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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
`
`GOOGLE INC.
`Petitioner
`
`v.
`
`BLACKBERRY LTD.
`Patent Owner
`
`____________________
`
`Patent No. 8,745,149
`____________________
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`DECLARATION OF DR. DAN R. OLSEN JR.
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`GOOGLE EXHIBIT 1002
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`Page 1 of 64
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`TABLE OF CONTENTS
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`INTRODUCTION .......................................................................................... 1
`I.
`BACKGROUND AND QUALIFICATIONS ................................................ 1
`II.
`III. SUMMARY OF OPINIONS .......................................................................... 4
`IV. PERSON OF ORDINARY SKILL IN THE ART ......................................... 5
`V.
`TECHNICAL BACKGROUND .................................................................... 6
`VI. OVERVIEW OF THE ’149 PATENT ........................................................... 9
`VII. CLAIM CONSTRUCTION ......................................................................... 10
`VIII. OVERVIEW OF THE PRIOR ART ............................................................ 10
`Appelman ............................................................................................ 11
`A.
`Toshio ................................................................................................. 12
`B.
`C. Milton ................................................................................................. 13
`D. MacPhail ............................................................................................ 14
`IX. THE PRIOR ART DISCLOSES OR SUGGESTS ALL OF THE
`FEATURES OF CLAIMS 1-17 OF THE ’149 PATENT ............................ 14
`The Combination of Appelman and Toshio Discloses or
`A.
`Suggests the Features of Claims 1-5, 9-13, and 17 ............................ 15
`1.
`Claim 1 ..................................................................................... 16
`2.
`Claim 2 ..................................................................................... 29
`3.
`Claim 3 ..................................................................................... 29
`4.
`Claim 4 ..................................................................................... 30
`5.
`Claim 5 ..................................................................................... 31
`6.
`Claim 9 ..................................................................................... 32
`7.
`Claim 10 ................................................................................... 35
`8.
`Claim 11 ................................................................................... 36
`9.
`Claim 12 ................................................................................... 36
`10. Claim 13 ................................................................................... 37
`11. Claim 17 ................................................................................... 37
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`B.
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`The Combination of Appelman and Milton Discloses or
`Suggests the Features of Claims 1, 5-7, 9, 13-15, and 17 .................. 40
`1.
`Claims 1, 9, and 17 .................................................................. 41
`2.
`Claim 5 ..................................................................................... 53
`3.
`Claim 6 ..................................................................................... 53
`4.
`Claim 7 ..................................................................................... 54
`5.
`Claim 13 ................................................................................... 54
`6.
`Claim 14 ................................................................................... 55
`7.
`Claim 15 ................................................................................... 55
`The Combination of Appelman, Toshio, and MacPhail
`Discloses or Suggests the Features of Claims 8 and 16 ..................... 55
`1.
`Claim 8 ..................................................................................... 56
`2.
`Claim 16 ................................................................................... 59
`The Combination of Appelman, Milton, and MacPhail
`Discloses or Suggests the Features of Claims 8 and 16 ..................... 60
`CONCLUSION ............................................................................................. 61
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`C.
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`D.
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`ii
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`X.
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`I, Dr. Dan R. Olsen Jr., declare as follows:
`
`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
`
`
`I.
`
`INTRODUCTION
`1.
`
`I have been retained by Google Inc. (“Petitioner”) as an independent
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`expert consultant in this proceeding before the United States Patent and Trademark
`
`Office (“PTO”) regarding U.S. Patent No. 8,745,149 (“the ’149 patent”) (Ex.
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`1001). I have been asked to consider whether certain references disclose or suggest
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`the features recited in claims 1-17 of the ’149 patent. My opinions are set forth
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`below.
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`2.
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`I am being compensated at my rate of $500 per hour for the time I
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`spend on this matter. My compensation is in no way contingent on the nature of
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`my findings, the presentation of my findings in testimony, or the outcome of this or
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`any other proceeding. I have no other interest in this proceeding.
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`II. BACKGROUND AND QUALIFICATIONS
`3.
`I have more than 35 years of experience in computer science and
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`human-computer interaction (HCI). I hold a doctorate in Computing and
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`Information from the University of Pennsylvania. For 3 ½ years I was an Assistant
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`Professor of Computer Science at Arizona State University. I then served for 30
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`years on the faculty of Brigham Young University, retiring as a full professor in
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`2015. During that time at BYU, I also served as the chair of the Department of
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`Computer Science. I took leave from BYU in 1996 to become the founding
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`director of the Human Computer Interaction Institute in the School of Computer
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`Science at Carnegie Mellon University. I returned to BYU in 1998. I am currently
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`the CEO of a software startup in educational technology (SparxTeq, Inc).
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`4.
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`During the course of my academic career, I authored over 70 papers in
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`the field of computer science. The topics on which I have published papers are:
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` User Interface Management Systems
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` Syntactic representations of user interfaces
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` Multi-user interaction across networks
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` Induction of interaction behavior from pictures
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` Novel interaction techniques using speech and laser pointers
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` Interactive machine learning
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` Interactive robotics
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` Interactive television
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`5.
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`I currently hold 4 patents in human-computer interaction. I have
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`authored 3 textbooks on the techniques of software design for human-computer
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`interaction.
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`6.
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`I have had extensive involvement in professional societies, such as the
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`Association for Computing Machinery (ACM), the premiere society in computing.
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`I have served in many offices of ACM’s Special Interest Group on Computer
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`2
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`Human Interaction (SIGCHI) and currently serve as its treasurer. I have been
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`conference chair of CHI, which is the premier conference in Computer Human
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`Interaction. I was the founding editor of ACM’s Transactions on Computer Human
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`Interaction. I was a co-founder and active leader for the conference on User
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`Interface Software and Technology (UIST) for the past 29 years. I have also served
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`at the governor’s request on the Utah Science, Technology and Research (USTAR)
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`board, which oversees and funds state economic development efforts in
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`technology.
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`7.
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`I twice received best paper awards in intelligent user interfaces. In
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`2004, I was appointed to the CHI Academy for international excellence in
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`Computer Human Interaction research. In 2007, I was recognized as one of ACM’s
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`Fellows for research in computer science and in 2012 received the CHI Lifetime
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`Research Award, which is the highest award in Computer Human Interaction.
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`8.
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`I understand that a copy of my curriculum vitae, which includes a
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`more detailed summary of my background, experience, and publications, is
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`provided as Ex. 1003.
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`3
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`
`III. SUMMARY OF OPINIONS1
`9.
`The opinions contained in this Declaration are based on the
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`documents I reviewed, my professional judgment, as well as my education,
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`experience, and knowledge regarding graphical user interfaces.
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`10.
`
`In forming my opinions expressed in this Declaration, I reviewed the
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`’149 patent (Ex. 1001), the prosecution file history for the ’149 patent (Ex. 1004);
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`International Publication No. WO 01/24036 (“Appelman”) (Ex. 1012); U.S. Patent
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`No. 5,631,949 (“Milton”) (Ex. 1006); Japanese Patent Application No. H03-89639
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`(“Toshio”) (Ex. 1007)2; U.S. Patent No. 6,661,434 (“MacPhail”) (Ex. 1009);
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`“Inside Macintosh Volume 1,” by Caroline Rose, et al. (Ex. 1013); and any other
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`materials I refer to in this Declaration in support of my opinions.
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`1 Citations to non-patent publications are to the original page numbers of the
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`publication, and citations to U.S. Patents are to the column:line number of the
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`patents.
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`2 I understand Ex. 1007 is a compilation containing the Japanese-language version
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`of Toshio (Ex. 1007 at 1-4), an English-language translation of Toshio (id. at 5-8),
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`and an affidavit (id. at 9). All citations to Toshio are to the original page numbers
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`of the English-language translation.
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`11. My opinions have also been guided by my appreciation of how a
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`person of ordinary skill in the art would have understood the claims and the
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`specification of the ’149 patent at the time of the alleged invention, which I have
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`been asked to initially consider was mid to late 2003 (including September 19,
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`2003, the filing date of U.S. Provisional Patent Application No. 60/504,379, to
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`which the ’149 patent claims priority). My opinions reflect how one of ordinary
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`skill in the art would have understood the ’149 patent, the prior art to the patent,
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`and the state of the art at the time of the alleged invention.
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`12. As I discuss in detail below, it is my opinion that certain references
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`disclose or suggest all the features recited in claims 1-17 of the ’149 patent.
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`IV. PERSON OF ORDINARY SKILL IN THE ART
`13. Based on my review of the types of problems encountered in the art,
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`prior solutions to those problems, the rapidity with which innovations were made,
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`the sophistication of the technology, and the educational level of active workers in
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`the field, I believe a person of ordinary skill in art at the time of the alleged
`
`invention, which I was asked to assume was mid to late 2003, would have had at
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`least a B.S. degree in computer science, electrical engineering, or equivalent
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`thereof, and at least two years of experience in the relevant field, e.g., graphical
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`user interfaces. More education can supplement practical experience and vice
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`versa.
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`5
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`14. All of my opinions in this declaration are from the perspective of one
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`of ordinary skill in the art, as I have defined it here, during the relevant timeframe,
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`i.e., mid to late 2003.
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`V. TECHNICAL BACKGROUND
`15. The ’149 patent and the prior art cited in this Declaration are generally
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`directed to providing time information for messages displayed on a device. At the
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`time of the alleged invention, a message was simply a sequence of bytes
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`transmitted over a network, such as via email or instant messaging. The concept of
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`a message was independent of the contents of the message, which could have
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`included text, audio, video, images, or any other content or combination of content.
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`For example, as email programs began to mature, the concept of a MIME-type
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`email was developed in the 1990s, which extended the format of email to support
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`textual and non-textual content.
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`16.
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`It was also well known at the time of the alleged invention that
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`messages exchanged between devices or users could be displayed in multiple
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`ways. One way was to display all messages that share common senders and
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`receivers. For example, a system could filter stored messages to identify messages
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`that share common senders and receivers and display them together ordered
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`sequentially according to time. A person of ordinary skill in the art would have
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`known how to filter messages in such a way using, for example, SQL (Standard
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`Query Language) or a simple one-loop program. Email often displayed messages
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`in such a way (typically referred to as an email “thread”).
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`17.
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`It was also well known at the time of the alleged invention that date
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`and time information could be represented in multiple ways. For example, well
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`before the date of the alleged invention, it was known and common for time to be
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`represented in different forms (e.g., 1:45PM and 13:45 represent the same time in
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`two different forms), and for dates to be represented in different forms (e.g., “15
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`January 17,” “January 15, 2017,” and “1/15/17” represent the same date in three
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`different forms). It was also known and common at the time of the alleged
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`invention to use a relative date/time (instead of or in addition to an absolute
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`date/time) when speaking about some past event. For example, when faced with
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`the need to reference a time from the day before, it was common to say “10:15
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`yesterday.” Phrases such as “noon, 3 days ago” and “two weeks ago” were also
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`known and commonly used well before the alleged invention. The ability and
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`understanding of when and how to use an absolute and/or relative date/time
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`expression was known and common well before the date of the alleged invention.
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`18.
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`In my opinion, prior to the alleged invention for the ’149 patent, the
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`concept of, and technologies to implement such a concept, updating a display in
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`response to a change in information was known and commonly used in art of the
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`’149 patent. For example, the book “Inside Macintosh” was published by Apple
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`U.S. Patent No. 8,745,149
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`Computer, Inc. in 1985. This book describes how to write software for the first
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`Apple Macintosh computer released in 1985. The computer and Inside Macintosh
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`were some of the most widely known references on graphical user interface
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`(“GUI”) software design and development. Inside Macintosh describes how a
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`window should be redrawn as a result of an “update” event. Ex. 1013 at I-278 to I-
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`279. This basic architecture of generating an event or method call to redraw a
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`region of the screen from underlying information has been part of GUI systems
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`since at least that time. Ex. 1013 discloses features consistent with the
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`understanding of the art prior to the alleged invention for the ’149 patent. Thus,
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`how to update a screen in response to changed information was well known at the
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`time of the alleged invention.
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`19. For instance, an example of this screen refresh technique can be found
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`in the redrawing of menu highlights as the mouse moves in Windows 95
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`(published in 1995). As the mouse moves, a redraw event is generated causing the
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`menu to be redrawn to highlight the menu item currently under the mouse.
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`Windows 95 was one of the most widely used pieces of software at the time. Also,
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`at the time of the alleged invention, computer animation was built around the idea
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`of redrawing the screen on a regular basis. As time changes, the redraw of the
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`screen was invoked to paint a new image to reflect changes in the underlying data.
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`U.S. Patent No. 8,745,149
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`This made logos fly across the screen in Microsoft PowerPoint and many other
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`forms of animation.
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`VI. OVERVIEW OF THE ’149 PATENT
`20. The ’149 patent, titled “Handheld Electronic Device and Associated
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`Method Providing Time Data in a Messaging Environment,” is generally directed
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`to providing time information associated with messages displayed on a handheld
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`device (e.g., PDAs, pagers, cellular telephones). Ex. 1001 at Abstract, 1:20-24,
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`1:26-29, 1:39-43, 5:31-8:38.
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`21. The ’149 patent explains that time information may provide
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`“additional information depending upon the prevailing circumstances.” Id. at 7:37-
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`40. For instance, if the time information is presented as a first time stamp that is
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`displayed upon receiving a message (id. at 8:10-13), but the conversation did not
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`resume until the following day, “the first time stamp 84 potentially could be
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`configured to automatically change from being displayed as ‘2:44 pm’ on the day
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`of communication of the non-responded-to message 80 to being displayed as, for
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`instance, ‘2:44 pm Thursday’ or, for instance, ‘2:44 PM Sep. 17, 2004’ or, for
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`instance, ‘2:44 pm yesterday’ on the following day, although other configurations
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`will be apparent and will be within the concept of the invention” (id. at 7:40-50).
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`22. The ’149 patent also explains that time information “can be
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`configured to depict relative times, i.e., elapsed times, rather than absolute times.”
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`U.S. Patent No. 8,745,149
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`Id. at 7:51-58, FIG. 10. According to the ’149 patent, such time information may
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`change as time progresses. Id. at 7:59-60. For instance, time information presented
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`as a relative timestamp “could progressively change from saying ‘less than one
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`minute ago’ to saying ‘one minute ago,’ ‘two minutes ago,’ ‘forty-five minutes
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`ago,’ and the like as time progressed.” Id. at 7:61-64. A relative time may also
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`change to an absolute time after the expiration of a given time duration. Id. at 7:64-
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`8:3.
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`VII. CLAIM CONSTRUCTION
`23.
`I understand that a claim subject to inter partes review receives the
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`broadest reasonable construction that would have been understood by one of
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`ordinary skill in the art at the time of the alleged invention in light of the
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`specification of the patent in which it appears. I also understand that any term that
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`is not construed should be given its plain and ordinary meaning under the broadest
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`reasonable construction. I followed these principles in forming my opinions in this
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`Declaration.
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`24.
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`I understand that Petitioner has proposed that the broadest reasonable
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`construction of the term “first input,” as recited in claims 1, 8, 9, 16, and 17, means
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`“any event detected by the electronic device.” I have been asked to consider and
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`have applied this construction in my analysis.
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`VIII. OVERVIEW OF THE PRIOR ART
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`A. Appelman
`25. Appelman is directed to an instant messaging application user
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`interface. Ex. 1012 at 1:6-8. For example, Appelman’s “FIG. 12 shows a screen
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`shot of a messaging application user interface used in AOL’s Instant Messenger.”
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`Id. at 7:12-13.
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`26. The messaging application (“MA”) “user interface 600 also includes
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`an output text field 614 where messages 616 that are sent and received by the MA
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`user interface 600 are displayed,” each message including “a time stamp field
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`624.” Id. at 16:23-28, FIG. 12. “The time at which the message 616 was sent or
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`received is shown in the time stamp field 624” of the MA user interface. Id. at
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`17:1-2.
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`27. For example, Appelman explains that an “instant message appears
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`essentially as soon as the message sender clicks the send button,” and, once
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`sent/received, the instant message has a corresponding timestamp that is displayed.
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`Id. at 2:18-19, 2:31-3:8, 8:1-8, 16:17-28, 17:30-18:1, 19:4-12, 20:11-17, 22:5-14,
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`23:16-23, 24:15-25, 25:12-26. Therefore, in my opinion, Appelman discloses an
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`instant messaging application that allows a user to have an instant messaging
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`conversation with another user where the displayed instant messages are time-
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`stamped in response to being sent/received.
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`B.
`Toshio
`28. Toshio relates to messages displayed on a selective call receiver, such
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`as a pager. Ex. 1007 at 229. Toshio explains that it was known to associate a time
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`with a message, but that “over several days, the message is displayed in a state
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`where it is impossible for the user to know which date the message came” and the
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`“display of time is confusing to a user, which is problematic.” Id. at 230. This is
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`because the message’s “time is effective only for that day” and becomes less
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`meaningful the next day. Id. Thus, Toshio provides a display function that is
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`“useful when displaying an incoming message on a day after the message was
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`received.” Id. In particular, Toshio determines if the “date has been updated” and,
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`if so, “the fact that the day the message was received is not today is memorized and
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`displayed along with the incoming message and the receipt time.” Id. For example,
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`12
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`U.S. Patent No. 8,745,149
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`when the date changes, Toshio displays “the number of elapsed days of a message
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`along with an incoming message and the time” the message was received. Id.
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`Toshio also explains that the display of the number of elapsed days “does not need
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`to be a complicated one.” Id. at 231. “[A] simple mark may be used as long as
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`identification is possible.” Id.
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`C. Milton
`29. Milton discloses automatically changing a voice message’s time
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`information from a relative time to an absolute time after a predetermined amount
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`of time. Ex. 1006 at 4:1-13. Milton explains that a user “can better determine his
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`course of action” if presented with a relative timestamp for newer messages. Id. at
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`1:60-61. If the elapsed time becomes too great, “rather than reporting the elapsed
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`time, the system can report the actual month and day on which the message” was
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`delivered. Id. at 1:67-2:4, 4:1-13. For example, as shown in FIG. 4, Milton
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`discloses determining a message’s age (step 45). Id. at 3:60-63. If the message was
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`received less than 24 hours ago (step 46),3 then the time information is converted
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`3 Consistent with the description corresponding to FIG. 4 (Ex. 1006 at 3:63-4:13),
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`one of ordinary skill in the art would have understood that the greater-than sign (>)
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`in decision box 46 of FIG. 4 is a typographical error and should be a less-than sign
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`(<). In fact, the specification repeatedly describes automatically changing a time
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`to a relative time (step 47) and reported as the number of elapsed hours and
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`minutes (step 48). Id. at 3:63-4:6. If the message was received more than 24 hours
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`ago (step 46), then the time information is converted to an absolute time (step 49)
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`and reported as the month and day that the message was received. Id. at 4:9-13.
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`D. MacPhail
`30. MacPhail addresses problems related to “displays having diverse sizes
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`and capacities.” Ex. 1009 at 2:8-50. For instance, MacPhail discloses displaying a
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`timestamp only upon request by a user, such as in response to a pointer being
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`placed over the time-stamped object. Id. at 9:64-10:11, 12:60-63. The pointer may
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`be moved “using a pointing device such as a mouse or trackball.” Id. at 9:66-67.
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`IX. THE PRIOR ART DISCLOSES OR SUGGESTS ALL OF THE
`FEATURES OF CLAIMS 1-17 OF THE ’149 PATENT
`31.
`I have reviewed Appelman, Toshio, Milton, and MacPhail, and as
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`described below, it is my opinion that Appelman in combination with one or more
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`of Toshio, Milton, and MacPhail discloses or suggests all of the features of claims
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`1-17 of the ’149 patent.
`
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`from relative to absolute after a predetermined amount of time. Id. at 1:67-2:4,
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`3:63-4:13, 5:19-23, 6:9-15.
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`In my opinion, as described below in section IX.A, the combination of
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`32.
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`Appelman and Toshio discloses or suggests all of the features of claims 1-5, 9-13,
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`and 17, where the claimed “first time information” is disclosed as an absolute time
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`and the claimed “second time information” is disclosed as a relative time. In my
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`opinion, as described below in section IX.C, the combination of Appelman, Toshio,
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`and MacPhail discloses or suggests all of the features of claims 8 and 16.
`
`33.
`
`In my opinion, as described below in section IX.B, the combination of
`
`Appelman and Milton discloses or suggests all of the features of claims 1, 5-7, 9,
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`13-15, and 17, where the claimed “first time information” is disclosed as a relative
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`time and the claimed “second time information” is disclosed as an absolute time. In
`
`my opinion, as described below in section IX.D, the combination of Appelman,
`
`Milton, and MacPhail discloses or suggests all of the features of claims 8 and 16.
`
`A. The Combination of Appelman and Toshio Discloses or Suggests
`the Features of Claims 1-5, 9-13, and 17
`I reviewed Appelman and Toshio, and, in my opinion, the combination
`
`34.
`
`of Appelman and Toshio discloses or suggests all of the features of claims 1-5, 9-
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`13, and 17 of the ’149 patent, where the claimed “first time information” is
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`disclosed as an absolute time and the claimed “second time information” is
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`disclosed as a relative time.
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`15
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
`
`
`1.
`
`Claim 1
`a)
`
`[1a] “A method of displaying an instant messaging
`conversation on a display of an electronic device, the
`method comprising:”
`
`35.
`
`I understand that a “method of displaying an instant messaging
`
`conversation on a display of an electronic device” is the preamble to claim 1 of the
`
`’149 patent. I have been asked to assume that the preamble is a claim limitation.
`
`Under that assumption, Appelman discloses these features. For example, Appelman
`
`describes a “computer system” (“electronic device”), which is, “for example, a
`
`personal or laptop computer.” Ex. 1012 at 1:10, 1:28-30; see also id. at 26:6-32,
`
`FIGs. 1-2. As shown in FIG. 1, Appelman’s computer system includes a display
`
`107 (“a display”) (id. at 1:17-19), for displaying an “instant message” (id. at 2:12-
`
`18). See also id. at Abstract, 2:25-3:16, 3:28-4:15, 5:1-4, 5:9-14, 6:3-8, 8:9-12,
`
`8:21-26, 9:1-10, 9:23-27, 10:1-5, 16:23-25, 18:2-19:29, 20:9-25:26, FIGs. 1-3, 5, 6,
`
`12-31.
`
`36. The instant messages are displayed as part of a conversation, as
`
`illustrated in FIGs. 3, 5, 6, and 12-31 of Appelman. Id. at 2:25-3:8 (describing that
`
`“FIG. 3 is a screen shot of an Instant Message (IM) window 130 as used in AOL’s
`
`Instant Messenger (‘AIM’) system,” that when “one user (PhillipsJC) types a
`
`comment 134 in text entry area 132 and clicks the Send button 133 . . . the entered
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`text . . . is displayed in the text display area 131 of the window 130 such that it is
`
`
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`
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`16
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`visible to both users,” and that a response “appears in the text display area 131
`
`underneath the previous comment 134”), 3:28-4:15, 5:1-14 (describing a user
`
`interface for “exchanging instant messages”), 6:4-8 (describing an interface for
`
`exchanging instant messages “without having to switch among several instant
`
`message windows”), 7:21-9:10 (explaining that the messaging application (MA)
`
`user interface is “any software application or other software program (such as an
`
`operating system or utility)
`
`that allows users
`
`to exchange
`
`information
`
`electronically, including by way of example instant messaging applications, e-mail
`
`programs, chat programs, etc.”), 16:11-17:6 (explaining that the user interface is
`
`implemented with AOL’s IM client software), 18:15-19 (explaining that “the
`
`recipient of the message . . . sends a responsive message [that] is also displayed”),
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`19:8-12, 19:18-21, 19:30-31.
`
`37. For example, FIG. 19 (below) shows a screen shot of a messaging
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`application (“MA”) user interface displaying an instant messaging conversation
`
`
`
`
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`17
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`between two people.4 Id. at 7:14, 17:5-6, 20:3-22. See also my analysis and
`
`citations below for remaining claim elements.
`
`
`
`b)
`
`[1b] “displaying a conversation of instant messages;”
`
`38.
`
`In my opinion, Appelman discloses these features for the same reasons
`
`as I discussed above with respect to claim element 1.a. For example, Appelman
`
`discloses a computer system that displays a conversation of instant messages
`
`between users, as illustrated in FIGs. 3, 5, 6, 12-31 of Appelman. See my analysis
`
`and citations above in section IX.A.1.a; see also my analysis and citations below in
`
`section IX.A.1.c.
`
`4 The string “T>” indicates that the message was sent to the user displayed in the
`
`address field, and the string “F>” indicates that the message was received from the
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`user displayed in the address field. See, e.g., Ex. 1012 at 8:14-21.
`
`
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`18
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`[1c] “displaying a first time information for an instant
`message in the conversation in response to a first input;
`and”
`
`c)
`
`39.
`
`In my opinion, Appelman discloses these features. As I discussed
`
`above for claim elements 1a and 1b, Appelman discloses a computer system that
`
`displays a conversation of instant messages. See my analysis and citations above in
`
`sections IX.A.1.a-b. As I explain below, Appelman discloses that a time stamp
`
`(“first time information”) is displayed for each instant message in the conversation,
`
`as shown in FIGs. 12 and 16-31. Ex. 1012 at 10:13-22, 18:2-28, 19:8-29, 20:9-15,
`
`20:20-33, 22:8-27, 23:16-24:4, 24:17-25:1, 25:20-26.
`
`40. For example, referring to FIG. 12 (annotated below), Appelman
`
`explains that the MA “user interface 600 also includes an output text field 614
`
`where messages 616 that are sent and received by the MA user interface 600 are
`
`displayed.” Id. at 16:23-25, FIG. 12. Appelman further explains that “[e]ach
`
`message 616 includes address information 618 and a message body 620,” where
`
`“the address information 618 includes a to/from field 622, a time stamp field 624,
`
`and an address field 626.” Id. at 16:25-28, FIG. 12. As shown in FIG. 12 below,
`
`the “time at which the message 616 was sent or received is shown in the time
`
`stamp field 624” in the form of an absolute time stamp (e.g., 13:20:05) (annotated
`
`in red). Id. at 17:1-2, FIG. 12.
`
`
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`
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`19
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`Declaration of Dr. Dan R. Olsen Jr.
`U.S. Patent No. 8,745,149
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`
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`41. The time stamp (“first time information”) for each instant message
`
`(“an
`
`instant message
`
`in
`
`the conversation”)
`
`is displayed
`
`in response
`
`to
`
`sending/receiving the message, which is a “first input,” as construed by Petitioner
`
`(see section VII), because sending/receiving a message is an event detected by the
`
`computer system. For instance, Appelman explains that an “instant message
`
`appears essentially as soon as the message sender clicks the send button” (id. at
`
`2:18-19), and that a corresponding timestamp is also displayed when the instant
`
`message appears (id. at 10:13-22, 18:2-28, 19:8-29, 20:9-15, 20:20-33, 22:8-27,
`
`23:16-24:4, 24:17-25:1, 25:20-26). For example, referring to FIG. 16, Appelman
`
`explains that “after the user sends the message 632,” “a time stamp field 642 . . .
`
`corresponding to the message 632 [is] displayed,” which “contains the time (i.e.,
`
`‘13:20:05’) at which the message 632 was sent.” Id. at 18:2-10. Similarly, whe