Case 1:20-cv-00457-ADA Document 1 Filed 03/25/20 Page 1 of 70
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Intellectual Ventures II LLC,
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`Plaintiff,
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`v.
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`VMware, Inc.
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`Defendant.
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`Civil Action No. 6:20-cv-220
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`JURY TRIAL DEMANDED
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff, Intellectual Ventures II LLC (“IV”), for its complaint against defendant,
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`VMware, Inc. (“VMware”), hereby alleges as follows:
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`THE PARTIES
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`1.
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`Intellectual Ventures II LLC (“Intellectual Ventures II”) is a Delaware limited
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`liability company having its principal place of business located at 3150 139th Avenue SE, Bellevue,
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`Washington 98005.
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`2.
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`Upon information and belief, VMware is a Delaware corporation with its
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`headquarters located at 3401 Hillview Avenue, Palo Alto, California. VMware has regular and
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`established places of business in this District, including two in Austin, Texas with over 700
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`employees. VMware also has at least two other offices in Texas—one in Coppell, Texas, and the
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`other in Farmers Branch, Texas. Defendant may be served with process through its registered
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`agent, Corporation Service Company, d/b/a CSC-Lawyers Incorporating Service Company, 211
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`E. 7th Street, Ste. 620, Austin, Texas 78701-3136
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`Case 1:20-cv-00457-ADA Document 1 Filed 03/25/20 Page 2 of 70
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`This is a civil action for patent infringement under the patent laws of the United
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`3.
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`JURISDICTION
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`States, 35 U.S.C. § 271, et seq. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331
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`and 1338(a).
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`4.
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`This Court has general personal jurisdiction over VMware because VMware is
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`engaged in substantial and not isolated activity at its regular and established places of business
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`within this judicial district. This Court has specific jurisdiction over VMware because VMware
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`has committed acts of infringement giving rise to this action and has established more than
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`minimum contacts within this judicial district, such that the exercise of jurisdiction over VMware
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`in this Court would not offend traditional notions of fair play and substantial justice.
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`5.
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`Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b)-(c) and
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`1400(b) because VMware maintains regular and established places of business and has committed
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`acts of patent infringement within this judicial district.
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`FACTUAL BACKGROUND
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`6.
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`Intellectual Ventures Management, LLC (“Intellectual Ventures”) was founded in
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`2000. Since then, Intellectual Ventures has been involved in the business of inventing.
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`Intellectual Ventures fosters inventions and facilitates the filing of patent applications for those
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`inventions; collaborates with others to develop and patent inventions; and acquires and licenses
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`patents from individual inventors, universities, corporations, and other institutions. A significant
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`aspect of Intellectual Ventures’ business is managing the plaintiff in this case, Intellectual
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`Ventures II.
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`7.
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`One founder of Intellectual Ventures is Nathan Myhrvold, who worked at Microsoft
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`from 1986 until 2000 in a variety of executive positions, culminating in his appointment as the
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`company's first Chief Technology Officer (“CTO”) in 1996. While at Microsoft, Dr. Myhrvold
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`founded Microsoft Research in 1991, and was one of the world’s foremost software experts.
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`Between 1986 and 2000, Microsoft became the world’s largest technology company.
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`8.
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`Under Dr. Myhrvold’s leadership, IV acquired more than 70,000 patents covering
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`some important inventions of the Internet era. Many of these inventions coincided with Dr.
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`Myhrvold’s successful tenure at Microsoft.
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`9.
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`Two significant accomplishments of the Internet era are the related technologies of
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`cloud computing and virtualization. Cloud computing enables ubiquitous access to shared pools
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`of configurable computing system resources, such as memory, and higher-level services, such as
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`virtual desktops or applications that run on these system resources. These resources and services,
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`often collectively referred to as “the cloud,” can be rapidly provisioned with minimal management
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`effort, often over the Internet. Virtualization allows for the creation of multiple software
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`environments of dedicated resources that each simulate for its users a computing environment
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`that was traditionally physically distinct such as a server or an operating system.
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`10.
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`Three of the many beneficial consequences of cloud computing and virtualization
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`are the consolidation of server resources that businesses require to run a varied suite of software
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`applications, the increased continuity of those server resources, and the outsourcing of those
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`server resources to companies that operate large server clouds. Server resources are consolidated
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`by replacing large numbers of physically distinct computer servers with a smaller number of
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`computer servers, where each can host many virtual servers (also known as virtual machines).
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`Each virtual machine (or “VM”) can execute the functions previously delivered by an entire
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`computer server. Many VMs can run on a single physical server, which results in server
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`consolidation and promotes scalability. Increased continuity is achieved in large part by enabling
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`VMs to seamlessly move from one computer server to another computer server, for example, in
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`the event that the first server becomes overloaded. Outsourcing of server resources requires
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`technology that provides several different customers (i.e., users) access to a pool of those
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`resources across a network, while providing each of those customers fault tolerance, performance
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`and security isolation from the other customers accessing that same pool of resources.
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`11.
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`The consolidation of servers by replacing a physical server with a virtual server has
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`enabled services to migrate into giant centralized “clouds,” such as the Google or Amazon cloud,
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`and more generally allows access to shared pools of configurable computing resources and
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`services over the Internet. This enables services to be delivered to a given customer using
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`centralized servers that seem as though they were located just a few feet away from the user, even
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`if they are actually located hundreds or even thousands of miles away (hence the terms “virtual
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`service” and “virtual server”).
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`12.
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`The concept of transferring VMs, in the event of a computer server overload, to a
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`different computer server has made VMs far less prone to outages, which in turn has changed
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`how companies that provide virtualization technologies such as VMware are perceived. Such
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`virtualization technology companies were previously associated with the limited function of
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`server consolidation and thought of as relatively unreliable. With the more resilient architecture
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`afforded by VMs that can move from physical server to physical server, however, virtualization
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`companies are now also recognized as critical enablers of business continuity and availability.
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`13.
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`Outsourcing of server resources to pools of physical servers, such as those found in
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`data centers, enables large-scale and inexpensive delivery of virtual server services to a wide
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`range of customers scattered across the Internet. The availability of large-scale and inexpensive
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`virtual server services to the public at large has further enabled customers to focus less on building
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`and maintaining their own network of physical computer servers and more on running their core
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`businesses. It has also allowed small and mid-size businesses to enjoy the sorts of cutting-edge
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`computing technologies that were previously reserved for larger companies that could afford to
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`build and maintain their own sophisticated networks of physical servers.
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`14.
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`VMware provides virtualization solutions and services to its customers. VMware’s
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`product offerings include: vSphere (including vCenter Server, vMotion and ESX/ESXi
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`hypervisor), VMware’s foundational virtualization platform; Horizon/Horizon View; SD-
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`WAN/VeloCloud, VMware’s SD-WAN solution; NSX, VMware’s network virtualization
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`solution; and vSAN, VMware’s storage virtualization product. With 117 worldwide offices,
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`VMware markets and sells these solutions and services throughout the globe, including in the
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`United States and Texas.
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`THE PATENTS-IN-SUIT
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`15.
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`On May 10, 2016, the Patent and Trademark Office (PTO) issued United States
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`Patent No. 9,338,217 (“the ’217 patent”), titled METHOD AND APPARATUS FOR
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`COMPUTING WITHIN A WIDE AREA NETWORK. The ’217 patent is valid and enforceable.
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`A copy of the ’217 patent is attached as Exhibit A.
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`16.
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`The ’217 patent relates to a system, method and/or apparatus for an improved way
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`to provide remotely hosted virtual machines to users.
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`17.
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`On June 20, 2017, the PTO issued United States Patent No. 9,686,378 (“the ’378
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`patent”), titled CONTENT MANAGEMENT AND TRANSFORMATION SYSTEM FOR
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`DIGITAL CONTENT. The ’378 patent is valid and enforceable. A copy of the ’378 patent is
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`attached as Exhibit B.
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`18.
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`On July 28, 2015, the PTO issued United States Patent No. 9,092,546 (“the ’546
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`patent”), titled CONTENT MANAGEMENT AND TRANSFORMATION SYSTEM FOR
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`DIGITAL CONTENT. The ’546 patent is valid and enforceable. A copy of the ’546 patent is
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`attached as Exhibit C.
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`19.
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`On March 21, 2006, the PTO issued United States Patent No. 7,016,963 (“the ’963
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`patent”), titled CONTENT MANAGEMENT AND TRANSFORMATION SYSTEM FOR
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`DIGITAL CONTENT. The ’963 patent is valid and enforceable. A copy of the ’963 patent is
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`attached as Exhibit D.
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`20.
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`The ’546, ’378 and ’963 patents relate to systems, methods and/or apparatus for an
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`improved way to invoke and deliver server-based applications to remote client devices based on
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`unique client characteristics.
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`21.
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`On November 9, 2004, the PTO issued United States Patent No. 6,816,464 (“the
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`’464 patent”), titled METHOD, SYSTEM, AND COMPUTER PROGRAM PRODUCT FOR
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`ROUTE QUALITY CHECKING AND MANAGEMENT. The ’464 patent is valid and
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`enforceable. A copy of the ’464 patent is attached as Exhibit E.
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`22.
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`The ’464 patent relates to a system, method and/or apparatus for an improved way
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`to test candidate network routes and select a subset thereof for interconnecting gateways across a
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`wide area network (WAN).
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`23.
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`Intellectual Ventures II is the owner and assignee of all rights, title and interest in
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`and to the ’217 patent, the ’378 patent, the ’546 patent, the ’963 patent, and the ’464 patent, and
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`holds all substantial rights therein, including the rights to grant licenses, to exclude others, and to
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`enforce and recover past damages for infringement of those patents.
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`COUNT I
`(VMware’s Infringement of U.S. Patent No. 9,338,217)
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`Paragraphs 1-23 are reincorporated by reference as if fully set forth herein.
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`24.
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`25.
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`The elements claimed by the ’217 patent, taken alone or in combination, were not
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`well-understood, routine or conventional to one of ordinary skill in the art at the time of the
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`invention. Rather, the ’217 patent claims and teaches, inter alia, an improved way to provide
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`remotely hosted virtual machines to users, which was not present in the state of the art at the time
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`of the invention. The invention improved upon then existing remote computing technology by
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`providing a hosting platform capable of delivering virtual machines to remote clients over a
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`network that each appear to clients as a fully functional computer. The invention further improved
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`on prior art solutions by storing a user’s personal state on the remote hosting platform and
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`allowing migration of the virtual machine across hosts while maintaining said personal state.
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`26.
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`Instead of providing downloadable applets which had to be run on a user’s local
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`machine, or allowing limited remote control of conventional computers in a master/slave
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`configuration, the inventions of the ’217 patent allowed for delivery and use of remotely hosted
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`virtual machines via a network, which were able to maintain user personal state and migrate from
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`host to host. Thus, the resulting virtual machines were more reliable, untethered to a particular
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`host or client machine, and provided full functionality to users relative to the prior art systems
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`discussed above.
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`27.
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`The invention represented a technical solution to an unsolved technological
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`problem. The written description of the ’217 patent describes, in technical detail, each of the
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`limitations in the claims, allowing a person of skill in the art to understand what those limitations
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`cover, and therefore what was claimed, and also understand how the non-conventional and non-
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`generic ordered combination of the elements of the claims differ markedly from what had been
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`conventional or generic in the industry at the time of the inventions of the ’217 patent. More
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`specifically, the claims of the ’217 patent each recite receiving at a server from at least one
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`network accessible computer a request, the host configured to implement a network accessible
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`stored personal state which is remotely stored at a remote server and accessible via the internet,
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`the network accessible stored personal state including a network accessible stored prior state of a
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`workspace from a previously used network accessible computer, the host computer being posted
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`for collaboration. Further, the claims recite that the server determines the workspace for the at
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`least one network accessible computer from the network accessible stored personal state, loads
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`the workspace into the at least one network accessible computer, wherein the workspace includes
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`one or more windows that were open at the time of previous use, receives another request via the
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`network from the client computer to collaborate with the host computer, and facilitate the
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`collaboration of the host computer and the client computer over the network.
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`28.
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`The system covered by the asserted claims, therefore, differs markedly from the
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`conventional and generic systems in use at the time of this invention, which inter alia lacked the
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`claimed combination of network accessible computers capable of providing fully functional
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`virtual machines to remote clients. Further, the claimed inventions differ from prior art systems
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`by remotely storing a personal state allowing for failover and migration, and also facilitating
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`collaboration between the host computer and a client computer.
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`29.
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`As described above, the ’217 patent is drawn to solving a specific, technical
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`problem arising in the context of remotely hosted virtual machine delivery and operation.
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`Consistent with the problem addressed being rooted in such remotely hosted virtual computing
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`environments, the ‘217 patent’s solutions consequently are also rooted in that same technology
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`and cannot be performed with pen and paper or in the human mind.
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`30.
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`VMware has directly infringed, and continues to directly infringe, literally and/or
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`by the doctrine of equivalents, individually and/or jointly, at least claims 1, 2, 4, 7, 8, 14-17, and
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`19 of the ’217 patent by making, using, testing, selling, offering for sale and/or importing into the
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`United States products and/or services covered by one or more claims of the ’217 patent.
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`VMware’s products and/or services that infringe the ’217 patent include, but are not limited to,
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`vSphere, ESX/ESXi, Horizon/View, vCenter Server, Connection Server, vMotion and vSAN, and
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`any other VMware products and/or services, either alone or in combination, that operate in
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`substantially the same manner.
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`31.
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`Claim 14 of the ’217 patent is reproduced below:
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`14. A method comprising:
`receiving a first request over a network at a server from at least one network
`accessible computer of a plurality of network accessible computers, the host
`computer configured to:
`implement a network accessible stored personal state, wherein the network
`accessible stored personal state is remotely stored at a remote server such that the
`network accessible stored personal state is accessible via internet, which permits
`the at least one network accessible computer to operate as a host computer for a
`client computer over the internet, the network accessible stored personal state
`including a network accessible stored prior state of a workspace of a previously
`used network accessible computer, and
`post the host computer for collaboration;
`determining, by the server, the workspace for the at least one network accessible
`computer from the network accessible stored personal state;
`loading, by the server, the workspace into the at least one network accessible
`computer, wherein the workspace includes one or more windows that were open at
`a time the previously used network accessible computer was previously used;
`receiving a second request over the network at the server from the client computer to
`collaborate with the host computer; and
`facilitating by the server the collaboration of the host computer and the client
`computer over the network.
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`32.
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`As one non-limiting example, VMware Horizon as integrated with vSphere
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`practices a method of receiving a first request over a network at a server from at least one network
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`accessible computer of a plurality of network accessible computers. The vSphere back-end
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`infrastructure, such as the View Connection Server and vCenter Server facilitate the delivery of
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`virtual desktops and applications which run on ESX/ESXi servers. The ESX/ESXi hosts
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`communicate requests, over a network, to the View Connection Server and vCenter Server, as
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`seen below:
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`33.
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`VMware Horizon as integrated with vSphere includes a host computer configured
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`to implement a network accessible stored personal state, which is remotely stored at a remote
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`server such that it is accessible via the internet, which permits the at least one network accessible
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`computer to operate as a host computer for a client computer over the internet. For instance, the
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`Case 1:20-cv-00457-ADA Document 1 Filed 03/25/20 Page 11 of 70
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`ESX/ESXi hosts and virtual machines hosted thereon, can use vSAN shared storage. The shared
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`storage allows for virtual machine state information, including personalized information, to be
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`stored at the vSphere back-end and available to all ESX/ESXi hosts and virtual machines they
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`host, as seen below:
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`34.
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`The network accessible stored personal state provided by VMware Horizon as
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`integrated with vSphere further includes a network accessible stored prior state of a workspace of
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`a previously used network accessible computer. The virtual machine state information stored on
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`the vSAN shared storage reflects stored personalized setting and preferences as well as the real-
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`time state of running virtual machines, including all programs and processes running at that time,
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`as seen below:
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`35.
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`VMware Horizon as integrated with vSphere further posts the host computer for
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`collaboration, as seen below:
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`36.
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`VMware Horizon as integrated with vSphere determines, by the server, the
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`workspace for the at least one network accessible computer from the network accessible stored
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`personal state. Each time a virtual machine is instantiated on an ESX/ESXi host the vSphere
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`back-end retrieves the stored state information from vSAN storage that corresponds with the
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`particular VM end user. The same process also occurs when recovering a VM from a failed state
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`or migrating a VM from one host to another using vMotion, as seen below:
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`37.
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`VMware Horizon as integrated with vSphere loads, by the server, the workspace
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`into the at least one network accessible computer, wherein the workspace includes one or more
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`windows that were open at a time the previously used network accessible computer was
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`previously used. The vSphere back-end infrastructure, such as the View Connection Server and
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`vCenter Server load the appropriate virtual machine state files stored in the vSAN shared storage
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`onto the virtual machine instantiated on the ESX/ESXi hosts. In the case of a recovery from a
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`failed state or a migration from one host to another, the stored state information includes all
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`programs, processes and windows being used at the time of the fail or migration, as seen below:
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`38.
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`VMware Horizon as integrated with vSphere receives a second request over the
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`network at the server from the client computer to collaborate with the host computer. The vSphere
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`back-end infrastructure, such as the View Connection Server and vCenter Server facilitate
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`connection and re-connection requests by a Horizon client, including after a migration or failure
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`situation, as seen below:
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`39.
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`VMware Horizon as integrated with vSphere facilitate by the server the
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`collaboration of the host computer and the client computer over the network. The vSphere back-
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`Case 1:20-cv-00457-ADA Document 1 Filed 03/25/20 Page 16 of 70
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`end infrastructure, such as the View Connection Server and vCenter Server facilitate connection
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`and re-connection requests by a Horizon client, which instantiates or re-instantiates the virtual
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`machines, including the stored personal state information, as seen below:
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`40.
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`Additionally, VMware has been, and currently is, an active inducer of infringement
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`of the ’217 patent under 35 U.S.C. § 271(b) and contributory infringement of the ’217 patent
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`under 35 U.S.C. § 271(c) either literally and/or by the doctrine of equivalents.
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`41.
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`VMware has actively induced, and continues to actively induce, infringement of
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`the ’217 patent by intending that others use, offer for sale, or sell in the United States, products
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`and/or services covered by one or more claims of the ’217 patent, including but not limited to
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`vSphere, ESX/ESXi, Horizon/View, vCenter Server, Connection Server, vMotion and vSAN, and
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`any VMware product and/or service, alone or in combination, that operates in materially the same
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`manner. VMware provides these products and/or services to others, such as customers, resellers
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`and end-user customers, who, in turn, use, provision for use, offer for sale, or sell in the United
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`States products and/or services that directly infringe one or more claims of the ’217 patent.
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`42.
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`VMware has contributed to, and continues to contribute to, the infringement of the
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`’217 patent by others by knowingly providing products and/or services that, when installed and
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`configured result in a system as intended by VMware, directly infringes one or more claims of
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`the ’217 patent.
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`43.
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`VMware knew of the ’217 patent, or should have known of the ’217 patent, but was
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`willfully blind to its existence. Upon information and belief, VMware has had actual knowledge
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`of the ’217 patent since at least as early as the service upon VMware of this Complaint. By the
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`time of trial, VMware will have known and intended (since receiving such notice) that its
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`continued actions would infringe and actively induce and contribute to the infringement of one or
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`more claims of the ’217 patent.
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`44.
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`VMware has committed, and continues to commit, affirmative acts that cause
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`infringement of one or more claims of the ’217 patent with knowledge of the ’217 patent and
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`knowledge or willful blindness that the induced acts constitute infringement of one or more claims
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`of the ’217 patent. As an illustrative example only, VMware induces such acts of infringement
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`by its affirmative actions of intentionally providing hardware and or software components that
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`when used in their normal and customary way as desired and intended by VMware, infringe one
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`or more claims of the ’217 patent and/or by directly or indirectly providing instructions on how
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`to use its products and/or services in a manner or configuration that infringes one or more claims
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`of the ’217 patent, including those found at one or more of the following:
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`- https://docs.vmware.com/en/VMware-Horizon-7/7.1/view-71-setting-up-virtual-
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`desktops.pdf
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`- https://docs.vmware.com/en/VMware-Horizon-7/7.2/view-72-architecture-planning.pdf
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`- https://www.vmware.com/products/vsphere.html
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`- https://www.vmware.com/content/dam/digitalmarketing/vmware/en/pdf/whitepaper/vmw
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`are-vsphere-vmfs-best-practices-whitepaper.pdf
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`- https://blogs.vmware.com/virtualblocks/2015/05/29/20-common-vsan-questions/
`
`- https://techzone.vmware.com/quick-start-tutorial-series-vmware-horizon-7
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`45.
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`VMware has also committed, and continues to commit, contributory infringement
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`by, inter alia, knowingly selling products and/or services that when used cause the direct
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`infringement of one or more claims of the ’217 patent by a third party, and which have no
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`substantial non-infringing uses, or include a separate and distinct component that is especially
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`made or especially adapted for use in infringement of the ’217 patent and is not a staple article or
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`commodity of commerce suitable for substantial non-infringing use.
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`46.
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`As a result of VMware’s acts of infringement, Plaintiff has suffered and will
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`continue to suffer damages in an amount to be proved at trial.
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`Case 1:20-cv-00457-ADA Document 1 Filed 03/25/20 Page 19 of 70
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`COUNT II
`(VMWare’s Infringement of U.S. Patent No. 9,686,378)
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`Paragraphs 1-46 are reincorporated by reference as if fully set forth herein.
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`The elements claimed by the ’378 patent, taken alone or in combination, were not
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`47.
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`48.
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`well-understood, routine or conventional to one of ordinary skill in the art at the time of the
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`invention. Rather, the ’378 patent claims and teaches, inter alia, an improved way to deliver
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`components of server-based applications to remote client devices that provide interfaces to the
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`applications at the client devices based on unique client characteristics, which were not present
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`in the state of the art at the time of the invention. The invention improved upon existing server-
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`based application delivery technology by enabling the dynamic creation of customized
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`application interfaces adapted for compatibility with a variety of client platform types.
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`49.
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`Instead of storing one or more static versions of server-based applications to which
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`clients could be re-directed, the server-based applications of the present invention are customized
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`based on client variables so that components of the applications implementing interfaces are
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`delivered to a remote client in a manner optimized for that client’s specific environment. For
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`example, the present invention allows for application component(s) residing on a server to be
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`invoked and transformed into an application interface presentable to clients, where said clients
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`would otherwise be incapable of or have difficulty displaying such components. Thus, the
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`resulting server-based application delivery systems and methods enabled a more flexible and
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`dynamic approach relative to prior art systems that were limited to providing static, pre-
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`configured application content.
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`50.
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`The invention represented a technical solution to an unsolved technological
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`problem. The written description of the ’378 patent describes, in technical detail, each of the
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`limitations in the claims, allowing a person of skill in the art to understand what those limitations
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`19
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`Case 1:20-cv-00457-ADA Document 1 Filed 03/25/20 Page 20 of 70
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`cover, and therefore what was claimed, and also understand how the non-conventional and non-
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`generic ordered combination of the elements of the claims differ markedly from what had been
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`conventional or generic in the industry at the time of the inventions of the ’378 patent. More
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`specifically, the claims of the ’378 patent each recite receiving, by a server, an indication of an
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`actuation of a user interface provided on a client device, wherein the client device is associated
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`with client variables indicating an environment of the client device, and in response to receiving
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`the indication, generating an updated version of the user interface for display in the environment
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`of the client device by invoking a version of an application component that is configured for the
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`environment of the client device, wherein the invoking of the application component processes
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`the indication of the actuation, and packaging the updated version of the user interface for
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`communication to the client device. Further embodiments claimed in the ’378 patent include
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`producing interim data in response to the invocation of the application component and using the
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`interim data to create an updated version of the user interface for display in the environment of
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`the client device.
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`51.
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`The system covered by the asserted claims, therefore, differs markedly from the
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`conventional and generic systems in use at the time of this invention, which inter alia lacked the
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`claimed combination of using client variables to determine a client environment and invoking an
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`application component of a server-based application from said variables and dynamically creating
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`a customized application interface based on the client’s specific environment. Embodiments of
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`the present invention further include updating the customized application interface in response to
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`a user actuation and using interim data to create the updated interface.
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`52.
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`As described above, the ’378 patent is drawn to solving a specific, technical
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`problem arising in the context of server-based application delivery to remote clients. Consistent
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`Case 1:20-cv-00457-ADA Document 1 Filed 03/25/20 Page 21 of 70
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`with the problem addressed being rooted in such server-based application delivery, the ’378
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`patent’s solutions consequently are also rooted in that same technology and cannot be performed
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`with pen and paper or in the human mind.
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`53.
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`VMware has directly infringed, and continues to directly infringe, literally and/or
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`by the doctrine of equivalents, individually and/or jointly, at least claims 1, 3, 4, 5, 6, 9, 10, 12,
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`13, 15, 16, 17, 18, 19, 20 of the ’378 patent by making, using, testing, selling, offering for sale
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`and/or importing into the United States products and/or services covered by one or more claims
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`of the ’378 patent. VMware’s products and/or services that infringe the ’378 patent include, but
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`are not limited to, Horizon/View, Horizon Client/Horizon HTML 5 Client, vSphere, ESX/ESXi,
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`vCenter Server, Connection Server, and any other VMware products and/or services, either alone
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`or in combination, that operate in substantially the same manner.
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`54.
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`Claim 1 of the ’378 patent is reproduced below:
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`1. A method implemented by a server, the method comprising:
`receiving, by the server from a client device, an indication of an actuation of a user
`interface provided on the client device, wherein the client device is associated with
`client variables defining an environment of the client device; and
`in response to receiving the indication of the actuation:
`invoking, by the server, a version of an application component that is configured for
`the environ