Case 3:20-cv-03706-JSC Document 1 Filed 06/04/20 Page 1 of 14
`
`
`LAW OFFICES OF MARC LIBARLE
`Marc Libarle (State Bar No. 071678)
`ml7006@gmail.com
`1388 Sutter St, Ste 910
`San Francisco, CA 94109
`Phone: (415) 928-2400
`
`HALLER LAW PLLC
`Timothy J. Haller (Pro Hac Vice Pending)
`haller@haller-iplaw.com
`230 E Delaware Pl, Ste 5E
`Chicago, IL 60611
`Phone: (630) 336-4283
`
`Attorneys for Plaintiff
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`
`INTERNET MEDIA INTERACTIVE
`CORP.,
`
`
`Plaintiff,
`
`v.
`
`
`AIRBNB, INC.,
`
`
`Defendant.
`
`Case No.
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`
`
`Plaintiff Internet Media Interactive Corp. (“Internet Media” or “Plaintiff”) complains of
`Defendant Airbnb, Inc. (“Airbnb” or “Defendant”) as follows, all upon Plaintiff’s best information
`and belief:
`
`NATURE OF LAWSUIT
`This is a claim for patent infringement arising under the patent laws of the United
`1.
`States, Title 35 of the United States Code.
`THE PARTIES
`Plaintiff Internet Media Interactive Corp. is a Delaware corporation with its
`2.
`principal place of business at 3511 Silverside Road, Suite 105, Wilmington, Delaware 19810.
`Internet Media is the named assignee of, owns all right, title and interest in, and has
`3.
`standing to sue for infringement of United States Patent No. 6,049,835, entitled “System For
`Providing Easy Access To The World Wide Web Utilizing A Published List Of Preselected
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`Internet Locations Together With Their Unique Multi-Digit Jump Codes,” which issued on April
`11, 2000 (“the ‘835 Patent”) (a true and correct copy is attached as Exhibit A).
`Internet Media has the exclusive right to enforce and collect all past damages for
`4.
`infringement of the ‘835 Patent. Internet Media has standing to sue for infringement of the ‘835
`Patent.
`
`Airbnb, Inc. is a Delaware corporation with the agent for service of process as
`5.
`Corporation Service Company doing business in California as CSC – Lawyers Incorporating
`Service, 2710 Gateway Oaks Drive, Suite 150N, Sacramento, California 95833 and maintaining
`its principal place of business at 888 Brannan Street, #4, San Francisco, California 94103.
`Defendant Airbnb owns, provides and operates the website www.airbnb.com and
`6.
`related URLs. Defendant also distributes advertisements through various media that instruct
`recipients to enter a code to redirect to a new location. Specifically, Defendant operates the account
`“@Airbnb” on Twitter, found at https://twitter.com/Airbnb.
`JURISDICTION AND VENUE
`Internet Media’s claim for patent infringement against Defendant arises under the
`7.
`patent laws of the United States including 35 U.S.C. §§ 271 and 281. Consequently, this Court has
`original and exclusive subject matter jurisdiction over this Complaint pursuant to 28 U.S.C. §§
`1331 and 1338(a).
`Defendant owns, operates and conducts business in the state of California and
`8.
`directs advertisements at residents of California – which are covered by at least Claim 11 of the
`‘835 Patent – and throughout the United States including California and this judicial district.
`Airbnb is currently doing business in this judicial district, has purposefully availed
`9.
`itself of the privilege of conducting business with residents of this judicial district, has purposefully
`reached out to residents of this judicial district, and has established sufficient minimum contacts
`with the State of California such that it should reasonably and fairly anticipate being haled into
`court in California.
`Airbnb has registered itself with the California Secretary of State to do business in
`10.
`California and has a designated agent incident to such registration.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Airbnb has established sufficient minimum contacts with the State of California
`11.
`such that it should reasonably and fairly anticipate being haled into court in California.
`Venue in this judicial district is proper under 28 U.S.C. § 1400(b).
`12.
`INFRINGEMENT OF UNITED STATES PATENT NO. 6,049,835
`Defendant has directly infringed the ‘835 Patent at least through its unauthorized
`13.
`use of the method of Claim 11 for providing automatic access to preselected locations on the
`Internet. Defendant alone, or based on the actions of other persons/entities attributable to
`Defendant, satisfied each of the limitations of Claim 11 as follows:
`Defendant has published a compilation of information with respect to
`a.
`preselected Internet locations (e.g., advertisements on Twitter or other online medium). On
`January 4, 2009, the Delaware District Court in proceedings related to the ‘835 Patent
`construed the similar phrase “a published compilation of preselected Internet locations” to
`mean “a publicly accessible collection of information which corresponds to preselected
`Web sites (or to any other type of preselected data found on the Internet) which have unique
`URL addresses, the URL addresses being associated with diverse individuals or entities.”
`Defendant has published a publicly accessible (e.g., via Twitter or other online medium)
`collection of information which corresponded to preselected Web sites which have unique
`URL addresses (e.g., information about a desired Web site destination of interest to a user),
`the URL addresses having been associated with entities other than Defendant.
`Said published compilation – published by Defendant – included a unique
`b.
`predetermined multi-digit jump code assigned to each of said preselected Internet locations
`for which information is published therein (e.g., shortened codes recognized by ow.ly). On
`January 4, 2009, the Delaware District Court also construed the phrase “a unique
`predetermined multi-digit jump code” to mean “a unique predetermined code consisting of
`more
`than one number.” Defendant’s published compilation
`included unique
`predetermined multi-digit jump codes consisting of more than one number (e.g., 3nE7b9).
`Defendant has provided – through its publication of compilations of various
`c.
`information on Twitter – a predetermined Internet location having an address published in
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 3:20-cv-03706-JSC Document 1 Filed 06/04/20 Page 4 of 14
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`
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`said published compilation (e.g., ow.ly). On January 4, 2009, the Delaware District Court
`also construed the similar phrase “a predetermined published Internet location” to mean “a
`predetermined Web site (or any other type of data found on the Internet); (a) which has a
`unique URL address included in the published compilation; and (b) which serves to provide
`access to other preselected Internet locations.” The predetermined Web site published by
`Defendant (a) had a unique URL address (e.g., ow.ly) included in the published
`compilation; and (b) which served to provide access to other preselected Internet locations.
`Said predetermined Internet location – managed by a link shortening service provider (e.g.,
`Hootsuite) – was characterized by means for capturing a desired multi-digit jump code
`assigned to said preselected Internet location such that a multi-digit jump code could be
`entered by a user after the predetermined Internet location was accessed.
`The user accessed said predetermined Internet location and entered said
`d.
`desired multi-digit jump code into said predetermined Internet location. Specifically, by
`clicking upon a URL embedded in the published compilation, the user accessed the
`predetermined Internet location (e.g., ow.ly) and, thereafter, entered the desired multi-digit
`jump code at said predetermined Internet location (e.g., ow.ly). As presently advised,
`Defendant is vicariously liable for the user’s performance of this step based on (a)
`Defendant conditioning participation in an activity (e.g., participating in promotional
`offerings) or receipt of a benefit (e.g., receiving promotional offerings or information of
`interest) upon the performance of this step – which step is required for the user to reach the
`new destination of interest; and (b) Defendant establishing the manner or timing of that
`performance – which, by the nature of the publication and the desired outcome from using
`the jump code to reach a new destination, necessarily requires performance of this step.
`The link shortening service provider (e.g., Hootsuite) received said multi-
`e.
`digit jump code entered into said predetermined Internet location after said multi-digit
`jump code had been captured at said predetermined Internet location. As presently advised,
`Defendant is vicariously liable for a third-party link shortening service provider’s (e.g.,
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 3:20-cv-03706-JSC Document 1 Filed 06/04/20 Page 5 of 14
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`Hootsuite) performance of this step based on the existence of an agreement (see,
`https://hootsuite.com/legal/terms#) between Hootsuite and Defendant.
`The link shortening service provider (e.g., Hootsuite) converted the
`f.
`received multi-digit jump code to a URL address corresponding to the desired preselected
`Internet location. As presently advised, Defendant is vicariously liable for a third-party link
`shortening service provider’s (e.g., Hootsuite) performance of this step based on the
`existence of an agreement (see, https://hootsuite.com/legal/terms#) between Hootsuite and
`Defendant.
`The link shortening service provider (e.g., Hootsuite) automatically
`g.
`accessed said desired preselected Internet location using said URL address corresponding
`to said desired preselected Internet location corresponding to said received multi-digit jump
`code.
`Defendant has directly infringed at least Claim 11 of the ‘835 Patent through the
`14.
`performance of all steps of the claimed method under the doctrine set forth in Akamai
`Technologies, Inc. v. Limelight Networks, Inc., 797 F.3d 1020 (Fed. Cir. 2015). See also Travel
`Sentry, Inc. v. David A. Tropp, 2016-2386 (Fed. Cir. Dec. 19, 2017). Defendant had the right and
`ability to stop or limit the infringement, did not do so, and has profited from such infringement.
`The acts of infringement of the ‘835 Patent by Defendant have injured Internet
`15.
`Media, and Internet Media is entitled to recover damages adequate to compensate it for such
`infringement from Defendant, but, in no event less than a reasonable royalty.
`PRAYER FOR RELIEF
`WHEREFORE, Plaintiff Internet Media Interactive Corp. respectfully requests that this
`Court enter judgment against Defendant Airbnb, Inc. and against its respective subsidiaries,
`successors, parents, affiliates, officers, directors, agents, servants, employees and all persons in
`active concert or participation with it, granting the following relief:
`The entry of judgment in favor of Internet Media and against Defendant;
`A.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 3:20-cv-03706-JSC Document 1 Filed 06/04/20 Page 6 of 14
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`An award of damages against Defendant adequate to compensate Internet Media
`B.
`for the infringement that has occurred, but in no event less than a reasonable royalty as permitted
`under 35 U.S.C. § 284, together with prejudgment interest from the date infringement began; and
`Such other relief to which Internet Media is entitled to under law and any other and
`C.
`further relief that this Court or a jury may deem just and proper.
`JURY DEMAND
`Plaintiff demands a trial by jury on all issues presented in this Complaint.
`
`June 4, 2020
`
`
`
`Respectfully Submitted:
`
`/s/ Marc Libarle
`LAW OFFICES OF MARC LIBARLE
`Marc Libarle (State Bar No. 071678)
`1388 Sutter St, Ste 910
`San Francisco, CA 94109
`Phone: (415) 928-2400
`ml7006@gmail.com
`
`HALLER LAW PLLC
`Timothy J. Haller (Pro Hac Vice Pending)
`haller@haller-iplaw.com
`
`Attorneys for Plaintiff
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 3:20-cv-03706-JSC Document 1 Filed 06/04/20 Page 7 of 14
`Case 3:20-cv-03706—JSC Document 1 Filed 06/04/20 Page 7 of 14
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`EXHIBIT A
`
`EXHIBIT A
`
`TO
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`TO
`COMPLAINT FOR PATENT
`INFRINGEMENT
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`COMPLAINT FOR PATENT
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`INFRINGEMENT
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`Case 3:20-cv-03706-JSC Document 1 Filed 06/04/20 Page 8 of 14
`I IIIII IIIIIIII Ill lllll lllll lllll lllll lllll lllll lllll lllll 111111111111111111
`US006049835A
`[11] Patent Number:
`[45] Date of Patent:
`
`United States Patent [19J
`Gagnon
`
`6,049,835
`Apr. 11, 2000
`
`[54]
`
`SYSTEM FOR PROVIDING EASY ACCESS
`TO THE WORLD WIDE WEB UTILIZING A
`PUBLISHED LIST OF PRESELECTED
`INTERNET LOCATIONS TOGETHER WITH
`THEIR UNIQUE MULTI-DIGIT JUMP CODES
`
`[75]
`
`Inventor: Eric F. Gagnon, Brooklyn, N.Y.
`
`[73] Assignee: Internet Media Corporation,
`Brooklyn, N.Y.
`
`[21] Appl. No.: 08/705,967
`
`[22]
`
`Filed:
`
`Aug. 30, 1996
`
`[51]
`[52]
`[58]
`
`[56]
`
`Int. Cl.7 ...................................................... G06F 15/16
`U.S. Cl. ............................................. 709/245; 709/227
`Field of Search .................................... 348/27, 8, 13;
`386/83; 709/218, 229, 219, 245, 227; 345/335;
`707/3; 235/375
`
`References Cited
`
`U.S. PATENT DOCUMENTS
`
`4,706,121 11/1987 Young ....................................... 348/27
`5,526,127
`6/1996 Yonetani et al.
`......................... 386/83
`5,572,643 11/1996 Judson
`.................................... 709/218
`
`102
`
`106
`
`5,612,730
`5,625,781
`5,659,729
`5,694,163
`5,708,780
`5,764,906
`5,804,803
`
`3/1997 Lewis .......................................... 348/8
`4/1997 Cline et al. ............................. 345/335
`8/1997 Nielsen
`. .... ... ... ... ... ... .... ... ... ... ... ... 707 /3
`12/1997 Harrison .................................... 348/13
`1/1998 Levergood et al.
`. .... ... ... ... ... ... 709 /229
`6/1998 Edelstein et al. ....................... 709/219
`9/1998 Cragun et al. .......................... 235/375
`
`Primary Examiner-Albert De Cady
`Assistant Examiner-David Ton
`Attorney, Agent, or Firm-Blank
`McCauley LLP
`
`[57]
`
`ABSTRACT
`
`Rome Comisky &
`
`A system for quickly and easily accessing preselected
`desired addresses or URLs on the Internet is disclosed in
`which a published list of Internet or World Wide Web sites
`together with their unique jump codes is utilized in connec(cid:173)
`tion with a corresponding specialized Web site which is
`accessed by a user using either a personal computer or a TV
`Internet Terminal and remote control, after which access a
`jump code corresponding to the preselected desired URL is
`entered by the user and software contained in the specialized
`Web site immediately and automatically accesses the desired
`Web site.
`
`20 Claims, 1 Drawing Sheet
`
`,-----,
`,-i
`! K>8
`L _____ _p
`
`100
`~'
`,
`~ o::-=-:!
`138
`I
`I
`
`136 D
`
`'
`
`I C
`
`

`

`Case 3:20-cv-03706-JSC Document 1 Filed 06/04/20 Page 9 of 14
`
`U.S. Patent
`
`Apr. 11, 2000
`
`6,049,835
`
`,-----,
`
`FIG. i
`
`102
`
`106
`
`! I08
`.~
`L _____ _p
`
`FIG. 2 ~-----,
`~, ===.1, I D 118
`
`i
`r--i
`106 j L _____ _J
`
`112
`
`

`

`Case 3:20-cv-03706-JSC Document 1 Filed 06/04/20 Page 10 of 14
`
`6,049,835
`
`1
`SYSTEM FOR PROVIDING EASY ACCESS
`TO THE WORLD WIDE WEB UTILIZING A
`PUBLISHED LIST OF PRESELECTED
`INTERNET LOCATIONS TOGETHER WITH
`THEIR UNIQUE MULTI-DIGIT JUMP CODES
`
`BACKGROUND OF THE INVENTION
`
`2
`into a
`features, such as secure credit card transactions,
`standardized, graphical, friendly interface that is easy for
`anyone to use. That is in contrast to the use of the Internet
`for electronic mail, which primarily consists of rapid text-
`s based communications among one or more individuals.
`The Web was designed by a British scientist in 1991 as a
`way to let researchers easily swap images instead of just
`messages. The creation of the first point-and-click software
`for "browsing" the Web, known as Mosaic, by the Univer-
`10 sity of Illinois, enabled ready access to the Web by non(cid:173)
`technically skilled users. Then, commercial companies, such
`as Netscape Communications Corporation, developed more
`sophisticated Web browsers, such as Netscape's Navigator.
`Another Web browser is the recently introduced Explorer
`15 3.0 from Microsoft Corporation. Web browsers are also
`provided by well-known major on-line computer services
`such as Compuserve, American On-line, Prodigy, MCI and
`Netcom. Recently, Microsoft's Windows 95 operating sys(cid:173)
`tem was introduced, which also includes its own Web
`20 browser.
`The standard protocols which define the Web work in
`combination with a Web browser which runs on personal
`computers and handles the chores of accessing and display(cid:173)
`ing graphics and texts, and playing back video and audio
`25 files found on the Web. In addition to providing Web access,
`Web browsers and the Web tie together all the Internet's
`other useful features that existed before the advent of the
`Web, such as the newsgroups, FTP text file access, access to
`the net's Gopher sites, and, of course, sending or receiving
`electronic mail.
`The World Wide Web standards are essentially a text
`coding, or "mark-up" method, where selected elements in a
`text file, such as article headlines, subheads, images and
`important words highlighted in the body of a text file can, by
`the insertion of special, bracketed codes ( called HTML or
`Hyper Text Mark-up Language codes), be turned into hot
`links that are easily and instantly accessible by anyone with
`a Web browser.
`The World Wide Web is considered by many to be the true
`information superhighway. It lays the foundation for the use
`of the Internet as an entirely new broadcast medium, one
`which provides individuals, groups, and companies with
`unprecedented new opportunities for broadcast communica-
`45 tion. For example, it is now fairly easy to create one's own
`Web site or address on the Web such that all users on the
`Internet can reach it The Web thus provides an outlet for
`anyone who desires to self-publish articles, graphics, video
`clips, and audio files over the net. Since any individual Web
`site can be freely accessed by anyone else with Web access,
`anyone who creates a Web site has a form for broadcasting
`their information, news, announcements, or creative works
`to an audience of millions. In addition, communication by
`Internet electronic mail can be established by any member of
`55 this audience with the author of a Web site, thus providing
`a new level of two-way communication to this new broad(cid:173)
`cast medium.
`Because the Web provides several key benefits for Inter(cid:173)
`net users, those benefits are encouraging
`the explosive
`60 growth of the Web and, ultimately, the acceptance of the
`Internet as the world's de facto computer communications
`medium.
`First, using the Web, is simplicity itself. Compared to the
`confusing Unix based commands which were required to use
`65 the Internet just a few years ago, using a Web browser
`provides the user with the same friendly, graphical point(cid:173)
`and-click access to all the Internet's features that the users
`
`30
`
`The present invention is directed to a system for providing
`users of the Internet with easy access to the World Wide
`Web. More particularly, the present invention is directed to
`providing a central location which World Wide Web users of
`the Internet can reach and can then instruct to provide them
`with ready access to a particular location on the World Wide
`Web portion of the Internet.
`Use of the Internet, a worldwide network of more than
`100,00 individual computer networks and over 50 million
`users, has been gaining in popularity in the last several years.
`At the present
`time, almost every
`large corporation,
`university, government, organization, and many businesses
`around the world are connected to and have access to the
`worldwide network known as the Internet. The Internet is a
`collection of individual computer networks which are con(cid:173)
`nected to each other by means of high-speed telephone and
`satellite data links, and which are all connected by a public(cid:173)
`domain communications software standard.
`The Internet was developed in the late 1960s, when it was
`established by the United States Defense Department as a
`research project for use by defense contractors and univer(cid:173)
`sities. The purpose of the Internet at that time was to create
`a military computer network which could still function
`reliably if any parts of it were destroyed in a nuclear war. A
`series of standardized communications protocols for sending
`information around the computer network were developed in
`order to ensure against the inherent unreliability of tele-
`phone lines and exposed telephone switching stations.
`For over 25 years, the Internet was used primarily as a
`research-oriented computer communications network for
`universities, defense contractors, governments, and organi(cid:173)
`zations in science and academia. During those years, it grew 40
`slowly but steadily and its proven freely, available commu(cid:173)
`nications protocols were also adopted by the computer and
`telecommunications
`industries and by large corporations,
`who used the Internet for electronic mail communications
`between and among their companies. In 1992, the United
`States Government turned over operation of the Internet's
`high-speed data links to commercial communications net(cid:173)
`works. That transfer, as well as the concurrent explosion in
`the use of personal computers, local area networks, bulletin
`boards systems, and consumer-oriented online services, 50
`caused the Internet to grow tremendously. Because of the
`convergence of those events, a critical mass for acceptance
`of the Internet as a standard means for the worldwide
`connection of individual computer networks of all kinds and
`sizes was created.
`One of the reasons for the explosive growth of the
`Internet, which is growing at an estimated rate of 15%-20%
`per month, is the widespread acceptance of the Internet as
`the standard for electronic mail. The Internet is also well
`known
`for
`its
`two other main
`features,
`its usenet
`newsgroups, which constitute thousands of on-line discus(cid:173)
`sion groups covering a wide variety of business, personal,
`and technical subjects, and the latest Internet phenomenon,
`the World Wide Web.
`The World Wide Web or Web, as it is more commonly
`known, is a standardized method of combining the display
`of graphics, text, video and audio clips, as well as other
`
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`Case 3:20-cv-03706-JSC Document 1 Filed 06/04/20 Page 11 of 14
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`6,049,835
`
`4
`truly useful information or other benefits. In addition, there
`are many Web sites which consist of nothing more than lists
`of links to other Web sites, which often do nothing more than
`link the visitor to a Web site to other useless Web link pages.
`Skimming along such pages can be a frustrating and infor(cid:173)
`mation starving experience, and one which should hopefully
`be avoided. Thus, while in general, the Web makes every(cid:173)
`thing on the Internet easy to find and access, there is a need
`for a directory of the well-thought out and useful sites,
`coupled with a way to easily and quickly access such sites
`in order for users to get the most from their Web experience
`as well as experiencing the best the Web has to offer. More
`particularly, given the 100,000 plus Web sites that exist at
`that the present time, with many more being added every
`day, there is a need for a system which the Web user can use
`to access Web sites which contain a substantial amount of
`original information, graphics, or multi-media, provide use(cid:173)
`ful advice, news or entertainment, and present the informa(cid:173)
`tion in a well-thought out and professional manner. Most
`20 importantly, there is a great need to provide Web users with
`a system for accessing such Web pages in an easy to use,
`automatic, and efficient manner.
`
`3
`have come to expect from any good stand-alone Windows
`commercial software product. Once a user has accessed the
`Web, any of the 100,000 or more Web sites and their linked
`articles, text articles, graphic images, video/audio clips,
`extensive software libraries, and communications features 5
`are easily accessible with a click of the user's mouse key. In
`addition, any good Web browser software also opens up the
`Web's multimedia potential by providing users with instant
`and automatic access to helper applications software that
`automatically plays video and sound clips. Such multimedia 10
`potential has become a big attraction on the Web.
`Web browsers also have a bookmark or hot list feature,
`which allows the user to capture and save the location of any
`Web site that is visited, so that such sites can be readily
`reaccessed by clicking on it from the user's Web browser at 15
`any time.
`Using the Web, users can get instant access to many types
`of information, entertainment, and inter-active resources
`which are now available on the Web. Because of the
`explosion of newly created Web sites, the user can get access
`to useful, practical information on an almost infinite variety
`of subjects. The Web also provides an instant connection to
`millions of other people on the Internet. The resources which
`may be found on the Web are almost limitless.
`In order to understand the use and operation of the Web, 25
`it is believed that certain terms that will be used herein
`should be defined. A Web browser, as previously discussed,
`is a graphical, Windows-based software program which is
`used on a personal computer to access the Web. A Web site
`or Web page describes an individual's "place" on the Web 30
`containing a single Web-published feature. A Web site is
`basically a collection of files located under a directory
`somewhere on someone's computer connected to the Inter(cid:173)
`net. A Web site may consist of one Web page or of many Web
`pages, and usually also includes onscreen graphics, pictures, 35
`texts and video and audio clips, or an archive of software
`that can be downloaded, stored and used freely on the
`visitor's own personal computer.
`Frequently, Web pages utilize links or hot links, two terms 40
`which are used interchangeably, to describe words or groups
`of words which are highlighted on Web pages. When a
`visitor clicks on a link with his mouse, he is immediately
`linked to another Web site or location on the current Web site
`containing the information that is referred to by the link. Any 45
`single Web site may contain dozens, hundreds, or even
`thousands of hot links, both to other sections within the same
`site or to other Web sites located anywhere else in the world.
`Some Web pages also include a links page or jump site
`which consists of lists of links to many other Web sites. 50
`These are often a Web site author's favorite sites or feature
`links to Web sites pertaining to a specific subject.
`Every Web site has an exact address, or location on the
`Web. Such addresses are known as a Uniform Resource
`Locator or URL. URLs consist of a confusing string of
`subdirectories, files or executable commands, separated by
`slashes, which are extremely difficult to work with and
`which must be typed into the user's Web browser exactly as
`they appear, including the use of upper and lower-case
`letters, in order to go to a Web site. While clicking on hot
`links will get the user to a Web site without having to type
`in a URL or copying a URL from a text file (if it is located
`on the user's computer) and pasting it into the user's Web
`browser-screen can save the user from this arduous task, the
`use of URLs has become the bane of the use of the Web.
`Another difficulty with accessing the 100,000 or more
`individual Web sites is that many of them do not offer any
`
`SUMMARY AND OBJECTS OF IBE
`INVENTION
`
`In light of the above-described drawbacks of accessing
`the World Wide Web, it is clear that there is still a need in
`the art for a system for quickly and easily accessing selected
`beneficial sites or addresses on the World Wide Web portion
`of the Internet.
`Therefore, it is a primary object of the present invention
`to provide a system by which user's of the World Wide Web
`portion of the Internet can readily access preselected Web
`sites or Internet addresses, after they have gained access to
`the World Wide Web portion of the Internet. More
`particularly, it is an object of the present invention to provide
`a specialized Web site which can be used in conjunction with
`published jump codes to readily and automatically access
`other Web sites or Internet locations, without the user having
`to remember or input the URL of the desired Web site.
`Even more particularly, it is an object of the present
`invention
`to provide a printed publication containing
`descriptions of selected Web sites or addresses together with
`jump codes therefor which can readily be used in conjunc(cid:173)
`tion with a specialized Web site which includes software
`which, upon recognizing the inputted jump code, quickly
`and automatically accesses the desired Web site.
`It is a further object of the present invention to be able to
`use the system of the present invention with any one of
`personal computers connected to the Web, Television Inter(cid:173)
`net Terminal devices, or any other electronic device which
`can be used for Internet access.
`The system of the present invention utilizes a published
`55 list of preselected Web sites, which are selected according to
`predetermined
`criteria,
`such as content, usefulness,
`presentation, and authorship. Each of the selected Web sites
`is assigned a specific four-digit jump code. A user desiring
`to access one of the preselected Web sites first gains access
`60 to the World Wide Web, using a Web browser, by accessing
`a special Web site which contains software for receiving any
`of the published four-digit jump codes and, based upon the
`stored relationship of the URLs corresponding to the input
`jump code, directly accesses the Web site corresponding to
`65 the jump code inputted by the user.
`In the case of so-called "set top" TV Internet Terminals,
`such as those soon to be available from Sony and Phillips,
`
`

`

`Case 3:20-cv-03706-JSC Document 1 Filed 06/04/20 Page 12 of 14
`
`6,049,835
`
`5
`the user accesses the specialized Web site using the TV
`Internet Terminal and then enters the desired jump codes
`using a remote control which is similar to a standard
`television channel selector. In that manner, users with the TV
`Internet Terminal will be able to access the desired Web sites
`using their television, the TV Internet Terminal, and the
`remote control push buttons.
`With these and other objects, advantages and features of
`the invention that may become hereinafter apparent, the
`nature of the invention may be more clearly understood by
`reference
`to the following detailed description of the
`invention, the appended claims and to the several drawings
`attached herein.
`
`BRIEF DESCRIPTION OF THE DRAWINGS
`FIG. 1 shows, in schematic block diagram form, the
`inventive system of the present invention for use in connec(cid:173)
`tion with personal computer access to the Internet; and
`FIG. 2 shows the system of the present invention for use
`with television Internet terminal access to the Internet.
`
`6
`As discussed above, in addition to Web sites, any other
`type of subject matter contained on the Internet which has a
`URL, can be accessed using the jump code provided there(cid:173)
`for. An example of such an additional use is the accessing of
`5 newsgroups, or Usenet Internet discussion newsgroups,
`where on-line discussions on thousands of subjects can be
`attained. Such newsgroups can also be accessed by means of
`the specialized JumpCity Web site 108. A listing of such
`newsgroups together with their assigned jump codes can be
`10 accomplished in a manner similar to