Petition’s Representation of Carmel
`
`Over
`
`Petition at 14 (emphasis added).
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 1 of 21
`
`

`

`EX2013-633:13-19, 633:24-634:6 (Dr. Jeffay)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 2 of 21
`
`

`

`EX2013-641:24-642:9 (Dr. Jeffay)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 3 of 21
`
`

`

`EX2013-635:6-18 (Dr. Jeffay)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 4 of 21
`
`

`

`EX2013-636:22-637:718 (Dr. Jeffay)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 5 of 21
`
`

`

`EX2013-637:24-638:8 (Dr. Jeffay)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 6 of 21
`
`

`

`EX2013-638:9-14 (Dr. Jeffay)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 7 of 21
`
`

`

`EX2013-638:24-639:7 (Dr. Jeffay)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 8 of 21
`
`

`

`EX2013-641:1-14 (Dr. Jeffay)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 9 of 21
`
`

`

`EX2013-650:2-9 (Dr. Jeffay)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 10 of 21
`
`

`

`EX2022 at 9 (PTAB appeals ’141 Reexamination decision).
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 11 of 21
`
`

`

`Petition at 36.
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 12 of 21
`
`

`

`’824/’636 Patent (visualization of sequential individual slice requests)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 13 of 21
`
`

`

`’824/’636 Patent (individual slice requests)
`
`• Sequential numbering on the server side
`(lim. d)
`• Media player is in charge of sequencing
`(lim. j)
`• Client request, specifying serial ID(s) (lim.
`f)
`• Server responds by sending the requested
`media data elements (lim. g)
`• Client continues with additional requests
`for the duration of playback (lims. f, g, and
`k)
`• Each element transmitted as fast as the
`data connection will allow (separate
`disclosure that the connection is faster
`than the playback rate) (lims. h and i)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`EX1001-14:48-15:1 (’824 Patent).
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 14 of 21
`
`

`

`’824/’636 Patent (individual slice requests)
`
`• Client is arranged to receive and
`buffer a predetermined number of
`elements,
`• to play back the media data
`elements sequentially,
`• and, as they are played out, request
`next sequential elements to
`approximately maintain the
`predetermined number of elements
`in the buffer.
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`EX1001-15:16-25 (’824 Patent).
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 15 of 21
`
`

`

`Carmel
`
`• Carmel does not disclose any HTTP request
`that identifies any element other than the
`starting slice of the requested stream
`
`• Carmel discloses embodiments that are
`admittedly “push”
`
`• Carmel discloses no buffer management
`
`• Carmel specifically references HTTP 1.1,
`which supports the “push” streaming
`disclosed in Carmel
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 16 of 21
`
`

`

`Carmel
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 17 of 21
`
`

`

`Carmel
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 18 of 21
`
`

`

`Carmel (visualization of push from starting slice)
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 19 of 21
`
`

`

`a
`
`b
`
`c
`
`d
`
`e
`
`f
`
`g
`
`h
`
`i
`
`j
`
`k
`
`l
`
`Limitation
`
`A method for distributing over the Internet, from a server system to one or more user systems, a pre-recorded audio or
`video program stored in digitally encoded form on computer-readable media, the method comprising:
`reading, by at least one computer of the server system, the pre-recorded audio or video program from the computer-
`readable media;
`supplying, at the server system, media data elements representing the program, each media data element comprising a
`digitally encoded portion of the program and having a playback rate;
`serially identifying the media data elements, said serial identification indicating a time sequence of the media data
`elements;
`storing the media data elements in a data structure under the control of the server system;
`
`receiving requests at the server system via one or more data connections over the Internet, for one or more of the media
`data elements stored in the data structure, each received request specifying one or more serial identifiers of the requested
`one or more media data elements, each received request originating from a requesting user system of the one or more
`user systems; and
`responsive to the requests, sending, by the server system, the one or more media data elements having the one or more
`specified serial identifiers, to the requesting user systems corresponding to the requests; wherein
`the data connection between the server system and each requesting user system has a data rate more rapid than the
`playback rate of the one or more media data elements sent via that connection;
`
`each sending is at a transmission rate as fast as the data connection between the server system and each requesting user
`system allow;
`the one or more media data element sent are selected without depending on the server system maintaining a record of the
`last media data element sent to the requesting user systems;
`all of the media data elements that are sent by the server system to the one or more user systems are sent in response to
`the requests; and
`all of the media data elements that are sent by the server system to the requesting user systems are sent from the data
`structure under the control of the server system as the media data elements were first stored therein.
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`Petition:
`Carmel
`19-23
`
`Petition:
`Petition:
`Feig
`Willebeek
`Nothing Nothing
`
`23-5
`
`Nothing Nothing
`
`25-28
`
`Nothing Nothing
`
`29-30
`
`31
`
`Nothing
`
`32-33
`
`Nothing Nothing
`
`33-36
`
`36-37
`
`Nothing
`
`38-39
`
`39-40
`
`Nothing
`
`40-42
`[Fails]
`
`44-46
`
`48-50
`[Fails]
`52-53
`[Fails]
`55-58
`
`43 (also
`general
`knowled
`ge, 44)
`46
`
`Nothing
`
`46-48
`
`50-51
`
`Nothing
`
`53-54
`
`Nothing
`
`Nothing Nothing
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 20 of 21
`
`

`

`Pet.(’824
`Patent)
`31
`
`37
`
`Limitation
`
`Motivation
`
`d. serially identifying the media data
`elements, said serial identification
`indicating a time sequence of the media
`data elements
`
`“simplify the operation of the combined system by using
`serial identifiers for sequential media data elements and
`allow the client to precisely control and select which
`segments it receives from the server, which supports
`Carmel’s goal of allowing a user to ‘decide and indicate at
`which slice of data stream 40 to begin downloading.’”
`
`f. receiving requests at the server system
`via one or more data connections over the
`Internet, for one or more of the media data
`elements stored in the data structure, each
`received request specifying one or more
`serial identifiers of the requested one or
`more media data elements, each received
`request originating from a requesting user
`system of the one or more user systems
`
`“would allow the client to precisely control and select
`which segments it receives from the server, which
`supports Carmel’s goal of allowing a user to ‘decide and
`indicate at which slice of data stream 40 to begin
`downloading.’”
`
`“The combination would also expand the types of
`servers that could be used within Carmel’s system by
`inducing ‘a non-streaming server to simulate a streaming
`server.’”
`
`WAG DEMONSTRATIVE EXHIBIT – NOT EVIDENCE – IPR2022-01430, -01433
`
`WAG, Exhibit 2023
`Amazon.com, Inc. v. WAG Acquisition, LLC, IPR2022-01430
`Page 21 of 21
`
`