`
`FOR THE DISTRICT OF DELAWARE
`
`EXPRESS MOBILE, INC.,
`
`v.
`
`GODADDY.COM, LLC,
`
`Plaintiff,
`
`Defendant.
`
`Civil Action No. 19-1937-RGA
`
`OPENING EXPERT REPORT OF PHILIP GREENSPUN, PH.D.
`REGARDING INVALIDITY OF THE PATENTS-IN-SUIT
`
`i
`
`Adobe v. Express Mobile - IPR2021-01225
`PO_EM044_2013-0001
`
`
`
`respect to Stevens for example, Stevens includes additional UI objects not discussed in Huang.
`
`Incorporating this disclosure would allow for additional web services using more complex UI
`
`objects to be used using the system and methods of Huang.
`
`XIX. SUMMARY OF MY OPINIONS CONCERNING INVALIDITY OF THE
`’755/287/044 PATENTS BASED ON ANTICIPATION AND/OR OBVIOUSNESS
`
`427.
`
`The Asserted Claims of the ’755, ’287, and ’044 patents are all invalid because
`
`they are:50
`
`a. Anticipated, each independently, and/or are rendered obvious alone in
`combination with the knowledge of a POSA, by BlackBerry MDS, iWeb,
`Huang, Arner, and NexaWeb; and/or
`
`b. Obvious based on either:
`
`1. BlackBerry MDS in combination with Arner, Huang, or Stevens;
`2.
`iWeb in combination with Huang, Stevens, or Huang and Stevens;
`
`3. Huang in combination with Stevens;
`
`4. Arner in combination with Huang and Stevens; or
`
`5. NexaWeb in combination with Arner, Huang, or Stevens.
`
`428. Attached as Exhibits N-AA are charts describing in detail how each of these
`
`references discloses each and every limitation of, and/or renders obvious, the asserted claims
`
`of the ’755, ’287, and ’044 patents.
`
`XX.
`
`SECONDARY CONSIDERATIONS OF NON-OBVIOUSNESS RELATING TO
`THE ’755, ’287, AND ’044 PATENTS
`
`429. As noted above, it is my understanding that there are “secondary
`
`considerations” that should be analyzed in an obviousness analysis. I am told that these
`
`considerations include (a) whether the prior art teaches away from the claimed invention, (b)
`
`50 To the extent this list conflicts with the accompanying claim charts, the claim charts govern.
`
`180
`
`Adobe v. Express Mobile - IPR2021-01225
`PO_EM044_2013-0002
`
`
`
`praising similar systems. I am not aware of anyone copying the Express Mobile system.
`
`XXI. CONCLUSION
`
`436.
`
`For all of the reasons set forth above and in the exhibits or attachments
`
`accompanying this report, it is my opinion that the asserted claims of the ’397, ’168, ’755,
`
`’287, and ’044 patents are invalid.
`
`*
`
`*
`
`*
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed on July
`
`30, 2021 in Oshkosh, Wisconsin.
`
`Philip Greenspun, Ph.D.
`
`183
`
`Adobe v. Express Mobile - IPR2021-01225
`PO_EM044_2013-0003
`
`
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