Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,725,836

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Analysis of Infringement of U.S. Patent No. 7,725,836 by Microchip Technology Incorporated

Plaintiffs Caddo Systems, Inc. and 511 Technologies, Inc. (“Caddo”), provide this final and exemplary infringement analysis 

with respect infringement of U.S. Patent No. 7,725,836 entitled “ACTIVE PATH NAVIGATION SYSTEM” (the “’836 patent”) by 

Microchip Technology Incorporated (“Microchip”). The following chart illustrates an exemplary analysis regarding infringement by 

Microchip’s products and services (“’836 Accused Instrumentalities”):

(i) web pages and content, including user interfaces such as a hierarchical information structure, to be interactively presented 

in browsers, including, without limitation, the web pages and content accessible via https://www.microchip.com/ (as shown 

below) including https://www.microchipdirect.com/ and maintained on servers located in and/or accessible from the United 

States under the control of Defendant that allow navigating within a multi-level hierarchical information structure where 

each level in the menu contains plural items, each said item being at least one of a function, a pointer to a location, and a

pointer to another level; 

(ii) software, including, without limitation, software that allows web pages and content to be interactively presented in and/or 

served to browsers to facilitate navigating within a multi-level hierarchical information structure where each level in the 

menu contains plural items, each said item being at least one of a function, a pointer to a location, and a pointer to another 

level; and

(iii) computer equipment, including, without limitation, computer equipment that stores, serves, hosts, supports, and/or runs any 

of the foregoing or that allows navigating within a multi-level hierarchical information structure where each level in the 

menu contains plural items, each said item being at least one of a function, a pointer to a location, and a pointer to another 

level, and any products, devices, systems, and/or components of systems with the same or substantially the same technical 

features and/or functionalities.

 

The analysis set forth below is based largely upon information from publicly available resources regarding the Accused 

Instrumentalities and Microchip’s limited discovery production, as discovery in this matter has not yet been completed. 

Unless otherwise noted, Caddo contends that Microchip directly infringes the ’836 patent in violation of 35 U.S.C. § 271(a) by 

making, using, and/or selling, and/or offering to sell in the United States, and/or importing into the United States, without authority or 

license, the Accused Instrumentalities. The following exemplary analysis demonstrates that infringement. Unless otherwise noted, 

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Caddo further contends that the evidence below supports a finding of indirect infringement under 35 U.S.C. § 271(b) and 35 U.S.C. § 

271(c) in conjunction with other evidence of liability.

Unless otherwise noted, Caddo believes and contends that each element of each claim asserted herein is literally met through 

Microchip’s provision or importation of the Accused Instrumentalities. However, to the extent that Microchip attempts to allege that 

any asserted claim element is not literally met, Caddo believes and contends that such elements are met under the doctrine of

equivalents. More specifically, in its investigation and analysis of the Accused Instrumentalities, Caddo did not identify any 

substantial differences between the elements of the patent claims and the corresponding features of the Accused Instrumentalities, as 

set forth herein. In each instance, the identified feature of the Accused Instrumentalities performs at least substantially the same 

function in substantially the same way to achieve substantially the same result as the corresponding claim element.

Caddo reserves the right to supplement and/or amend the positions taken in this infringement analysis, including with respect

to literal infringement and infringement under the doctrine of equivalents, if and when warranted by further information obtained by 

Caddo, including but not limited to information adduced through information exchanges between the parties, fact discovery, expert 

discovery, and/or further analysis. 

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U.S. Patent 

No. 

7,725,836

Claims

Infringement by the Microchip ’836 Accused Instrumentalities

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1. A method 

for navigating 

within a 

multi-level 

hierarchical 

information 

structure 

where each 

level in the 

menu 

contains 

plural items, 

each said item 

being at least 

one of a 

function, a 

pointer to a 

location, and 

a pointer to 

another level, 

said method 

comprising 

the steps of:

The ’836 Accused Instrumentalities (“Accused Instrumentalities”) include:

(iv) web pages and content, including user interfaces such as a hierarchical information structure, to be interactively 

presented in browsers, including, without limitation, the web pages and content accessible via 

https://www.microchip.com/ and maintained on servers located in and/or accessible from the United States under the 

control of Defendant that allow navigating within a multi-level hierarchical information structure where each level in 

the menu contains plural items, each said item being at least one of a function, a pointer to a location, and a pointer to 

another level; 

(v) software, including, without limitation, software that allows web pages and content to be interactively presented in 

and/or served to browsers to facilitate navigating within a multi-level hierarchical information structure where each 

level in the menu contains plural items, each said item being at least one of a function, a pointer to a location, and a 

pointer to another level; and

(vi) computer equipment, including, without limitation, computer equipment that stores, serves, hosts, supports, and/or 

runs any of the foregoing or that allows navigating within a multi-level hierarchical information structure where each 

level in the menu contains plural items, each said item being at least one of a function, a pointer to a location, and a 

pointer to another level, and any products, devices, systems, and/or components of systems with the same or 

substantially the same technical features and/or functionalities.

Direct Infringement

Microchip has directly infringed claims 1-5 and 7-8 of the ’836 patent under 35 U.S.C. § 271(a) each time that it makes, uses, 

tests, and/or hosts in the United States the Accused Instrumentalities, or products, devices, systems, and/or components of 

systems, that practice the claimed methods described hereinbelow. Microchip also directly infringes each of the Asserted 

Claims under 35 U.S.C. § 271(a) each time that it imports the Accused Instrumentalities into the United States. 

Indirect Infringement

Microchip has induced and continues to induce infringement by others of claims 1-5 and 7-8 of the ’836 patent under 35 U.S.C. 

§ 271(b) by (a) providing the Accused Instrumentalities to third parties and intending them to use the Accused Instrumentalities; 

(b) advertising these Accused Instrumentalities through Microchip’s own and through third party websites; (c) encouraging 

customers and other third parties to communicate directly with Microchip about the Accused Instrumentalities for purposes of 

technical assistance and repair as well as sales and marketing; (d) providing instructions as to how to use the Accused 

Instrumentalities in an infringing manner.

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Microchip has contributed to and continues to contribute to infringement by others of claims 1-5 and 7-8 of the ’836 patent 

under 35 U.S.C. § 271(c) by providing the Accused Instrumentalities, including web pages and content, user interfaces (e.g., 

hierarchical collapsing menu structure, hierarchical information structure, information structure, and/or hierarchical menu 

structure), software, and/or computer equipment as identified above, in the United States without authority, Microchip 

contributes to the direct infringement of third-parties including end users of the Accused Instrumentalities.

To the extent that the preamble of Claim 1 is a limitation, the ’836 Accused Instrumentalities provide, or support the provision 

of, a method as described below.

The ’836 Accused Instrumentalities provide a method for navigating within a multi-level hierarchical information structure 

where each level in the menu contains plural items, each said item being at least one of a function, a pointer to a location, and a 

pointer to another level, as shown below:

See, e.g., https://www.microchip.com/design-centers/automotive-solutions/automotive-applications (last visited Feb. 10, 2020) 

(annotated). 

See also MCHP-CADDO_0000930:

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See MCHP-CADDO-0000931.

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As another example, the ’836 Accused Instrumentalities provide a method for navigating within a multi-level hierarchical 

information structure where each level in the menu contains plural items, each said item being at least one of a function, a 

pointer to a location, and a pointer to another level, as shown below:

See https://www.microchip.com (last accessed Jun. 8, 2021).

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providing a 

graphical user 

menu system 

displaying the 

items of a 

given level of 

the 

hierarchical 

information 

structure and 

enabling 

selection 

thereof and 

constructing 

an Active 

Path as a 

sequence of 

active links as 

the user 

navigates the 

information 

structure 

using the 

graphical user 

menu system, 

with one said 

active link 

corresponding 

to each of the 

hierarchical 

The ’836 Accused Instrumentalities provide a graphical user menu system displaying the items of a given level of the 

hierarchical information structure and enabling selection thereof and constructing an Active Path, which has been construed by 

this Court (Dkt. 34) as a sequence of links dynamically created as a menu item is navigated, as a sequence of active links as the 

user navigates the information structure using the graphical user menu system, with one said active link corresponding to each of 

the hierarchical levels accessed by the user, said active links providing direct access to one of a function, corresponding level 

and menu item without the need to navigate using said graphical user menu system.

For example, the ’836 Accused Instrumentalities provide a graphical user menu system displaying the items of a given level of 

the hierarchical information structure and enabling selection thereof (e.g., “Products” displays and enables selection of items of a 

given level, such as “Amplifiers and Linear” and items within that same level). 

Furthermore, the ’836 Accused Instrumentalities construct a sequence of links dynamically created as a menu item is navigated

as a sequence of active links as the user navigates the information structure using the graphical user menu system (e.g., the ’836 

Accused Instrumentalities construct a sequence of links dynamically created active path (e.g., “Amplifiers and Linear—

Comparators”) as a sequence of active links as the user navigates the information structure using the graphical user menu system 

(e.g., as “Amplifiers and Linear” and “Comparators” are selected)), with one said active link corresponding to each of the 

hierarchical levels accessed by the user, said active links providing direct access to one of a function, corresponding level and 

menu item without the need to navigate using said graphical user menu system (e.g., the ’836 Accused Instrumentalities’ 

sequence of links dynamically created as a menu item is navigated “Amplifiers and Linear—Comparators” corresponds to each 

of the hierarchical levels accessed by the user, including “Amplifiers and Linear” and “Comparators,” each link providing direct 

access to one of a function, corresponding level and menu item without the need to navigate using said graphical user menu 

system) as shown below: 

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020).

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levels 

accessed by 

the user, said 

active links 

providing 

direct access 

to one of a 

function, 

corresponding 

level and 

menu item 

without the 

need to 

navigate 

using said 

graphical user 

menu system;

See also MCHP-CADDO_0000935:

As another example, the ’836 Accused Instrumentalities construct a sequence of links dynamically created as a menu item is 

navigated as a sequence of active links as the user navigates the information structure using the graphical user menu system 

(e.g., the ’836 Accused Instrumentalities construct a sequence of links dynamically created as a menu item is navigated (e.g., 

“Amplifiers and Linear—Comparators”) as a sequence of active links as the user navigates the information structure using the 

graphical user menu system (e.g., as “Amplifiers and Linear” and “Comparators” are selected)), with one said active link 

corresponding to each of the hierarchical levels accessed by the user, said active links providing direct access to one of a 

function, corresponding level and menu item without the need to navigate using said graphical user menu system (e.g., the ’836 

Accused Instrumentalities’ sequence of links dynamically created as a menu item is navigated “Amplifiers and Linear—

Comparators” corresponds to each of the hierarchical levels accessed by the user, including “Amplifiers and Linear” and 

“Comparators,” each link providing direct access to one of a function, corresponding level and menu item without the need to 

navigate using said graphical user menu system) as shown below: 

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See also https://www.microchip.com/en-us/products/amplifiers-and-linear-ics/comparator-ics (last accessed June 8, 2021); see 

id:

As another example, the ’836 Accused Instrumentalities construct a sequence of links dynamically created as a menu item is 

navigated as a sequence of active links as the user navigates the information structure using the graphical user menu system 

(e.g., the ’836 Accused Instrumentalities construct a sequence of links dynamically created as a menu item is navigated (e.g., 

“Microcontrollers and Microprocessors—8-bit MCUs”) as a sequence of active links as the user navigates the information 

structure using the graphical user menu system (e.g., as “Microcontrollers and Microprocessors” and “8-bit MCUs” are 

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selected)), with one said active link corresponding to each of the hierarchical levels accessed by the user, said active links 

providing direct access to one of a function, corresponding level and menu item without the need to navigate using said 

graphical user menu system (e.g., the ’836 Accused Instrumentalities’ sequence of links dynamically created as a menu item is 

navigated “Microcontrollers and Microprocessors —8-bit MCUs” corresponds to each of the hierarchical levels accessed by the 

user, including “Microcontrollers and Microprocessors” and “8-bit MCUs,” each link providing direct access to one of a 

function, corresponding level and menu item without the need to navigate using said graphical user menu system) as shown 

below: 

See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus (last accessed June 8, 2021); 

see id.:

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a given said 

active link 

enabling the 

user to 

browse items 

of the 

hierarchical 

information 

structure 

starting from 

the level 

corresponding 

with the 

given active 

link and items 

on 

hierarchically 

subordinate 

levels without 

affecting the 

Active Path.

A given said active link in the ’836 Accused Instrumentalities enables the user to browse items of the hierarchical information 

structure starting from the level corresponding with the given active link and items on hierarchically subordinate levels without 

affecting the Active Path (the term “active path” has been construed by the Court (Dkt. 34) as a sequence of links dynamically 

created as a menu item is navigated).

For example, in the ’836 Accused Instrumentalities, a given said active link enables the user to browse items of the hierarchical 

information structure starting from the level corresponding with the given active link and items on hierarchically subordinate 

levels without affecting the sequence of links dynamically created as a menu item is navigated (e.g., the ’836 Accused 

Instrumentalities enable the user to browse items of the hierarchical information structure starting from “Amplifiers and Linear” 

and items on subordinate levels such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” without affecting the sequence of links 

dynamically created as a menu item is navigated “Amplifiers and Linear—Comparators”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

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See also MCHP-CADDO_0000935:

As another example, in the ’836 Accused Instrumentalities, a given said active link (e.g., “Microcontrollers and 

Microprocessors”) enables the user to browse items of the hierarchical information structure (e.g., items such as “8-bit MCUs” 

and “32-bit MCUs”) starting from the level corresponding with the given active link (e.g., the level corresponding to “Product 

Categories” and “Development Tools”) and items on hierarchically subordinate levels (e.g., items associated with “Part Number: 

DM164136” and “Part Number: DM330028”) without affecting the Active Path, as shown below:

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See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors#Development%20Tools (last accessed 

Jun. 8, 2021); see also id.:

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2. The 

method for 

navigating 

according to 

claim 1, 

further 

comprising: 

providing 

pre-defined 

short-cuts 

enabling 

direct access 

to a given 

menu item; 

and

The ’836 Accused Instrumentalities provide pre-defined short-cuts enabling direct access to a given menu item.

For example, the ’836 Accused Instrumentalities provide pre-defined short-cuts enabling direct access to a given menu item 

(e.g., the ’836 Accused Instrumentalities provide pre-defined shortcuts, such as “Amplifiers and Linear” or “Comparators” in the 

collapsing menu enabling direct access to a given menu item) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020).

See MCHP-CADDO_0000935.

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See MCHP-CADDO_0001040-41.

For example, the ’836 Accused Instrumentalities further provide pre-defined shortcuts to enable direct access to a given item 

(e.g., the ’836 Accused Instrumentalities provide pre-defined shortcuts such as “Microcontrollers and Microprocessors” or “8-bit 

MCUs” in the collapsing menu enabling direct access to a given menu item), as shown below:

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See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus (last accessed June 7, 2021).

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dynamically 

constructing 

the Active 

Path when a 

pre-defined 

short-cut is 

executed, 

with one said 

active link 

corresponding 

to each of the 

menu items 

necessary to 

access said 

given menu 

item using 

said graphical 

user menu 

system.

The ’836 Accused Instrumentalities dynamically construct the Active Path, which has been construed by this Court (Dkt. 34) as 

a sequence of links dynamically created as the menu system is navigated, when a pre-defined short-cut is executed, with one said 

active link corresponding to each of the menu items necessary to access said given menu item using said graphical user menu 

system.

For example, the ’836 Accused Instrumentalities dynamically construct the sequence of links dynamically created as the menu 

system is navigated when a pre-defined short-cut is executed, with one said active link corresponding to each of the menu items 

necessary to access said given menu item using said graphical user menu system (e.g., the sequence of links dynamically created 

as a menu item is navigated is automatically constructed when “Amplifiers and Linear” or “Comparators” is executed, with each 

active link “Amplifiers and Linear” or “Comparators” corresponding to each of the menu items necessary to access the given 

menu item using the graphical user menu system). 

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000935:

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As another example, the ’836 Accused Instrumentalities dynamically construct the sequence of links dynamically created as the 

menu system is navigated when a pre-defined short-cut is executed (e.g., when the short-cut corresponding to the link “CAN 2.0 

MCUs” is executed), with one said active link (e.g., the link “CAN 2.0 MCUs” in the path “Products / Interface and 

Connectivity / CAN / CAN 2.0 MCUs”) corresponding to each of the menu items necessary to access said given menu item 

using said graphical user menu system (e.g., the link “CAN 2.0 MCUs” corresponding to the menu item “CAN 2.0 MCUs”), as 

shown below:

See, e.g., https://www.microchip.com/en-us/products/interface-and-connectivity/can/can-2-0-mcus; see also id.:

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3. The 

method for 

navigating 

according to 

claim 1, 

wherein 

rolling over a 

selected 

active link 

triggers the 

display of 

sibling menu 

items on the 

hierarchically 

subordinate 

levels 

associated 

with said 

selected 

active link.

The ’836 Accused Instrumentalities allow rolling over a selected active link triggers the display of sibling menu items on the 

hierarchically subordinate levels associated with said selected active link.

For example, in the ’836 Accused Instrumentalities, rolling over a selected active link triggers the display of sibling menu items 

on the hierarchically subordinate levels associated with said selected active link (e.g., the ’836 Accused Instrumentalities allow 

rolling over the link “Amplifiers and Linear” to trigger the display of sibling menu items on the hierarchically subordinate levels 

associated with the selected active link “Amplifiers and Linear” such as “Operational Amplifiers,” “Instrumentation 

Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current 

Monitors”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

As another example, rolling over a selected active link triggers the display of sibling menu items on the hierarchically 

subordinate levels associated with said selected active link (e.g., the ’836 Accused Instrumentalities allow rolling over the link 

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“Amplifiers and Linear” to trigger the display of sibling menu items on the hierarchically subordinate levels associated with the 

selected active link “Amplifiers and Linear” such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense 

Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “Current/Voltage/Power Monitor ICs”) as shown below:

See MCHP-CADDO_0000935. 

As another example, in the ’836 Accused Instrumentalities, rolling over a selected active link (e.g., rolling over and selecting 

“Microcontrollers and Microprocessors” in “Products / Microcontrollers and Microprocessors / 8-bit MCUs”) triggers the 

display of sibling menu items on the hierarchically subordinate levels associated with said selected active link (e.g., “Product 

Categories,” “Developments,” “Software Solutions,” “Application Design Centers,” and “Product Selections”) as shown below: 

See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors (last accessed Jun. 8, 2021).

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To the extent Microchip contends that the ’836 Accused Instrumentalities do not literally meet the limitation of rolling over a 

selected active link triggers the display of sibling menu items on the hierarchically subordinate levels associated with said selected 

active link, the limitation is met under the doctrine of equivalents by the ’836 Accused Instrumentalities because it performs 

substantially the same function (displaying items such as “Product Categories,” “Developments,” “Software Solutions,” 

“Application Design Centers,” and “Product Selections”) in substantially the same way (e.g., displaying the menu items on the 

hierarchically subordinate levels associated with the active link “Microcontrollers and Microprocessors”) to produce substantially 

the same result (e.g., sibling menu items on the hierarchically subordinate levels associated with “Microcontrollers and 

Microprocessors” are displayed).

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4. The 

method for 

navigating 

according to 

claim 1, 

wherein 

selecting a 

given active 

link triggers 

the execution 

of a function 

associated 

with said 

given active 

link.

Selecting a given active link in the ’836 Accused Instrumentalities triggers the execution of a function associated with said given 

active link.

For example, the ’836 Accused Instrumentalities allow selecting a given active link triggers the execution of a function 

associated with said given active link (e.g., selecting a given active link such as “Amplifiers and Linear” triggers the execution 

of a function, such as displaying sibling menus (e.g., “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense 

Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors”) or directing user to certain 

content) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

As another example, the ’836 Accused Instrumentalities allow selecting a given active link triggers the execution of a function 

associated with said given active link (e.g., selecting a given active link such as “Amplifiers and Linear” triggers the execution 

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of a function, such as displaying sibling menus (e.g., “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense 

Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “Current/Voltage/Power Monitor ICs”) as shown below:

See MCHP-CADDO_0000935.

As another example, selecting a given active link triggering the execution of a function associated with said given active link 

(e.g., selecting a given active link such as “CAN” in the path “Products / Interface and Connectivity / CAN” triggers the 

execution of a function, such as displaying sibling menus (e.g., “MCU, DSC and MPU Products,” “Interface and Connectivity 

Products,” “Development Tools,” and “Documentation” associated with “CAN”) or directing user to certain content such as 

content under the link “CAN”), as shown below:

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See, e.g., https://www.microchip.com/en-us/products/interface-and-connectivity/can (last accessed June 8, 2021).

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5. The 

method for 

navigating 

according to 

claim 1, 

wherein 

selecting a 

given active 

link triggers 

display of 

information 

associated 

with said 

given active 

link.

Selecting a given active link in the ’836 Accused Instrumentalities triggers display of information associated with said given 

active link.

For example, the ’836 Accused Instrumentalities allow selecting a given active link to trigger display of information associated 

with said given active link (e.g., the ’836 Accused Instrumentalities allow selecting the link “Amplifiers and Linear” to trigger 

display of information (e.g., displaying “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors”) associated with the link “Amplifiers and 

Linear”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

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As another example, the ’836 Accused Instrumentalities allow selecting a given active link to trigger display of information 

associated with said given active link (e.g., the ’836 Accused Instrumentalities allow selecting the link “Amplifiers and Linear” 

to trigger display of information (e.g., displaying “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense 

Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “Current/Voltage/Power Monitor ICs”) associated with the 

link “Amplifiers and Linear”) as shown below:

See MCHP-CADDO_0000935.

As another example, selecting a given active link triggers the display of information associated with said given active link (e.g., 

selecting a given active link such as “CAN” in the path “Products / Interface and Connectivity / CAN ” triggers the display of 

the information associated with said given active link (e.g., “MCU, DSC and MPU Products,” “Interface and Connectivity 

Products,” “Development Tools,” and “Documentation” associated with “CAN”) or directing user to certain content such as 

content under the link “CAN”), as shown below:

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See, e.g., https://www.microchip.com/en-us/products/interface-and-connectivity/can (last accessed June 8, 2021).

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7. The 

method 

according to 

claim 1, 

wherein the 

multi-level 

hierarchical 

information 

structure is a 

website.

The multi-level hierarchical information structure in the ’836 Accused Instrumentalities is a website.

For example, the multi-level hierarchical information structure in the ’836 Accused Instrumentalities is a website as shown 

below:

(See, e.g., https://www.microchip.com/ (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000934:

See also https://www.microchip.com/ (last accessed June 8, 2021):

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8. A method 

for navigating 

websites 

including a 

plurality of 

hierarchically 

organized 

web pages, 

said method 

comprising:

To the extent that the preamble of Claim 8 is a limitation, the ’836 Accused Instrumentalities provide, or support the provision 

of, a method as described below.

The ’836 Accused Instrumentalities provide a method for navigating websites including a plurality of hierarchically organized

web pages.

For example, the ’836 Accused Instrumentalities provide a method for navigating websites including a plurality of hierarchically 

organized web pages as shown below:

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See, e.g., https://www.microchip.com/ (last visited Feb. 10, 2020).

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As another example, the ’836 Accused Instrumentalities provide a method for navigating websites including a plurality of 

hierarchically organized web pages as shown below:

See https://www.microchip.com (last accessed Jun. 8, 2021).

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providing a 

means for 

navigating the 

multi-level 

hierarchical 

website; 

The ’836 Accused Instrumentalities provide a means for navigating the multi-level hierarchical website. The Court has 

construed this term (Dkt.. 34) and determined it is governed by 35 U.S.C. § 112(6). The function of this term is navigating the 

multi-level hierarchical website, and the structure of this means-plus-function claim is a graphical user menu system.

Based on the Court’s construction, the ’836 Accused Instrumentalities provide a means for navigating the multi-level 

hierarchical website (e.g., the ’836 Accused Instrumentalities provide a graphical user menu system for navigating a multi-level 

hierarchical website), including through the graphical user menu system shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020).

See also MCHP-CADDO_0000935:

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See also:

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See https://www.microchip.com/ (last accessed June 8, 2021).

See also https://www.microchip.com/en-us/products/amplifiers-and-linear-ics/comparator-ics (last accessed June 8, 2021) 

below:

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dynamically 

constructing 

an Active 

Path as a 

sequence of 

active links as 

the user 

navigates the 

multi-level 

hierarchical 

website, 

wherein each 

said active 

link 

corresponds 

to a level in 

the 

hierarchical 

structure;

The ’836 Accused Instrumentalities dynamically construct an Active Path, which has been construed by this Court (Dkt. 34) as a 

sequence of links dynamically created as a menu item is navigated, as a sequence of active links as the user navigates the multilevel hierarchical website, wherein each said active link corresponds to a level in the hierarchical structure.

For example, the ’836 Accused Instrumentalities dynamically construct a sequence of links dynamically created as a menu item 

is navigated as a sequence of active links as the user navigates the multi-level hierarchical website (e.g., the ’836 Accused 

Instrumentalities dynamically construct a sequence of links dynamically created as a menu item is navigated (e.g., “Amplifiers 

and Linear—Comparators”) as a sequence of active links as the user navigates the multi-level hierarchical website (e.g., as 

“Amplifiers and Linear” and “Comparators” are selected)), wherein each said active link corresponds to a level in the 

hierarchical structure, as shown below: 

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020).

See also MCHP-CADDO_0000935:

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As another example, the ’836 Accused Instrumentalities dynamically construct a sequence of links dynamically created as a 

menu item is navigated as a sequence of active links as the user navigates the multi-level hierarchical website (e.g., the path 

“Products / Microcontrollers and Microprocessors / 8-bit MCUs / AVR® MCUs / AVR® DA”) as a sequence of active links as 

the user navigates the multi-level hierarchical website (e.g., as “Products,” “Microcontrollers and Microprocessors,” “8-bit 

MCUs,” “AVR® MCUs” and “AVR® DA” are selected), wherein each said active link corresponds to a level in the hierarchical 

structure, as shown below: 

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See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus/avr-mcus/avr-da (last visited 

Jun. 7, 2021).

As another example, the ’836 Accused Instrumentalities dynamically construct a sequence of links dynamically created as a 

menu item is navigated as a sequence of active links as the user navigates the multi-level hierarchical website (e.g., the path 

“Products / Microcontrollers and Microprocessors / 8-bit MCUs”) wherein each said active link corresponds to a level in the 

hierarchical structure (e.g., “Microcontrollers and Microprocessors” corresponds to one level in the hierarchical structure and “8-

bit MCUs” corresponds to another level in the hierarchical structure), as shown below: 

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See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus (last accessed Jun. 8, 2021); 

see also id.

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wherein a 

user may 

directly 

access any 

given level of 

the 

hierarchical 

structure by 

selecting a 

given said 

active link;

The ’836 Accused Instrumentalities allow a user to directly access any given level of the hierarchical structure by selecting a 

given said active link.

For example, the ’836 Accused Instrumentalities allow a user to directly access any level of the hierarchical structure by 

selecting “Amplifiers and Linear,” as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020).

See also MCHP-CADDO_0000935:

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See MCHP-CADDO_0001040-41.

As another example, the ’836 Accused Instrumentalities allow a user to directly access any given level of the hierarchical 

structure by selecting a given said active link (e.g., a user may directly access “Microcontrollers and Microprocessors” in the 

“Products / Microcontrollers and Microprocessors” or “Products / Microcontrollers and Microprocessors / 8-bit MCUs” to 

access items such as “Product Categories,” “Development Tools,” “Software Solutions,” “Application Design Centers,” and 

“Product Selections”), as shown below:

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See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors (last accessed Jun. 8, 2021).

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each said 

active link 

providing the 

user the 

ability to 

directly 

browse items 

on any given 

level of the 

hierarchical 

menu 

structure and 

hierarchically 

subordinate 

items without 

affecting the 

Active Path.

Each said active link in the ’836 Accused Instrumentalities provides the user the ability to directly browse items on any given 

level of the hierarchical menu structure and hierarchically subordinate items without affecting the Active Path, which has been 

construed by this Court (Dkt. 34) as a sequence of links dynamically created as a menu item is navigated.

For example, each active link provides the user the ability to directly browse items on any given level of the hierarchical menu 

structure and hierarchically subordinate items without affecting the sequence of links dynamically created as a menu item is 

navigated (e.g., the ’836 Accused Instrumentalities enable the user to browse items of the hierarchical information structure 

starting from “Amplifiers and Linear” and items on subordinate levels such as “Operational Amplifiers,” “Instrumentation 

Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” 

without affecting the sequence of links dynamically created as a menu item is navigated “Amplifiers and Linear—

Comparators”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020).

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As another example, each active link provides the user the ability to directly browse items on any given level of the hierarchical 

menu structure and hierarchically subordinate items without affecting the sequence of links dynamically created as a menu item 

is navigated (e.g., the ’836 Accused Instrumentalities enable the user to browse items of the hierarchical information structure 

starting from “Amplifiers and Linear” and items on subordinate levels such as “Operational Amplifiers,” “Instrumentation 

Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “Current/Voltage/Power 

Monitor ICs” without affecting the sequence of links dynamically created as a menu item is navigated “Amplifiers and Linear—

Comparators”) as shown below:

See MCHP-CADDO_0000935.

As another example, each active link in the ’836 Accused Instrumentalities provides the user the ability to directly browse items 

on any given level of the hierarchical menu structure and hierarchically subordinate items without affecting the sequence of links 

dynamically created as a menu item is navigated (e.g., the ’836 Accused Instrumentalities provide the user the ability to directly 

browse items (e.g., “Product Categories,” “Developments,” “Software Solutions,” “Application Design Centers,” and “Product 

Selections”) in the path “Products / Microcontrollers and Microprocessors” without affecting the a sequence of links 

dynamically created as a menu item is navigated) as shown below:

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See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors#Product%20Categories (last visited Jun. 

7, 2021).

As another example, each active link in the ’836 Accused Instrumentalities provides the user the ability to directly browse items 

on any given level of the hierarchical menu structure (e.g., the level corresponding to “Product Categories” and “Development 

Tools”) and hierarchically subordinate items (e.g., subordinate items associated with “Part Number: DM164136” and “Part 

Number: DM330028”) without affecting the sequence of links dynamically created as a menu item is navigated, as shown 

below:

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See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors#Development%20Tools (last accessed 

Jun. 8, 2021).

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