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`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 1 of 24
`
`STUART G. GROSS (#251019)
`sgross@grosskleinlaw.com
`GEORGE A. CROTON (#323766)
`gcroton@grosskleinlaw.com
`TIMOTHY S. KLINE (#319227)
`tk@grosskleinlaw.com
`GROSS & KLEIN LLP
`The Embarcadero
`Pier 9, Suite 100
`San Francisco, CA 94111
`t (415) 671-4628
`f (415) 480-6688
`
`
`
`Counsel for Plaintiff Express Mobile, Inc.
`
`
`
`Steven F. Molo (pro hac vice forthcoming)
`smolo@mololamken.com
`Benoit Quarmby (pro hac vice forthcoming)
`bquarmby@mololamken.com
`Leonid Grinberg (pro hac vice forthcoming)
`lgrinberg@mololamken.com
`MOLOLAMKEN LLP
`430 Park Avenue
`New York, NY 10022
`Telephone: (212) 607-8160
`Facsimile:
`(212) 607-8161
`
`Rayiner I. Hashem (pro hac vice forthcoming)
`rhashem@mololamken.com
`Sarah J. Newman (pro hac vice forthcoming)
`snewman@mololamken.com
`Benjamin T. Sirolly (pro hac vice forthcoming)
`bsirolly@mololamken.com
`MOLOLAMKEN LLP
`The Watergate, Suite 500
`600 New Hampshire Avenue, N.W.
`Washington, D.C. 20037
`Telephone: (202) 556-2000
`Facsimile:
`(202) 556-2001
`
`
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN FRANCISCO DIVISION
`
`Case No.
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`JURY TRIAL DEMANDED
`
`
`EXPRESS MOBILE, INC.,
`
`
`
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`
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`Plaintiff,
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`
`
`v.
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`PINTEREST, INC.,
`
`Defendant.
`
`
`
`
`
`
`
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`

`

`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 2 of 24
`
`
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`Plaintiff Express Mobile, Inc. (“Express Mobile” or “Plaintiff ”), for its complaint against
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`Defendant Pinterest, Inc. (“Pinterest” or “Defendant”), alleges the following:
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`NATURE OF THE ACTION
`
`1.
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`This is an action for patent infringement arising under the patent laws of the United
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`States, 35 U.S.C. §§ 1 et seq.
`
`THE PARTIES
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`2.
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`Express Mobile is a corporation organized under the laws of the State of Delaware with
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`a place of business at 38 Washington Street, Novato, CA 94947.
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`3.
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`Pinterest is a corporation organized under the laws of the State of Delaware with a place
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`of business at 808 Brannan Street, San Francisco, CA 94013. It can be served through its registered
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`agent in California, Anthony T. Falzone, at 808 Brannan Street, San Francisco, CA 94013.
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`4.
`
`Pinterest offers services throughout the United States, including in this judicial District,
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`and introduces services into the stream of commerce that incorporate infringing technology knowing
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`that those services would be used in this judicial District and elsewhere in the United States.
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`JURISDICTION AND VENUE
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`5.
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`6.
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`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
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`This Court has personal jurisdiction over Pinterest because it has purposefully availed
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`itself of the rights and benefits of the laws of this State and this District. Pinterest resides in the
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`Northern District of California by maintaining a regular and established place of business at 808
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`Brannan Street, San Francisco, CA 94013. This Court also has personal jurisdiction over Pinterest
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`because it has done and is doing substantial business in this District, both generally and with respect to
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`the allegations in this complaint, including Pinterest’s one or more acts of infringement in this District.
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`7.
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`Venue is proper in this District under 28 U.S.C. §§ 1391(b) and (c) and 1400(b).
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`Pinterest has committed acts of infringement through provision of its website builder in the Northern
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`District of California and has at least one regular and established place of business in this District,
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`specifically 808 Brannan Street, San Francisco, CA 94013. Pinterest’s office in San Francisco is a
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`physical place in the District, it is an established location where Pinterest’s business has been carried
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`COMPLAINT FOR PATENT INFRINGEMENT
`
`

`

`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 3 of 24
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`
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`out for years, and Pinterest publicly advertises its presence in the District. See In re Cray, Inc., 871
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`F.3d 1355, 1360-61 (Fed. Cir. 2017).
`
`BACKGROUND
`
`8.
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`Plaintiff Express Mobile is an innovator and leader in the business of developing mobile
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`application and website design and creation platforms. Express Mobile is managed by individuals with
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`many years of technology and business experience. The CEO of Express Mobile, Steve Rempell, is the
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`inventor of the breakthrough technology held in Express Mobile’s patent portfolio. Mr. Rempell has
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`over 50 years’ experience working in technology companies, with much of that experience focused on
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`web-based technologies and applications.
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`9.
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`Before the Express Mobile invention at issue, webpages were created, stored, and
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`rendered using code files that defined all the fixed parameters of the webpage, including, for example,
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`the formatting and location of text, or the location, size, and aspect ratio of images. Typically,
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`webpages could not be viewed during the creation process as they would later appear in the various
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`available browsers or on different devices, and each individual webpage of a website needed to be
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`stored as a separate file. The size and formatting of the stored files led to slow download times to the
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`user’s computer, increasing the wait time for a page to load.
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`10.
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`Express Mobile developed groundbreaking improvements in the process for creating,
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`storing, and building webpages and websites. Express Mobile’s invention enables defining the
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`webpage as a collection of user settings, storing information related to those settings in a database, and
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`then later using that information to render a webpage. The page can be viewed, as it is created or
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`edited, in the same manner that it would appear on different types of screens when later accessed. The
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`result is not a collection of computer code, but instead a group of user-selected objects and settings
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`describing the final webpage. These objects and settings can be saved in a database for ease of access
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`and efficient storage. The invention allows faster loading speeds and permits more efficient storage of
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`the data used to later build the webpages. It also makes changing the webpage more efficient through
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`editing user settings rather than editing multiple lines or versions of code.
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`11.
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`Defendant Pinterest is a consumer-products social media and branding company. Its
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`eponymous service, Pinterest, is an image-centric social media and marketing site. Pinterest allows
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`3
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`COMPLAINT FOR PATENT INFRINGEMENT
`
`

`

`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 4 of 24
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`users to create webpages (“pin boards” or “boards”) comprised of images (“pins”) and links. The site
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`offers search functionality that allows users to find preexisting pins to include on their boards.
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`Pinterest boards are often home or fashion oriented, and pins are therefore often items like furniture or
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`home decor. Once created, boards can be shared publicly or with friends.
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`12.
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`Although Pinterest boards are conceptually simple (a matrix of images), the site contains
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`menus for uploading images, creating section headings, and reorganizing images. The site reacts in real
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`time to changes made via the menus.
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`13.
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`Settings describing the content of the pin board and controlling the appearance of the
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`pins are stored in a database. When another user accesses a pin board, the settings are retrieved from
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`the database and are used in conjunction with JavaScript “run time files” to render the pin board on the
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`other user’s browser, reflecting the pinned content and all associated settings (such as labels and
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`organization).
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`COUNT I – INFRINGEMENT OF U.S. PATENT NO. 6,546,397
`
`14.
`
`The allegations set forth in the foregoing paragraphs 1 through 13 are incorporated into
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`this First Claim for Relief.
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`15.
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`On April 8, 2003, U.S. Patent No. 6,546,397 (“the ’397 patent”), entitled Browser Based
`
`Web Site Generation Tool and Run Time Engine, was duly and legally issued by the United States
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`18
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`Patent and Trademark Office. A true and correct copy of the ’397 patent is attached as Exhibit A.
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`16.
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`The claimed invention of the ’397 patent resolves technical problems related to website
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`creation and generation. Prior to the invention taught and disclosed in the ’397 patent, webpages were
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`generally created, stored, and rendered either by programming directly in HTML, CSS,1 or JavaScript
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`code, or by using a visual editor that produced HTML files. The result was a collection of pages of
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`computer code – typically HTML, CSS, JavaScript, or Java applets – which defined the visual layout,
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`style, and business logic of websites.
`
`
`1 CSS, or “Cascading Style Sheets,” is a programming language designed to interoperate with HTML
`to specify the appearance and placement of web elements.
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`4
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`COMPLAINT FOR PATENT INFRINGEMENT
`
`

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`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 5 of 24
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`17.
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`Conventional website creation and generation methods suffered from many flaws.
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`Creating a webpage could be cumbersome. Webpages could not be viewed throughout the creation
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`process as they would later appear in various browsers or on different devices. Each individual
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`webpage of a website was stored as a separate HTML, CSS, or JavaScript file, which wasted computer
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`resources and required longer access times in the form of hard drive access while editing websites, and
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`in the form of network traffic while downloading them. Prior-art methods also led to slow
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`downloading of the webpage file to a user’s computer and slower rendering by the browser, which
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`increased the wait time for a page to load.
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`18.
`
`Unlike prior-art methods, the ’397 patent brings together disparate ideas and concepts
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`for creating, storing, and building webpages. The Express Mobile invention at issue defines webpages
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`as combinations of user-selected objects and settings stored in a database, rather than as combinations
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`of computer code. Because code files do not need to be stored, the page structure – the vast majority of
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`the HTML code itself – is created on the fly each time the page is loaded in a user browser. This
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`unconventional step of building the webpage HTML code on the fly is performed by the run time
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`engine of the invention, using data representative of the user settings. This allows the system to
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`optimize the page based on device-specific information, including the operating system, browser, and
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`screen size. Moreover, the process of defining the webpages is done through a “What You See Is What
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`You Get” or “WYSIWYG” environment, so that, as the page is created or edited, it can be viewed in
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`the same manner it will appear on different types of screens when later accessed.
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`19.
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`Express Mobile’s patents are directed at a revolutionary technological solution to a
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`technological problem – how to create webpages for the Internet in a manner that permits “What You
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`See Is What You Get” editing, and a number of other improvements over the then-existing
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`methodologies. The claims are not drawn so broadly as to be divorced from the patent-eligible
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`technological improvements described in the specification.
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`20.
`
`The invention claimed in the ’397 patent is not merely the routine or conventional use of
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`website creation systems and methods. Rather, the invention enables the creation of websites through
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`browser-based visual editing tools such as selectable settings panels that describe website elements,
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`with one or more settings corresponding to commands. The invention also enables retrieving that
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`5
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`COMPLAINT FOR PATENT INFRINGEMENT
`
`

`

`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 6 of 24
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`information to generate a website. Those features are implemented exclusively using computer
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`technology, including using virtual machines.
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`21.
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`The invention claimed in the ’397 patent offers substantial improvements in computer
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`performance and web design. For example, the invention allows for faster loading speeds, more
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`efficient storage of webpage data, and the ability to change the webpage more efficiently by editing
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`user settings rather than multiple versions of code. The invention also permits scaling of webpages and
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`elements within the webpage to most efficiently use the screen space. Taken separately or together, the
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`claim elements of the invention significantly improve the operation of a computer and the process of
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`web design.
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`22.
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`The claims of the ’397 patent do not merely recite the performance of some business
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`practice known from the pre-Internet world along with the requirement to perform it on the Internet.
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`Instead, the claims of the ’397 patent recite one or more inventive concepts that are rooted in
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`computerized website creation technology, and overcome problems specifically arising in the realm of
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`computerized website creation technologies.
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`23.
`
`The invention claimed in the ’397 patent neither preempts all ways of using website or
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`webpage authoring tools nor preempts the use of all website or webpage authoring tools or any other
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`well-known or prior-.art technology. Accordingly, each claim of the ’397 patent recites a combination
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`of elements sufficient to ensure that the claim in practice amounts to significantly more than a patent on
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`an ineligible concept.
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`24.
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`Express Mobile is the assignee and owner of the right, title, and interest in and to the
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`’397 patent, including the right to assert all causes of action arising under that patent and the right to
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`any remedies for infringement of it.
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`25.
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`Pinterest has manufactured, used, offered for sale, or sold browser-based website
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`building tools that infringed, either literally or under the doctrine of equivalents, the ’397 patent in
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`violation of 35 U.S.C. § 271(a).
`
`26.
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`Upon information and belief, Pinterest has infringed at least claim 1 of the ’397 patent.
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`27.
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`Claim 1 of the ’397 patent recites a method to allow users to produce Internet websites
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`on and for computers having a browser and a virtual machine capable of generating displays, said
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`COMPLAINT FOR PATENT INFRINGEMENT
`
`

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`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 7 of 24
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`method comprising: (a) presenting a viewable menu having a user-selectable panel of settings
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`describing elements on a website, said panel of settings being presented through a browser on a
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`computer adapted to accept one or more of said selectable settings in said panel as inputs therefrom,
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`and where at least one of said user-selectable settings in said panel corresponds to commands to said
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`virtual machine; (b) generating a display in accordance with one or more user-selected settings
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`substantially contemporaneously with the selection thereof; (c) storing information representative of
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`said one or more user-selected settings in a database; (d) generating a website at least in part by
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`retrieving said information representative of said one or more user-selected settings stored in said
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`database; (e) building one or more webpages to generate said website from at least a portion of said
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`database and at least one run time file, where said at least one run time file uses information stored in
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`said database to generate virtual machine commands for the display of at least a portion of said one or
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`more webpages.
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`28.
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`Pinterest has infringed claim 1 of the ’397 patent. During the relevant time periods,
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`Pinterest practiced a method to allow users to produce Internet websites called “Pinboards” on and for
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`computers having a browser and a virtual machine capable of generating displays. Pinboards
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`comprised “Pins” – widgets that include an image, text, and a hyperlink to another website.
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`29.
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`By way of example, Pinterest presented a viewable menu displaying user-selectable
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`settings that allowed users to specify which Pins they wanted to appear on their Pinboards. By way of
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`further example, Pinterest presented a viewable menu displaying user-selectable settings that allowed
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`users to specify the design of Pinboards, including settings that corresponded to headings on Pinboards,
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`as well as the number of sections the Pins on the Pinboard were organized into.
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`30.
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`By way of further example, Pinterest presented a viewable menu of buttons to create or
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`delete additional Pinboards. By way of further example, Pinterest allowed users to click and drag Pins
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`on the Pinboards, placing them in their desired locations. Pins could also be moved between Pinboards.
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`31.
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`Once a user selected any of these settings, Pinterest updated the Pinboards in accordance
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`with the selected settings substantially contemporaneously with the selection thereof. A user could
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`continue changing settings, and Pinterest would update accordingly.
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`32.
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`On information and belief, Pinterest stored all user-selected settings in a database.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`

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`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 8 of 24
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`33.
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`Those user-selectable settings corresponded to commands to a virtual machine. When a
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`setting was selected, Pinterest used it to generate JSON code. One or more run time files containing
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`HTML and JavaScript code communicated with the Pinterest web server to send and retrieve the
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`encoded user-selected settings and thus generated Pinboards.
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`34.
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`By way of example, when a user first loaded Pinterest, the Pinterest web server sent the
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`run time files to the user’s web browser. The run time files then communicated with the Pinterest web
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`server to retrieve the user-selectable settings stored in the database, and used them to generate virtual
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`machine commands in the form of JSON code, which was sent to the web browser. The web browser’s
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`virtual machine executed the JSON code. That execution, in combination with the commands in the
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`run time files, generated Pinboards in accordance with the saved settings.
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`35.
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`Pinterest’s infringement has damaged and injured Express Mobile.
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`COUNT II – INFRINGEMENT OF U.S. PATENT NO. 9,063,755
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`36.
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`The allegations set forth in the foregoing paragraphs 1 through 35 are incorporated into
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`this Second Claim for Relief.
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`37.
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`On June 23, 2015, U.S. Patent No. 9,063,755 (“the ’755 patent”), entitled Systems and
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`Methods for Presenting Information on Mobile Devices, was duly and legally issued by the United
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`States Patent and Trademark Office. A true and correct copy of the ’755 patent is attached as Exhibit
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`B.
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`38.
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`The invention claimed in the ’755 patent resolves technical problems related to
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`generating and distributing dynamic content on a device display, such as the display of a mobile device.
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`Before the patents-in-suit, content and applications for device displays were generally created using
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`code written for each individual type of device. As device types proliferated, programming content and
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`applications for each device became increasingly expensive and time-consuming. Doing so also
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`limited the ability of providers to update the capabilities of, and increase the available content for,
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`many devices.
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`39.
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`The invention of the ’755 patent resolves technical problems related to generating and
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`distributing dynamic content on a device display. The invention features a computer memory and an
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`authoring tool or Player configured to define a User Interface (“UI”) object for display on the device,
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`COMPLAINT FOR PATENT INFRINGEMENT
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`

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`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 9 of 24
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`where the defined UI object corresponds to a web component and where each UI object is either: (1)
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`selected by a user or (2) automatically selected by the system as a preferred UI object corresponding to
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`a symbolic name of the web component. Additionally, the computer memory and the authoring tool or
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`Player are configured to build an Application consisting of one or more webpage views to provide for
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`the display of at least a portion of one or more of the webpages. These features are exclusively
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`implemented using computer technology.
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`40.
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`Unlike methods in the prior art, the ’755 patent brings together disparate ideas and
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`concepts for generating and distributing content suitable for display on different devices with varying
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`characteristics, using a combination of device-independent and device- and platform-dependent code.
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`This can include building a webpage or application using a “What You See Is What You Get” or
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`“WYSIWYG” environment, so that, as the page or app is created or edited, it can be viewed in the
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`same manner it will appear on different types of screens when later accessed. The invention can also
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`include an authoring tool that can create an Application, where the Application is device-independent
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`code, and a Player, where the Player is device- and platform-dependent code. The Player enables the
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`Application to function on a variety of devices or platforms, with differing functionality. This enables
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`users of the authoring tool to create and distribute device-independent Applications for different device
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`types, without individually tailoring the device-independent Applications for each device type.
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`41.
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`The claims of the ’755 patent do not merely recite the performance of some business
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`practice known from the pre-Internet world along with the requirement to perform it on the Internet.
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`Instead, the claims of the ’755 patent recite one or more inventive concepts that are rooted in the
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`computerized generation of content on a device display, such as a mobile device, and overcome
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`problems specifically arising in the realm of computerized display content generation technologies.
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`42.
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`The claims of the ’755 patent recite an invention that is not merely the routine or
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`conventional use of systems and methods for the computerized generation of content on a device
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`display. Instead, the invention describes systems for use with devices with authoring tools or Players
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`specific to each device and Applications that are independent of the device.
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`43.
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`The invention claimed in the ’755 patent offers substantial improvements in device
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`performance and web or application design. For example, the invention allows for faster loading
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 10 of 24
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`speeds, more efficient storage of webpage or application data, and the ability to change a webpage or
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`application more efficiently by editing user settings rather than multiple versions of code. The
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`invention also permits scaling of webpages and elements within the webpage, or applications and
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`elements within the application, to most efficiently use the screen space. Taken separately or together,
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`the claim elements of the invention significantly improve the operation of a computer and the process
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`of web design.
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`44.
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`The invention claimed in the ’755 patent neither preempts all ways for the computerized
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`generation of content on a device display, such as a mobile device, nor preempts the use of all
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`authoring tools or Players for the computerized generation of content on a device display, such as a
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`mobile device, or any other well-known or prior-art technology.
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`45.
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`Accordingly, each claim of the ’755 patent recites a combination of elements sufficient
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`to ensure that the claim in practice amounts to significantly more than a patent on an ineligible concept.
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`46.
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`Express Mobile is the assignee and owner of the right, title, and interest in and to the
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`’755 patent, including the right to assert all causes of action arising under the patent and the right to any
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`remedies for infringement of it.
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`47.
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`Pinterest has manufactured, used, offered for sale, or sold browser-based website
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`building tools that infringe, either literally or under the doctrine of equivalents, one or more claims of
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`the ’755 patent in violation of 35 U.S.C. § 271(a).
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`48.
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`Upon information and belief, Pinterest has infringed and continues to infringe at least
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`claim 23 of the ’755 patent.
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`49.
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`Claim 23 of the ’755 patent recites a method of providing information to a device having
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`a display from a web component of a web service to a device on a network, said method comprising:
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`accepting, on the device, a first code over the network, where said first code is device-platform-
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`dependent; accepting, on the device, a second code over the network, where said second code is device-
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`independent and includes a plurality of symbolic names of inputs and outputs associated with the web
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`service; and executing said first code on the device, where the symbolic names are provided from a
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`registry of one or more web components related to inputs and outputs of a web service obtainable over
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`a network, where the web service requires both an input symbolic name and one or more associated
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`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 11 of 24
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`input values and returns one or more output values having an associated output symbolic name, and
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`where the registry includes (a) symbolic names required for evoking one or more web components each
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`related to a set of inputs and outputs of a web service obtainable over a network, where the symbolic
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`names are character strings that do not contain either a persistent address or pointer to an output value
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`accessible to the web service, and (b) the address of the web service; where said executing includes:
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`processing said symbolic names of the second code on the device, transmitting processed instructions
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`from the device to the web service, and accepting a third code on the device over the network, where
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`said third code is a device-independent third code including the output of the web component provided
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`by the web service over the network and in response to the second code.
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`50.
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`Pinterest infringes claim 23 of the ’755 patent through a combination of features that
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`collectively practice each limitation of claim 23. Pinterest practices a method for providing information
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`to a device having a display, including a web browser. The information comes from a web service, the
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`Pinterest web server.
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`51.
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`Pinterest accepts and executes device- and platform-dependent code from the Pinterest
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`web server, including HTML, CSS, and JavaScript. It also accepts device-independent code from the
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`Pinterest web server, which includes symbolic names of inputs and outputs. Unlike the device-
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`platform-independent code, the device-dependent code is written for specific device platforms and
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`devices, such as browsers, laptops, tablets, or smartphones.
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`52.
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`The symbolic names are provided from a registry of web components related to inputs
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`and outputs obtainable over a network. The web components include images, text blocks, hyperlinks,
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`and other common web components.
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`53.
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`The registry that Pinterest uses contains the address of a web service available over a
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`network (the Pinterest web server) and symbolic names related to inputs and outputs of the web service.
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`The symbolic names are character strings that do not contain either a persistent address or pointer to an
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`output value. The Pinterest web server accepts both an input symbolic name and one or more
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`associated input values from a user and returns one or more outputs having an associated symbolic
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`name.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 12 of 24
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`54. When the browser executes the code provided to it, it processes the symbolic names and
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`transmits instructions back to the web service. In response, it accepts new, device-independent code
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`from the web service.
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`55.
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`Pinterest was made aware of the ’755 patent and its infringement thereof at least as early
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`as February 6, 2020, when Express Mobile provided notice to Pinterest of the ’755 patent.
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`56.
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`Upon information and belief, since at least the time Pinterest received notice, Pinterest
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`has induced and continues to induce others to infringe at least claim 23 of the ’755 patent under 35
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`U.S.C. § 271(b) by, among other things, and with specific intent or willful blindness, actively aiding
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`and abetting others to infringe, including but not limited to Pinterest’s partners, clients, customers, and
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`end users, whose use of Pinterest constitutes direct infringement of at least one claim of the ’755 patent.
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`In particular, Pinterest’s actions that aid and abet others such as customers, clients, partners,
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`developers, and end users to infringe include advertising Pinterest as a way for users to organize ideas,
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`links, and media they find online. On information and belief, Pinterest has engaged in such actions
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`with specific intent to cause infringement or with willful blindness to the resulting infringement
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`because Pinterest has had actual knowledge of the ’755 patent and knowledge that its acts were
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`inducing infringement of the ’755 patent since at least the date Pinterest received notice that such
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`activities infringed the ’755 patent.
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`57.
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`Since February 6, 2020, Pinterest’s infringement of the ’755 patent has been willful.
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`58.
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`Pinterest’s infringement has damaged and continues to damage and injure Express
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`Mobile.
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`COUNT III – INFRINGEMENT OF U.S. PATENT NO. 9,471,287
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`59.
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`The allegations set forth in the foregoing paragraphs 1 through 58 are incorporated into
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`this Third Claim for Relief.
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`60.
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`On October 18, 2016, U.S. Patent No. 9,471,287 (“the ’287 patent”), entitled Systems
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`and Methods for Integrating Widgets on Mobile Devices, was duly and legally issued by the United
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`States Patent and Trademark Office. A true and correct copy of the ’287 patent is attached as Exhibit
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`C.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 3:20-cv-08335-TSH Document 1 Filed 11/25/20 Page 13 of 24
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`61.
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`The invention claimed in the ’287 patent resolves technical problems related to
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`generating and distributing dynamic content on a device display, such as the display of a mobile device.
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`Before the patents-in-suit, content and applications for device displays were generally created using
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`code written for each individual type of device. As device types proliferated, programming content and
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`applications for each device became increasingly expensive and time-consuming. Doing so also
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`limited the ability of providers to update the capabilities of, and increase the available content for,
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`many devices.
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`62.
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`The invention of the ’287 patent resolves technical problems related to generating and
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`distributing dynamic content on a device display, such as the display of a mobile device. The invention
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`of the ’287 patent features a registry and an authoring tool or Player configured to define a UI object for
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`display on the device, where the UI object co