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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`GOOGLE LLC,
`Petitioner,
`
`v.
`
`BLACKBERRY LTD.,
`Patent Owner.
`____________
`
`Case IPR2017-00913 (Patent 8,402,384 B2)
`Case IPR2017-00914 (Patent 8,713,466 B2)
`____________
`
`Record of Oral Hearing
`Held: May 30, 2018
`
`
`
`
`Before SALLY C. MEDLEY, ROBERT J. WEINSCHENK, and
`RICHARD H. MARSCHALL, Administrative Patent Judges.
`
`
`
`
`
`
`
`
`
`

`

`Case IPR2017-00913 (Patent 8,402,384 B2)
`Case IPR2017-00914 (Patent 8,713,466 B2)
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`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`NAVEEN MODI, ESQUIRE
`PHILLIP W. CITROEN, ESQUIRE
`JOSEPH E. PALYS, ESQUIRE
`Paul Hastings, LLP
`875 15th St NW #10
`Washington, DC 20005
`202-551-1990
`
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`CHING-LEE FUKUDA, ESQUIRE
`Sidley Austin, LLP
`787 Seventh Avenue
`New York, New York 10019
`212-839-7364
`
`and
`
`SAMUEL A. DILLON, ESQUIRE
`SHARON LEE, ESQUIRE
`Sidley Austin, LLP
`1501 K Street N.W.
`Washington, D.C. 20005
`202-736-8298
`
`
`
`
`The above-entitled matter came on for hearing on Wednesday, May 30,
`
`2018, commencing at 3:19 pm, at the U.S. Patent and Trademark Office, 600
`Dulany Street, Alexandria, Virginia.
`
`
`
`
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`Case IPR2017-00913 (Patent 8,402,384 B2)
`Case IPR2017-00914 (Patent 8,713,466 B2)
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`
`P R O C E E D I N G S
`- - - - -
`
`THE USHER: All rise.
`
`JUDGE WEINSCHENK: Be seated. All right. Welcome back
`
`everyone. This is a hearing for IPR2017-00913 and -00914. Google LLC
`versus Blackberry LTD. Let's start with appearances again. Who do we
`have for petitioner?
`
`MR. CITROEN: Good afternoon, Your Honor. Phillip Citroen for
`Paul Hastings on behalf of Google and with me here today is Joseph Palys
`and Naveen Modi also for Paul Hastings and petitioner.
`
`JUDGE WEINSCHENK: All right. And who do we have for patent
`owner?
`
`MS. FUKUDA: Ching-Lee Fukuda, Sidley Austin representing patent
`owner Blackberry. With me is my colleague Sharon Lee who will also be
`arguing today. And Sam Dillon who is attending.
`
`JUDGE WEINSCHENK: Okay, thank you. As you know from the
`order, again each side will have 60 minutes to present their arguments, so we
`are going to test your endurance here today. We will start with petitioner
`and follow up with patent owner. Petitioner just let us know how much time
`you would like to reserve for rebuttal.
`
`MR. CITROEN: I'd like to reserve about 20 minutes, Your Honor.
`
`JUDGE WEINSCHENK: 20?
`
`MR. CITROEN: Yes please.
`
`JUDGE WEINSCHENK: Sure.
`
`MR. CITROEN: And, Your Honors, before I go on we have
`demonstratives printed out if you would like a copy.
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`Case IPR2017-00913 (Patent 8,402,384 B2)
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`JUDGE WEINSCHENK: Sure.
`
`MR. CITROEN: Thank you. Okay. If we are all ready I will kick it
`
`off. So thank you. Good afternoon, Your Honor, my name is Phillip again.
`And we are as Your Honor mentioned we are here to discuss the
`consolidated hearings for 2017-00913 and -00914. These proceedings
`involves the ’384 patent and the ’466 patent. These are related patents and
`they share the same specification.
`If we can go to Slide 2, for the Boards convenience we have listed the
`grounds that were instituted in this proceeding which covers and this is for
`the ’913 proceedings, this covers all the claims of the ’384 patent. And if we
`go to the next slide, Slide 3 it shows the grounds again that Your Honors are
`aware of that were instituted by the Board. And these grounds cover the
`’466 claims.
`So in our view, based on the evidence that the Board relied on to
`institute these proceedings and the additional evidence that is of record, we
`believe that the Board should enter final written decisions in these
`proceedings finding all challenge claims unpatentable and they should be
`terminated.
`So if we can go to Slide 4, we wanted to just show Your Honors an
`exemplary claim and this is independent Claim 1 for the ’384 patent and
`while there is a lot of words in Claim 1, in our view the concepts described
`here are not complex and rather than go through all the limitations here what
`we have done is just highlight a few of the important limitations that are
`kind of at the heart of the disputes between the parties. And I will get into
`some of this more as we go on.
`And if we look at the Slide 5, next slide, here is Claim 1 for the ’466
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`Case IPR2017-00913 (Patent 8,402,384 B2)
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`patent and again a long claim with a lot of words, we don’t think the
`concepts here are complex and if you compare the claims there are some
`minor differences but we don't think the differences are actually meaningful
`for our purposes here today.
`The arguments with respect to the independent claims apply equally across
`all the proceedings, the two proceedings for all independent claims.
`So if we can go to the next slide, Slide 6 please. So, Your Honor, you
`may have noticed that petitioner's slides are bifurcated into two sections.
`We have a section on claim construction and then we have another section
`that addresses the issues related to the prior art. For purposes of my opening
`presentation, I don't plan to discuss the claim construction issues and there's
`two reasons why we plan to go straight to the issues for the prior art.
`The first is we believe our papers sufficiently describe why the patent
`owner’s claim construction arguments with respect to the additional dynamic
`preview information and selectable link is incorrect and second and probably
`most importantly we believe that the construction in the end doesn't matter.
`The prior art discloses these limitations whether or not the Board adopts
`patent owner’s construction or agrees with the construction that it adopted in
`this institution decision.
`So unless Your Honors have any specific questions about the claim
`construction issues I would like to jump forward and go straight to the prior
`art. Okay.
`So with that can we go to Slide 20 please? So you can see on Slide 20
`there is several issues here. So the patent owner in these proceedings have
`advanced several issues in the two proceedings. All of them we believe
`should be rejected and I plan to address most of them here today. I'm going
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`Case IPR2017-00913 (Patent 8,402,384 B2)
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`to focus primarily on the first four issues here and depending on time I will
`get into some of the later issues that are shown here in the slide.
`And just to frame our discussion, I think it is important to recognize as
`Your Honors know that there are two different what we call interfaces in
`Cadiz that we discuss in our papers. One is called the person centric
`interface which deals with contacts that are displayed in the side bar and the
`person window and then there is another type of interface that deals with an
`email or an inbox which again is information that could be displayed on the
`sidebar that’s described in Cadiz or another window email specific view. So
`I'm going to address the two personal centric interface arguments that the
`patent owner has raised first and then go on to email centric interface.
`So if we could go to Slide 21. So my first issue is with respect to the
`person centric interface, does Cadiz disclose a software, the software
`application limitations. If we go to Slide 22 to set up the argument or to set
`up the issue here, what the patent owner has argued is that the claimed
`dynamic preview information and the claimed additional dynamic preview
`information is not disclosed by Cadiz's person centric interface because the
`information is not determined from information managed by the same
`software application.
`And if, Joe, if we could pull up Cadiz Figures 8A and B I think it is
`helpful to see the figures to understand the argument. So it’s a little small so
`I apologize but the issue is the patent owner has argued in 8B the person
`window which is on the top right there are multiple channels of
`communication and they're, the identifiers there 840 it's difficult to see.
`There are multiple channels of communication that identify different
`availabilities. You can see possibly available, not available as examples.
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`Case IPR2017-00913 (Patent 8,402,384 B2)
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`Then you have on the left hand side Figure 8A and that's a sidebar.
`Their position is that the person or the contact that corresponds with
`the person window in this example it is Gavin only has one availability and
`in this particular example it's the persons face is actually oriented forward if
`they are available or its oriented to the side if they are not available. Of
`course there are other ways that you can display availability. There is 805 at
`the bottom, you have a small icon which is better for devices with small
`displays. But just to get to the heart of the argument, there is one availability
`shown for a contact in the sidebar but when you open the person window
`there is multiple availabilities.
`So according to the patent owner, this means that there must be some
`separate intermediate and what they call an availability application which
`isn’t disclosed in Cadiz that must take the information that is shown in
`Figure 8B, the person window, aggregates the information and then displays
`a single availability and a sidebar. And we believe that argument is wrong
`and there are several reasons for that and I would like to walk through those.
`And the first one if we can go back to the slide please. Go to Slide 23.
`So the first reason is we believe that even under their interpretation if there
`is this so called availability application, it doesn't matter because of what the
`claims require. If you look at the claims here at the highlighted portions in
`particular, they only require that both the dynamic preview information
`which is at the top portion that is highlighted in yellow and the additional
`dynamic preview information which is highlighted in yellow towards the
`bottom, they must be determined from information managed by the same
`software application. And that’s precisely what Cadiz discloses regardless
`of whether there is this availability application or not.
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`In Cadiz, the contacts availability shown in the person window as well
`as in the sidebar is determined from the same underlying communication
`application and I would like to just give an example. Joe, if we can go back
`to Cadiz, I think it would help. So Cadiz has one example of a
`communication application identifies MSN instant messenger. So if you use
`that example application and for simplicity let's assume that's the only
`messaging application that you have for Gavin that would show in person
`window 8B. If the contact is available MSN messenger it would indicate
`their availability in Figure 8B based on the information that MSN messenger
`manages and it would also indicate their availability in a sidebar Figure 8A
`and again that’s based on the information that MSN messenger manages.
`And that’s all the claims require.
`
`JUDGE WEINSCHENK: How do we know that though? I mean,
`you're telling us that from this figure, but is there some explanation in the
`reference that tells us that?
`
`MR. CITROEN: There is, Your Honor. And if I may, I actually have
`a slide I think that will help guide our discussion. If we can go to Slide 25.
`So if you -- actually let's start with Slide 24 first. So in the petition we
`explained and in the reply as well the way Cadiz works is that you have
`these tickets such a person ticket that is shown in the sidebar that’s
`combined with a viewer which is what displays the ticket information and
`combined the called times and that’s in your container or the side bar. And
`how does it get the availability information? It uses the services which in
`our petition we explained discloses application and the patent owner doesn’t
`dispute that.
`So the Cadiz reference then goes into more detail about how this
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`Case IPR2017-00913 (Patent 8,402,384 B2)
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`process works of actually getting the information from services and
`displaying the availability in the ticket items and viewers. So if we go to the
`next slide, we answered a snippet from one of the portions of Cadiz that we
`cited in the petition in our reply and here you can see a specific example and
`there is really two here. So let me start with the first one.
`It says this person centric interface provides a communications status
`via any of the member of communication channels for each of the displayed
`entities. So in other words, availability may be tied to only one
`communication channel, so MSN messenger application or it's up to the user
`or the designer it could be multiple communications channel. The big
`benefit of Cadiz's system is that its adjustable, it's customizable. You can
`decide with your viewer and your items whether or not you are selecting one
`or multiple communications channels for showing availability.
`
`JUDGE MARSCHALL: Does Cadiz tie in this description with
`Figures 8A and 8B?
`
`MR. CITROEN: So Figure 8A and 8B are just example screen
`captures. Everything that is shown in those figures are described in detail in
`the other portions of the specification. There is actually only three or four
`paragraphs that describe those screen captures, 8A and 8B. What those
`screen captures are showing are items in the side bar with the tickets and the
`viewers and it shows a person window or an expanded tool tip window is
`what its generically called earlier in the specification and the figures all
`build upon one another. At the end they give some specific examples of
`what it may look like on display.
`
`JUDGE MARSCHALL: So it is your positon that communication
`status 45 corresponds to the face and Figure 8A?
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`Case IPR2017-00913 (Patent 8,402,384 B2)
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`MR. CITROEN: Yes. As one example. Yes. There is also, there are
`
`other examples. It explains that the face is just one way to indicate
`availability. You can also use I think if we, I mentioned it earlier, in Figure
`8A there is also a small icon, it calls it I can't remember what it's called, I
`apologize. But it’s a small figure icon that can also show the person
`availability. It's labeled there as 805 so that’s another example.
`
`JUDGE MARSCHALL: Is there any text in Cadiz --
`
`MR. CITROEN: Yes.
`
`JUDGE MARSCHALL: Is there any text in Cadiz that ties those
`things together or is it kind of implicit in the disclosure that there is detailed
`disclosure in their earlier paragraphs and then some specific examples later?
`
`MR. CITROEN: There is text that ties it all together. Cadiz is a very
`long reference. As you know its 200 plus paragraphs but if you walk
`through each of the figures and I can do that. I was planning to do that a
`little bit with respect to a Claim 4 arguments and I can do that now if you
`would like.
`For each figure they build upon one another. Figure 2 refers to the
`device in Figure 1. Figure 3 builds upon the program modules and so forth
`and so on. Figure 8A and also B and C and Figure 10 those are example
`screen images on what when you have it on a display what it may look like.
`It's this very specific example. The disclosure that appears previously is all
`describing the concepts that are explained in those screen images.
`So before I move on, just to continue to answer your question, so one
`example here is it says any of a number of communications channels so
`that’s one way. If you have more than one communications channel in the
`person window this tells you, you can just have one. So you either can say
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`maybe MSN instant messenger is the one that you care about. That’s the
`one it will display in the sidebar.
`But there is also another functionality and again we cited this in our
`papers. The best available. You can let the system decide for you what it
`believes is the best communications channel and it will show you the
`availability based on that determination.
`And I’ll just note that the patent owner doesn't address these portions
`of Cadiz. They simply look at Figures 8A and 8B and ignore the underlying
`disclosure that describes the concepts that are underlying those figures. But
`when you look at it as a whole, in totality all the figures that describe these
`concepts in detail and they are tied together, it is very clear that it's
`customizable, the user can decide whether it is one communication channel,
`multiple communications channel or the best available one. It's up to the
`designer.
`
`JUDGE MEDLEY: Excuse me. Did you cite to this paragraph in
`Cadiz in your petition?
`
`MR. CITROEN: Yes.
`
`JUDGE MEDLEY: Or is it only cited in your reply?
`
`MR. CITROEN: No, we cited in petition multiple times, Your Honor.
`And if you would like examples, I may have some here. A few I have here,
`I believe there are more, but page 14, 15, 19, 31, and this is for the ’384
`proceeding, and I think there are corresponding pages in the ’466 petition as
`well that cites those pages.
`
`JUDGE MEDLEY: Thank you.
`
`MR. CITROEN: So if so actually if there is any more questions with
`respect to this topic if there is no more questions I will move on to the
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`second issue. Okay. If we could go to Slide 26 please.
`So the next issue I would like to discuss again this deals with the
`person centric interface and if we can go to Slide 27. So the issue is whether
`Cadiz's person centric interface discloses the limitations related to an
`embedded selectable leak. Leak, excuse me, link. Panel argues that Cadiz's
`personal centric interface does not disclose this limitation because the action
`buttons in Cadiz's person centric interface are the circles shown in Figure 8B
`which they say is not dynamic and therefore doesn’t meet their construction.
`And if we just show 8B really fast, Joe, so their argument is that the
`circles and this is for Figure 8B, the top right, next to the element 840 is a
`few circles there that appear between -- beside short message, email,
`voicemail, calling and person. Their position is that those must be the action
`buttons for the person centric interface.
`So we can go back to Slide 27. So we have listed several reasons here
`on the bottom of the slide that we think their argument is wrong but I think
`the most glaring is probably the last one. We have in our argument an
`obviousness position that was not addressed at all by the patent owner in
`their papers. They don't address it and we think that alone should be the end
`of it. The patent owner didn’t address it, we go through the rationale and
`explain how it could have been done and that should be the end of the issue
`and they shouldn’t be able to address that issue today either.
`But in addition to that, there is also two more reasons. So if we can
`go to slide let me see. Actually we can stay here. So the first issue is that
`their argument is based strictly on their claim construction position which is
`that additional dynamic preview information must be dynamic and that the
`selectable leak that’s -- leak I keep saying that. Link that's embedded in the
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`additional dynamic preview information itself must also be dynamic. So we
`have explained in our papers in detail why we think that that the argument is
`wrong and if the Board agrees with us we think this argument it just goes
`away. Under our construction, even if the circles are the action buttons we
`would win because we believe those action buttons, the circles would still be
`within the window and therefore be a selectable link embedded in additional
`dynamic preview information.
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`JUDGE MARSCHALL: Is it your position that the circles are
`dynamic?
`
`MR. CITROEN: So Cadiz doesn't actually describe the circles. They
`appear in the figure but there is no discussion of the circles. It also for the
`action buttons it doesn’t state what in the person window is the action
`buttons. It's actually described before Figure 8B is actually described which
`again shows that the concepts are all together the different figures describe
`the concepts and they rely on each one, they build on one another.
`So we, there is really no explanation what those circles are but there
`are other portions of Cadiz that indicates that colors for example may be
`used to indicate the age of information or the status or the availability of a
`user. It doesn't tie that directly to these circles but they're, if you look at the
`figure, they appear to be different colors. That may be an explanation but
`the truth is, Your Honor, it doesn't say.
`
`JUDGE MARSCHALL: What are you relying on in Figure 8B for the
`selectable link?
`
`MR. CITROEN: Sure. So if we can go back to -- so actually let's go
`to Slide 28 please. I just want to show, I think it is helpful to see what Cadiz
`actually says. It's a broad disclosure and it's at the top here. It doesn’t
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`actually restrict the location of the action buttons at all. It just says that the
`action buttons are in the person window and so Dr. Olson explained, he was
`actually asked this question during his deposition so what in your opinion
`would be the action buttons in the person window and he explained based on
`this broad disclosure that it could be anything into at window. It could be
`the circles. It could be the texts, a person of ordinary skill in the art would
`understand how to implement a system where they're just links. They would
`understand how to implement a system where any of the information that's
`shown there could be the action buttons.
`So to answer your question, it could be any of this information shown
`here including probably available. 40 minutes which is all dynamic
`information that is one example and an example he gave during his
`deposition he was asked about this.
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`JUDGE MARSCHALL: So without getting to obviousness, is it your
`position that Cadiz expressly discloses a selectable link and even though it
`doesn't say where it's located that anywhere in this window is sufficient?
`
`MR. CITROEN: Yes, Your Honor. We do believe that that is
`sufficient. Just because it's a, it is a broad disclosure and we have expert
`testimony explaining that a person of ordinary skill in the art would
`understand that it could be anything in these windows and also the fact that
`Cadiz does explain how you can implement links using the HTML,
`DHTML, Java Script, there is plenty of examples that a person of ordinary
`skill in the art could use.
`
`JUDGE MARSCHALL: Now some of those portions of the window
`are dynamic and some are not, so I would assume that this argument is
`premised on using your claim construction, correct?
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`Case IPR2017-00913 (Patent 8,402,384 B2)
`Case IPR2017-00914 (Patent 8,713,466 B2)
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`MR. CITROEN: Well, even under their own claim construction, I
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`think that we would still satisfy this claim limitation because under their
`claim construction, the selectable link just needs to be dynamic. So if the
`selectable link is probably available, under their construction that would
`satisfy the claim limitation.
`Now under our construction, there is additional options. So if we
`assume that the circles are not dynamic which we don’t know for sure. If we
`assume the circles are not dynamic under our construction that would be
`sufficient as well.
`
`JUDGE MARSCHALL: Under their construction it doesn’t
`necessarily disclose that you choose a dynamic portion of the window to be
`the selectable link. So that would require you to resort to obviousness,
`correct?
`
`MR. CITROEN: Well, we think based on the expert testimony the
`broad disclosure of Cadiz is, it’s relevant for all that it discloses. Would be
`sufficient. We have the obviousness position that comes in just because it
`doesn't actually say it’s a link and we have it as a backup position that of
`course this would have been obvious even if it’s not embedded.
`
`JUDGE WEINSCHENK: What are you relying on for your
`obviousness argument? Is it just the testimony of your expert witness or is
`there something else?
`
`MR. CITROEN: It's a combination of the expert's testimony and if
`you look at his declaration he points to other portions of Cadiz that describes
`the idea of using links to reach other information. So that’s what he relies
`on for purposes. And there may be, I will have to take a look but there may
`be some other evidence that he cites as well.
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`Case IPR2017-00913 (Patent 8,402,384 B2)
`Case IPR2017-00914 (Patent 8,713,466 B2)
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`JUDGE WEINSCHENK: Okay. The Federal Circuit has cautioned
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`us sometimes not to rely on, you know, expert testimony in place of a claim
`limitation. How is this different than that?
`
`MR. CITROEN: I believe he does support his testimony with
`evidence. As I explained I think the pieces of Cadiz that he refers to explain
`that a person of ordinary skill in the art knew that you could achieve or you
`would achieve a system where you gain access to additional information that
`isn’t displayed using links is actually in Cadiz itself. And that that benefit of
`using the links could it have been used here to -- and of course he doesn't, I
`don't believe this is part of Cadiz but he explains that there is also a benefit
`of having text that’s directly linkable because it then reduces clutter on the
`screen so you don’t have separate action buttons or icon buttons I should say
`that would be necessary to gain access to some additional information that's
`shown here or to activate a software application that's the same.
`So looking at the time, if we could go to issue three, Slide 29 unless
`there is any other questions, Your Honors, on issue two? Okay.
`So the third issue deals with and this is a separate interface now. The
`two arguments are -- the two positions that the patent owner has taken with
`respect to the person centric interface do not apply here for the email centric
`interface and that would include the claim construction argument that they
`have made.
`They've only made one argument and the only issue the Board needs
`to decide with respect to this interface is whether it would have been obvious
`to a person of ordinary skill in the art to modify the email window that's
`described in Cadiz to activate or invokes an email application. In our view
`the answer is yes.
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`Case IPR2017-00913 (Patent 8,402,384 B2)
`Case IPR2017-00914 (Patent 8,713,466 B2)
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`So if we can go to the next slide, Slide 30, so to understand patent
`owner’s argument, I think it is helpful just quickly to discuss what Cadiz
`describes here. And if -- I'm going to start with the green portion here. It
`describes an email viewer than can be uploaded in two different ways. One
`way is an email specific viewer, another is a viewer that instantiates an
`instance of the users email application. And regardless of the
`implementation you can see it refers to this functionality in the previous
`highlighted portion in yellow there. There is only a limited number of email
`functionalities that are actually described in Cadiz and when we asked patent
`owner’s expert if he agreed that these are just some of the possible email
`functionalities that were known at the time he agreed with that as well. So
`under either implementation the email specific viewer or the instantiated
`application there is only limited email functionalities that are provided.
`If we can go to Slide 31, so Figure 10 confirms that Cadiz's email
`window provides those limited functionalities and you can see the buttons at
`the top right that correspond with the text. I won't walk through each of
`those. We discussed this in our reply and wen talked to Dr. Ligler, asked
`him questions, and he confirmed what each of these buttons are. And that
`again there are other functionalities that are not here.
`During his deposition Dr. Ligler confirmed that there is no
`functionality available in this window, this email window to compose a new
`email message. There is no functionality here to access a deleted email
`folder and there is no functionality to create a new folder. Those are some
`of the examples of email functionality that you are just not provided by this
`specific window that Cadiz describes. So I don't --
`
`JUDGE MARSCHALL: Dr. Ligler does not describe these
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`Case IPR2017-00913 (Patent 8,402,384 B2)
`Case IPR2017-00914 (Patent 8,713,466 B2)
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`functionalities, correct?
`
`MR. CITROEN: Not with respect to Figure 10 and as far as I know
`he doesn’t describe those functionalities elsewhere either. So in order to
`actually access those functions, you would presumably need to activate the
`full function of the application somehow.
`So as explained in our petition, in our replies, a person of ordinary
`skill in the art of course they're already motivated in order to access those
`additional functionalities to modify a viewer like this so that there is an
`embedded selectable link such as an email that when you click it, it will
`actually instantiate the full functioning application that would allow the user
`then to gain access to other types of email functionalities such as those I just
`listed off.
`And I think it is important to note that the patent owner actually does
`not dispute that this is a benefit. That this benefit exists I should say. Really
`their argument is that a person of ordinary skill in the art motivated to
`provide a user with these additional functionalities would have implemented
`this in a different way. That’s really their argument.
`And if we go to Slide 32, their argument is that this would have been a
`better user experience. That’s their position and I know, I realize, Your
`Honor is probably familiar with the case law but we just want to emphasize
`that obviousness does not seek out the most preferred or best combination.
`All that is required is a reason to make the proposed combination. We
`provided several reasons and the patent owner doesn’t dispute any of them.
`So we think that's sufficient for this claim limitation but I will also
`point out that the patent owner doesn’t actually address the potential benefits
`of just having the email viewer implemented in the first way in the first
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`Case IPR2017-00913 (Patent 8,4