UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PLAID TECHNOLOGIES INC.
`Petitioner
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`v.
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`YODLEE, INC.
`Patent Owner
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`Case CBM2016-00056
`Patent 6,510,451 B2
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`DECLARATION OF ZAYDOON JAWADI IN SUPPORT OF PATENT
`OWNER’S RESPONSE
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`1
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`YODLEE 2004
`PLAID TECHNOLOGIES V. YODLEE, INC.
`CBM2016-00056
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PLAID TECHNOLOGIES INC.
`Petitioner
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`v.
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`YODLEE, INC.
`Patent Owner
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`Case CBM2016-00056
`Patent 6,510,451 B2
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`DECLARATION OF ZAYDOON JAWADI IN SUPPORT OF PATENT
`OWNER’S RESPONSE
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`1
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`YODLEE 2004
`PLAID TECHNOLOGIES V. YODLEE, INC.
`CBM2016-00056
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`Declaration of Zaydoon Jawadi
`CBM2016-00056
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`TABLE OF CONTENTS
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`I. UNDERSTANDING OF PATENT LAW ..................................................... 4
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`II. BACKGROUND .............................................................................................. 6
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`III. LEVEL OF ORDINARY SKILL & CLAIM CONSTRUCTION ...............12
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`IV. The ‘451 Claims Are Not Directed to an Abstract Idea and They
`Contain an Inventive Concept .....................................................................14
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`A. The ‘451 claims are not directed to the abstract idea of
`“managing multiple tasks, plus performance on the Internet.” ....... 14
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`B. The ’451 claims contain an inventive concept ..................................... 20
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`V. The ReferEnced prior art, alone or in combination, does not render
`obvious any asSerted clAim of the ’451 patent .........................................21
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`A. Farber in combination with Zhao does not Render Obvious Any
`Claim of the ’451 Patent .......................................................................... 21
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`B. Bayardo in combination with Zhao does not Render Obvious Any
`Claim of the ’451 Patent .......................................................................... 28
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`Declaration of Zaydoon Jawadi
`CBM2016-00056
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`I, Zaydoon Jawadi, declare as follows:
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`1.
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`I am making this declaration at the request of the Patent Owner,
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`Yodlee, Inc. (“Yodlee” or “Patent Owner”) in the matter of Covered Business
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`Methods (“CBM”) Review of U.S. Patent No. 6,510,451 B2 (the ’451 Patent).
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`2.
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`I am being compensated for my work. My compensation does not
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`depend in any way on the outcome of this proceeding or upon the opinions or
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`testimony that I provide.
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`3.
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`In forming the opinions I express below, I considered all of the
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`information I cite throughout my analysis, including:
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`a.
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`b.
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`c.
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`d.
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`e.
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`f.
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`The ’451 Patent (Ex. 1001)
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`The File History of the ’451 Patent (Exs. 1006-1013)
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`Petition by Plaid Technologies, Inc. (Paper 2)
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`Declaration of Petitioner’s Expert, Todd Mowry (Ex. 1002)
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`U.S. Patent No. 5,819,284 to Farber, et al. (Ex. 1003)
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`Bayardo, “Info-Sleuth: Agent-Based Semantic Integration of
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`Information in Open and Dynamic Environments,” SIGMOD (1997)
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`(“Bayardo”) (Ex. 1004)
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`g.
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`Zhao, “WebEntree: A Web Service Aggregator,” IBM Systems
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`Journal 37(4) (1998) (“Zhao”) (Ex. 1005)
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`h.
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`Decision of Institution (Paper 10)
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`i.
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`Deposition of Petitioner’s Expert, Todd Mowry (Ex. 2002)
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`4.
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`I summarize my relevant knowledge and experience below. My
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`Curriculum Vitae contains additional information and is Ex. 2005.
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`5.
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`I received a B.S. in Electrical Engineering from Mosul University in
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`1977. I received an M.S. in Computer Science from Columbia University in 1981,
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`with a Citation for Outstanding Achievement – Dean’s Honor Student.
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`6.
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`I hold a California community college computer science lifelong
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`instructor credential. I have taught various computer technologies to thousands of
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`engineers and academic students.
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`7.
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`8.
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`Prior to 2007, I held a number of jobs in industry.
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`For example, from 2001 to 2006, I was President and cofounder of
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`CoAssure, Inc., a provider of automated Web-based telecommunication test
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`services serving Fortune-500 companies. The system included aggregating data
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`from multiple data sources into an intermediary server and/or website, storing the
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`aggregated data, and presenting the aggregated data to the end user’s browser
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`through the Internet.
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`9.
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`Also, in 1999 I co-founded a company called Can Do, Inc.
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`CanDo.com was a startup Internet eCommerce company targeting people with
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`disabilities. The CanDo.com website had over 10,000 items for sale, and extensive
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`consumer features, such as news, chat, messages, and product information. The
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`company was funded by leading venture capital firms. Technology included
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`magnification software to make websites more usable by vision-impaired people
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`and sound adaptation software to make websites more accessible by hearing-
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`impaired individuals.
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`10. The CanDo.com website technology included capabilities for
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`aggregating news and other articles, aggregating pricing and product information,
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`aggregating order processing and inventory information, and other aggregation.
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`11. The CanDo.com hearing accessibility technology comprised
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`adaptation, delivery, and real-time streaming of audio data files through the
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`Internet to compensate for users’ hearing loss, based on users’ personal hearing
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`profiles. Audio data is transmitted from audio sources to an intermediary server,
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`which adapts the audio; the adapted audio is then transmitted to the client, which is
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`typically the end user’s browser.
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`12. Additionally, I have experience with data networking, including when
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`I was General Manager, Data Networking Business Unit, Xyratex International
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`LTD (NASDAQ: XRTX, now Seagate, NASDAQ: STX) from 1997 to 1998,
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`where I was responsible for Gigabit Ethernet network protocol analyzer products
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`used to monitor and analyze network traffic, including TCP/IP packets and other
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`Internet traffic.
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`I.
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`UNDERSTANDING OF PATENT LAW
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`13.
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`I am not a patent attorney, and I am presenting no opinions on the law
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`related to patent validity. Counsel has explained certain legal principles to me that
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`I have relied on in forming my opinions set forth in this declaration.
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`14.
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`I have been advised and it is my understanding that patent claims in a
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`CBM are given their broadest reasonable interpretation in view of the patent
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`specification, file history, and the understanding of one having ordinary skill in the
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`relevant art at the time of invention.
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`15.
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`I understand that prior art to the ʼ451 patent may include patents and
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`printed publications in the relevant art that predate the October 14, 1999
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`application priority date. I have not been asked to determine whether any
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`reference is or is not prior art.
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`16.
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`I understand that a claim is invalid if it is anticipated or obvious.
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`Anticipation of a claim requires that every element of a claim be disclosed
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`expressly or inherently in a single prior art reference. Obviousness of a claim
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`requires that the claim be obvious from the perspective of a person having ordinary
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`skill in the relevant art at the time the invention was made. I understand that a
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`claim may be obvious from a combination of two or more prior art references.
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`17.
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`I understand that an obviousness analysis requires an understanding of
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`the scope and content of the prior art, any differences between the alleged
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`invention and the prior art, and the level of ordinary skill in evaluating the
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`pertinent art.
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`18.
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`I further understand that certain factors may support or rebut the
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`obviousness of a claim. I understand that such secondary considerations include,
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`among other things, commercial success of the patented invention, skepticism of
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`those having ordinary skill in the art at the time of invention, unexpected results of
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`the invention, any long-felt but unsolved need in the art that was satisfied by the
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`invention, the failure of others to make the invention, praise of the invention by
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`those having ordinary skill in the art, and copying of the invention by others in the
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`field. I understand that there must be a nexus—a connection—between any such
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`secondary considerations and the invention. I also understand that
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`contemporaneous and independent invention by others is a secondary consideration
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`tending to show obviousness.
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`19.
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`I further understand that a claim may be obvious if common sense
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`directs one to combine multiple prior art references or add missing features to
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`reproduce the alleged invention recited in the claims. If a person having ordinary
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`skill in the relevant art can implement a predictable variation, obviousness likely
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`bars its patentability. For the same reason, if a technique has been used to improve
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`one device and a person having ordinary skill in the art would recognize that it
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`would improve similar devices in the same way, using the technique is obvious. I
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`further understand that a claim can be obvious if it unites old elements with no
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`change to their respective functions, or alters prior art by mere substitution of one
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`element for another known in the field and that combination yields predictable
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`results. While it may be helpful to identify a reason for this combination, common
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`sense should guide and no rigid requirement of finding a teaching, suggestion or
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`motivation to combine is required. When a product is available, design incentives
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`and other market forces can prompt variations of it, either in the same field or a
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`different one.
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`II. BACKGROUND
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`20. The ‘451 Patent is directed to an innovative mechanism for
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`completing multi-part Internet tasks and communicating integrated results to a
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`client. Performing a multi-part Internet task requires the sequential or parallel
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`completion of many subtasks and is hampered by the fractured nature of the
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`diverse Web services supporting each subtask. Ex. 1001, ’451 Patent at 1:32-35.
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`Not only does a generic multi-part Internet task need to be decomposed into
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`serviceable subtasks, but each subtask must to be managed through delegation to
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`corresponding Web services, each of which has different interface(s) and
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`protocol(s), and the results aggregated. Id. at 1:35-43.
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`21. By providing a single-point interface to receive a multi-part Internet
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`task and then seamlessly decomposing and coordinating dissemination of subtasks
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`to corresponding Web services, the claimed Internet portal system provides
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`structure and increases reliability for completion of the entered tasks (and
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`constituent subtasks). Advantages of such a single-point interface include: (1)
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`increased coordination between subtasks thorough the use of helper applications,
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`or “guards,” which verify parameters specific to each subtask (id. at 5:39-6:15),
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`and (2) verification of subtask completion by employing transaction protocols (id.
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`at 6:26-36, 7:16-25).
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`22. The ’451 Patent specification provides detailed teaching of
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`instructions for the operation of an interface that “manages task decomposition . . .
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`on behalf of a subscribing user . . . to facilitate a main task for a user.” Id. at 4:59-
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`66. For example, a user may enter information regarding a multi-part Internet task
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`through the single-point interface. Ex. 1001, ’451 Patent at 5:25-27. The Internet
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`portal system provides abstract definitions for various tasks and includes
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`parameters for the tasks. Id. at 5:27-30. Such parameters become rules that affect
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`all of the sub-parameters that must be met in order to accomplish the multi-part
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`Internet task. Id. at 5:30-33. Thus, the described instructions act to research the
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`necessary parameters to accomplish a multi-part Internet task according to various
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`rules as well as user profile data regarding subscribed-to Web services. Id. at 5:33-
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`38. Additionally, the Internet portal system employs helper applications, or
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`“guards,” which verify parameters for each multi-part Internet task and
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`corresponding subtasks based on information stored in a user’s profile. Id. at 5:39-
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`45. In some instances, guard values may be set by a user of the Internet portal
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`system. Id. at 5:39-53. In other instances, guards may be set automatically based
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`on a user’s profile. Id. at 5:58-62.
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`23. Further, the ’451 Patent describes operations for delegation of
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`subtasks decomposed from a multi-part Internet task to various corresponding Web
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`services. For example, the Internet portal system disperses subtasks to Web
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`services according to a data type required by those services (“WEB communication
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`accomplished via browsing technique would use HTML or other suitable
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`languages,” “POP3 communication would cover e-mail,” and “[n]ews
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`communication would cover such as instant messaging and posting”). Id. at 7:1-7.
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`Once subtasks are performed or verifiably assured, a gathering agent collects and
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`disseminates data received from various Web services regarding the completion of
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`each subtask and presents the data to the user. Id. at 7:16-19.
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`24. Claim 1, which is representative of the ’451 Patent’s independent
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`claims, includes three elements (a, b, and c) along with seven sub elements (c1-c7)
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`of element c, labeled [a], [b], and [c1]-[c7] below for convenience:
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`1. [pre] An Internet portal system for accomplishing a multi-
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`component task involving interaction with one or more Internet Web sites,
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`comprising:
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`[a] an Internet-connected server having access to client related
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`data;
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`[b] an internet-capable client station usable by a client; and
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`[c0] software executing on the server for managing individual
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`component tasks in execution of the multi-component task;
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`wherein the software, [c1] in response to initiation of a multi-
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`component task specified by the client, transparently to the client, and
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`without interaction from the client [c2] defines the component tasks
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`based on pre-programmed client-related data, [c3] identifies third-
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`party Internet Web services needed for completion of the tasks, [c4]
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`performs and manages interaction with the identified Web sites, [c5]
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`gathering results of the interactions, [c6] integrates the gathered
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`results, and [c7] communicates final results to the client at the client
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`station.
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`25. First, in elements [a] and [b], claim 1 specifies that the claimed
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`Internet portal system comprises an Internet-connected server having access to
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`client-related data and an Internet-capable client station usable by a client. Support
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`for these elements appears in the ’451 Patent at least at FIG. 1 and the associated
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`text description. See, e.g., Ex. 1001, ’451 Patent at 3:45-5:10, FIG. 1.
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`26. Next, in sub element [c0], claim 1 specifies that the claimed Internet
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`portal system comprises software executing on the server for managing individual
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`component tasks in execution of the multi-component task. Support for element
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`[c] and its sub elements appears in the ‘451 Patent at least at FIGS. 1, 2, 3 and the
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`associated text description. See, e.g., Id. at 4:52-7:25, FIGS. 1-3.
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`27.
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`In sub element [c1], claim 1 specifies that the claimed Internet portal
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`system performs sub elements [c2]-[c7] in response to initiation of a multi-
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`component task specified by the client, transparently to the client, and without
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`interaction from the client. Support for sub element [c1] appears in the ‘451 Patent
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`at least at 6:37-41. The specification explains that a user may enter a main task at
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`a single-point interface and then the subtasks “are performed by the service in the
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`background.” Id. at 6:41-42.
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`28. Next, in sub element [c2], the claimed Internet portal system defines
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`the component tasks based on pre-programmed client-related data. Support for sub
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`element [c2] appears in the ‘451 Patent at least at 5:11-38. The specification
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`explains that the Internet portal system provides, for any task, abstract definitions
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`and parameters, which become rules affecting all of the sub-parameters that must
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`be met in order to accomplish a multi-part Internet task. Id. at 5:27-33.
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`Parameters necessary to accomplish the multi-part Internet task are then
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`determined according the rules and user profile data. Id. at 5:33-38.
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`29.
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`In sub element [c3], claim 1 specifies that the claimed Internet portal
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`system identifies third-party Internet Web services needed for the completion of
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`the component tasks. Support for sub element [c3] appears in the ‘451 Patent at
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`least at 5:11-6:25. Specifically, the specification explains that the software acts to
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`research what parameters, including the Web required sources, are necessary to
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`perform a multi-component task. Id. at 5:32-35.
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`30. Next, in sub element [c4], the claimed Internet portal system performs
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`and manages interaction with the identified Web sites. Support for sub element
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`[c4] appears in the ‘451 Patent at least at 5:11-6:35 and at 7:1-25. The
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`specification explains that once a series of help functions verify particular rules for
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`each defined component task representing a part of the multi-component task, the
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`component tasks “are propagated to the appropriate WEB service.” Id. at 5:63-65.
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`The invention “disperses subtasks to corresponding WEB services according to a
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`data type required by those services.” Id. at 7:1-2. Further, the described Internet
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`portal system is implemented with transaction protocol to save historical data for
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`each transaction, which allows rollback and rollforward actions in case a step or
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`subtask fails. Id. at 6:26-37.
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`31.
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`In sub elements [c5] and [c6], claim 1 specifies that the claimed
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`Internet portal system gathers results of the interactions and integrates the gathered
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`results. Support for sub elements [c5] and [c6] appears in the ‘451 Patent at least
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`at 7:16-25. The specification explains that “[o]nce subtasks are performed or
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`verifiably assured, a gathering agent represented . . . collects and disseminates all
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`of the required data from various WEB services.” Id. at 7:16-19.
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`32. Next, in sub element [c7], the claimed Internet portal system
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`communicates the final results to the client station. Support for sub elements [c5]
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`and [c6] appears in the ‘451 Patent at least at 7:16-25. The specification explains
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`that once the required results from various Web services that performed each
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`subtask are gathered and integrated, the invention “presents the data to the user.”
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`Id. at 7:16-19.
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`33.
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`In summary, the ’451 Patent is directed to an innovative mechanism
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`for completing multi-part Internet tasks and communicating integrated results to a
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`client.
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`III. LEVEL OF ORDINARY SKILL & CLAIM CONSTRUCTION
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`34. Counsel has informed me that I should consider the materials above
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`through the lens of one of ordinary skill in the art related to the ʼ451 patent at the
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`time of the invention. I have been advised that there are multiple factors relevant
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`to determining the level of ordinary skill in the pertinent art, including the
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`educational level of active workers in the field at the time of the invention, the
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`sophistication of the technology, the type of problems encountered in the art, and
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`the prior art solutions to those problems.
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`35.
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`In my opinion, as of October 14, 1999 (the filing date of the ʼ451
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`patent), in the late 1990s, persons of ordinary skill in the art in the field pertinent to
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`the ’451 Patent were people with at least a B.S. degree, or its equivalent, in
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`computer science or a related field and approximately two years of practical
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`experience working with design and implementation of computer software and
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`networked systems, or an equivalent combination of academic study and work
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`experience.
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`36.
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`I have considered the level of ordinary skill set forth by Petitioner’s
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`expert: “one having a Bachelor’s Degree in electrical engineering, computer
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`science, or a related scientific field, and some work experience in the computer
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`science field which could include programming experience.” Ex. 1002 at ¶ 27.
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`37.
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`I believe myself to have been one of ordinary skill in the art through
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`my education and work experience during the relevant timeframe, under either
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`proposed level of skill. I am also familiar with the knowledge and capabilities of
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`one of ordinary skill in art in 1999. Specifically, my experience at CoAssure, Inc.,
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`and at Can Do, Inc., and my other roles in industry allowed me to become
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`personally familiar with the level of skill of individuals and the general state of the
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`art at that time.
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`38.
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`I have reviewed the Institution Decision for the ʼ451 patent, and
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`where a claim term (i.e., the term “defining component tasks based on pre-
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`programmed client-related data by software executing on the Internet-connected
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`subscription server”) was interpreted by the Board, I have employed the Board’s
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`interpretation for that term. For terms not interpreted by the Board (i.e., all other
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`claim terms), I have applied the broadest reasonable interpretation in view of the
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`specification, as advised by counsel.
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`IV. THE ‘451 CLAIMS ARE NOT DIRECTED TO AN ABSTRACT
`IDEA AND THEY CONTAIN AN INVENTIVE CONCEPT
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`A. The ‘451 claims are not directed to the abstract idea of “managing
`multiple tasks, plus performance on the Internet.”
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`39.
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`I respectfully disagree with Dr. Mowry’s report regarding the
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`conclusion that claim 8 is directed to the abstract idea of “managing multiple tasks,
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`plus performance on the Internet.” Dr. Mowry opines that the claims simply recite
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`elements that were well known and conventional with a directive to perform them
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`using the Internet. See Ex. 1002 at ¶¶ 24-27. I believe that this is an incorrect
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`evaluation of the claimed invention derived from considering the claim language
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`absent guidance from the specification. Indeed, the specification describes with
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`particularity how the method of claim 8 resolves technical problems arising only
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`within the context of the Internet. These technical challenges, and therefore the
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`corresponding claimed solution, would not exist beyond the realm of the Internet.
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`Thus, claim 8 represents a significant improvement in the way computers operate,
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`which is different from merely employing a business practice using software
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`running on a generic computer.
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`40. Many of the technical problems identified in the ’451 Patent revolve
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`around the difficulty, and particularly the involvement required by a user, to
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`identify and interact with multiple Web services for the completion of multi-part
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`Internet tasks, while aggregating the results. ’451 Patent at 1:16-49. For example,
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`the ’451 Patent explains: “Many companies, through innovative applications, have
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`made it progressively easier to use their individual Web services.” Id. at 1:30-32.
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`“However, performing a main task that requires the sequential or parallel
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`completion of many sub-tasks is seriously hampered by the fractured nature of the
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`diverse Web services.” Id. at 1:32-35. “A user would still be required to visit
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`several WEB services and manually configure such sub-tasks in order to ultimately
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`accomplish the main goal.” Id. at 1:35-38. These illustrative recitations from the
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`’451 Patent demonstrate the technical nature of the claimed invention that is
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`inextricably tied to the Internet. In short, human users were having difficulties
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`performing multi-part tasks on the Internet, because requisite resources and
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`services are fractiously distributed and scattered across the Web in the late 1990’s.
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`Thus, the inventors of the ’451 Patent recognized that “[w]hat [was] clearly needed
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`is a method and apparatus that allows a user to accomplish a main task including
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`completion of sub-tasks performed by diverse WEB services without requiring that
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`the user manually visit each WEB service associated with a sub-task.” Id. at 1:44-
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`48.
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`41. The ’451 Patent explains that the claimed invention alleviates several
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`problems with the completion of multi-part Internet tasks by providing “a single
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`point interface (browser interface) for a user to delegate a task.” Id. at 5:14-15.
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`This interface or portal server is configured to facilitate “a seamless cooperation in
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`the data transfer and dissemination between WEB servers.” ’451 Patent at 2:56-
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`57. The’451 Patent accomplishes this seamless cooperation by “manag[ing] task
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`decomposition and delegation as well as contact management in association with
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`[the] WEB servers . . . on behalf of a subscribing user.” Id. at 2:59-61. The portal
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`server maintains a data repository, which stores data about users such as
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`“identification, account information, and . . . profiling data consisting of any data
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`associated with a user profile regarding WEB services that a user may subscribe
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`to.” Id. at 2:25-32. Once a user has entered multi-part Internet task, the portal
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`server defines the subtasks for the multi-part Internet task, based in part on the
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`information contained in the data repository. Id. at 6:64-66. The portal server then
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`acts to research what parameters will be necessary to accomplish each subtask
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`according to particular parameters or rules. Id. at 5:33-36. Once the subtasks and
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`parameters are determined, the portal server verifies them with a series of Guard
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`functions and “disperses the subtasks to the selected WEB services according to
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`the data type required by those services.” ’451 Patent at 6:66-7:2. Specifically, the
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`patent gives examples of using a HTML for WEB communication, POP3 for e-
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`mail communication, and news communication for instant messaging and posting.
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`Id. at 7:2-6.
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`42. Task management via interaction with Web servers is a capability
`
`unique to computers, and represents an important difference between how humans
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`navigate the Internet compared to how computers do that. Indeed, humans do not
`
`interact directly with Web servers. Rather, humans interact with, for example,
`
`Web browsers or client applications that present the information in forms readily
`
`understood by humans. The invention described by the ’451 patent is also capable
`
`of performing tasks, including interacting with Web servers, in parallel, by
`
`multicasting. ’451 Patent at 6:53-58. In the context of the ‘451 Patent,
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`multicasting is a way of communicating through a computer network where
`
`information is addressed and sent to multiple recipients simultaneously. A human
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`user cannot multicast to websites that maintain or need the user’s information
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`without help from a computer specifically equipped to interact in that manner. For
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`example, a task of refreshing an end user’s information in multiple accounts can be
`
`performed by delegating each sub-task to update an end user’s account information
`
`associated with a particular website. See, e.g., id. at 7:43-50, 8:24-35. By
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`performing sub-tasks in parallel, the ’451 patent can refresh an end user’s account
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`information among multiple websites at the same time. The hierarchical structure
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`of defining tasks and subtasks is particularly suitable for scaling the invention to
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`work with thousands of websites. As such, the method recited in claim 8 is not
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`merely an automated routine that is performed faster or more efficiently on a
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`computer than by a human user. Instead, the claimed subject matter is directed to a
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`method that is specifically intended to improve the way in which computers
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`operate to perform tasks on the Internet that human users are ill-equipped to
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`perform.
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`43. Aspects of this technical solution discussed above are recited in each
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`of the independent claims: claim 1 (“[a]n Internet portal system for accomplishing
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`a multi-component task . . . software executing on the server . . . in response to
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`initiation of a multi-component task specified . . . defines the component tasks
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`based on pre-programmed client-related data, identifies third-party Internet Web
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`services needed for completion of the tasks, performs and manages interaction with
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`the identified Web sites, gathering results of the interactions, integrates the
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`gathered results, and communicates final results to the client at the client station”)
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`and claim 8 (“[a] method for accomplishing . . a multi-component task involving
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`interaction with one or more Internet Web sites . . . defining component tasks
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`based on pre-programmed client-related data . . . identifying third-party Web
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`servers for completion of the component tasks . . . managing execution of the
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`component tasks . . . including interaction with the Web servers identified . . .
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`gathering and integrating results of the component tasks and communicating final
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`results to the client”).
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`44. The ’451 Patent addresses the further technical problem that
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`decomposing a multi-part Internet task into its component sub-tasks requires
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`defining those sub-tasks in a way that allows reconciling relevant user profile
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`information with particular parameters necessary to complete each sub-task. The
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`’451 Patent describes tasks and subsequent component sub-tasks having certain
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`definitions and parameters. “Such parameters become rules that effect all of the
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`sub-parameters that must be met in order to enable the user to accomplish the . . .
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`main task.” Id. at 5:28-33. As the ’451 Patent describes, the Internet portal system
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`“acts to research what parameters will be necessary to allow the user to [complete
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`each component task] according to appointment parameters or rules.” Id. at 5:33-
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`37. “This research is accomplished by accessing appropriate databases . . . which
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`contain user profile data regarding subscribed-to WEB services.” Id. at 5:37-39.
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`The ’451 Patent also describes that the system employs helper applications, or
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`“guards,” that “verify parameters associated with facts known about [a particular
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`component task] and the user-data generic to the user's subscribed-to WEB
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`services.” ’451 Patent at 5:44-47. Thus, determining the specifics of rules for
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`decomposing a multi-part Internet task into component tasks was a technical
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`challenge that was solved with the Internet portal system.
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`45.
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`In sum, the ’451 Patent recites multiple technical problems, provides
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`technical solutions to those problems, and then recites the solutions in the claim 8.
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`For at least these reasons, claim 8 is not directed to an abstract idea.
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`B.
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`The ’451 claims contain an inventive concept
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`46. Not only is claim 8 directed to a non-abstract improvement in
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`computer technology, it is my opinion that claim 8 involves an inventive concept
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`as well. In other words, the ’451 Patent claims significantly more than the abstract
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`idea of “identifying sub-tasks within a larger task, managing completion of these
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`sub-tasks, and communicating the results to the client.” As explained above, claim
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`8 recites a combination of features that enable a computer system to accomplish a
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`main task on behalf of a user, including completion of sub-tasks performed by
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`diverse Web services. This technological feat is performed without user-
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`interaction, alleviating the burden of requiring the user to manually visit and
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`interact with each Web service associated with a sub-task.
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`47. Dr. Mowry’s opinion of the claims as nothing more than a directive to
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`perform known elements through conventional computing technology is an overly
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`simplistic characterization and a misleading analysis of the ’451 Patent. See Ex.
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`1002 at ¶ 67. To the contrary, the solution set forth in claim 8 is non-conventional,
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`non-generic, and deeply rooted in computer technology, not only because it
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`addre
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