UNITED STATES PATENT AND TRADEMARK OFFICE
`APPLICATION NO. FILING DATE
`90/014,759 05/28/2021
`94761 7590
`Hudnell Law Group P.C.
`800 West El Camino Real
`Suite 180
`Mountain View, CA 94040
`09/02/2022
`FIRST NAMED INVENTOR
`9697264
`UNITED STATES DEPARTMENT OF COMMERCE
`United States Patent and Trademark Office
`Address: COMMISSIONERFORPATENTS
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`www.uspto.gov
`ATTORNEY DOCKET NO.
`02198-00053
`CONFIRMATION NO.
`1873
`EXAMINER
`BONSHOCK, DENNIS G
`ART UNIT PAPER NUMBER
`3992
`MAIL DATE DELIVERY MODE
`09/02/2022 PAPER
`Please find below and/or attached an Office communication concerning this application or proceeding.
`The time period for reply, if any, is set in the attached communication.
`PTOL-90A (Rev. 04/07)
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`DO NOT USE IN PALM PRINTER
`(THIRD PARTY REQUESTER'S CORRESPONDENCE ADDRESS)
`Marissa Ducca
`Quinn Emanuel Urquhard & Sullivan, LLP
`1300 I Street, NW, 9th Floor
`Washington, DC 20005
`Commissioner for Patents
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`www.uspto.gov
`EX PARTEREEXAMINATION COMMUNICATION TRANSMITTAL FORM
`REEXAMINATION CONTROL NO. 90/014,759.
`PATENT UNDER REEXAMINATION 9697264.
`ART UNIT 3992.
`Enclosed is a copy of the latest communication from the United States Patent and Trademark
`Office in the above identified ex parte reexamination proceeding (37 CFR 1.550(f)).
`Where this copy is supplied after the reply by requester, 37 CFR 1.535, or the time for filing a
`reply has passed, no submission on behalf of the ex parte reexamination requester will be
`acknowledged or considered (37 CFR 1.550(g)).
`PTOL-465 (Rev.07-04)
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`Application/Control Number: 90/014,759
`Art Unit: 3992
`Notice of Pre-A/A or A/A Status
`The present application is being examined under the pre-AIA first to invent
`provisions.
`Ex Parte Reexamination
`Page 2
`This is a Final Office Action, responsive to the Response submitted on
`7/14/2022, affecting claims 1-18 of United States Patent Number: 9,697,264 issued to
`Dinn (hereinafter the '264 patent). The Reexamination was ordered on 7/2/2021 in
`response to the Request for ex parte reexamination filed 5/28/2021.
`On 7/28/2021 (supplemental arguments dated 10/1/2021), Patent Owner filed a
`petition under 37 C.F.R. § 1.181 requesting the Office rescind the Order on grounds of
`35 U.S.C. 325(d). This Petition has since been dismissed by the Office on 2/23/2022
`noting:
`"The present reexamination proceeding is only Samsung's second challenge to
`the same claims of the '264 patent before the Office, and the totality of the
`grounds in the Request that raise an SNQ do not present the same or
`substantially the same prior art or arguments as the grounds presented in the
`'0736 IPR, which proceeding was denied institution on the merits. The Office has
`considered all of the patent owner's arguments concerning 35 U.S.C. 325(d), and
`in view of the particular facts and circumstances in this instance, patent owner's
`July 28, 2021 petition (supplemented on October 1, 2021), requesting the Office
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`Application/Control Number: 90/014,759 Page 3
`Art Unit: 3992
`to vacate the present ex parte reexamination pursuant to 35 U.S.C. 325(d), is
`dismissed." (see the full DECISION ON PETITIONS for further explanation)
`Extensions of time under 37 CFR 1.136(a) will not be permitted in these
`proceedings because the provisions of 37 CFR 1 .136 apply only to "an applicant" and
`not to parties in a reexamination proceeding. Additionally, 35 U.S.C. 305 requires that
`ex parte reexamination proceedings "will be conducted with special dispatch" (37
`CFR 1.550(a)). Extensions of time in ex parte reexamination proceedings are provided
`for in 37 CFR 1.550(c).
`References
`• Pearlman et al., U.S. Publication No.: 2002/0113825 (hereinafter Pearlman/ Ex.
`1005)
`• Dostie et al., U.S. Publication No.: 2004/0021691 (hereinafter Dostie/ Ex. 1006)
`• Badarneh, WO 2002-091160 (hereinafter Badarneh / Ex. 1007)
`• Josenhans, U.S. Publication No.: 2002/0078013 (hereinafter Josenhans / Ex. 1008)
`• Schroeder et al., U.S. Patent No.: 5,797,098 (hereinafter Schroeder/ Ex. 1009)
`• Krohn, U.S. Patent No.: 6,593,913 (hereinafter Krohn/ Ex. 1010)
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`Application/Control Number: 90/014,759
`Art Unit: 3992
`Prosecution History
`Original Prosecution:
`Page 4
`The patent application that issued as the '264 Patent was originally filed as a
`PCT on December 28, 2007 and entered in to national stage on February 22, 2010 as
`U.S. Patent Application No. 12/448,601 (the '601 Application").
`8/27/2012-The Office issued a Non-Final Office Action rejecting Claims 1-7, 12-13,
`16-18, and 21-26 of the '601 Application under 35 U.S.C. §102 over Dinn (US
`2005/0043063), claims 3 and 20 over Dinn in view of O'Dell (US 6,801,559), Claim 8
`over Dinn in view of Boillot (US 2008/0235621 ), Claims 9 and 10 over Dinn in view of
`Alabaster (US 2003/0129570) Claims 11 and 14 over Dinn in view of Kraft et al. (US
`6,744,423), claim 15 over Din in view of Kraft in further view of Kemppinen (US
`2004/0227732), and claim 19 over Dinn and Ramer et al. (US 2007/0060114). The
`Non-Final Office Action further provisionally rejected claims 1 , 2, 12, 13, 16, and 17 on
`the ground of nonstatutory obviousness-type double patenting over claim 52, 53, and
`56-59 of co-pending US Application 13/081990 in view of Kraft et al. (US 6,744,423).
`4/5/2016 - The Patent Owner filed an amended claim set adding in claim language
`for:
`- "selecting items from at least two collections of items, said at least two collections
`of items being individually indexed by a list of respective item identifiers ... "
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`- "generating, on a device, an initial display including a plurality of parts of said item
`identifiers for selection, wherein said plurality of parts of said item identifiers
`include at least one part of said item identifier corresponding to a first collection of
`items and at least one part of said item identifier corresponding to a second
`collection of items"
`- "enabling selection of one of said plurality of parts of said item identifiers;
`identifying, based at least in part on the part of the item identifier selected, which
`of the at least two collections of items the selected part of the item
`identifier corresponds to;
`- generating, on said device, a display of a further plurality of parts of said item
`identifiers for selection in response to selection of said one or more parts, wherein
`said further plurality of parts of item identifiers include at least one further part of
`said item identifiers corresponding to the one or more collections of items
`identified based on the selection of said one or more parts;
`7/13/2016 - The Patent Owner filed a Terminal Disclaimer disclaiming the terminal
`part of the statutory term of any patent granted on the instant application which would
`extend beyond the expiration date of the fully statutory term of the prior patents:
`8,996,579, 8,676,852, 8,375,058, 8,370,393.
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`Application/Control Number: 90/014,759 Page 6
`Art Unit: 3992
`7/18/2016 - The Office issued an Examiners amendment clarifying several issues in
`the claims and a Notice of Allowance allowing claims 1, 2, and 4-19 for the reason that:
`'The prior art of record does not teach or render obvious the limitations
`"generating, on a device, an initial display including a plurality of parts of said
`item identifiers for selection, wherein said plurality of parts of said item identifiers
`include at least one part of an item identifier corresponding to a first collection of
`items and at least one part of an item identifier corresponding to a second collection
`of items; enabling selection of one of said plurality of parts of said item identifiers;
`identifying, based at least in part on the part of the item identifier selected, which of
`the at least two collections of items the selected part of the item identifier
`corresponds to; generating, on said device, a display of a further plurality of parts of
`said item identifiers for selection in response to selection of said one of said plurality
`of parts of said item identifiers, wherein said further plurality of parts of item
`identifiers include at least one further part of said item identifiers corresponding to
`the one or more collections of items identified based on the selection of said one of
`said plurality of parts of said item identifiers" in the combinations recited in claim 1.'
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`Application/Control Number: 90/014,759
`Art Unit: 3992
`inter partes Review:
`IP R2020-00736:
`Page 7
`Petitioner previously filed a petition for IPR against the 9,697,264 patent citing
`U.S. Patent Nos. 7,152,213 (Pu), 6,59,913 (Krohn), and 5,797,098 (Schroeder) as well
`as U.S. Pat. Pub. No 2002/0113825 (Perlman) and 2004/002169 (Dostie) on March 17,
`2020. On September 22, 2020, the Board denied institution. Ex. 1012
`The Board denied institution partly on their finding that neither Perlman nor Pu
`disclosed "said at least two collections of items being individually indexed." Similarly,
`the Board rejected petitioner's arguments around Krohn in combination with Dostie
`finding the combination did not sufficiently disclose "wherein generating said initial
`display comprises selecting said one or more parts of said item identifiers to be
`displayed based on a dynamic prioritization scheme that adjusts priorities of said item
`identifiers based on the number of times a particular item identifier from said list of item
`identifiers was previously selected." The Board found that this combination did not
`sufficiently explain how "the learning algorithm of Dostie ... would be combined with
`Krohn's 'populating circles' algorithm ... to determine the next set of characters to
`display" (Ex. 1012 at 35).
`Litigation History
`The '264 Patent is currently involved in the below cited litigation:
`Kannuu Pty Ltd. v. Samsung Electronics Co., Ltd., No. 1 :19-cv-4297 (S.D.N. Y)
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`Kannuu Pty Ltd. v. Samsung Electronics Co., Ltd., No. 21-1638 (US CAFC) (appeal of
`1: 19-cv-4297)
`Claim Construction
`The IPR revealed a discrepancy between the Patent Owner and the 3PR as to
`how limiting language surrounding the 'said at least two collections of items being
`individually indexed' should be. 3PR has taken the position and continues to assert that
`"the broadest reasonable interpretation of this claim neither requires separate
`databases nor separate dictionaries", where the Board found the language to be far
`more limiting.
`As an initial matter the Examiner notes that the body of the claim builds on a
`definition set forth in the preamble specifically discussing the separate collections of
`items individually.
`MPEP 2011.02:
`"If the claim preamble, when read in the context of the entire claim, recites
`limitations of the claim, or, if the claim preamble is 'necessary to give life,
`meaning, and vitality' to the claim, then the claim preamble should be construed
`as if in the balance of the claim." Pitney Bowes, Inc. v. Hewlett-Packard Co., 182
`F.3d 1298, 1305, 51 USPQ2d 1161, 1165-66 (Fed. Cir. 1999).
`I. PREAMBLE STATEMENTS LIMITING STRUCTURE
`Any terminology in the preamble that limits the structure of the claimed invention
`must be treated as a claim limitation. See, e.g., Corning Glass Works v. Sumitomo
`Elec. U.S.A., Inc., 868 F.2d 1251, 1257, 9 USPQ2d 1962, 1966 (Fed. Cir. 1989)
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`Page 9
`The Examiner further notes that the specification defines, in column 32, lines 8-
`39 and column 43, lines 22-43, searching from "multiple, simultaneous dictionaries",
`where the system provides "two partial word completion dictionaries being traversed
`simultaneously". The specification further explains 'structures' it views as a
`'dictionaries', i.e. list of media I help items (see column 43, lines 22-41 ). Given the
`claims organization and the support from the specification, the Examiner interprets the
`"individually indexed" "collections" to be separately stored data stores, where the
`specification defines these as either dictionaries or databases.
`Claim Rejections -35 USC § 103
`In the event the determination of the status of the application as subject to AIA 35
`U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any
`correction of the statutory basis for the rejection will not be considered a new ground of
`rejection if the prior art relied upon, and the rationale supporting the rejection, would be
`the same under either status.
`The following is a quotation of pre-AIA 35 U.S.C. 103(a) which forms the basis
`for all obviousness rejections set forth in this Office action:
`(a) A patent may not be obtained though the invention is not identically disclosed or described
`as set forth in section 102, if the differences between the subject matter sought to be patented
`and the prior art are such that the subject matter as a whole would have been obvious at the
`time the invention was made to a person having ordinary skill in the art to which said subject
`matter pertains. Patentability shall not be negatived by the manner in which the invention was
`made.
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`Application/Control Number: 90/014,759
`Art Unit: 3992
`Rejection 1: Perlman / Dostie / Josenhans (Krohn / Badarneh)
`Page 1 0
`Claims 1-8, 11, 12 and 15-18 are rejected under pre-AIA 35 U.S.C. 103(a) as
`being unpatentable over U.S. Publication No. 2002/0113825 to Perlman et al ("Perlman"
`/ Ex. 1005), U.S. Publication No. 2004/0021691 to Dostie et al. ("Dostie"/ Ex. 1006), and
`U.S. Publication No. 2002/0078013 to Josenhans et al. ("Josenhans" / Ex. 1008).
`With regard to claim 1, the combination teaches "two collections of items
`being individually indexed" ... where "an initial display including a plurality of
`parts of said item identifiers for selection, wherein said plurality of parts of said
`item identifiers include at least one part of an item identifier corresponding to a
`first collection of items and at least one part of an item identifier corresponding to
`a second collection of items ... "; in that Perlman teaches searching a database of
`organized entries by partial input based prediction of a user's intended search target
`(Ex. 1005, [0019] and [0025]). Perlman describes different database lists such as
`one database list as a "list of available multimedia content" accessible by
`the television/computer (Ex. 1005, [0017]) while other database lists may include
`words of messages previously transmitted to buddies (id., [0033] -[0034]) or words in
`a "built-in dictionary" that is automatically extended each time a user enters a full word
`([0035] -[0036]). Perlman further discloses, in Figures 2-8, a GUI with character­
`mapped buttons 110 in a "star" configuration corresponding to the same "star"
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`configuration on a remote control input device to a television. Id., [0014], Other
`Page 11
`configurations are also expressly disclosed. Ex. 1005, [0016]. The GUI includes an
`initial display with one or more parts of item identifiers (.e.g., the letters shown in area
`110) for selection by a user, with the list of entries continuously changing to reflect the
`user's character selections (see Ex. 1005, [0025]) .
`•••• ,?·'ii
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`FIG. 3
`Josenhans teaches a system for searching database entries where partial text entry
`reveals options from the database including adjacent entries that the user may be
`intending to enter [0035] -[0037]. Josenhans further teaches "a search table is thus set
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`up in which, for each connected database ... " "He thus has the impression that he is
`searching for the desired information in a single database. This allows the user to
`search in various databases just as simply as when searching in a single database." Ex.
`1008 at [001 0]. Accordingly, Josenhans discloses a system where various search
`terms are stored in separate databases, and further discloses that the system works so
`that a user can simply search all of the databases at once without knowing that they are
`actually using identifiers from separate databases.
`The combination further teaches enabling selection of one of said plurality of
`parts of said item identifiers; Perlman discloses H1is limitation. Ex, 1003, 9584. A user
`may select a letter from the GU! by using the character-mapped buttons of the star
`configuration of the remote control device. Ex. 1005, [0017] ("As the user selects letters
`via the displayed character-mapped buttons 110, the user's letter selections will appear
`in a text box 130, and the database list 120 will change to reflect the user's selections."),
`The combination further teaches identifying, based at least in part on the part of
`the item identifier selected, which of the at least two collections of items the
`selected part of the item identifier corresponds to; in that as the user types,
`Perlman identifies which of the at least two collections of items the selected part of the
`item identifier corresponds to and displays a new database list 120 "to reflect the user's
`selections." Ex. 1005, [0017], For example, once an initial letter is selected, all items
`matching that collection are identified and included in the new database list. Ex. 1005,
`[0017] ("Initially (i.e., before the user has selected a character), the alphanumeric
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`Art Unit: 3992
`characters mapped to the character-mapped buttons 101, 110 correspond to the most
`common first letters of words in the database list 120. Once the user selects a first
`character, a new set of characters are mapped to the character-mapped buttons
`101,110 which correspond to the most common second letters of words in the database
`list 120 which begin with the first-selected character."). In addition, Perlman discloses a
`"prioritization" scheme where a built-in dictionary is used in the word selection/linking
`process. Ex. 1005, [0033]-[0035], Perlman therefore identifies whether the selected part
`of the item identifier corresponds to a word in the built-in dictionary (one "collection") or
`has been previously transmitted to a buddy (another "collection").
`To the extent Perlman does not disclose this feature, Dostie discloses a character
`prediction process where multiple active dictionaries (or "collections") may be used and
`the system identifies which dictionary a selected part of an item identifier corresponds
`to. Ex. 1011, [0157] (multiple active dictionaries), [0167] (combining search results for
`character prediction from multiple dictionaries), [0215] (multiple active dictionaries with
`adjustable priorities). It would have been obvious to support multiple collections or
`active dictionaries in Perlman, as taught by Dostie, so that a user could search for items
`across collections, such as a song title, song artist, or song genre.
`The combination further teaches generating~ on said device) a display of a further
`plurality of parts of said item identifiers for selection in response to selection of
`said one of said plurality of parts of said Item identif!erss wherein said further
`plurality of parts of item identifiers include at least one further part of said item
`identifiers corresponding to the one or more collections of items identified based
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`on the selection of said one of said plurality of parts of said item Identifiers;
`Perlman discloses this limitation. Ex. 1003, 9588-90. !n Figures 2-8, Perlman describes
`a GU! with character-mapped buttons 1 i 0 in a "star" configuration corresponding to the
`same "star" configuration on a remote control input device to a television. Id., §[0014].
`After the user selects a letter (e.g., the character "8'), a new set of parts of item
`identifiers are automatically mapped to the character-mapped buttons ot the "star"
`configuration GUI and displayed for another user selection, as shown below.
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`1 t~~J ttfff~:j
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`The new parts of item identifiers are selected for display using a ranking scheme
`based at least in paii on the "most common" next letters in the database list matching
`the item identitiers. Ex, 1003, 9590; Ex. 1005, ,rroo17J ("Initially (i.e., before the user has
`selected a character), the alphanumeric characters mapped to the character~mapped
`buttons 101, 110 correspond to the most comrnon first letters of vvords in the database
`list 120. Once the user selects a first ci1aracter, a new set of characters are mapped to
`the character-mapped buttons 101, 110 which correspond to the most common second
`letters of words in the database list i 20 which begin with the first-selected character.'").
`The combination further teaches enabling selection of one of said further plurality
`of parts of said item identifiers in order to add to said selected one of said
`plurality of parts of said item identifiers to build a larger part or whole of said
`selected Item Identifier; Perlman discloses this lirnitation. Ex. 1003, 1591. A user may
`select a letter from the GUI by using the character-mapped buttons of the star
`configuration of the remote control device. Ex. i 005, ,[[0017] ("As the user selects
`letters via the displayed character-mapped buttons 1 i 0, the user's letter selections wi!I
`appear in a text box i 30, and the database list ·120 will change to reflect the user's
`selections.''). As shovvn above, the letter 'A' is added to 'B' to build 'BA' in Figure 4, and
`the letter 'N' is added to 'BA' to build 'BAN' in Figure 5.
`The combination further teaches wherein generating said initial display
`comprises selecting said one or more parts of said item identifiers to be
`displayed based on a dynamic prioritization scheme that adjusts priorities of
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`said item identifiers based on the number of times a particular item identifier from
`said list of item identifiers was previously selected, in that Perlman discloses the
`parts of item identifiers are selected for display based on dynamic prioritization
`schemes, including "the user's preferences for each of the multimedia selections," such
`as frequency of playback, or a combination of user preferences and "incidence of each
`of the characters." Id., [0019] (describing rankings based user preferences, such
`as frequency of playback, and rankings based on combinations of 50%
`character incidence/50% user preferences or 75% character incidence/25% user
`preferences). Accordingly, "if a user plays back a particular multimedia program more
`frequently than any other program, the characters corresponding to that program may
`be displayed, notwithstanding the fact that they are relatively uncommon." Id. In
`addition, Perlman discloses a "built-in dictionary" that is "extended each time a user
`enters a full word." Id., [0035]. Perlman therefore discloses dynamic prioritization based
`on the number of times a particular item identifier from the list of item identifiers was
`previously entered/selected. Id. ("Prioritization in the word list in this embodiment may
`be decided based on the number of words that are known to precede the dictionary
`entry, and/or based on the frequency of the dictionary entry.")
`Dostie also discloses this feature. Dostie describes assigning and adjusting the
`priorities of the active dictionaries, permitting the user to "influence when
`completion candidates from particular dictionaries will appear in the search list." Ex.
`1006, [0215]. In addition, each active dictionary in Dostie possess a "learning
`ability" whereby the dictionary is "programmed to learn to adapt the rankings of
`completion candidates within the candidate tree 21 to the preferences of the user as the
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`data entry system 26 is used over time." Id., [0208]-[0215], Each time the user selects a
`particular item identifier, "the preference values of the nodes involved are incremented,"
`causing the system to prioritize dynamically previously selected items. Id., [0209]. It
`would have been obvious to incorporate Dostie's dynamic prioritization scheme into
`Perlman so that the predicted characters were more relevant to the user, making input
`even more efficient.
`It would have been obvious to incorporate Dostie's dictionary trees (with mutually
`exclusive identifiers and subsets of identifiers) stored in memory of computing devices
`and rankings based on tree hierarchy classifications into Perlman because it was well
`known at the time of Perlman to conduct database searches using hierarchical trees like
`the ones described in Dostie. Ex. 1003, 1617. Moreover, Dostie provides express
`motivation to incorporate its candidate trees into systems like Perlman in order to
`"rapidly predict potential completion candidates" and "provide[] a mechanism for
`supporting enhanced data entry techniques such as character prediction," like the
`mechanisms described in Perlman. Ex. 1006, 1[0097].
`As explained by Dr. Forlines, "the most efficient way to identify matching prefixes
`would be to use a hierarchical search tree." Ex. 1003, 1618. This is because "a
`hierarchical search tree promotes efficient traversal forward and backward through a
`series of search candidates, which are often stored in nodes of the tree." Id. In addition,
`"the nodes of a search tree are often associated with weights, which can be used in the
`candidate ranking process." Id. Hierarchical trees also "promote simple ranking of
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`candidates stored in the tree because the number of nodes in the search path through
`the tree can simply be summed (for example, ranking of 1 per node)." Id. In fact,
`database search techniques routinely used search trees and other hierarchical
`classifications in the searching, ranking, and selection processes. Id. Moreover, as
`described above, Perlman already displays a sorted list of database items matching the
`first NV letters of the user's input. At the time of Perlman, this form of search was almost
`always performed using a hierarchical search tree. Id. Because of the well-known
`benefits of using hierarchical search trees to search a database, these trees would have
`been "a trivial and routine addition" to Perlman that would have permitted simple and
`efficient searching based on a known prefix of database entries, like the searching
`discussed in Perlman. KSR lnt'I Co. v. Teleflex Inc., 550 U.S. 398,416 (2007)
`(combination of familiar elements according to known methods is likely obvious when it
`does no more than yield predictable results). This is especially true since Perlman
`discloses "forward and backward/reverse searching capabilities" (Ex. 1005 at [0027])
`that would "likely have used hierarchical search trees as these were in standard use for
`database searching at the time to move back and forward through the tree. Ex. 1003,
`1618.
`It would have been equally obvious to incorporate Josenhans' database
`structures into Perlman and Dostie because, like Perlman, Josenhans deals with a
`system of text entry techniques, with character prediction, and a "method of searching
`for data in at least two databases." Specifically, one of ordinary skill in the art would look
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`to references such as Josenhans to determine the best way to incorporate and setup
`the databases of Perlman. Ex. 1003, 1620 (which further references 11355-356).
`With regard to claim 2, which teaches "[t]he method according to claim 1, further
`comprising: enabling selection of additional parts of said item identifiers until said item
`identifier is completed, and enabling selection of the item identifier to select the item."
`Perlman discloses this limitation. Ex. 1003, 1595. A user can continue selecting
`additional letters until the multimedia program or title is completed. Ex. 1005, 1 1 [0017],
`[0025] -[0026] (describing examples in which the user iterates the selections until "ACE
`OF BASE' or 'BANGLES' is selected using the select button).
`With regard to claim 3, which teaches "[t]he method according to claim 1, wherein
`said item identifiers includes a sequence of one or more text symbols and said plurality
`of parts of said item identifier is a subsequence of text symbols." Perlman discloses this
`limitation. Ex. 1003, 1596. As shown in the figures above, the item identifiers
`correspond to available multimedia content (artist titles or song titles), entered one text
`symbol at a time.
`With regard to claim 4, which teaches "[t]he method according to claim 3, wherein
`said item identifiers are each a text string." Perlman discloses this limitation. Ex. 1003,
`1597. As shown in the figures above, the item identifiers correspond to available
`multimedia content (artist titles or song titles), which are text strings.
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`With regard to claim 5, which teaches "[t]he method according to claim 4, wherein
`said text string is a word." Perlman discloses this limitation. Ex. 1003, 11598-99. As
`shown in the figures above, the item identifiers correspond to available multimedia
`content (artist titles or song titles), which are words.
`In addition to character item identifiers, Perlman supports groups of letters and
`"textual multi-word typing" where "the most likely series of words are provided in the
`content list 110 when the user selects a particular set of characters (e.g., based on the
`user's prior typing)." Ex. 1005, 11 [0029] (groups of letters), [0033]-[0034] (words).
`Groups of letters and sets of characters, such as the examples given in Perlman- "Ace
`of Base" and "Bangles"-include text strings and words. Id., 11 [0025]-[0026].
`With regard to claim 6, which teaches "[t]he method according to claim 5,
`wherein at least one collection of items is a collection of words from at least one
`language." Perlman discloses this limitation. Ex. 1003, 1600. Perlman discloses a "built­
`in dictionary" that can be "pre-trained" with a number of common word sequences from
`the English language. Ex. 1005, 1 [0035].
`With regard to claim 7, which teaches "[t]he method according to claim 5,
`wherein at least one collection of items is a collection of songs." Perlman discloses this
`limitation. Ex. 1003, 1601. Perlman discloses that its database list of "available
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`multimedia content" can support an "MP3 music title search" that includes is a collection
`of songs. Ex. 1005, 1 [0017], Fig. 8.
`With regard to claim 8, which teaches "[t]he method according to claim 5,
`wherein at least one collection of items is a collection of contacts." Perlman in view of
`Dostie renders this claim obvious. Ex. 1003, 1602. Dostie explains that "the data entry
`system 26 is able to use multiple character sequences (such as a phrase) to locate
`phrases, names, addresses and the like stored in the dictionary 20." Ex. 1006, 1 [0203].
`Dostie also discloses that its dictionary is split into two sides-a completion candidate
`side and a corresponding "object side" that stores "objects such as names, addresses,
`phone numbers, and other information associated with the completion candidate." Id., 1
`1 [0234]-[0235]. The "names, addresses, phone nu