” [Zaurus_1, p. 37] • Claim 30 [E]: and storage means, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile phone to perform operations including;

[Zaurus_2, p. 195]; See also, Zaurus_1, pp. 40, 63, 67 • Claim 30 [F]: rendering a browser interface via which a user is enabled to request to access to a Web page having an original format comprising HTML based content defining an original page layout, functionality, and design of content on the Web page; “The Internet browser in the MI-100 series incorporates HTML 3.2 specifications in important places, and therefore has rich expressive capabilities.” [Zaurus_2, p. 68]

Pad++ discloses “a zoomable Web browser using Pad++, a substrate for building multiscale dynamic user interfaces,” where “[c]licking on a link brings up a new page.” [Bederson-3 at 262]

“When you follow a link, the relevant document is loaded into Pad++ and placed

- 22 -

on the surface to the right of the original document, at a smaller scale. ” [Tour at 91];

Furthermore, Tour is an illustration of a web browsing implementation of Pad++, one of ordinary skill in the art would have considered Tour in clarifying the terminology used in Pad++. Specifically, section 3 of Tour illustrates a web browser implementation of the Pad++ system: “A zooming version of Mosaic and Netscape? This is not such a strange idea. The third example Pad++ application we will look at is a simple Pad++ web browser.” Tour at 86. Page 87 of Tour shows “a screen snapshot showing Pad++ displaying an HTML document.”; See also, Zaurus_1, p. 154; Zaurus_2, pp. 26, 68; Bederson-3 at 260, 262; Bederson-4 at 1103; Tour at 87, 89 • Claim 30 [G]: retrieving HTML based content associated with the Web page, The Power Zaurus offers Internet access via its “ZaurusNet” feature, which can be achieved by using its built-in modem or an external modem, PHS, or a mobile phone. [Zaurus_1, p. 19]

“The Internet browser in the MI-100 series incorporates HTML 3.2 specifications in important places, and therefore has rich expressive capabilities.” [Zaurus_2, p. 68]; See also Zaurus_1, pp. 40, 44, 93; Zaurus_2, pp. 26, 176.

“visualization and navigation of WWW pages written using standard HTML” using “a prototype zooming browser to explore alternative mechanisms for navigating the WWW. . . As a link is followed the page becomes the focus and existing pages are dynamically repositioned and scaled.” [Bederson-3 at 260] • Claim 30 [H]: translating at least a portion of the HTML based content from its original format to produce translated content including scalable vector based content that supports a scalable resolution independent representation of the HTML based content that preserves an original page layout, functionality and design of the at least a portion of the HTML based content when scaled and rendered; “To switch the screen from a reduced view to a magnified view, touch Reduce ▼ followed by Magnify . To switch back from a magnified view to a reduced view, touch Magnify ▼ followed by Reduce.” [Zaurus_2, p. 86]

You can see and write on the area outside of the screen by scrolling the screen horizontally and vertically [...] [Zaurus_1, p. 29]

Pad++ teaches the translation of standard HTML into Pad++ objects that comprise

- 23 -

“scalable” and “vector-based” content and/or page layout information (See e.g., Bederson-2 at 3-4; Reference Manual at 4-8; Programmer’s Guide at 2-3, 30, 47, 49, 50, 60-64, 71, and 72, and Tour at 87-96); and Vector-based layout of the elements of an HTML-based Web page comprising vectors generated from resolution-independent coordinates relative to a fixed datum point (See e.g., Bederson-4 at 1129-1132, Programmer’s Guide at 4-8, Reference Manual at 2-3, 30, 47, 49, 50, 60-64, 71, and 72).

Pad ++ teaches translating HTML-based Web content to produce Pad++ “objects” that enable zooming and panning of Web pages. See Bederson-3 at 260, 262, and 264. A Pad++ object is “a graphical entity that is manipulated as a whole by the system. This might be a simple object such as a poly-line segment, or a compound object such as an HTML page composed of many characters, line segments and images.” [Bederson-4 at 1104]

“Pad ++ reads hypertext written in the Hypertext Markup Language (HTML), the language used to describe hypertext documents used by WWW browsers such as Mosaic and Netscape. Pad++ also can follow links across the internet. Figure 5 shows a snapshot where several hypertext links have been followed. Two views show the same tree focused on different nodes. The Pad ++ user interface for accessing hypertext is similar to traditional systems, but zooming mechanisms are employed.” [Bederson-5 at 12]

“The Pad++ object corresponding to each page element associates the page element with an (x,y) coordinate relative to a common datum point (i.e., a fixed known primary datum, such as the default origin (0,0)). For example, the Pad++ reference disclose that “each view has an offset and a magnification, which are stored as a triplet (xview, yview, zoom). Every object has a position and a scale (xoffset, yoffset, scale). In addition, objects such as polygons and lines also have coordinates (x1, y1, …).” [Bederson-4 at 1132]

“AnchorPos tells how to position the object relative to the positioning point for the item (see -place); it may have any of the forms accepted by Tk_GetAnchor. For example, if anchorPos is "center" then the object is centered on the point; if anchorPos is "n" then the object will be drawn so that its top center point is at the positioning point. This option defaults to center.” [Reference Manual at 47]

“Pad++ maintains a distinction between the surface and the view. All graphical items sit at a distinct location on the surface with a given size. The view shows any given location on the surface at any magnification.” [Programmer’s Guide

- 24 -

at 6-8]

Thus, those of ordinary skill in the art would also understand the Pad++ HTML document as “translating [...] to fit across the display.” • Claim 30 [I]: and employing the scalable vector based content to render a view of at least a portion of the Web page on the display using a first scale factor, wherein preservation of the functionality defined by the HTML based content includes preservation of hyperlink functionality. A “vector” for each object is generated and stored because otherwise, the –place command would not return a resulting location for the object relative to the primary datum. A –place of X, Y only makes sense if the coordinate X, Y is known to be relative to a known reference point, i.e., the origin at the center of the Pad++ surface. Since we have an origin (tail location) and a – place (a head, or object anchor location), then we have necessarily defined a vector. Using the common shorthand used in the ‘353 and ‘926 patents, one of skill in the art would understand that this vector in Pad++ is from the known origin of the Pad++ surface to the “-anchor” of the object. Thus, in Pad++, a vector is generated from the primary datum to the -anchor datum for each object, just as in item 158 of Figure 5 of the ‘353 and ‘926 patents. Also, that the –place command returns this location means that Pad++ has created a reference that links the object to its vector and anchor, just as in item 160 of Figure 5 of the ‘353 and ‘926 patents. [Grimes-1, ¶¶ 55-56]; See also, Bederson-2 at 4; Bederson-4 at 1132; Reference Manual at 47; Programmer’s Guide at 6-8; RLP 1, Claim 1[H]. • Claim 31: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising enabling the user to zoom in on a user selectable portion of a display of the Web page in response to a user interface input made via the touch sensitive display. Pad++ teaches or suggests “execution of the instructions performs further operations comprising enabling the user to zoom in on a user-selectable portion of a display of the Web page in response to a user interface input made via the

- 25 -

touch-sensitive display.” Bederson-3 at 260, 262; Bederson-5 at 4-5, 7.; See also RLP 1, Claim 30 [H]; Zaurus_1, p. 19, 20, 29, 44, 55, 86, 93; Zaurus_2, p. 26, 33 • Claim 40: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising enabling a user to view a column of the Web content at a higher resolution than a current resolution by tapping on the column via the touch sensitive display, wherein in response thereto, the display is re rendered such that content corresponding to the selected column is displayed to fit across the touch sensitive display. See RLP 1, Claim 1[H] – 1[I]. See also Zaurus_1, p. 19, 20, 29, 44, 55, 66, 86, 93; Zaurus_2, p. 26, 33, 36; Bederson-3 at 260, 262, 264; Bederson-4 at 1120, 1128- 29, 1131-32; Bederson-5 at 12, 14, 23; Programmer’s Guide at 6-8; Reference Manual at 2-3, 47, 49-50; Tour at 86-87, 89, 91, 93, 96 • Claim 41 [A]: The mobile phone of claim 30, wherein the Web content includes at least one image, It can display images not only in GIF format, but also in the commonly found JPEG format on a page in 16-gradation grayscale. [Zaurus_2, p. 68] • Claim 41 [B]: and wherein execution of the instructions performs further operations comprising enabling a user to view an image at a higher resolution than a current resolution by tapping on the image via the touch sensitive display, wherein in response thereto, the display is re rendered such that the image is displayed to fit across at least one of a width and height of a display area of the touch sensitive display. “The Internet browser in the MI-100 series incorporates HTML 3.2 specifications in important places, and therefore has rich expressive capabilities.” [Zaurus_2, p. 68]

Pad++ discloses “a zoomable Web browser using Pad++, a substrate for building multiscale dynamic user interfaces,” where “[c]licking on a link brings up a new page.” [Bederson-3 at 262]

- 26 -

• Claim 43 [A]: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising: generating a display list associated with the scalable vector based content; Specifically, “[e]very object has a position and a scale (xoffset, yoffset, scale). In addition, objects such as polygons and lines also have coordinates (x1, y1, …).” [Bederson-4 at 1132.

“Objects exist on a surface within the surface’s coordinate system. The Pad++ coordinate system uses a standard right-handed Cartesian coordinate system. The X axis increases to the right and the Y axis increases up.” [Bederson-4 at 1129

Thus, as the Pad++ references disclose assigning the objects with coordinates, the Pad++ references disclose “generating a vector from the primary datum to the object datum for the object.” Additionally, pages 6-8 of the Programmer’s Guide describe creating or rendering objects (e.g., a rectangle) on a surface of the Pad++ system. That is, the Programmer’s Guide teaches or suggests “defining a primary datum corresponding to a page layout.”

At p. 6, the Programmer’s Guide recites that the command “.pad create rectangle 0 0 100 100 –tags “rect2” –fill white” will draw a white rectangle on the Pad++ surface.

The Pad++ object corresponding to each page element associates the page element with an (x,y) coordinate relative to a common datum point (i.e., a fixed known primary datum, such as the default origin (0,0)). For example, the Pad++ reference disclose that “each view has an offset and a magnification, which are stored as a triplet (xview, yview, zoom). Every object has a position and a scale (xoffset, yoffset, scale). In addition, objects such as polygons and lines also have coordinates (x1, y1, …).” [Bederson-4 at 1132] See also, Bederson-2 at 4 Bederson-4 at 1129, 1132; Bederson-5 at 16; Programmer’s Guide at 6-8; Reference Manual at 47; see also Grimes Declaration, ¶ 55-56 • Claim 43 [B]: and employing the display list to re render the display at different scale factors to enable rapid zooming of the Web page. “visualization and navigation of WWW pages written using standard HTML” using “a prototype zooming browser to explore alternative mechanisms for navigating the WWW. . . As a link is followed the page becomes the focus and existing pages are dynamically repositioned and scaled.” [Bederson-3 at 260]

Pad++ discloses “a zoomable Web browser using Pad++, a substrate for building multiscale dynamic user interfaces,” where “[c]licking on a link brings up a new

- 27 -

page.” [Bederson-3 at 262]

“This command will return the data “50 50 1.” This means the rectangle “rect2” is located with its center (e.g., the object datum) at 50 50, with a scale factor of “1.” That is, there is necessarily a vector representing the “place” of “rect2” that has its “tail” at coordinates (0,0) (e.g., the primary datum) and its “head” at coordinates (50,50) (e.g., the object datum).” [Programmer’s Guide, p. 7].

“When you follow a link, the relevant document is loaded into Pad++ and placed on the surface to the right of the original document, at a smaller scale. ” [Tour at 91]; See also, Zaurus_1, p. 19-20, 29, 55, 86, 93, 154; Zaurus_2, pp. 26, 68; Bederson-3 at 260, 262, 264; Bederson-4 at 1103-04, 1120, 1128-29, 1132-33; Tour at 86-87, 89, 91, 93, 96 • Claim 52 [A]: A mobile device, comprising: a processor, wireless communications means, to facilitate wireless communication with a network via which Web content may be accessed; See RLP 1, Claim 30 [A]-[B]. • Claim 52 [B]: a touch sensitive display; See RLP 1, Claim 30 [C]. • Claim 52 [C]: flash memory, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile device to perform operations including See RLP 1, Claim 30 [D]. • Claim 52 [D]: rendering a browser interface via which a user is enabled to request access to a Web page comprising HTML based Web content defining an original page layout, functionality, and design of content on the Web page; See RLP 1, Claim 30 [F]. • Claim 52 [E]: retrieving and processing the HTML based Web content to produce scalable content; See RLP 1, Claim 30 [F]. • Claim 52 [F]: and employing the scalable content and/or data derived therefrom to, render a view of the Web page on the touch sensitive display; See RLP 1, Claim 30 [H] and RLP 1, Claim 30 [I]. • Claim 52 [G]: and re render the Web page in response to associated user inputs to enable the user to iteratively zoom in and out views of the Web page while preserving an original page layout, functionality, and design defined by the HTML based Web content as interpreted by a rendering engine, wherein preservation of the functionality defined by the HTML based Web content

- 28 -

includes preservation of hyperlink functionality. The Internet browser in the MI-100 series incorporates HTML 3.2 specifications in important places, and therefore has rich expressive capabilities. [Zaurus_2, p. 68] “visualization and navigation of WWW pages written using standard HTML” using “a prototype zooming browser to explore alternative mechanisms for navigating the WWW. . . As a link is followed the page becomes the focus and existing pages are dynamically repositioned and scaled.” [Bederson-3 at 260] Pad++ discloses “a zoomable Web browser using Pad++, a substrate for building multiscale dynamic user interfaces,” where “[c]licking on a link brings up a new page.” [Bederson-3 at 262] “When you follow a link, the relevant document is loaded into Pad++ and placed on the surface to the right of the original document, at a smaller scale. ” [Tour at 91]. “To switch the screen from a reduced view to a magnified view, touch Reduce ▼ followed by Magnify . To switch back from a magnified view to a reduced view, touch Magnify ▼ followed by Reduce.” [Zaurus_2, p. 86]

You can see and write on the area outside of the screen by scrolling the screen horizontally and vertically [...] [Zaurus_1, p. 29]

Pad++ teaches the translation of standard HTML into Pad++ objects that comprise “scalable” and “vector-based” content and/or page layout information (See e.g., Bederson-2 at 3-4; Reference Manual at 4-8; Programmer’s Guide at 2-3, 30, 47, 49, 50, 60-64, 71, and 72, and Tour at 87-96); and Vector-based layout of the elements of an HTML-based Web page comprising vectors generated from resolution-independent coordinates relative to a fixed datum point (See e.g., Bederson-4 at 1129-1132, Programmer’s Guide at 4-8, Reference Manual at 2-3, 30, 47, 49, 50, 60-64, 71, and 72).

“The Pad++ object corresponding to each page element associates the page element with an (x,y) coordinate relative to a common datum point (i.e., a fixed

- 29 -

known primary datum, such as the default origin (0,0)). For example, the Pad++ reference disclose that “each view has an offset and a magnification, which are stored as a triplet (xview, yview, zoom). Every object has a position and a scale (xoffset, yoffset, scale). In addition, objects such as polygons and lines also have coordinates (x1, y1, …).” [Bederson-4 at 1132]

See also, Zaurus_1, pp. 19-20, 29, 44, 55, 93; Zaurus_2, pp. 26, 86; Bederson-3 at 260, 262, 264; Bederson-4 at 1132 33, 1104, 1120, 1128-29, 1132; Bederson-5 at 4, 12, 23; Tour at 86-87, 89, 91, 93, 96; Reference Manual at 47; Programmer’s Guide at 6, 8. • Claim 55: The mobile device of claim 52, wherein execution of the instructions performs further operations comprising enabling the user to zoom in on a user selectable portion of a display of the Web page in response to a user interface input made via the touch sensitive display. See RLP 1, Claim 52 [G] and RLP 1, Claim 30 [C]. • Claim 59 : The mobile device of claim 52, wherein at least a portion of the scalable content comprises scalable vector based content. A “vector” for each object is generated and stored because otherwise, the –place command would not return a resulting location for the object relative to the primary datum. A –place of X, Y only makes sense if the coordinate X, Y is known to be relative to a known reference point, i.e., the origin at the center of the Pad++ surface. Since we have an origin (tail location) and a – place (a head, or object anchor location), then we have necessarily defined a vector. Using the common shorthand used in the ‘353 and ‘926 patents, one of skill in the art would

- 30 -

understand that this vector in Pad++ is from the known origin of the Pad++ surface to the “-anchor” of the object. Thus, in Pad++, a vector is generated from the primary datum to the -anchor datum for each object, just as in item 158 of Figure 5 of the ‘353 and ‘926 patents. Also, that the –place command returns this location means that Pad++ has created a reference that links the object to its vector and anchor, just as in item 160 of Figure 5 of the ‘353 and ‘926 patents. [Grimes-1, ¶¶ 55-56]; See also, Bederson-2 at 4; Bederson-4 at 1132; Reference Manual at 47; Programmer’s Guide at 6-8. • Claim 72 [A]: The mobile device of claim 52, wherein execution of the instructions performs further operations comprising: parsing HTML based code corresponding to the received Web content to identify content on the Web page; See RLP 1, Claim 30 [F]. • Claim 72 [B]: logically grouping selected content into objects; Spatial indexing in Pad++ is described as follows: “There are several widely used spatial indexing algorithms (a survey of spatial indexing algorithms and their applications can be found elsewhere.). Many are hierarchical, and are based on partitioning space in smaller and smaller segments. Algorithms include R-trees, MX-CIF quad-trees, binary space partitioning trees, and k-d trees .... In implementing Pad++, we chose to use an R-tree. An R-tree is a hierarchical structure based on bounding regions. Objects are contained in leaf nodes, and internal nodes contain regions that specify the bounds of its children.... Regions can overlap, so while an object is only a member of a single region, a query can need to look at several regions at each level. R-trees are similar to quad-trees, except that they partition space into regions based on the objects within the space, and not based on fixed-sized grids [...]. This supports our goal to handle very dynamic data spaces, in which many objects move and resize over time.” [Bederson-4 at 1120]

Pad++ further discloses that “[o]bjects are stored internally in a hierarchy based on bounding boxes which allow fast indexing to visible objects.” [Bederson-5 at 23]

“Objects: every graphical item on a Pad++ surface is derived from a base Object class. This class defines much of the behavior common to all objects. It controls where and at what size an object appears, the object’s transparency, and the range of sizes at which it is visible. It also controls the object’s stickiness and drawing order, as well as what layer it is on...” [Bederson-4 at 1128]; See also, Bederson- 3 at 262; Bederson-4 at 1120). • Claim 72 [C]: defining a primary datum corresponding to the original page

- 31 -

layout; Pad++ teaches or suggests defining a primary datum [...]. For example, pages 6-8 of the Programmer’s Guide describe creating or rendering objects (e.g., a rectangle) on a surface of the Pad++ system.

“Surfaces, views, and portals The Pad++ dataspace is structured around surfaces and views. A surface is a plane on which objects exist. The Pad++ environment supports multiple surfaces simultaneously. Each surface can be visible within toplevel windows, or can be seen within portals. Objects exist on a surface within the surface’s coordinate system. The Pad++ coordinate system uses a standard right-handed Cartesian coordinate system. The X axis increases to the right and the Y axis increases up. Note that this is different from many graphical windowing systems. All coordinates are specified in floating point units that by default correspond to the dimensions of a single pixel on the screen. This means that, when the top-level view is at a scale of 2.0, a line drawn on the surface from 0.0 to 100.0 is 200 pixels long. Dimensions can also be specified in inches, millimeters, or points.

Surfaces are mapped to the screen through views. Each surface that is mapped to a top-level window implicitly gets a view that controls what part of the surface is visible in that window. Views specify the visible portion of a surface with a point and a magnification. The point specifies the portion of the surface that will appear at the center of the view. The magnification specifies how much the surface should be enlarged or shrunk.” [Bederson-4 at 1129]

“[E]ach view has an offset and a magnification, which are stored as a triplet (xview, yview, zoom). Every object has a position and a scale (xoffset, yoffset, scale). In addition, objects such as polygons and lines also have coordinates (x1, y1, …)...” [Bederson-4 at 1131-1132]

Pad++ recites that the command .pad create rectangle 0 0 100 100 –tags “rect2” – fill white will draw a white rectangle on the Pad++ surface. [Programmer’s Guide, p. 6]; See also, Bederson-4 at 1104, 1120, 1128; Bederson-5 at 23; Bederson-3 at 260, 262, and 264 • Claim 72 [D]: and, for each object, defining an object datum corresponding to a layout location datum for the object’s associated display content; Pad++ discloses for each object, defining an object datum corresponding to a layout location datum for the object's associated display content. “... Every object has a position and a scale (xoffset, yoffset, scale). In addition, objects such as polygons and lines also have coordinates (x1, y1, …)...” [Bederson-4 at 1132]

- 32 -

“[2] -anchor anchorPos (available only for all item types) AnchorPos tells how to position the object relative to the positioning point for the item (see -place); it may have any of the forms accepted by Tk_GetAnchor. For example, if anchorPos is "center" then the object is centered on the point; if anchorPos is "n" then the object will be drawn so that its top center point is at the positioning point. This option defaults to center.” [Reference Manual at 47] • Claim 72 [E]: generating a vector from the primary datum to the object datum for the object; Pad++ teaches or suggests “generating a vector from the primary datum to the object datum for the object.” Specifically, “[e]very object has a position and a scale (xoffset, yoffset, scale). In addition, objects such as polygons and lines also have coordinates (x1, y1, …).” [Bederson-4 at 1132]

As Pad++ discloses assigning the objects with coordinates, Pad++ discloses “generating a vector from the primary datum to the object datum for the object.” See also, Bederson-2 at 4; Bederson-4 at 1129, 1132; Reference Manual at 47; Programmer’s Guide at 6-8; Grimes-1, ¶¶55 56 • Claim 72 [F]: and creating a reference that links the object to its corresponding vector. “[e]very object has a position and a scale (xoffset, yoffset, scale). In addition, objects such as polygons and lines also have coordinates (x1, y1, …).” [Bederson-4 at 1132]

Moreover, “[e]ach item has a unique identifying number (its id), which is assigned to that item when it is created.” and “[e]ach item may also have any number of tags associated with it. A tag is just a string of characters, and it may take any form except that of an integer. . . . Then, all of those items can be modified by referring to that tag.” [Reference Manual, p. 3]; See also, Reference Manual, p. 3; Bederson-4 at 1129, 1132; Programmer’s Guide at 8 • Claim 75 [A]: The mobile device of claim 52, wherein the original format of the Web page defines a width for the Web page, and wherein execution of the instructions performs further operations comprising: determining an applicable scale factor to fit the width of the Web page across a display area of the touch sensitive display; Pad++ discloses “a zoomable Web browser using Pad++, a substrate for building

- 33 -

multiscale dynamic user interfaces,” where “[c]licking on a link brings up a new page.” [Bederson-3 at 262]

“Pad++ supports panning and zooming. Zooming can involve simple geometric scaling....” [Bederson-3 at 262]

“The user controls where they look on this vast data surface by panning and zooming.” [Bederson-5 at 4]

“To understand this, note that each view has an offset and a magnification, which are stored as a triplet (xview, yview, zoom). Every object has a position and a scale (xoffset, yoffset, scale). In addition, objects such as polygons and lines also have coordinates (x1, y1, …). To apply a coordinate transformation from object to screen coordinates, we start by applying the transform for the current view (in these examples, we show only the x coordinate).” [Bederson-4 at 1132-33] • Claim 75 [B]: and employing the scale factor to render the display area. See RLP 1, Claim 75 [A].

2. RLP Issue # 2: Claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75 are obvious under 35

U.S.C. § 103(a) as being unpatentable over Zaurus in view of the Pad++ and

Scalable Vector Graphics (“SVG”) Requirements. This RLP is new because neither the original Examiner nor the Examiners in the Prior Reexaminations considered the newly cited Zaurus, Pad++, and SVG combination of references.

- 34 -

• Claim 30 [E]: and storage means, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile phone to perform operations including; See RLP 1, Claim 30 [E]. • Claim 30 [F]: rendering a browser interface via which a user is enabled to request to access to a Web page having an original format comprising HTML based content defining an original page layout, functionality, and design of content on the Web page; See RLP 1, Claim 30 [F]. • Claim 30 [G]: retrieving HTML based content associated with the Web page, See RLP 1, Claim 30 [G]. • Claim 30 [H]: translating at least a portion of the HTML based content from its original format to produce translated content including scalable vector based content that supports a scalable resolution independent representation of the HTML based content that preserves an original page layout, functionality and design of the at least a portion of the HTML based content when scaled and rendered; See RLP 1, Claim 30 [H].

For the reasons set forth in RLP 1, Zaurus and Pad++ teach the claim elements required in claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75. However, to the extent that Zaurus and Pad++ may not teach vector-based content, SVG discloses wherein at least a portion of the scalable content comprises scalable vector-based content.

- 35 -

zoom in on a user selectable portion of a display of the Web page in response to a user interface input made via the touch sensitive display. See RLP 1, Claim 31. • Claim 40: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising enabling a user to view a column of the Web content at a higher resolution than a current resolution by tapping on the column via the touch sensitive display, wherein in response thereto, the display is re rendered such that content corresponding to the selected column is displayed to fit across the touch sensitive display. See RLP 1, Claim 40. • Claim 41 [A]: The mobile phone of claim 30, wherein the Web content includes at least one image, See RLP 1, Claim 41 [A]. • Claim 41 [B]: and wherein execution of the instructions performs further operations comprising enabling a user to view an image at a higher resolution than a current resolution by tapping on the image via the touch sensitive display, wherein in response thereto, the display is re rendered such that the image is displayed to fit across at least one of a width and height of a display area of the touch sensitive display. See RLP 1, Claim 41 [A]. • Claim 43 [A]: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising: generating a display list associated with the scalable vector based content; See RLP 1, Claim 43 [A] and RLP 2, Claim 30 [H]. • Claim 43 [B]: and employing the display list to re render the display at different scale factors to enable rapid zooming of the Web page. See RLP 1, Claim 43 [B]. • Claim 52 [A]: A mobile device, comprising: a processor, wireless communications means, to facilitate wireless communication with a network via which Web content may be accessed; See RLP 1, Claim 52 [A]. • Claim 52 [B]: a touch sensitive display; See RLP 1, Claim 52 [B]. • Claim 52 [C]: flash memory, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile device to perform operations including See RLP 1, Claim 52 [C]. • Claim 52 [D]: rendering a browser interface via which a user is enabled to request access to a Web page comprising HTML based Web content defining

- 36 -

an original page layout, functionality, and design of content on the Web page; See RLP 1, Claim 52 [D]. • Claim 52 [E]: retrieving and processing the HTML based Web content to produce scalable content; See RLP 1, Claim 52 [E]. • Claim 52 [F]: and employing the scalable content and/or data derived therefrom to, render a view of the Web page on the touch sensitive display; See RLP 1, Claim 52 [F]. • Claim 52 [G]: and re render the Web page in response to associated user inputs to enable the user to iteratively zoom in and out views of the Web page while preserving an original page layout, functionality, and design defined by the HTML based Web content as interpreted by a rendering engine, wherein preservation of the functionality defined by the HTML based Web content includes preservation of hyperlink functionality. See RLP 1, Claim 52 [G]. • Claim 55: The mobile device of claim 52, wherein execution of the instructions performs further operations comprising enabling the user to zoom in on a user selectable portion of a display of the Web page in response to a user interface input made via the touch sensitive display. See RLP 1, Claim 55. • Claim 59 : The mobile device of claim 52, wherein at least a portion of the scalable content comprises scalable vector based content. See RLP 1, Claim 59 and RLP 2, Claim 30 [H]. • Claim 72 [A]: The mobile device of claim 52, wherein execution of the instructions performs further operations comprising: parsing HTML based code corresponding to the received Web content to identify content on the Web page; See RLP 1, Claim 72 [A]. • Claim 72 [B]: logically grouping selected content into objects; See RLP 1, Claim 72 [B]. • Claim 72 [C]: defining a primary datum corresponding to the original page layout; See RLP 1, Claim 72 [C]. • Claim 72 [D]: and, for each object, defining an object datum corresponding to a layout location datum for the object’s associated display content; See RLP 1, Claim 72 [D]. • Claim 72 [E]: generating a vector from the primary datum to the object datum for the object;

- 37 -

See RLP 1, Claim 72 [E] and RLP 2, Claim 30 [H]. • Claim 72 [F]: and creating a reference that links the object to its corresponding vector. See RLP 1, Claim 72 [F] and RLP 2, Claim 30 [H]. • Claim 75 [A]: The mobile device of claim 52, wherein the original format of the Web page defines a width for the Web page, and wherein execution of the instructions performs further operations comprising: determining an applicable scale factor to fit the width of the Web page across a display area of the touch sensitive display; See RLP 1, Claim 75[A]. • Claim 75 [B]: and employing the scale factor to render the display area. See RLP 1, Claim 72 [B].

3. RLP Issue # 3: Claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75 are obvious over Zaurus in view of Pad++ and SVF References. This RLP is new because neither the original

Examiner nor the Examiners in the Prior Reexaminations considered the newly cited Zaurus, Pad++ and SVF References combination of references.

•Claim 30 [A]: A mobile phone, comprising: a processor, See RLP 1, Claim 30 [A]. •Claim 30[B]: wireless communications means operatively coupled to the processor, to facilitate communication with a mobile service provider network via which Web content may be accessed; See RLP 1, Claim 30 [B]. •Claim 30 [C]: a touch sensitive display; See RLP 1, Claim 30 [C]. • Claim 30 [D]: a memory, operatively coupled to the processor See RLP 1, Claim 30 [D]. • Claim 30 [E]: and storage means, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile phone to perform operations including; See RLP 1, Claim 30 [E]. • Claim 30 [F]: rendering a browser interface via which a user is enabled to request to access to a Web page having an original format comprising HTML

- 38 -

based content defining an original page layout, functionality, and design of content on the Web page; See RLP 1, Claim 30 [F]. • Claim 30 [G]: retrieving HTML based content associated with the Web page, See RLP 1, Claim 30 [G]. • Claim 30 [H]: translating at least a portion of the HTML based content from its original format to produce translated content including scalable vector based content that supports a scalable resolution independent representation of the HTML based content that preserves an original page layout, functionality and design of the at least a portion of the HTML based content when scaled and rendered; See RLP 1, Claim 30 [H].

For the reasons set forth in RLP 1, Zaurus and Pad++ teach the claim elements required in claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75. However, to the extent that Zaurus and Pad++ may not teach vector-based content, the SVF References discloses wherein at least a portion of the scalable content comprises scalable vector-based content.

“SVF is designed to be a simple format for describing vector images.” [SVF at 1] “As with most vector formats, the origin (0,0) is in the lower left comer with increasing x coordinates moving to the right and increasing y coordinates moving up.” [SVF at 1]

“The SVF plug-in also features navigation via HTML hyperlinks [...]” [SVF Press 2]

“Both plug-ins work with popular Web browsers such as Netscape Navigator.” [SVF Press 1] • Claim 30 [I]: and employing the scalable vector based content to render a view of at least a portion of the Web page on the display using a first scale factor, wherein preservation of the functionality defined by the HTML based content includes preservation of hyperlink functionality. See RLP 1, Claim 30 [I] and RLP 3, Claim 30 [H]. • Claim 31: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising enabling the user to zoom in on a user selectable portion of a display of the Web page in response to a user interface input made via the touch sensitive display. See RLP 1, Claim 31.

- 39 -

• Claim 40: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising enabling a user to view a column of the Web content at a higher resolution than a current resolution by tapping on the column via the touch sensitive display, wherein in response thereto, the display is re rendered such that content corresponding to the selected column is displayed to fit across the touch sensitive display. See RLP 1, Claim 40. • Claim 41 [A]: The mobile phone of claim 30, wherein the Web content includes at least one image, See RLP 1, Claim 41 [A]. • Claim 41 [B]: and wherein execution of the instructions performs further operations comprising enabling a user to view an image at a higher resolution than a current resolution by tapping on the image via the touch sensitive display, wherein in response thereto, the display is re rendered such that the image is displayed to fit across at least one of a width and height of a display area of the touch sensitive display. See RLP 1, Claim 41 [A]. • Claim 43 [A]: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising: generating a display list associated with the scalable vector based content; See RLP 1, Claim 43 [A] and RLP 3, Claim 30 [H]. • Claim 43 [B]: and employing the display list to re render the display at different scale factors to enable rapid zooming of the Web page. See RLP 1, Claim 43 [B]. • Claim 52 [A]: A mobile device, comprising: a processor, wireless communications means, to facilitate wireless communication with a network via which Web content may be accessed; See RLP 1, Claim 52 [A]. • Claim 52 [B]: a touch sensitive display; See RLP 1, Claim 52 [B]. • Claim 52 [C]: flash memory, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile device to perform operations including See RLP 1, Claim 52 [C]. • Claim 52 [D]: rendering a browser interface via which a user is enabled to request access to a Web page comprising HTML based Web content defining an original page layout, functionality, and design of content on the Web page; See RLP 1, Claim 52 [D].

- 40 -

• Claim 52 [E]: retrieving and processing the HTML based Web content to produce scalable content; See RLP 1, Claim 52 [E]. • Claim 52 [F]: and employing the scalable content and/or data derived therefrom to, render a view of the Web page on the touch sensitive display; See RLP 1, Claim 52 [F]. • Claim 52 [G]: and re render the Web page in response to associated user inputs to enable the user to iteratively zoom in and out views of the Web page while preserving an original page layout, functionality, and design defined by the HTML based Web content as interpreted by a rendering engine, wherein preservation of the functionality defined by the HTML based Web content includes preservation of hyperlink functionality. See RLP 1, Claim 52 [G]. • Claim 55: The mobile device of claim 52, wherein execution of the instructions performs further operations comprising enabling the user to zoom in on a user selectable portion of a display of the Web page in response to a user interface input made via the touch sensitive display. See RLP 1, Claim 55. • Claim 59 : The mobile device of claim 52, wherein at least a portion of the scalable content comprises scalable vector based content. See RLP 1, Claim 59 and RLP 3, Claim 30 [H]. • Claim 72 [A]: The mobile device of claim 52, wherein execution of the instructions performs further operations comprising: parsing HTML based code corresponding to the received Web content to identify content on the Web page; See RLP 1, Claim 72 [A]. • Claim 72 [B]: logically grouping selected content into objects; See RLP 1, Claim 72 [B]. • Claim 72 [C]: defining a primary datum corresponding to the original page layout; See RLP 1, Claim 72 [C]. • Claim 72 [D]: and, for each object, defining an object datum corresponding to a layout location datum for the object’s associated display content; See RLP 1, Claim 72 [D]. • Claim 72 [E]: generating a vector from the primary datum to the object datum for the object; See RLP 1, Claim 72 [E] and RLP 3, Claim 30 [H]. • Claim 72 [F]: and creating a reference that links the object to its corresponding vector.

- 41 -

See RLP 1, Claim 72 [F] and RLP 3, Claim 30 [H]. • Claim 75 [A]: The mobile device of claim 52, wherein the original format of the Web page defines a width for the Web page, and wherein execution of the instructions performs further operations comprising: determining an applicable scale factor to fit the width of the Web page across a display area of the touch sensitive display; See RLP 1, Claim 75[A]. • Claim 75 [B]: and employing the scale factor to render the display area. See RLP 1, Claim 72 [B].

4. RLP Issue # 4: Claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75 are obvious over Zaurus in

view of Pad++ and VML. This RLP is new because neither the original Examiner

nor the Examiners in the Prior Reexaminations considered the newly cited Zaurus,

Pad++ and VML combination of references.

- 42 -

• Claim 30 [G]: retrieving HTML based content associated with the Web page, See RLP 1, Claim 30 [G]. • Claim 30 [H]: translating at least a portion of the HTML based content from its original format to produce translated content including scalable vector based content that supports a scalable resolution independent representation of the HTML based content that preserves an original page layout, functionality and design of the at least a portion of the HTML based content when scaled and rendered; See RLP 1, Claim 30 [H].

For the reasons set forth in RLP 1, Zaurus and Pad++ teach the claim elements required in claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75. However, to the extent that Zaurus and Pad++ may not teach vector-based content, the VML References discloses wherein at least a portion of the scalable content comprises scalable vector-based content.

VML “defines a format for the encoding of vector information together with additional markup to describe how that information [for example, webpage content] may be displayed and edited.” [VML at p. 1]

“2D coordinates are defined as single attributes ‘x,y’ rather than pairs of attributes.” [VML at p. 7]

“Vector 2D [is] numeric data in the from X,Y. Usually used to list a coordinate in 2D space. May be in form ‘x y’ or ‘x, y’.” [VML at p. 11]

“The coordorigin attribute defines the coordinate at the top left corner of the containing block. . . . The rationale behind this is that the vectors defining a shape can be specified in a local coordinate system.” [VML at p.10]

“coordorigin Vector2D "0 0" The coordinates at the top-left corner of the containing block." [VML at p. 15] • Claim 30 [I]: and employing the scalable vector based content to render a view of at least a portion of the Web page on the display using a first scale factor, wherein preservation of the functionality defined by the HTML based content includes preservation of hyperlink functionality. See RLP 1, Claim 30 [I] and RLP 4, Claim 30 [H]. • Claim 31: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising enabling the user to

- 43 -

zoom in on a user selectable portion of a display of the Web page in response to a user interface input made via the touch sensitive display. See RLP 1, Claim 31. • Claim 40: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising enabling a user to view a column of the Web content at a higher resolution than a current resolution by tapping on the column via the touch sensitive display, wherein in response thereto, the display is re rendered such that content corresponding to the selected column is displayed to fit across the touch sensitive display. See RLP 1, Claim 40. • Claim 41 [A]: The mobile phone of claim 30, wherein the Web content includes at least one image, See RLP 1, Claim 41 [A]. • Claim 41 [B]: and wherein execution of the instructions performs further operations comprising enabling a user to view an image at a higher resolution than a current resolution by tapping on the image via the touch sensitive display, wherein in response thereto, the display is re rendered such that the image is displayed to fit across at least one of a width and height of a display area of the touch sensitive display. See RLP 1, Claim 41 [A]. • Claim 43 [A]: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising: generating a display list associated with the scalable vector based content; See RLP 1, Claim 43 [A] and RLP 4, Claim 30 [H]. • Claim 43 [B]: and employing the display list to re render the display at different scale factors to enable rapid zooming of the Web page. See RLP 1, Claim 43 [B]. • Claim 52 [A]: A mobile device, comprising: a processor, wireless communications means, to facilitate wireless communication with a network via which Web content may be accessed; See RLP 1, Claim 52 [A]. • Claim 52 [B]: a touch sensitive display; See RLP 1, Claim 52 [B]. • Claim 52 [C]: flash memory, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile device to perform operations including See RLP 1, Claim 52 [C]. • Claim 52 [D]: rendering a browser interface via which a user is enabled to request access to a Web page comprising HTML based Web content defining

- 44 -

an original page layout, functionality, and design of content on the Web page; See RLP 1, Claim 52 [D]. • Claim 52 [E]: retrieving and processing the HTML based Web content to produce scalable content; See RLP 1, Claim 52 [E]. • Claim 52 [F]: and employing the scalable content and/or data derived therefrom to, render a view of the Web page on the touch sensitive display; See RLP 1, Claim 52 [F]. • Claim 52 [G]: and re render the Web page in response to associated user inputs to enable the user to iteratively zoom in and out views of the Web page while preserving an original page layout, functionality, and design defined by the HTML based Web content as interpreted by a rendering engine, wherein preservation of the functionality defined by the HTML based Web content includes preservation of hyperlink functionality. See RLP 1, Claim 52 [G]. • Claim 55: The mobile device of claim 52, wherein execution of the instructions performs further operations comprising enabling the user to zoom in on a user selectable portion of a display of the Web page in response to a user interface input made via the touch sensitive display. See RLP 1, Claim 55. • Claim 59 : The mobile device of claim 52, wherein at least a portion of the scalable content comprises scalable vector based content. See RLP 1, Claim 59 and RLP 4, Claim 30 [H]. • Claim 72 [A]: The mobile device of claim 52, wherein execution of the instructions performs further operations comprising: parsing HTML based code corresponding to the received Web content to identify content on the Web page; See RLP 1, Claim 72 [A]. • Claim 72 [B]: logically grouping selected content into objects; See RLP 1, Claim 72 [B]. • Claim 72 [C]: defining a primary datum corresponding to the original page layout; See RLP 1, Claim 72 [C]. • Claim 72 [D]: and, for each object, defining an object datum corresponding to a layout location datum for the object’s associated display content; See RLP 1, Claim 72 [D]. • Claim 72 [E]: generating a vector from the primary datum to the object datum for the object;

- 45 -

See RLP 1, Claim 72 [E] and RLP 4, Claim 30 [H]. • Claim 72 [F]: and creating a reference that links the object to its corresponding vector. See RLP 1, Claim 72 [F] and RLP 4, Claim 30 [H]. • Claim 75 [A]: The mobile device of claim 52, wherein the original format of the Web page defines a width for the Web page, and wherein execution of the instructions performs further operations comprising: determining an applicable scale factor to fit the width of the Web page across a display area of the touch sensitive display; See RLP 1, Claim 75[A]. • Claim 75 [B]: and employing the scale factor to render the display area. See RLP 1, Claim 72 [B].

5. RLP Issue # 5: Claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75 are obvious under 35

U.S.C. § 103(a) as being unpatentable over Zaurus in view of Hara, Tsutsumitake and the SVG. This RLP is new because neither the original Examiner nor the

Examiners in the Prior Reexaminations considered the newly cited Zaurus, Hara,

Tsutsumitake, and SVG combination of references.

- 46 -

• Claim 30 [F]: rendering a browser interface via which a user is enabled to request to access to a Web page having an original format comprising HTML based content defining an original page layout, functionality, and design of content on the Web page; “The Internet browser in the MI-100 series incorporates HTML 3.2 specifications in important places, and therefore has rich expressive capabilities.” [Zaurus_2, p. 68]

Hara explicitly recites that "[t]he information processing device 10 requests data from the server 21 on the network 20. In the WWW, the data request is performed using the HTTP protocol. At that time, the data requested by the information processing device 10 (the client) is structured in a particular format known as an HTML document." [Hara, ¶39].

Additionally, Hara discloses that the HTML document includes text data, such as character, images and so forth, and that the magnification of the web content takes into account the layout of the data, such as the layout of a plurality of images. See Hara, ¶¶ 17 and 40. See also, Zaurus_1, p. 154; Zaurus_2, p. 26; Hara, ¶¶ 11, 30, 57, 58, 59, 67 • Claim 30 [G]: retrieving HTML based content associated with the Web page, See RLP 1, Claim 30 [G]. • Claim 30 [H]: translating at least a portion of the HTML based content from its original format to produce translated content including scalable vector based content that supports a scalable resolution independent representation of the HTML based content that preserves an original page layout, functionality and design of the at least a portion of the HTML based content when scaled and rendered; “To switch the screen from a reduced view to a magnified view, touch Reduce ▼ followed by Magnify . To switch back from a magnified view to a reduced view, touch Magnify ▼ followed by Reduce.” [Zaurus_2, p. 86]

You can see and write on the area outside of the screen by scrolling the screen horizontally and vertically, [...] [Zaurus_1, p. 29]

Hara teaches "[w]hen there is a plurality of image data, then the coordinate locations and sizes thereof are determined and recorded in the image size table 32." Hara, ¶54]. Hara discloses in FIG. 3 translating the image data of the Web content into height width, and position data (relative to a fixed datum point) that can be entered into an equation to render and scale the Web content into

- 47 -

displayable content on the mobile information device. See e.g., Hara FIG. 3, ¶ 16, 58, 78-79]. Specifically, Hara teaches “translating [...] into scalable content that supports a scalable resolution independent representation of the Web page that preserves the original page layout, functionality and design of the content defined by its original format when scaled and rendered.” See Hara, ¶¶ 10, 12, 16, 25, 37, 47, 49, 54, 55, 60, 63-66, 78-82, 86, 87, 93; FIGS. 2-4, 6.

"5) Display of Clickable Data In an HTML document, the "AREA SHAPE" tag name is used when data is to be clickable. Whether or not this tag is used is evaluated at the time that the HTML document is read.

Normally, the image data defines the upper left as the origin (0,0), as in FIG. 9 (a). For the method of specification, as indicated in FIG. 9 (b), the following notation is used: < AREA SHAPE = "RECT" COORDS = Xl, YI, X2, Y2" HREP = "test.html" > In this example, a case is illustrated wherein, when the range of the rectangle (SHAPE = "RECT"), defined by the coordinate (Xl, YI) and the coordinate (X2, Y2), is clicked by the pointing device 18, then the HTML document with the filename "test.html" is obtained from the server. Note that in addition to RECT (a rectangular shape), there is also CIRCLE (a circle), and SHAPE (a polygon).

Tsutsumitake converts stored document files from a first format to a second format, suitable for screen display (Figure 10). The first format may be HTML (Figure 2) and the second format illustrated in Figure 3. The second format utilizes coordinates in relationship to a reference point. “This external format for documents is a format such as SGML (Standardized Generalized Markup Language) or HTML (Hypertext Markup Language), which is used in the WWW (World Wide Web).” [Tsutsumitake, p. 10]

- 48 -

[Tsutsumitake, Fig. 2-3, 10]

FIG. 10: A diagram showing an example of summary display of a document in accordance with summary display information. [Tsutsumitake, p. 20]; See also, Hara, ¶¶ 10, 12, 16, 25, 37, 47, 49, 54, 55, 60, 63-66, 78-82, 86, 87, 93; Figures. 2-4, 6). • Claim 30 [I]: and employing the scalable vector based content to render a view of at least a portion of the Web page on the display using a first scale factor, wherein preservation of the functionality defined by the HTML based content includes preservation of hyperlink functionality. "the magnifications NW and NH in the horizontal direction and the vertical direction for the image data can be expressed by the following equations wherein the width of the screen resolution is defined as GW, the height of the screen resolution is defined as GH, the width of the image resolution is defined as iW, and the height of the image resolution is defined as iH: NW=GW/iW; NH =

- 49 -

GH/iH. When matching to the width (horizontalwidth) of the display device, the value for the magnification NW is set in themagnification parameter table 33. If matching to the height of (vertical width) of the display screen, the value for the magnification NH is set in the magnification parameter table 33. On the other hand, when there is a user specification (Step S20: Yes), then the CPU 11 references the user-specified size table 34 in the RAM 12 to check the size specified by the user, to calculate the magnification for the image data inaccordance with the specified size (Step S25)." [Hara, ¶¶ 78-80]

"This configuration enables the user to specify a magnification arbitrarily, such as, for example, the actual dimensions (Ix magnification), a magnification using the width of the display screen as the reference, or a magnification using the height as a reference." [Hara, ¶¶ 9, 15]

"This structure enables the display to be confined within the display screen of various image data at a magnification that takes the layout into account, even in a case wherein a layout into account, [...]." [Hara, ¶¶ 11, 17]

“The W3C has chartered a Scalable Vector Graphics working group to produce a specification for an SVG format, [...]. This will mean that the graphics in Web documents will be smaller, faster, more interactive, and be displayable on a wider range of device resolutions from small mobile devices through office computer monitors to high resolution printers. This will be a significant advance in Web functionality.” [SVG, p. 1]; See also, Hara, ¶¶ 10, 12, 16, 37, 47, 54, 55, 60, 63-66, 78-82, 86, 87, 93; FIGS. 2-6. • Claim 31: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising enabling the user to zoom in on a user selectable portion of a display of the Web page in response to a user interface input made via the touch sensitive display. See RLP 1, Claim 31. • Claim 40: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising enabling a user to view a column of the Web content at a higher resolution than a current resolution by tapping on the column via the touch sensitive display, wherein in response thereto, the display is re rendered such that content corresponding to the selected column is displayed to fit across the touch sensitive display. As illustrated on page 86 of Zaurus_2, Zaurus is configured to switch between reduced display and magnified display.

- 50 -

[Zaurus_2, p. 86] See also, Zaurus_1, p. 19, 20, 29, 44, 55, 66, 86, 93; Zaurus_2, p. 26, 33, 36; Hara, ¶¶ 9-13, 15-17, 29, 36, 38, 41, 48-52, 56, 61-62, 67-68, 83, 85, 88-89, 92- 93, 97, 99-100, Fig. 7-8; RLP 1, Claim 1[H] – 1[I]. • Claim 41 [A]: The mobile phone of claim 30, wherein the Web content includes at least one image, See RLP 1, Claim 41[A]. • Claim 41 [B]: and wherein execution of the instructions performs further operations comprising enabling a user to view an image at a higher resolution than a current resolution by tapping on the image via the touch sensitive display, wherein in response thereto, the display is re rendered such that the image is displayed to fit across at least one of a width and height of a display area of the touch sensitive display.

[Zaurus_2, p. 26] [Zaurus_2, p. 86]

“To switch the screen from a reduced view to a magnified view, touch Reduce ▼ followed by Magnify. To switch back from a magnified view to a reduced view, touch Magnify ▼ followed by Reduce.” [Zaurus_2, p. 86]; See also, Zaurus_1, pp. 19, 20, 29, 44, 55, 93; Zaurus_2, pp. 26, 33, 86, 36). • Claim 43 [A]: The mobile phone of claim 30, wherein execution of the instructions performs further operations comprising: generating a display list associated with the scalable vector based content; “The W3C has chartered a Scalable Vector Graphics working group to produce a

- 51 -

specification for an SVG format, [...]. This will mean that the graphics in Web documents will be smaller, faster, more interactive, and be displayable on a wider range of device resolutions from small mobile devices through office computer monitors to high resolution printers. This will be a significant advance in Web functionality.” [SVG, p. 1] • Claim 43 [B]: and employing the display list to re render the display at different scale factors to enable rapid zooming of the Web page. Hara explicitly recites that "[t]he information processing device 10 requests data from the server 21 on the network 20. In the WWW, the data request is performed using the HTTP protocol. At that time, the data requested by the information processing device 10 (the client) is structured in a particular format known as an HTML document." [Hara, ¶39].

Additionally, Hara discloses that the HTML document includes text data, such as character, images and so forth, and that the magnification of the web content takes into account the layout of the data, such as the layout of a plurality of images. See Hara, ¶¶ 17 and 40. See also, Zaurus_1, p. 19-20, 29, 55, 86, 93, 154; Zaurus_2, p. 26, 68; Hara, ¶¶ 11, 30, 57, 58, 59, 67. • Claim 52 [A]: A mobile device, comprising: a processor, wireless communications means, to facilitate wireless communication with a network via which Web content may be accessed; See RLP 5, Claim 30 [A]-[B]. • Claim 52 [B]: a touch sensitive display; See RLP 5, Claim 30 [C]. • Claim 52 [C]: flash memory, operatively coupled to the processor, in which a plurality of instructions are stored that when executed by the processor enable the mobile device to perform operations including See RLP 5, Claim 30 [D]. • Claim 52 [D]: rendering a browser interface via which a user is enabled to request access to a Web page comprising HTML based Web content defining an original page layout, functionality, and design of content on the Web page; See RLP 5, Claim 30 [F]. • Claim 52 [E]: retrieving and processing the HTML based Web content to produce scalable content; See RLP 5, Claim 30 [F]. • Claim 52 [F]: and employing the scalable content and/or data derived therefrom to, render a view of the Web page on the touch sensitive display; See RLP 5, Claim 30 [H] and RLP 5, Claim 30 [I].

- 52 -

• Claim 52 [G]: and re render the Web page in response to associated user inputs to enable the user to iteratively zoom in and out views of the Web page while preserving an original page layout, functionality, and design defined by the HTML based Web content as interpreted by a rendering engine, wherein preservation of the functionality defined by the HTML based Web content includes preservation of hyperlink functionality. The Internet browser in the MI-100 series incorporates HTML 3.2 specifications in important places, and therefore has rich expressive capabilities. [Zaurus_2, p. 68] See also, Zaurus_1, pp. 19-20, 29, 44, 55, 93; Zaurus_2, pp. 26, 86; • Claim 55: The mobile device of claim 52, wherein execution of the instructions performs further operations comprising enabling the user to zoom in on a user selectable portion of a display of the Web page in response to a user interface input made via the touch sensitive display. See RLP 1, Claim 52 [G] and RLP 1, Claim 30 [C]. • Claim 59 : The mobile device of claim 52, wherein at least a portion of the scalable content comprises scalable vector based content. See RLP 5, Claim 43 [A]. • Claim 72 [A]: The mobile device of claim 52, wherein execution of the instructions performs further operations comprising: parsing HTML based code corresponding to the received Web content to identify content on the Web page; Hara discloses that "[w]hen there is a plurality of image data, then the coordinate locations and sizes thereof a determined and recorded in the image size table 32 .... the image sizes are calculated for the case wherein a plurality of image data is displayed." [Hara, ¶¶ 54-55]

Moreover, "if two images, image 1 (with a width WI and a height HI) and image 2 (with a width W2 and a height H2) are on the same line, then if HI > H2, "WI + W2" will be set as the width information in the row information control table 35, and "H2" [sic] will be set as the height information ." [Hara, ¶ 87].

Tsutsumitake teaches parsing HTML-based code corresponding to the retrieved Web page to determine the original page layout of the content on the Web page. Specifically, Tsutsumitake converts stored document files from a first format to a second format, suitable for screen display (Figure 10). The first format may be HTML (Figure 2) and the second format illustrated in Figure 3. The second format utilizes coordinates in relationship to a reference point.

- 53 -

[Tsutsumitake, Fig. 2]

This external format for documents is a format such as SGML (Standardized Generalized Markup Language) or HTML (Hypertext Markup Language), which is used in the WWW (World Wide Web). [Tsutsumitake, p. 10]; See also, Hara, ¶¶ 10, 12, 16, 37, 47, 54, 55, 60, 63-66, 78-82, 86, 87, 93; Figures 2-6. • Claim 72 [B]: logically grouping selected content into objects;

[Tsutsumitake, Fig. 3] Each block 300 is made up of an x coordinate 301 and a y coordinate 302 indicating the display position when displayed at a display device 106, which will be described later; a tag (ID tag) 303 for identifying the data type, such as a character string or an image; and a data part 304 in which the actual character string data or image data (the file name of the image file in which the data is stored) is set. Processing to generate this sort of document structure from a document in the document file 104 is processing that generally takes time. [Tsutsumitake, p. 11]; See also, RLP 5, Claim 72 [B]. • Claim 72 [C]: defining a primary datum corresponding to the original page layout; Finally, Hara teaches, for each object, defining an object datum corresponding to a layout location datum for the object's associated display content; generating a vector from the primary datum to the object datum for the object; and creating a reference that links the object to the vector that is generated. See Hara, ¶ 78-79].

"Furthermore, this de vice is embodied through a computer that reads in a program that is recorded on a recording medium, such as a magnetic disk, and wherein operations are controlled in accordance with the program.” [Hara, ¶ 22]; See also, RLP 3, Claim 58 [B]. • Claim 72 [D]: and, for each object, defining an object datum corresponding to a layout location datum for the object’s associated display content;

- 54 -

[Tsutsumitake, Fig. 9]

FIG. 9 is an example in which the summary display information for a document with the document ID "123" (the document with the external format shown in FIG. 2, and the display image as in FIG. 4) is for straight lines (linear parts) (of a certain width) and an image. There are a total of four straight lines: a straight line with a length of 12 and starting position at xy coordinates (5, 3), a straight line with a length of 12 and starting position at xy coordinates (5, 50), etc. The image has a size of 40 × 30 and the upper left tip is at xy coordinates (12, 13). [Tsutsumitake, pp. 14-15]; See also, RLP 5, Claim 72 [C]. • Claim 72 [E]: generating a vector from the primary datum to the object datum for the object; "5) Display of Clickable Data In an HTML document, the "AREA SHAPE" tag name is used when data is to be clickable. Whether or not this tag is used is evaluated at the time that the HTML document is read.

- 55 -

[Tsutsumitake, Fig. 10] An example of the FIG. 2 document converted to the internal-format structure is shown in FIG. 3. In FIG. 3, the character string portions and an image portion are in units of block 300, and are linked by a linear list comprising a column of pointers 310. A pointer 310 is provided for each block 300, and has pointer information pointing to the corresponding block 300 and pointer information pointing to the pointer (310) of the next block (300). Furthermore, if the next block (300) does not exist, information indicating that fact is used instead of pointer information. Each block 300 is made up of an x coordinate 301 and a y coordinate 302 indicating the display position when displayed at a display device 106, which will be described later; a tag (ID tag) 303 for identifying the data type, such as a character string or an image; and a data part 304 in which the actual character string data or image data (the file name of the image file in which the data is stored) is set. Processing to generate this sort of document structure from a document in the document file 104 is processing that generally takes time. [Tsutsumitake, p. 11, ¶¶ 27-28]

FIG. 10: A diagram showing an example of summary display of a document in accordance with summary display information. [Tsutsumitake, p. 20]; See also, RLP 5, Claim 72 [D]. • Claim 72 [F]: and creating a reference that links the object to its corresponding vector. "Furthermore, the configuration set forth in (l), set forth above, comprises: image position identifying means for identifying position information thereof when a plurality of image data exist within the data to be displayed; and size calculating means for calculating, as a display size, the sum of the width directions of the individual image data, and the maximum value in the height direction, based on the position information identified by the image position identifying means; wherein: the magnification calculating means calculate the display magnification relative to the individual image data based on the display size obtained by the

- 56 -

display size calculating means." [Hara, ¶ 10]

[Tsutsumitake, Fig. 3] Also, if display coordinates for each item in the second-format document structure of that document are provided in the document state information in addition to the above-mentioned information on the scroll position and cursor position, based only on that document state information it becomes possible to reproduce the document display state prior to when the document was switched, not completely but almost so. In this case, processing to convert the first format of the document in the document storage means to the second format is not required, so it is possible to switch and display the target document even faster. [Tsutsumitake, p. 8, ¶ 14]

Each block 300 is made up of an x coordinate 301 and a y coordinate 302 indicating the display position when displayed at a display device 106, which will be described later; a tag (ID tag) 303 for identifying the data type, such as a character string or an image; and a data part 304 in which the actual character string data or image data (the file name of the image file in which the data is stored) is set. Processing to generate this sort of document structure from a document in the document file 104 is processing that generally takes time. [Tsutsumitake, p. 11, ¶ 28]; See also, RLP 5, Claim 72 [E]. • Claim 75 [A]: The mobile device of claim 52, wherein the original format of the Web page defines a width for the Web page, and wherein execution of the instructions performs further operations comprising: determining an applicable scale factor to fit the width of the Web page across a display area of the touch sensitive display; Hara teaches "[w]hen there is a plurality of image data, then the coordinate locations and sizes thereof are determined and recorded in the image size table 32." Hara, ¶54]. Hara discloses in FIG. 3 translating the image data of the Web content into height width, and position data (relative to a fixed datum point) that can be entered into an equation to render and scale the Web content into displayable content on the mobile information device. See e.g., Hara FIG. 3, ¶ 16, 58, 78-79]. Specifically, Hara teaches “translating [...] into scalable content that

- 57 -

supports a scalable resolution independent representation of the Web page that preserves the original page layout, functionality and design of the content defined by its original format when scaled and rendered.” See Hara, ¶¶ 10, 12, 16, 25, 37, 47, 49, 54, 55, 60, 63-66, 78-82, 86, 87, 93; FIGS. 2-4, 6.

At the time of the display, the clickable control table 36 is stored in the RAM 12, as illustrated in FIG. 9 (c). This clickable control table 36 stores the RAPE [sic] of the clickable region, the coordinate values thereof, and information indicating the link destination." [Hara, ¶¶ 63-66]; See also RLP 1, Claim 30 [C]. • Claim 75 [B]: and employing the scale factor to render the display area. See RLP 1, Claim 75 [A].

VI. CONCLUSION Petitioner respectfully submits that this Petition shows a reasonable likelihood that Petitioner will prevail with respect to at least one of the claims of the ‘926 Patent for which Petitioner seeks Review. Accordingly, Petitioner requests the USPTO to grant this Petition and to initiate Inter Partes Review and

find claims 30, 31, 40, 41, 43, 52, 55, 59, 72, and 75 to be unpatentable.

- 58 -

The undersigned attorney may be reached by telephone at (202) 625-3507.

The Commissioner is hereby authorized to charge any fee which may be required in connection with this Petition to Deposit Account No. 50-1214.

Respectfully submitted,

Date: October 2, 2012 /Richard P. Bauer/ Katten Muchin Rosenman LLP KATTEN MUCHIN ROSENMAN LLP Richard P. Bauer 2900 K Street NW - Suite 200 Registration No. 31,588 Washington, DC 20007-5118

- 59 -

CERTIFICATE OF SERVICE

Pursuant to 37 CFR 42.6, I hereby certify that on Tuesday, October 02,

2012, a true copy of the accompanying PETITION FOR INTER PARTES

REVIEW OF U.S. PATENT NO. 7,831,926, including all exhibits, was served

upon the following, by EXPRESS MAIL(R):

Morgan Chu ([email protected])

Irell & Manella LLP

1800 Avenue of the Stars, Suite 900

Los Angeles, CA 90067-4276

Respectfully submitted,

/Richard P. Bauer/ Richard P. Bauer Reg. No. 31,588

PATENT ADMINISTRATOR Katten Muchin Rosenman LLP 2900 K Street NW - Suite 200 Washington, DC 20007-5118

- 60 -