`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`
`
`ADOBE INC.,
`Petitioner
`
`v.
`
`EXPRESS MOBILE, INC.,
`Patent Owner.
`
`
`_______________
`
`Case IPR2021-01225
`Patent No. 9,928,044
`_______________
`
`
`DECLARATION OF KEVIN C. ALMEROTH, PH.D.
`
`
`
`
`
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`Adobe v. Express Mobile - IPR2021-01225
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`
`TABLE OF CONTENTS
`
`
`INTRODUCTION AND BACKGROUND .................................................... 1
`I.
`QUALIFICATIONS ........................................................................................ 2
`II.
`III. MATERIALS CONSIDERED ...................................................................... 13
`IV. PERSON OF ORDINARY SKILL IN THE ART (“POSA”) ....................... 13
`V.
`BACKGROUND OF THE ’755 PATENT ................................................... 15
`A.
`Technology Background ..................................................................... 15
`B.
`Brief Summary of the ’755 Patent ...................................................... 16
`VI. SUMMARY OF THE ASSERTED REFERENCES .................................... 17
`A. U.S. Patent Pub. No. 2007/0118844 (“Huang”) ................................. 17
`B.
`U.S. Patent Pub. No. 2007/0067421 (“Angelov”) .............................. 19
`VII. DETAILED ANALYSIS OF CLAIM 1 ........................................................ 21
`A. Huang and Angelov fail to disclose or render obvious “the
`device provides the user provided one or more input values and
`corresponding input symbolic name to the web service.” .................. 23
`Huang and Angelov fail to disclose or render obvious “the web
`service utilizes the input symbolic name and the user provided
`one or more input values.” .................................................................. 30
`Huang and Angelov fail to disclose or render obvious “said
`Player receives the output symbolic name.” ....................................... 33
`D. Huang and Angelov fail to disclose or render obvious “an
`authoring tool configured to . . . produce a Player.” ........................... 33
`VIII. ANALYSIS OF DEPENDENT CLAIMS 2, 7, and 11 ................................. 40
`IX. LEGAL STANDARDS ................................................................................. 41
`X. ADDITIONAL REMARKS .......................................................................... 44
`
`B.
`
`C.
`
`i
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`I.
`
`INTRODUCTION AND BACKGROUND
`I have been retained as an expert witness by Express Mobile, Inc.
`1.
`
`(“Express Mobile”) and have been asked to provide my expert opinions regarding
`
`U.S. Patent No. 9,928,044 (“the ’044 patent,” Ex. 1001).
`
`2.
`
`In this declaration I provide my independent analysis of the ’044 patent
`
`in light of the materials cited below and my knowledge and experience in this field
`
`during the relevant time frame. I have been asked to consider what one of ordinary
`
`skill in the art at the time of the invention of the ’044 patent (a “POSA”; refer to IV
`
`below) would have understood from the specification, including scientific and
`
`technical knowledge related to the patent. I have also been asked to consider whether
`
`certain references disclose or render obvious the invention described by claims 1, 3,
`
`5-6, 11, 13, 15, 17, 19-20, 25, and 27 of the ’044 patent.
`
`3. My findings, as explained below, are based on my study, experience,
`
`and background in the fields discussed below, informed by my education in
`
`computer science and web-based design, and my extensive experience in the fields
`
`of browser-based user interfaces and network services. I have also relied on my
`
`review and analysis of the cited references, information provided to me, and
`
`information that I have independently reviewed.
`
`4.
`
`I am being compensated for my independent analysis as an expert with
`
`respect to this inter partes review proceeding, but my compensation is not contingent
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`in any way on the content of my analysis or the outcome of this proceeding. I have
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`no financial interest in Petitioner (Adobe) and I have no financial interest in the
`
`challenged patent.
`
`II. QUALIFICATIONS
`I am currently a Professor Emeritus in the Department of Computer
`5.
`
`Science at the University of California, Santa Barbara (UCSB). While active at
`
`UCSB, I held faculty appointments and was a founding member of the Computer
`
`Engineering (CE) Program, Media Arts and Technology (MAT) Program, and the
`
`Technology Management Program (TMP). I also served as the Associate Director
`
`of the Center for Information Technology and Society (CITS) from 1999 to 2012. I
`
`have been a faculty member at UCSB since July 1997.
`
`6.
`
`I hold three degrees from the Georgia Institute of Technology: (1) a
`
`Bachelor of Science degree in Information and Computer Science (with minors in
`
`Economics, Technical Communication, and American Literature) earned in June
`
`1992; (2) a Master of Science degree in Computer Science (with specialization in
`
`Networking and Systems) earned in June 1994; and (3) a Doctor of Philosophy
`
`(Ph.D.) degree in Computer Science (Dissertation Title: Networking and System
`
`Support for the Efficient, Scalable Delivery of Services in Interactive Multimedia
`
`System, minor in Telecommunications Public Policy) earned in June 1997. During
`
`my education, I have taken a wide variety of courses as demonstrated by my minor.
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`My undergraduate degree also included a number of courses more typical of a degree
`
`in electrical engineering
`
`including digital
`
`logic, signal processing, and
`
`telecommunications theory.
`
`7.
`
`One of the major concentrations of my research over the past 30+ years
`
`has been the delivery of multimedia content and data between computing devices,
`
`including various network architectures. In my research, I have studied large-scale
`
`content delivery systems, and the use of servers located in a variety of geographic
`
`locations to provide scalable delivery to hundreds or thousands of users
`
`simultaneously. I have also studied smaller-scale content delivery systems in which
`
`content is exchanged between individual computers and portable devices. My work
`
`has emphasized the exchange of content more efficiently across computer networks,
`
`including the scalable delivery of content to many users, mobile computing, satellite
`
`networking, delivering content to mobile devices, and network support for data
`
`delivery in wireless networks.
`
`8.
`
`In 1992, the initial focus of my research was on the provision of
`
`interactive functions (e.g., VCR-style functions like pause, rewind, and fast-forward)
`
`for near video-on-demand systems in cable systems; in particular, how to aggregate
`
`requests for movies at a cable head-end and then how to satisfy a multitude of
`
`requests using one audio/video stream broadcast
`
`to multiple
`
`receivers
`
`simultaneously. This research has continually evolved and resulted in the
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`development of techniques to scalably deliver on-demand content, including audio,
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`video, web documents, and other types of data, through the Internet and over other
`
`types of networks, including over cable systems, broadband telephone lines, and
`
`satellite links.
`
`9.
`
`An important component of my research has been investigating the
`
`challenges of communicating multimedia content, including video, between
`
`computers and across networks including the Internet. Although the early Internet
`
`was used mostly for text-based, non-real time applications, the interest in sharing
`
`multimedia content, such as video, quickly developed. Multimedia-based
`
`applications ranged from downloading content to a device to streaming multimedia
`
`content to be instantly used. One of the challenges was that multimedia content is
`
`typically larger than text-only content, but there are also opportunities to use
`
`different delivery techniques since multimedia content is more resilient to errors. I
`
`have worked on a variety of research problems and used a number of systems that
`
`were developed to deliver multimedia content to users. One content-delivery method
`
`I have researched is the one-to-many communication facility called “multicast,” first
`
`deployed as the Multicast Backbone, a virtual overlay network supporting one-to-
`
`many communication. Multicast is one technique that can be used on the Internet to
`
`provide streaming media support for complex applications like video-on-demand,
`
`distance learning, distributed collaboration, distributed games, and large-scale
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`wireless communication. The delivery of media through multicast often involves
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`using Internet infrastructure, devices and protocols, including protocols for routing
`
`and TCP/IP.
`
`10. Starting in 1997, I worked on a project to integrate the streaming media
`
`capabilities of the Internet together with the interactivity of the web. I developed a
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`project called the Interactive Multimedia Jukebox (IMJ). Users would visit a web
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`page and select content to view. The content would then be scheduled on one of a
`
`number of channels, including delivery to students in Georgia Tech dorms delivered
`
`via the campus cable plant. The content of each channel was delivered using
`
`multicast communication.
`
`11.
`
`In the IMJ, the number of channels varied depending on the capabilities
`
`of the server including the available bandwidth of its connection to the Internet. If
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`one of the channels was idle, the requesting user would be able to watch their
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`selection immediately. If all channels were streaming previously selected content,
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`the user's selection would be queued on the channel with the shortest wait time. In
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`the meantime, the user would see what content was currently playing on other
`
`channels, and because of the use of multicast, would be able to join one of the
`
`existing channels and watch the content at the point it was currently being
`
`transmitted.
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`12. The IMJ service combined the interactivity of the web with the
`
`streaming capabilities of the Internet to create a jukebox-like service. It supported
`
`true Video-on-Demand when capacity allowed, but scaled to any number of users
`
`based on queuing requested programs. As part of the project, we obtained permission
`
`from Turner Broadcasting to transmit cartoons and other short-subject content. We
`
`also connected the IMJ into the Georgia Tech campus cable television network so
`
`that students in their dorms could use the web to request content and then view that
`
`content on one of the campus's public access channels.
`
`13. More recently, I have also studied issues concerning how users choose
`
`content, especially when considering the price of that content. My research has
`
`examined how dynamic content pricing can be used to control system load. By
`
`raising prices when systems start to become overloaded (i.e., when all available
`
`resources are fully utilized) and reducing prices when system capacity is readily
`
`available, users’ capacity to pay as well as their willingness can be used as factors
`
`in stabilizing the response time of a system. This capability is particularly useful in
`
`systems where content is downloaded or streamed on-demand to users.
`
`14. As a parallel research theme, starting in 1997, I began researching
`
`issues related to wireless devices and sensors. In particular, I was interested in
`
`showing how to provide greater communication capability to “lightweight devices,”
`
`i.e., small form-factor, resource-constrained (e.g., CPU, memory, networking, and
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`power) devices. Starting in 1998, I published several papers on my work to develop
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`a flexible, lightweight, battery-aware network protocol stack. The lightweight
`
`protocols we envisioned were similar in nature to protocols like Bluetooth, Universal
`
`Plug and Play (UPnP) and Digital Living Network Alliance (DLNA).
`
`15. From this initial work, I have made wireless networking-including ad
`
`hoc, mesh networks and wireless devices-one of the major themes of my research.
`
`My work in wireless network spans the protocol stack from applications through to
`
`the encoding and exchange of data at the data link and physical layers.
`
`16. At the application layer, even before the large-scale “app stores” were
`
`available, my research looked at building, installing, and using apps for a variety of
`
`purposes, from network monitoring to support for traditional computer-based
`
`applications (e.g., content retrieval) to new applications enabled by ubiquitous,
`
`mobile devices. For example, my research has looked at developing applications for
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`virally exchanging and tracking “coupons” through “opportunistic contact” (i.e.,
`
`communication with other devices coming into communication range with a user).
`
`In many of the courses I have taught there is a project component. Through these
`
`projects I have supervised numerous efforts to develop new “apps” for download
`
`and use across a variety of mobile platforms.
`
`17. Toward the middle of the protocol stack, my research also looked to
`
`build wireless infrastructure support to enable communication among a set of mobile
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`devices unaided by any other kind of network infrastructure. These kinds of
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`networks are useful either in challenged network environments (e.g., when a natural
`
`disaster has destroyed existing infrastructure) or when suitable support for network
`
`communication never existed. The deployment of such networks (or even the use of
`
`traditional network support) are critical to support services like disaster relief,
`
`catastrophic event coordination, and emergency services deployment.
`
`18. Yet another theme is monitoring wireless networks, in particular
`
`different variants of IEEE 802.11 compliant networks, to (1) understand the
`
`operation of the various protocols used in real-world deployments, (2) use these
`
`measurements to characterize use of the networks and identify protocol limitations
`
`and weaknesses, and (3) propose and evaluate solutions to these problems. I have
`
`successfully used monitoring techniques to study wireless data link layer protocol
`
`operation and to improve performance by enhancing the operation of such protocols.
`
`For wireless protocols, this research includes functions like network acquisition and
`
`channel bonding.
`
`19. Protecting networks, including their operation and content, has been an
`
`underlying theme of my research almost since the beginning of my research career.
`
`Starting in 2000, I have been involved in several projects that specifically address
`
`security, network protection, and firewalls. After significant background work, a
`
`team on which I was a member successfully submitted a $4.3M grant proposal to the
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`Army Research Office (ARO) at the Department of Defense to propose and develop
`
`a high-speed intrusion detection system. Key aspects of the system included
`
`associating streams of packets and analyzing them for viruses and other malware.
`
`Once the grant was awarded, we spent several years developing and meeting the
`
`milestones of the project. A number of my students worked on related projects and
`
`published papers on topics ranging from intrusion detection to developing advanced
`
`techniques to be incorporated into firewalls. I have also used firewalls, including
`
`their associated malware detection features, in developing techniques for the
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`classroom to ensure that students are not distracted by online content.
`
`20. Recent work ties some of the various threads of my past research
`
`together. I have investigated content delivery in online social networks and
`
`proposed reputation management systems in large-scale social networks and
`
`marketplaces. On the content delivery side, I have looked at issues of caching and
`
`cache placement, especially when content being shared and the cache has
`
`geographical relevance. We were able to show that effective caching strategies can
`
`greatly improve performance and reduce deployment costs. Our work on reputation
`
`systems showed that reputations have economic value, and as such, creates a
`
`motivation to manipulate reputations. In response, we developed a variety of
`
`solutions to protect the integrity of reputations in online social networks. The
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`techniques we developed for content delivery and reputation management were
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`particularly relevant in peer-to-peer communication and recommendations for
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`downloadable "apps."
`
`21. As an important component of my research program, I have been
`
`involved in the development of academic research into available technology in the
`
`marketplace. One aspect of this work is my involvement in the Internet Engineering
`
`Task Force (IETF). The IETF is a large and open international community of
`
`network designers, operators, vendors, and researchers concerned with the evolution
`
`of the Internet architecture and the smooth operation of the Internet. I have been
`
`involved in various IETF groups including many content delivery-related working
`
`groups like the Audio Video Transport (AVT) group, the MBone Deployment
`
`(MBONED) group, Source Specific Multicast (SSM) group, the Inter-Domain
`
`Multicast Routing (IDMR) group, the Reliable Multicast Transport (RMT) group,
`
`the Protocol Independent Multicast (PIM) group, etc. I have also served as a member
`
`of the Multicast Directorate (MADDOGS), which oversaw the standardization of all
`
`things related to multicast in the IETF. Finally, I was the Chair of the Internet2
`
`Multicast Working Group for seven years.
`
`22. My involvement in the research community extends to leadership
`
`positions for several academic journals and conferences. I am the co-chair of the
`
`Steering Committee for the ACM Network and System Support for Digital Audio
`
`and Video (NOSSDAV) workshop and on the Steering Committees for the
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`International Conference on Network Protocols (ICNP), ACM Sigcomm Workshop
`
`on Challenged Networks (CHANTS), and IEEE Global Internet (GI) Symposium. I
`
`have served or am serving on the Editorial Boards of IEEE/ACM Transactions on
`
`Networking, IEEE Transactions on Mobile Computing, IEEE Network, ACM
`
`Computers in Entertainment, AACE Journal of Interactive Learning Research
`
`(JILR), and ACM Computer Communications Review. I have co-chaired a number
`
`of conferences and workshops including the IEEE International Conference on
`
`Network Protocols (ICNP), IEEE Conference on Sensor, Mesh and Ad Hoc
`
`Communications and Networks
`
`(SECON),
`
`International Conference on
`
`Communication Systems and Networks (COMSNETS), IFIP/IEEE International
`
`Conference on Management of Multimedia Networks and Services (MMNS), the
`
`International Workshop On Wireless Network Measurement (WiNMee), ACM
`
`Sigcomm Workshop on Challenged Networks (CHANTS), the Network Group
`
`Communication (NGC) workshop, and the Global Internet Symposium, and I have
`
`served on the program committees for numerous conferences.
`
`23. Furthermore, in the courses I taught at UCSB, a significant portion of
`
`my curriculum covered aspects of the Internet and network communication
`
`including the physical and data link layers of the Open System Interconnect (OSI)
`
`protocol stack, and standardized protocols for communicating across a variety of
`
`physical media such as cable systems, telephone lines, wireless, and high-speed
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`Local Area Networks (LANs). The courses I have taught also cover most major
`
`topics in Internet communication, including data communication, multimedia
`
`encoding, and mobile application design. My research and courses have covered a
`
`range of physical infrastructures for delivering content over networks, including
`
`cable, Integrated Services Digital Network (ISDN), Ethernet, Asynchronous
`
`Transfer Mode (ATM), fiber, and Digital Subscriber Line (DSL). For a complete list
`
`of courses I have taught, see Ex. 2004, which is my curriculum vitae (CV).
`
`24.
`
`In addition, I co-founded a technology company called Santa Barbara
`
`Labs that was working under a sub-contract from the U.S. Air Force to develop very
`
`accurate emulation systems for the military's next generation internetwork. Santa
`
`Barbara Labs' focus was in developing an emulation platform to test the performance
`
`characteristics of the network architecture in the variety of environments in which it
`
`was expected to operate, and, in particular, for network services including IPv6,
`
`multicast, Quality of Service (QoS), satellite-based communication, and security.
`
`Applications for this emulation program included communication of a variety of
`
`multimedia-based services, including video conferencing and video-on-demand.
`
`25.
`
`In addition to having co-founded a technology company myself, I have
`
`worked for, consulted with, and collaborated with companies for nearly 30 years.
`
`These companies range from well-established companies to start-ups and include
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`IBM, Hitachi Telecom, Turner Broadcasting System (TBS), Bell South, Digital
`
`Fountain, RealNetworks, Intel Research, Cisco Systems, and Lockheed Martin.
`
`26.
`
`I am a Member of the Association of Computing Machinery (ACM)
`
`and a Fellow of the Institute of Electrical and Electronics Engineers (IEEE).
`
`27. Additional details about my employment history, fields of expertise,
`
`and publications are further included in my current curriculum vitae (Ex. 2004).
`
`III. MATERIALS CONSIDERED
`In forming my opinions expressed herein, I have reviewed, without
`28.
`
`limitation: all materials cited and referenced herein and all materials cited and
`
`referenced in the petition, including exhibits thereto. I have considered the claims,
`
`specification, and prosecution history of the ’044 patent. I have also considered the
`
`materials submitted to the PTAB by both parties in connection with IPR2021-00709,
`
`IPR2021-00710, IPR2021-00711 (the “Google IPRs”), which related to the ’755
`
`patent family, and the October 4, 2021 decisions by the PTAB denying institution of
`
`each of the three Google IPRs. As part of my analysis for this Declaration, I have
`
`considered my own knowledge and experience, including my work and experience
`
`with web-based user interfaces, Web site design, and programming.
`
`IV. PERSON OF ORDINARY SKILL IN THE ART (“POSA”)
`I understand that the teaching of the prior art is viewed through the eyes
`29.
`
`of a POSA. Counsel for Express Mobile has informed me that a person of ordinary
`
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`skill in the art is a hypothetical person who is presumed to have known the relevant
`
`art at the time of the invention. In my opinion, the relevant field of art for the ’044
`
`patent is that of software development and web design and development. I have also
`
`been informed by counsel for Express Mobile that the person of ordinary skill is
`
`generally familiar with the type of problems encountered in the field and the prior
`
`art solutions to those problems and possesses an ordinary level of creativity.
`
`30. For the purpose of this Declaration, counsel for Express Mobile has
`
`instructed me to assume that, for the ’044 patent, the time of the invention is in the
`
`2008 timeframe, and specifically November 11, 2008, which is the filing date of
`
`U.S. Provisional Application No. 61/113,471 identified in the ’044 patent. However,
`
`I understand that the conception dates of the inventions disclosed may have been
`
`earlier than those dates. For example, counsel informed me that the ’044 patent
`
`family may have a conception date of at least as early as January 12, 2008. Any such
`
`earlier conception date does not alter my opinion regarding a person of ordinary skill
`
`in the art.
`
`31.
`
`In my opinion, a person of ordinary skill in the art of the ’044 patent
`
`would include someone who had a bachelors or graduate degree in computer science,
`
`mathematics, engineering, or a similar discipline together with knowledge of
`
`software development and web design and development,
`
`together with
`
`approximately two or three years of experience in the field relating to web design
`
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`and development. The required levels of educational and industry experience are on
`
`a sliding scale relative to each other. For example, a person of ordinary skill could
`
`potentially have no educational degree but more industry experience or, conversely,
`
`could have something higher than an undergraduate degree with fewer years of
`
`industry experience. In the relevant time frame, I qualified as a person of ordinary
`
`skill in the art.
`
`V. BACKGROUND OF THE ’044 PATENT
`A. Technology Background
`32. Although I will discuss further details of the ’044 patent below, I
`
`provide here some background information regarding technologies relevant to the
`
`inventions claimed in the ’044 patent.
`
`33. The ’044 patent is within a family of patents (the “Web Component
`
`Patents”) that arose from a recognition that “[i]nternet-connected mobile devices
`
`[were] becoming ever more popular,” but that many mobile devices “d[id] not have
`
`the capabilities of non-mobile devices including computing, input and output
`
`capabilities” with web services available on the Internet. ’044 Patent at 1:14-17.
`
`Before the invention of the Web Component Patents, accessing web services from a
`
`web page or a web application required manually coding the following data flow:
`
`receiving and parsing user inputs to a web page, connecting to a web service, sending
`
`user inputs to the remote web service, receiving and parsing outputs from the web
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`services, and generating HTML code to display the outputs. The Web Component
`
`Patents addressed this problem.
`
`34. The Web Component Patents also note that with the ubiquity of the
`
`Internet comes a wide range of devices: “[t]he mobility of the user while using . . .
`
`devices provides challenges and opportunities for the user of the Internet.” ’044
`
`Patent at 1:18-20. For example, “there are a large number of types of devices and
`
`they tend to have a shorter lifetime in the marketplace,” and “[t]he programming of
`
`the myriad of mobile devices is a time-consuming and expensive proposition.” ’044
`
`Patent at 1:20-25. For this reason, there was “a need in the art for a method and
`
`apparatus that permits for the efficient programming of mobile devices,” which
`
`“should be easy to use and provide output for a variety of devices.” ’044 Patent at
`
`1:26-29. The Web Component Patents, including the ’044 patent, address these
`
`needs by providing an efficient way of generating code that can be used to allow a
`
`device to interact with web services.
`
`Brief Summary of the ’044 Patent
`B.
`35. The ’044 patent relates to an architecture that allows for the display of
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`web service content on a device platform. In some embodiments, “[t]he system
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`includes a database of web services obtainable over a network and an authoring tool.
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`The authoring tool is configured to define an object for presentation on the display,
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`select a component of a web service included in said database, associated said object
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`with said selected component, and produce code that when executed on the platform,
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`provides said selected component on the display of the platform.” ’044 Patent at
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`1:34-42. In other embodiments, the claims recite a method that performs similar
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`functionality. Id. at 1:51-58. Within the claimed architecture, the invention includes
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`the use of symbolic names that are used to associate inputs and outputs of web
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`services with objects on a display. Id. at 38:28-40 (claim 1). And the invention
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`includes software code, including an application and a player, wherein the
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`application is a device independent code that may be interpreted by the player. Id.
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`at 2:1-3. Unique to the ’044 patent claims, moreover, is a database that stores UI
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`object settings that are utilized by the Player to display web page elements. Id. at
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`38:15-24 (claim 1).
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`VI. SUMMARY OF THE ASSERTED REFERENCES
`A. U.S. Patent Pub. No. 2007/0118844 (“Huang”)
`I have reviewed Ex. 1005, which is U.S. Patent Pub. No. 2007/0118844
`36.
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`by Huang et al. I refer to Ex. 1005 herein as “Huang.” Huang discloses using an
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`intermediary web server to communicate information between a device and a web
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`service. Huang’s “goal is to access databases and/or business logic of organizations
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`via web services” and to do so in a “vendor-independent” manner. Huang at ¶¶ 007,
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`057, 075. As Huang explains, “[o]ne approach to invoking the web service object
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`would be to call vendor-specific objects directly from applications.” Huang at ¶ 074.
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`However, Huang provides that this approach—a device directly communicating with
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`a web service—should be avoided because “[t]hat approach requires the application
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`to know details about each vendor specific object, and ties the application to a
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`particular web services vendor.” Id. Instead, Huang proposes a system that relies on
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`a Generic Web Service Model (also referred to as a Generic WS Object or a
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`WSObject) and a Web Service Factory Application Programming Interface. See id.
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`at ¶¶ 044, 74. Specifically, in Huang’s system, “[a]pplications interact with the
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`generic web services object and need not contain hard-coded dependencies on
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`vendor specific objects [i.e., objects of the web service].” Id. at ¶ 74. Rather than
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`having a device interact directly with a web service, Huang discloses using a
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`WSObjectMapping, “which maps, i.e., converts the Generic WS Object Model 130
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`(WSObject) to vendor-specific Application Programming Interfaces.” Id. at ¶ 044.
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`Huang’s use of the intermediary, including its WSObjectMapping, is illustrated in
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`Figure 1A, below (annotated).
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`Id. at Fig. 1A (annotated). As shown and described, Huang’s intermediary
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`Application Server 120 (annotated in red) allows the application and player
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`(annotated in blue) to know no details about each vendor specific object (annotated
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`in green). Id. at ¶ 74. Instead, the intermediary server receives generic requests from
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`the application and player and converts the requests into queries specific to a web
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`service. See, e.g., id. at ¶¶ 044, 074. Then the intermediary, alone, interacts with the
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`web service. Id. at ¶ 124. Huang’s web service implementation uses the intermediary
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`server to display web services in a browser. Id. at ¶¶ 41-42 & FIG. 1A.
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`B. U.S. Patent Pub. No. 2006/0200749 (“Shenfield”)
`I have reviewed Ex. 1007, which is U.S. Patent Pub. No. 2006/0200749
`37.
`
`by Shenfield. I refer to Ex. 1007 herein as “Shenfield.” I have also reviewed the
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`petition and Dr. Cullimore’s declaration in support thereof, and I note that Petitioner
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`primarily relies on Huang for purportedly disclosing almost all claim elements of
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`claim 1 of the ’044 patent, including the claim elements I discuss in this declaration.
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`38. To the extent that Petitioner relies on Shenfield, I note that Shenfield is
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`directed toward a “Web Application” converter that “convert[s] a page-based
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`application to a component based application for execution on a device.” Shenfield
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`at Abstract. As Shenfield notes, the conversion was designed to move away from
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`the disadvantage of page-based applications on web browsers, which “ha[d] a
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`disadvantage of requesting pages (screen definitions in HTML) from the Web
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`Service, which hinders the persistence of data contained in the screens