Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`EXHIBIT C-1:
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`VMware, Inc. (“VMware” or “Defendant”) provides this chart subject to all reservations, objections, statements, and disclaimers set
`forth herein and in VMware’s Preliminary Invalidity Contentions Cover Pleading, as well as any amendment, supplement, or
`modification thereof, which are incorporated herein by reference in their entirety.
`
`On information and belief, Chow ’175 was filed on June 7, 1996 and is available as prior art at least under 35 U.S.C. §§ 102(e).
`
`As illustrated in the chart below, Chow ’175 anticipates asserted claims 1-4, 6, 9-14, 22-26 of the ’752 Patent. To the extent Chow ’175
`is found not to expressly disclose certain limitations in the asserted claims, such limitations are inherent. To the extent Chow ’175 is
`found not to anticipate any asserted claims or claim elements of the ’752 Patent, the reference nevertheless renders those claims or claim
`elements obvious under 35 U.S.C. § 103, either alone or in combination with other art identified in the cover pleading, herein, or
`Appendix C of VMware’s Preliminary Invalidity Contentions. These Preliminary Invalidity Contentions are not an admission by
`VMware that the accused products, including any current or past versions of the accused products, are covered by, or infringe the
`asserted claims, but are based instead on the recognition that if the claims are interpreted to be broad enough to encompass the accused
`products, the claims must also be construed to have that same scope when considering whether they are invalid.
`
`The following chart is partially based on, but is not limited by, the claim constructions implicit in Plaintiff’s Infringement Contentions,
`to the extent that such constructions are apparent from the Infringement Contentions. VMware notes that in many instances, Plaintiff’s
`Infringement Contentions fail to provide adequate notice of Plaintiff’s construction of the asserted claims and fail to comply with the
`Court’s scheduling order and other applicable rules. VMware does not accept the assumptions concerning the scope and meaning
`implicit in Plaintiff’s Infringement Contentions, to the extent those assumptions are discernible, and reserves the right to challenge
`Plaintiff’s proposed (or implied) constructions. VMware also reserves the right to revise and supplement these charts if and when
`Plaintiff is permitted to provide revised Infringement Contentions or otherwise make its positions known. To the extent that these
`Preliminary Invalidity Contentions rely on or otherwise embody particular constructions of terms or phrases in the asserted claims,
`VMware does not necessarily advocate any such construction as proper constructions of those terms or phrase. VMware also reserves
`the right to revise and supplement these charts after the Court construes the claims. Citations given in the chart below are merely
`representative of the respective elements and are not meant to be exhaustive.
`
`1
`
`EX2004
`VMware v. IV
`IPR2020-00470
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`1.pre
`
`Claim Recitation
`1. A system for performing user customized
`network-based operations, comprising:
`
`Exemplary Citations to Chow ’175
`To the extent the preamble is considered a limitation, Chow ’175
`discloses a system for performing user customized network-based
`operations.
`
`See, e.g., Chow ’175 at 1:11-5:
`
`See, e.g., Chow ’175 at 3:57-4:5:
`
`2
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`See, e.g., Chow ’175 at Fig. 1:
`
`See, e.g., Chow ’175 at Fig. 3:
`
`3
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at Fig. 8:
`
`4
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 11:18-42:
`
`5
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at Fig. 31:
`
`6
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 5:15-31:
`
`7
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at Fig. 36:
`
`8
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`9
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`1.1
`
`means for receiving data for creating a
`network-based agent;
`
`Exemplary Citations to Chow ’175
`To the extent it is found that Chow does not expressly disclose this
`limitation, the limitation is inherent. Moreover, to the extent it is
`found that Chow does not anticipate this claim, Chow renders it
`obvious, either alone, in combination with the knowledge of a person
`of ordinary skill in the art, and/or in combination with other prior art
`references identified in the cover pleading, herein, or in Appendix C
`of VMware’s Preliminary Invalidity Contentions. A person of
`ordinary skill in the art would have been motivated to combine Chow
`with any of the other prior art references identified in the cover
`pleading or herein with a reasonable expectation of success because
`each of these references contains familiar elements within similar
`fields of endeavor to address similar known problems, according to
`known methods which would yield predictable results.
`Chow ’175 discloses means for receiving data for creating a network-
`based agent.
`
`See, e.g., Chow ’175 at 11:18-42:
`
`10
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at Fig. 31:
`
`11
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 5:15-31:
`
`12
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at Fig. 36:
`
`To the extent it is found that Chow does not expressly disclose this
`limitation, the limitation is inherent. Moreover, to the extent it is
`found that Chow does not anticipate this claim, Chow renders it
`obvious, either alone, in combination with the knowledge of a person
`of ordinary skill in the art, and/or in combination with other prior art
`references identified in the cover pleading, herein, or in Appendix C
`of VMware’s Preliminary Invalidity Contentions. A person of
`ordinary skill in the art would have been motivated to combine Chow
`with any of the other prior art references identified in the cover
`pleading or herein with a reasonable expectation of success because
`each of these references contains familiar elements within similar
`
`13
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`1.2
`
`means for invoking, in response to receiving a
`URL defining a type of event and identifying
`the network-based agent, an execution of the
`network-based agent;
`
`Exemplary Citations to Chow ’175
`fields of endeavor to address similar known problems, according to
`known methods which would yield predictable results.
`Chow ’175 discloses means for invoking, in response to receiving a
`URL defining a type of event and identifying the network-based
`agent, an execution of the network-based agent.
`
`See, e.g., Chow ’175 at 5:32-63:
`
`14
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 5:64-6:67:
`
`15
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`16
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`17
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See also, e.g., Chow ’175 at 9:59-10:12:
`
`18
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at Fig. 3:
`
`19
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 9:52-10:30:
`
`20
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`21
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at Fig. 5:
`
`22
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at Fig. 9:
`
`23
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 11:48-12:36:
`
`24
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`25
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 20:17-47:
`
`26
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 41:8-30:
`
`27
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`To the extent it is found that Chow does not expressly disclose this
`limitation, the limitation is inherent. Moreover, to the extent it is
`found that Chow does not anticipate this claim, Chow renders it
`obvious, either alone, in combination with the knowledge of a person
`of ordinary skill in the art, and/or in combination with other prior art
`references identified in the cover pleading, herein, or in Appendix C
`of VMware’s Preliminary Invalidity Contentions. A person of
`ordinary skill in the art would have been motivated to combine Chow
`
`28
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`1.3
`
`means, including the network-based agent, for
`using a service and a service resource
`configured to be consumed by the network-
`based agent for performing the operation,
`wherein an amount of the service resource is
`exhausted upon being consumed by the
`network-based agent; and
`
`Exemplary Citations to Chow ’175
`with any of the other prior art references identified in the cover
`pleading or herein with a reasonable expectation of success because
`each of these references contains familiar elements within similar
`fields of endeavor to address similar known problems, according to
`known methods which would yield predictable results.
`
`Chow ’175 discloses means, including the network-based agent, for
`using a service and a service resource configured to be consumed by
`the network-based agent for performing the operation, wherein an
`amount of the service resource is exhausted upon being consumed by
`the network-based agent.
`
`See, e.g., Chow ’175 at 9:32-58:
`
`29
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 25:33-26:17:
`
`30
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`31
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`1.4
`
`Claim Recitation
`means for communicating a result of the
`operation over a network communications link.
`
`Exemplary Citations to Chow ’175
`Chow ’175 discloses means for communicating a result of the
`operation over a network communications link.
`
`See, e.g., citations with regard to claim 1.1-1.3 supra.
`
`See also, e.g., Chow ’175 at 9:23-51:
`
`32
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See also, e.g., Chow ’175 at 10:40-11:17:
`
`33
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`34
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`To the extent it is found that Chow does not expressly disclose this
`limitation, the limitation is inherent. Moreover, to the extent it is
`found that Chow does not anticipate this claim, Chow renders it
`obvious, either alone, in combination with the knowledge of a person
`of ordinary skill in the art, and/or in combination with other prior art
`references identified in the cover pleading, herein, or in Appendix C
`of VMware’s Preliminary Invalidity Contentions. A person of
`ordinary skill in the art would have been motivated to combine Chow
`with any of the other prior art references identified in the cover
`pleading or herein with a reasonable expectation of success because
`each of these references contains familiar elements within similar
`fields of endeavor to address similar known problems, according to
`known methods which would yield predictable results.
`
`35
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`2
`
`Claim Recitation
`2. The system of claim 1, wherein the network
`communications link is a communications link
`in a public-switched communications network.
`
`Exemplary Citations to Chow ’175
`Chow ’175 discloses the system of claim 1, wherein the network
`communications link is a communications link in a public-switched
`communications network.
`
`See, e.g., Chow ’175 at 9:23-32:
`
`To the extent it is found that Chow does not expressly disclose this
`limitation, the limitation is inherent. Moreover, to the extent it is
`found that Chow does not anticipate this claim, Chow renders it
`obvious, either alone, in combination with the knowledge of a person
`of ordinary skill in the art, and/or in combination with other prior art
`references identified in the cover pleading, herein, or in Appendix C
`of VMware’s Preliminary Invalidity Contentions. A person of
`ordinary skill in the art would have been motivated to combine Chow
`with any of the other prior art references identified in the cover
`pleading or herein with a reasonable expectation of success because
`each of these references contains familiar elements within similar
`fields of endeavor to address similar known problems, according to
`known methods which would yield predictable results.
`
`36
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`3.pre
`
`Claim Recitation
`3. The system of claim 1, further comprising:
`
`Exemplary Citations to Chow ’175
`Chow ’175 discloses the system of claim 1.
`
`3.1
`
`means for mediating an interaction between
`the means for using the service and the service.
`
`See, e.g., citations with regard to claim 1 supra.
`
`To the extent it is found that Chow does not expressly disclose this
`limitation, the limitation is inherent. Moreover, to the extent it is
`found that Chow does not anticipate this claim, Chow renders it
`obvious, either alone, in combination with the knowledge of a person
`of ordinary skill in the art, and/or in combination with other prior art
`references identified in the cover pleading, herein, or in Appendix C
`of VMware’s Preliminary Invalidity Contentions. A person of
`ordinary skill in the art would have been motivated to combine Chow
`with any of the other prior art references identified in the cover
`pleading or herein with a reasonable expectation of success because
`each of these references contains familiar elements within similar
`fields of endeavor to address similar known problems, according to
`known methods which would yield predictable results.
`Chow ’175 discloses means for mediating an interaction between the
`means for using the service and the service.
`
`See, e.g., citations with regard to claim 1 supra.
`
`See also, e.g., Chow ’175 at 40:29-45:
`
`37
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See also, e.g., Chow ’175 at 41:30-50:
`
`38
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See also, e.g., Chow ’175 at 9:59-10:12:
`
`39
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`To the extent it is found that Chow does not expressly disclose this
`limitation, the limitation is inherent. Moreover, to the extent it is
`found that Chow does not anticipate this claim, Chow renders it
`obvious, either alone, in combination with the knowledge of a person
`of ordinary skill in the art, and/or in combination with other prior art
`references identified in the cover pleading, herein, or in Appendix C
`of VMware’s Preliminary Invalidity Contentions. A person of
`ordinary skill in the art would have been motivated to combine Chow
`with any of the other prior art references identified in the cover
`
`40
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`4.pre
`
`4. The system of claim 3, wherein the means
`for mediating comprises:
`
`4.1
`
`means for monitoring an amount of the service
`resource used by the network-based agent.
`
`Exemplary Citations to Chow ’175
`pleading or herein with a reasonable expectation of success because
`each of these references contains familiar elements within similar
`fields of endeavor to address similar known problems, according to
`known methods which would yield predictable results.
`Chow ’175 discloses the system of claim 3.
`
`See, e.g., citations with regard to claim 3 supra.
`
`To the extent it is found that Chow does not expressly disclose this
`limitation, the limitation is inherent. Moreover, to the extent it is
`found that Chow does not anticipate this claim, Chow renders it
`obvious, either alone, in combination with the knowledge of a person
`of ordinary skill in the art, and/or in combination with other prior art
`references identified in the cover pleading, herein, or in Appendix C
`of VMware’s Preliminary Invalidity Contentions. A person of
`ordinary skill in the art would have been motivated to combine Chow
`with any of the other prior art references identified in the cover
`pleading or herein with a reasonable expectation of success because
`each of these references contains familiar elements within similar
`fields of endeavor to address similar known problems, according to
`known methods which would yield predictable results.
`Chow ’175 discloses means for monitoring an amount of the service
`resource used by the network-based agent.
`
`See, e.g., citations with regard to claim 1.3 supra.
`
`See, e.g., Chow ’175 at 25:33-26:17:
`
`41
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`42
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`6.pre
`
`Claim Recitation
`6. The system of claim 1, further comprising:
`
`Exemplary Citations to Chow ’175
`Chow ’175 discloses the system of claim 1.
`
`6.1
`
`means for allowing a user to modify the
`network-based agent.
`
`See, e.g., citations with regard to claim 1 supra.
`
`To the extent it is found that Chow does not expressly disclose this
`limitation, the limitation is inherent. Moreover, to the extent it is
`found that Chow does not anticipate this claim, Chow renders it
`obvious, either alone, in combination with the knowledge of a person
`of ordinary skill in the art, and/or in combination with other prior art
`references identified in the cover pleading, herein, or in Appendix C
`of VMware’s Preliminary Invalidity Contentions. A person of
`ordinary skill in the art would have been motivated to combine Chow
`with any of the other prior art references identified in the cover
`pleading or herein with a reasonable expectation of success because
`each of these references contains familiar elements within similar
`fields of endeavor to address similar known problems, according to
`known methods which would yield predictable results.
`Chow ’175 discloses means for allowing a user to modify the
`network-based agent.
`
`See, e.g., Chow ’175 at 5:32-63:
`
`43
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 5:64-6:67:
`
`44
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`45
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`46
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See also, e.g., Chow ’175 at 9:59-10:12:
`
`47
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at Fig. 3:
`
`48
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 9:52-10:30:
`
`49
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`50
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at Fig. 5:
`
`51
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at Fig. 9:
`
`52
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 11:48-12:36:
`
`53
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`54
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`See, e.g., Chow ’175 at 20:17-47:
`
`55
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`
`To the extent it is found that Chow does not expressly disclose this
`limitation, the limitation is inherent. Moreover, to the extent it is
`found that Chow does not anticipate this claim, Chow renders it
`obvious, either alone, in combination with the knowledge of a person
`of ordinary skill in the art, and/or in combination with other prior art
`references identified in the cover pleading, herein, or in Appendix C
`
`56
`
`

`

`Intellectual Ventures I LLC, et al. v. VMware, Inc.
`Western District of Texas, No. 6:19-cv-449
`EXHIBIT C-1
`Invalidity Chart for U.S. Patent No. 7,949,752 based on U.S. Patent No. 6,029,175 (“Chow ’175”)
`
`Claim
`
`Claim Recitation
`
`Exemplary Citations to Chow ’175
`of VMware’s Preliminary Invalidity Contentions. A person of
`ordinary skill in the art would have been motivated to combine Chow
`with any of the other prior art references identified in the cover
`pleading or herein with a reasonable expectation of success because
`each of these references contains familiar elements within similar
`fields of endeavor to address similar known problems, according to
`known methods which would yield predictable results.
`
`9.pre
`
`9. A system for performing user customized
`network-based operations, comprising:
`
`Chow ’175 discloses a system for performing user customized
`network-based operations.
`
`See, e.g., citations to claim 1 supra.
`
`To the extent it is found that Chow does not expressly disclose this
`limitation, the limitation is inherent. Moreover, to the extent it is
`found that Chow does not anticipate this claim, Chow renders it
`obvious, either alone, in combination with the knowledge of a person
`of ordinary skill in the art, and/or in combination with other prior art
`references identified in the cover pleading, herein, or in Appendix C
`of VMware’s Preliminary Invalidity Contentions. A person of
`ordinary skill in the art would have been motivated to combine Chow
`with any of the other prior art references identified in the cover
`pleading or herein with a reasonable expectation of success because
`each of these references contains familiar elements within similar
`fie