‘ 

EXHIBIT 6

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 1 of 141
From: Jensen, Travis 

Sent: 

To: 

Wednesday, November 17, 2021 11 :44 AM 

Alex Chan 

Cc: Vikhyat Kaushal; Timothy Devlin; Microchip-Caddo_OHS; coburn; Veronica McCarty; Frost, Claudia; 

Mao, Lillian J.; bshelton 

Subject: 

Attachments: 

RE: Caddo v. Microchip/NXP - Wroblewski Reference Letter 

A-4 Supplemental Wroblewski Chart [redline].docx 

Alex, 

Below is Microchip and NXP's portion of the joint statement regarding supplementation of the Wroblewski invalidity 

contentions. Please provide Caddo's position so we can submit to the Court. Thanks, Travis 

### 

Dear Jun, 

The parties in the above-captioned matters met and conferred on October 29, 2021 to discuss supplementing 

Defendants' invalidity contentions related to work done by Luke Wroblewski but were unable to reach a 

resolution. The parties are now requesting the Court's assistance to resolve this dispute. The parties are 

available for a Zoom/telephonic hearing if the Court desires. As required by the Court's Order Governing 

Proceedings, the parties provide the following chart delineating the precise issues and specific relief requested 

by both parties. 

Issue Relief 

Supplementing Defendants' invalidity Defendants' Request: The Court should grant 

contentions with work done by Luke leave for defendants to supplement their 

Wroblewski (a third-party fact witness) invalidity contentions as shown in the 

attached document, which adds citations to 

[Defendants' Position] Microchip and NXP newly obtained evidence regarding the 

identified and charted the work of Luke Wroblewski prior art reference. 

Wroblewski (a third-party prior artist), 

including his "Site-Seeing" book, as prior art Plaintiffs' Request: [ ... ] 

in both their initial and final invalidity 

contentions. 

Good cause exists for defendants to 

supplement their invalidity contentions 

because the amendments are based on 

information not reasonably available when 

serving final contentions on June 11, 

2021. After serving their final invalidity 

contentions, defendants diligently sought 

discovery and took Mr. Wroblewski's 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 2 of 141
deposition for a full day on October 13, 

2021. 

In preparation for, and at his deposition 

(which was taken remotely at his home 

where he maintains his files), Mr. Wroblewski 

identified additional prior art documents 

such as hand written notes evidencing when 

he conceived and reduced to practice the 

claimed invention. 

On October 23, 2021, plaintiffs demanded 

that defendants withdraw their contentions 

for Wroblewski. On October 29, 2021, 

defendants notified plaintiffs of their intent 

to amend the contentions based on the 

information Mr. Wroblewski 

provided. Having now received Mr. 

Wroblewski's transcript and document 

productions, Defendants have diligently 

analyzed those materials and prepared the 

amended contentions attached hereto. 

Defendants maintain that the final invalidity 

contentions sufficiently disclose their 

theories relating to Wroblewski, but because 

Caddo has challenged them, in an abundance 

of caution Microchip and NXP seek leave to 

supplement their contentions. 

Mr. Wroblewski's work is highly relevant to 

this case because, in the course of writing his 

"Site-Seeing" book, he conceived and 

implemented precisely the "drop down 

breadcrumb" navigation feature that is 

claimed in the asserted patents. Mr. 

Wroblewski completed work on the relevant 

sections of his book no later than April 2002 

(as shown by the manuscripts he produced), 

provided handwritten notes dated Dec. 16, 

2001 disclosing a drop-down breadcrumb, 

and testified that he implement the invention 

on his website, all before the asserted 

patents' earliest filing date. In addition to 

qualifying as prior art under section 

102(g)(2), Mr. Wroblewski's work is evidence 

of simultaneous invention (which tends to 

show obviousness), the level of ordinary skill 

2 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 3 of 141
in the art, and also provides evidence of 

motivation to combine. 

Plaintiffs will not be prejudiced by the 

supplement. Plaintiffs have long been on 

notice that defendants' believe Mr. 

Wroblewski's work invalidates the asserted 

claims, including over 100 pages of claim 

charts in the final invalidity contentions. In 

addition, the parties have yet to exchange 

expert reports or take expert depositions, 

through which plaintiffs will have a full 

opportunity to respond to and test 

defendants' invalidity theories. 

Because the proposed amendments are 

based on newly obtained discovery, 

defendants have acted diligently in seeking 

discovery and seeking to amend, and 

plaintiffs will not be prejudiced, good cause 

exists for defendants to amend their 

invalidity contentions relating to Wroblewski. 

[Plaintiffs' Position] 

From: Alex Chan <achan@devlinlawfirm.com> 

Sent: Friday, October 29, 20219:18 AM 

To: coburn <coburn@sheltoncoburn.com>; Jensen, Travis <tjensen@orrick.com>; Veronica McCarty 

<vmccarty@devlinlawfirm.com>; Frost, Claudia <cfrost@orrick.com>; Mao, Lillian J. <lmao@orrick.com>; bshelton 

<bshelton@sheltoncoburn.com> 

Cc: Vikhyat Kaushal <vkaushal@devlinlawfirm.com>; Timothy Devlin <tdevlin@devlinlawfirm.com> 

Subject: Re: Caddo v. Microchip/NXP - Wroblewski Reference Letter 

Travis, Bradley, 

We will oppose. Also, please confirm that the parties are at an impasse so that we can also cross move to strike 

Defendants' final invalidity contentions. 

Thanks much, 

Alex 

From: Bradley Coburn <coburn@sheltoncoburn.com> 

Date: Friday, October 29, 2021 at 10:07 AM 

To: "Jensen, Travis" <tjensen@orrick.com>, Veronica McCarty <vmccarty@devlinlawfirm.com>, "Frost, 

Claudia" <cfrost@orrick.com>, "Mao, Lillian J." <lmao@orrick.com>, bshelton 

<bshelton@sheltoncoburn.com> 

Cc: Alex Chan <achan@devlinlawfirm.com>, Vikhyat Kaushal <vkaushal@devlinlawfirm.com>, Timothy Devlin 

3 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 4 of 141
<tdevlin@devlinlawfirm.com> 

Subject: RE: Caddo v. Microchip/NXP - Wroblewski Reference Letter 

Veronica, 

NXP joins Microchip's positions regarding the Wroblewski reference. Please let us know, too, whether Caddo opposes 

supplementation. 

Best, 

Bradley 

Bradley D. Coburn 

Shelton Coburn LLP 

Austin I Nashville 

T: (512) 589-9154 I F: (512) 263-2166 

coburn@sheltoncoburn.com I www.sheltoncoburn.com 

From: Jensen, Travis <t jensen@orrick.com> 

Sent: Friday, October 29, 202110:05 AM 

To: Veronica McCarty <vmccarty@devlinlawfirm.com>; Frost, Claudia <cfrost@orrick.com>; Mao, Lillian J. 

<lmao@orrick.com>; Bradley Coburn <coburn@sheltoncoburn.com>; Barry Shelton <bshelton@sheltoncoburn.com> 

Cc: Alex Chan <achan@devlinlawfirm.com>; Vikhyat Kaushal <vkaushal@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Subject: RE: Caddo v. Microchip/NXP - Wroblewski Reference Letter 

Veronica, 

We only recently received Mr. Wroblewski's deposition transcript earlier this week and will need a chance to review 

it. However, I anticipate we will be amending our contentions as to all asserted claims in all asserted patents. Mr. 

Wroblewski testified extensively for the better part of a full day and touched on aspects that would implicate practically 

all of the claim elements as well as motivation to combine a drop down menu with breadcrumb and the level of skill 

required to do so, not to mention simultaneous invention as evidence of obviousness. I expect that many of the 

amendments would focus on the materials Mr. Wroblewksi created in preparing the manuscript for his book (both his 

handwritten notes and layout files), including the work performed on his website in relation to writing his book. We 

reserve the right to supplement with any materials identified by Mr. Wroblewski during his deposition, including his 

post-deposition production. My prior email already identified exemplary material we intend to add (e.g., LW_0856 at 

881). Providing a comprehensive list will require us to prepare the actual invalidity contentions themselves. We have 

provided sufficient information for Caddo to determine whether it opposes supplemental or not. Please let us 

know. Thanks, Travis 

From: Veronica McCarty <vmccarty@devlinlawfirm.com> 

Sent: Friday, October 29, 2021 8:51 AM 

To: Jensen, Travis <t jensen@orrick.com>; Frost, Claudia <cfrost@orrick.com>; Mao, Lillian J. <lmao@orrick.com>; 

coburn <coburn@sheltoncoburn.com>; bshelton <bshelton@sheltoncoburn.com> 

Cc: Alex Chan <achan@devlinlawfirm.com>; Vikhyat Kaushal <vkaushal@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Subject: RE: Caddo v. Microchip/NXP - Wroblewski Reference Letter 

Travis, 

I am following up on the questions below. 

4 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 5 of 141
Best, 

DEVLIN 

LAW FIRM LLC 

tm ,....mw 

\;lallat,:- Qla'IID,IAlllllld11llll•01 

The information contained in this communication is confidential and is intended only for the use of the intended addressee. It is the 

property of Devlin Law Firm LLC, and may contain information subject to attorney-client privilege and/or may constitute inside 

information. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be 

unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail 

to correspondence@devlinlawfirm.com, and destroy this communication and all copies thereof, including all attachments. 

From: Veronica McCarty 

Sent: Monday, October 25, 20214:21 PM 

To: Jensen, Travis <tjensen@orrick.com>; Frost, Claudia <cfrost@orrick.com>; Mao, Lillian J. <lmao@orrick.com>; 

coburn <coburn@sheltoncoburn.com>; bshelton <bshelton@sheltoncoburn.com> 

Cc: Alex Chan <achan@devlinlawfirm.com>; Vikhyat Kaushal <vkaushal@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Subject: RE: Caddo v. Microchip/NXP - Wroblewski Reference Letter 

Travis, 

Caddo disagrees with Microchip's analysis below. However, before Caddo responds to whether it opposes Microchip's 

proposed motion to supplement its invalidity contentions, we will need more information so our clients can properly 

consider your request. For example, which patent(s) and which claim limitation(s) will Microchip be 

supplementing? Also, which aspect of the Wroblewski reference is Microchip proposing that it will be 

supplemented? Additionally, what materials will be added to the proposed supplemental contentions? 

Once we have this information, we will respond regarding our position. 

Thanks much, 

DEVLIN 

LAW FIRM LLC 

. ~ .,..., ... ., ·~-

flllllll.D!W 

\;lallat,:- Qla'IID,IMllllllll•M_,OI' 

The information contained in this communication is confidential and is intended only for the use of the intended addressee. It is the 

property of Devlin Law Firm LLC, and may contain information subject to attorney-client privilege and/or may constitute inside 

information. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be 

unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail 

to correspondence@devlinlawfirm.com, and destroy this communication and all copies thereof, including all attachments. 

From: Jensen, Travis <tjensen@orrick.com> 

Sent: Saturday, October 23, 20213:05 PM 

To: Veronica McCarty <vmccarty@devlinlawfirm.com>; Frost, Claudia <cfrost@orrick.com>; Mao, Lillian J. 

<lmao@orrick.com>; coburn <coburn@sheltoncoburn.com>; bshelton <bshelton@sheltoncoburn.com> 

Cc: Alex Chan <achan@devlinlawfirm.com>; Vikhyat Kaushal <vkaushal@devlinlawfirm.com>; Timothy Devlin 

5 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 6 of 141
<tdevlin@devlinlawfirm.com> 

Subject: RE: Caddo v. Microchip/NXP - Wroblewski Reference Letter 

Veronica, 

Microchip will not withdraw its Wroblewksi-related invalidity contentions. Mr. Wroblewski's testimony confirmed that 

his work related to the Site Seeing book qualified as prior art under both 102(a) and 102(g)(2). Specifically, Mr. 

Wroblewski testified that he wrote the Site-Seeing book (MCHP-CADDO_0010195), including the manuscript for it which 

does pre-date June 6, 2002 (LW_0013 with metadata dated April 4, 2002), and even provided his notes at the deposition 

where he first documented the drop-down breadcrumb feature (LW_0856 at 881). Your statement that "Mr. 

Wroblewski's document production to the parties, both before and after the Wroblewski Deposition, contains no 

supporting documents demonstrating that the alleged breadcrumb functionality was available prior to June 6, 2002" is 

simply not true. For example, Mr. Wroblewki testified that his publicly available website (which predated June 6, 2002) 

implemented the drop-down breadcrumb functionality described in his book and explained why that was the case (viz., 

because he took various screenshots on multiple different browsers to show how the website rendered). It makes no 

difference whether a particular snapshot on the Internet Archive happened to show the feature or not. Moreover, the 

Site Seeing book itself is evidence of simultaneous invention, motivation to combine, the level of ordinary skill in the art, 

and secondary considerations for obviousness. See, e.g., Geo M. Martin Co. v. Alliance Mach. Sys. Int'/ LLC 618 F.3d 

1294, 1305-1306 (Fed. Cir. 2010) (citations omitted) ("Independently made, simultaneous inventions, made within a 

comparatively short space of time, are persuasive evidence that the claimed apparatus was the product only of ordinary 

mechanical or engineering skill."); Newell Cos. v. Kenney Mfg. Co., 864 F.2d 757, 766 (Fed. Cir. 1988) (stating that a 

document which "was not technically 'prior art,,, was admissible to show that a person of ordinary skill in the art 

suggested solutions to the problem similar to that claimed in the patent.); NPF Ltd. v. Smart Parts, Inc., Case No. 05-1273 

(Fed. Cir. 2006); Ecolochem, Inc. v. Southern Cal. Edison Co., 227 F.3d 1361, 1379 (Fed. Cir. 2000). Additionally, Caddo's 

own interrogatory responses list priority dates after June 6, 2002 for five of the six asserted patents. See Caddo Supp. 

Response to Interrogatory No. 1 (10/3/2021). And four of the six asserted patents issued from CIP applications which 

added new matter after June 6, 2002. 

Your statement that "Mr. Wroblewski testified that he did not invent the Accused Instrumentalities" is beside the 

point. Microchip has never stated that Mr. Wroblewski had anything to do with the "Accused Instrumentalities" (i.e., 

the www.microchip.com website). Your assertion (without any citation to actual testimony) that "[Mr. Wroblewski said] 

he did not invent anything in the Wroblewski Reference" is a non-sequitur. Mr. Wroblewski unequivocally testified that 

he wrote the entire book as the sole author. The fact that he said the combination of a drop-down menu with 

breadcrumbs was not an inventive concept and merely a natural combination that any beginner web-designer could do 

in early 2002 is further evidence of invalidity, not the other way around. For at least these reasons, Microchip will not 

withdraw its invalidity contentions. In view of Mr. Wroblewski's testimony and additional document productions, 

Microchip intends to seek leave of Court to supplement its invalidity contentions related to Wroblewski. Please let us 

know if you oppose. Thanks, Travis 

From: Veronica McCarty <vmccarty@devlinlawfirm.com> 

Sent: Saturday, October 23, 20219:59 AM 

To: Jensen, Travis <t jensen@orrick.com>; Frost, Claudia <cfrost@orrick.com>; Mao, Lillian J. <lmao@orrick.com>; 

coburn <coburn@sheltoncoburn.com>; bshelton <bshelton@sheltoncoburn.com> 

Cc: Alex Chan <achan@devlinlawfirm.com>; Vikhyat Kaushal <vkaushal@devlinlawfirm.com>; Timothy Devlin 

<tdevlin@devlinlawfirm.com> 

Subject: Caddo v. Microchip/NXP - Wroblewski Reference Letter 

Counsel, 

Please see the attached letter. 

Best, 

6 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 7 of 141
DEVLIN 

LAW FIRM LLC 

. ~ ...... ...,., ·~-

tmCIQIIIAw. ~ . DI! w 

t.11111•~ 111 I oar, •1• ....., .. 1111,.,,,m 

The information contained in this communication is confidential and is intended only for the use of the intended addressee. It is the 

property of Devlin Law Firm LLC, and may contain information subject to attorney-client privilege and/or may constitute inside 

information. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be 

unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail 

to correspondence@devlinlawfirm.com, and destroy this communication and all copies thereof, including all attachments. 

NOTICE TO RECIPIENT I This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you 

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the error by return e-mail and please delete this message from your system. Thank you in advance for your cooperation. 

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7 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 8 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-1- 

Case No. 6:20-cv-244-ADA (W.D. Tex.) Case No. 6:20-cv-245-ADA (W.D. Tex.)

Invalidity of U.S. Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,880; 1

by 

Wroblewski 

REFERENCE: “Site-Seeing: A Visual Approach to Web Usability,” by Luke Wroblewski (“Wroblewski” or “Site SeeinMinds in April no later than June 2002. Wroblewski is prior art to the ’411, ’301, ’517, ’836, ’880, and ’127 patents undand § 102(g)(2). Depending on the priority date of each Asserted Patent, Site Seeing may also qualify as prior art under unless otherwise indicated.1Mr. Luke Wroblewski, the author of Site Seeing, was deposed on October 13, 2021. His deposition testimony confirmed Site Seeing book qualified as prior art under both 102(a) and 102(g)(2). Mr. Wroblewski’s deposition also uncovered adwere subsequently produced) that Mr. Wroblewksi created in preparing the manuscript for his book (both his handwritteincluding the work performed on his website in relation to writing his book. Exemplary documents include, e.g., LW_0showing conception). Mr. Wroblewski testified that he wrote the Site-Seeing book (MCHP-CADDO_0010195), includiwhich pre-dates June 6, 2002 (LW_0013 with metadata dated April 4, 2002), and even provided his notes at the depositithe drop-down breadcrumb feature (LW_0856 at 881). Mr. Wroblewki testified that his publicly available website (whiimplemented the drop-down breadcrumb functionality described in his book and explained why that was the case (viz., bscreenshots on multiple different browsers to show how the website rendered). The Site Seeing book is also evidence of 1 To the extent that these Invalidity Contentions rely on or otherwise embody particular constructions of terms or phrases in the Asserted Claims

such constructions as proper constructions of those terms or phrases. Various positions put forth in this document are predicated on Plaintiff’s in

interpretation of its claims as evidenced by its Preliminary Infringement Contentions, dated September 17, 2020. Those positions are not intend

Defendant’s interpretation of the true and proper scope of Plaintiff’s claims, and Defendant reserves the right to adopt claim construction positio

with various positions put forth in this document. 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 9 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-2- 

motivation to combine, the level of ordinary skill in the art, and secondary considerations for obviousness. See, e.g., GeMach. Sys. Int’l LLC 618 F.3d 1294, 1305-1306 (Fed. Cir. 2010) (citations omitted) (“Independently made, simultaneoucomparatively short space of time, are persuasive evidence that the claimed apparatus was the product only of ordinary mskill.”); Newell Cos. v. Kenney Mfg. Co., 864 F.2d 757, 766 (Fed. Cir. 1988) (stating that a document which “was not tecadmissible to show that a person of ordinary skill in the art suggested solutions to the problem similar to that claimed in Smart Parts, Inc., Case No. 05-1273 (Fed. Cir. 2006); Ecolochem, Inc. v. Southern Cal. Edison Co., 227 F.3d 1361, 1379 Mr. Wroblewski conceived of the idea claimed in the asserted patents by late 2001, as reflected for example, in the noE.g., LW_0856 at LW_0881 (referring to “Cascading menu, dynamic menu (LukeW), BREADCRUMBS BREADCRUMBS ~ GENERIC (LukeW.com)”); Wroblewski Tr. at 83. Mr. Wroblewski reduced the idea to pracimplemented the “drop-down breadcrumb” menu on his website, www.lukew.com, in order to take screenshots for Wroblewski Tr. at 153-154, 194-195, 214; LW_0184; LW_0190. Starting in the late 1990’s, the field of web design and web usability was in “an exploratory phase and people are trying best practices, standards, ... expectations are.” Wroblewski Tr. at 35; see also, e.g., id. at 85-86. By early 2002 (and land dynamic user-controlled menus were both in widespread use on the web. Id. at 60-61, 68-79. Breadcrumb naviga2002 and becoming increasingly common. Id. at 65-66. One of ordinary skill in the art would have been aware of theoptions and have considered them and their advantages and disadvantages in designing navigation. Id. at 71-72, 81-83. Indeed, Mr. Wroblewski testified that he simply “merg[ed]” two concepts (breadcrumbs and drop-down menus) that werup with the claimed invention. Wroblewski Tr. at 83-84. In addition, the combination would not have required simplement and would yield predictable results, as it involved no more than the use of basic, common HTML elements. 200 (“It’s, literally, three HTML tags ... So from a skills required to build that out in code is very much a noncomplicated cwork is evidence of simultaneous invention, which tends to show the obviousness of the asserted claims. See, e.g., GMach. Sys. Int’l LLC, 618 F.3d 1294, 1305-1306 (Fed. Cir. 2010) (citations omitted) (“Independently made, simultaneocomparatively short space of time, are persuasive evidence that the claimed apparatus was the product only of ordinaskill.”). What follows immediately below is a summary of information testified about by Mr. Wroblewski. Luke Wroblewski is the sole author of “Site-Seeing: A Visual Approach to Web Usability” which was published in Juparent application of the Asserted Patents was filed. See MCHP-CADDO_0010195. Mr. Wroblewski was a leader in we

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 10 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-3- 

the early 2000s. Mr. Wroblewski was engaged in November of 2001 to author a book on website design, which culmin

Seeing the following year. Wroblewski Tr. at 16-17 (“I got the final addendum to the publishing agreement on Decemabout the book, which included some back-and-forth of sharing outlines and rough notes of what would be in the boomonths prior to that because we had a preliminary agreement dated November 27, 2001.”); see also LW_0890 (Contact A2001 referencing “Publishing Agreement dated November 27, 2001”). Mr. Wroblewski worked quickly and diligently to prepare an outline for his book, much of which took the form of handwTr. at 16-17, 36-37 (“You know, as part of this digging up of files, I actually uncovered the original notes that I (demonstrating). And you can see here, I would kind of start with generalized outlines. So the original proposal required uLW_0856 (handwritten notes). Mr. Wroblewski testified that he had the idea for the combination of a dynamic breadcrumb trial and a dropdown menu and showed the handwritten notes where we first made note of it. LW_0856 at LW_0881. The relevant text states: “ cascading menu, dynamic menu (LukeW), BREADCRUMBREADCRUMB ~ Generic (Lukew.com).” The reference to NCSA is the National Center for Supercomputing Applicat

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 11 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-4- 

leader in web design techniques and development where Mr. Wroblewksi used to work. Wroblewski Tr. at 21. Wroblewski’s website. The preceding page in the handwritten notes is dated December 16, 2001. LW_0856 at LW_0880With respect to timing, Mr. Wroblewski testified as follows: 

Q. When did you first come up with this idea of combining the breadcrumb with the drop-down? A. You know, it’s a good question. And I was flipping through my notes to the book, and I actually found, back (demonstrating) -- when I was doing the outline for the book prior to publishing it, there is a little bullet here. It generic/lukew.com,” and then above it, “Cascading Menu,” “Dynamic Menu,” “Breadcrumb,” “NCSA.” So dubook and thinking through what content would be in it, I had called it a “Dynamic breadcrumb” and written it dothat I would like to include in the book. So that would have been in the early phases of putting together the outlinwriting the chapter. 

Wroblewski Tr. at 83. No later than February 8, 2002, Mr. Wroblewski had completed the manuscript for the chapter ultimately contained the breadcrumb-dropdown concept. Wroblewski Tr. at 46-49; see also LW_0013 (excerpted below)

Drop down the breadcrumbs Though breadcrumbs are useful for showing you your position within a Web space, they provide little understanding of the scope of the entire site and offer no navigation choices beyond backtracking and returning home. Steve Krug, author of Don’t Make Me Think: A Common Sense Approach to Web Usability (2000, New Riders), compares breadcrumbs to written directions: “The directions can be useful, but you can learn more from [a] map.” In the example above, from the LukeW.com site, breadcrumbs are combined with drop-down menus to not only provide users with an understanding of their current position, but also an awareness of all the possible paths they didn’t take. In the current site implementation, only the portfolio 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 12 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-5- 

This version of Mr. Wroblewski’s manuscript looks visually different than the print version because it had not yet been 32-33 (“These are the Word files for the book as opposed to the Quark files which have the final layout. ‘Quark’ meanilayout program used back then to do graphic design.”); 49-50 (“Q. Is it fair to say you would consider February 2002 the the chapter? A. Yes. I will -- actually, let me take a step back. It was probably before then. I would consider February 8

samples use the drop-down method. (If users are interested in one Web design example, it is likely they might want to see more. This navigation features allows them to see the other available samples.) However, the technique could easily be expanded to the entire breadcrumb path (below) to provide a sense of context and scale (where am I, within how much?).When opened, the drop-down menu provides you with a sense of context: where you are and where you can go. 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 13 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-6- 

the final document version of it and sent it over for the publisher and for graphic design work. It may have been completit sat there until I actually packaged it up and sent it over.”). The “print” layout is at LW_0025 at 38 (see also LW_0110 was completed no later than April 16, 2002 according to the meta data (Wroblewski Ex. 1 at row 26). The graphics shown in the manuscript were screenshots of Mr. Wroblewski’s website (www.lukew.com) where he concept. See, e.g., Wroblewski Tr. at 214 (“So I would have gone into one of those pages, modified the HTML to impland taken the screenshots. And those screenshots that are in the folder of it how it looks like on different browsers -- righa web page. The best way I would be able to get those screenshots from the different platforms, from the PC and the Maby actually having it live on a server so I can go in to change over to PC, take the screenshot; change over to Mac, take tMr. Wroblewski’s files provided in this case contained additional screenshots that were not included in his book but available website in early 2002: “Q. And this example on page 59, you said this is the only example of dynamic breadcrThat was published, yes. In the Images folder that I provided, there was a number of, like, different renderings of what rendered as based off of what, like, different browsers supported.” Wroblewksi Tr. at 153-154; see also 194-195. For exacontained screenshots of his website as rendered by different web browsers at the time, such as “Internet Explorer 5” (ie5(nn4) as shown below. LW_0184 (lukew_ie5_mac.bmp) LW_0190 (lukew_nn4_mac.bmp). The metadata for these files indicate that dropdown breadcrumb was available on www.lukew.com no later than April 21 at rows 184 and 191. 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 14 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-7- 

Mr. Wroblewksi authored and maintained a publicly available website at the URL: www.lukew.com. See, e.g., Wroblewswaiting for that, what was the URL of your website? A. lukew.com. Q. Has that been your website throughout time? A. Fo194-195 (“Q. But how the image for the book was created was through -- was through photo -- was through Photoshop? A. of Photoshop and screenshots of HTML code. There was no -- like, all these elements were not created from scratch. Thsaid, an existing web page design where I started to introduce some additional HTML elements, and then took a screensinto Photoshop to clean it up, remove some of the elements, and style it a bit differently. Q. Which website were you -on? A. lukew.com, my personal website. Q. And did you keep it as it’s shown on page -- as it's shown on page 59 of Eway after you got your screenshot? A. There is a period of time that I kept it as the image of both, I believe.”); 230-234 reflection of how your website looked and operated early 2002, either the partial character of the Wayback Machinpersonally took of your own website in early 2002? A. Oh, I think the screenshots would be more accurate because they these missing images and missing content that the Wayback Machine has here. As you can see, like, in this case, it’s nthe images, but it is rendering the breadcrumb with the drop-down.”). The Site-Seeing book published in June of 2002. Wroblewski Tr. at 52 (“Q. Do you recall when the ‘Site-Seeing’ book believe it was June 2002.”); 53 (“It just has two files inside the printed edition. But off their record, I seem to rememblike, a publication date.”). The preface indicates that it was completed in April 2002. See MCHP-CADDO_0010195 at 258 of the Site-Seeing book, titled “Drop Down the Breadcrumbs” is shown below. MCHP-CADDO_0010195 at 273. 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 15 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-8- 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 16 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-9- 

The text accompanying this section explains that: 

Though breadcrumbs are useful for showing you your position within a Web space, they provide little understandentire site and offer no navigation choices beyond backtracking and returning home. Steve Krug, author of DonCommon Sense Approach to Web Usability (2000, New Riders), compares breadcrumbs to written directions: "useful, but you can learn more from [a] map." In the example above, breadcrumbs are combined with drop-doprovide users with an understanding of their current position, but also an awareness of all the possible paths tcurrent site implementation, only the portfolio samples use the drop-down method. (If users are interested in one it is likely they might want to see more. This navigation features allows them to see the other available samples.) Hcould easily be expanded to the entire breadcrumb path (below) to provide a sense of context and scale (where am 

Id. All of the aforementioned work by Mr. Wroblewski was done in the United States. See, e.g., Wroblewsi Tr. at 20-22 (wIllinois), 58 (“Q. And just to confirm, was the book published and publicly distributed in the United States? A. It was -102, 212 (“Q. But you did have -- your website was publicly available in early 2002, right? A. Yes. Q. And so the ultiwas to make the information in your book available to the public, correct? A. t was to make it available, yes, publicly, cIn summary, Mr. Wroblewksi came up with the same drop-down breadcrumb concept in the Asserted Patents. And he 2002 filing date of the earliest patent application as is well document by his hand-written notes, screenshots of his publidraft manuscripts for his book, and the publication of the Site-Seeing book itself. The similarity of the Mr. Wroblewskithat of the Asserted Patents (on the bottom) is readily apparent and striking, as illustrated in the comparison below. Waccompanying testimony). 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 17 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-10- 

As Mr. Wroblewski repeatedly (and correctly) testified, combing breadcrumbs with a drop-down menu was not a patenta

on obvious and natural combination that was trivial to implement. See, .e.g. Wroblewski Tr. at 80 (“Q. Did you considNo, I did not.”), 102-103 (“Those are pretty standard HTML controls, and the combination of those two things does nothat is patent[able]... But I very much viewed it as a combination of pretty accepted conventions already and then, thereand of itself, if that makes sense.”), 168 (“I view that as just the combination of two standard elements into kind ofaugmentation, if you will. ... I said the things I published in my book, I do not view as innovative or, you know, when I puto me to try and patent it.”), 198-199 (“The average web developer would be able to use those common HTML elementliterally, three HTML tags: an unordered list, and a linked tag, and a select tag. So the entire code there, absent the conlike, two lines of code. Q. Do you think -- what you’ve created on page 59, do you think that’s, that’s average? A. It’s baif you learn to code HTML, the first thing you will learn to code is a paragraph; the second thing you will learn to codthird or fourth thing is going to be an unordered list, and a select menu. So from a skills required to build that out in code is category.”), 200 (“I’m saying it’s not innovative. ... But I didn’t think of it as particularly innovative, which is a differe

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 18 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-11- 

’411 Claim 1-I 

’411 Patent Claim 1 Disclosure 

1. A method for navigating within a multi-level hierarchical collapsing menu 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: 

To the extent the preamble is limiting, Wroblewski, as evidenced by the example citations below, diswithin a multi-level hierarchical collapsing menu structure where each level in the menu contains plu

least one of a function, a pointer to a location, and a pointer to another level, as this language appears 

See e.g.: 

 “Another popular solution is to use ‘space-saving’ navigation elements to strike an adequate 

adequate navigation/content balance. Cascading menus, dynamic user-controlled menus, drare just a few ‘space-saving’ elements common today. (See sidebar to right) Each of these 

and drawbacks, which you need to be aware of before committing your site to one.” Wroble

 Wroblewski at 56: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 19 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-12- 

’411 Patent Claim 1 Disclosure 

 Wroblewski at 54: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 20 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-13- 

’411 Patent Claim 1 Disclosure 

 Wroblewski at 63: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 21 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-14- 

’411 Patent Claim 1 Disclosure 

See also LW

_

0003; LW

_

0013.

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 22 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-15- 

’411 Patent Claim 1 Disclosure 

[a] providing a graphical user menu system displaying the items of a given level and enabling selection thereof, wherein access of said given level requires sequential access of each of the levels preceding said given level in the hierarchy; 

Wroblewski, as evidenced by the example citations below, discloses providing a graphical user menu 

given level and enabling selection thereof, wherein access of said given level requires sequential accesaid given level in the hierarchy, as this claim limitation appears to be interpreted by Caddo. 

See e.g.: 

 “Another popular solution is to use ‘space-saving’ navigation elements to strike an adequate 

adequate navigation/content balance. Cascading menus, dynamic user-controlled menus, drare just a few ‘space-saving’ elements common today. (See sidebar to right) Each of these 

and drawbacks, which you need to be aware of before committing your site to one.” Wroble

 Wroblewski at 56: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 23 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-16- 

’411 Patent Claim 1 Disclosure 

 Wroblewski at 54: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 24 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-17- 

’411 Patent Claim 1 Disclosure 

 Wroblewski at 63: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 25 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-18- 

’411 Patent Claim 1 Disclosure 

See also LW_0003; LW_0013.

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 26 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-19- 

’411 Patent Claim 1 Disclosure 

[b] automatically constructing an Active Path as a sequence of hierarchical active links as items are selected using the graphical user menu system without the need for any additional interaction with the graphical user system, with one said active link corresponding to each of the items selected, each said active link being independently selectable thereby providing direct access to the hierarchical level from which the corresponding item was selected without the need to navigate using said graphical user menu system; and 

The Court construed “Active Path” as “a sequence of links dynamically created as a menu system is nConstruction Order dated April 24, 2021, pg. 2. Hereinafter in this document, “Active Path” refers b

and to Caddo’s interpretation of that term. Wroblewski, as evidenced by the example citations below

constructing an Active Path as a sequence of hierarchical active links as items are selected using the g

without the need for any additional interaction with the graphical user system, with one said active lin

items selected, each said active link being independently selectable thereby providing direct access to 

the corresponding item was selected without the need to navigate using said graphical user menu syst

(including the Court’s construction) appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 56: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 27 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-20- 

’411 Patent Claim 1 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 28 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-21- 

’411 Patent Claim 1 Disclosure 

 LW_0184: 

 LW_0190: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 29 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-22- 

’411 Patent Claim 1 Disclosure 

See also LW_0003; LW_0013.

[c] displaying the Active Path as an alternative to the graphical user menu system for navigating the multi-level hierarchical collapsing menu structure after the user has finished selecting items using the graphical user system such that the Active Path is displayed after the multi-level hierarchical collapsing menu structure has collapsed; 

Wroblewski, as evidenced by the example citations below, discloses displaying the Active Path as an menu system for navigating the multi-level hierarchical collapsing menu structure after the user has fgraphical user system such that the Active Path is displayed after the multi-level hierarchical collapsias this claim limitation appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 56: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 30 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-23- 

’411 Patent Claim 1 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 31 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-24- 

’411 Patent Claim 1 Disclosure 

 LW_0184: 

 LW_0190: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 32 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-25- 

’411 Patent Claim 1 Disclosure 

See also LW_0003; LW_0013.

[d] wherein pre-selecting a given active link triggers the display of sibling menu items on the level associated with said given active link without disturbing the displayed Active Path. 

Wroblewski, as evidenced by the example citations below, discloses that pre-selecting a given active menu items on the level associated with said given active link without disturbing the displayed Activ

appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 56:  Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 33 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-26- 

’411 Patent Claim 1 Disclosure 

See also LW_0003; LW_0013; Wroblewski Tr. at 74-75. 

At a minimum, it would have been obvious to a POSITA to include that pre-selecting a given active l

menu items. See Exhibits B-1 (displaying sibling items) and B-2 (pre-selecting and rolling over). Se

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 34 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-27- 

’411 Patent Claim 1 Disclosure 

75 (“Q. And kind of going back to what you mentioned earlier. Was it a design choice whether to -- menus, to expand by clicking or hovering? A. Yeah. You can implement it one way or the other. Agaarguments people had about, "Well, you should require the user to click so you're not popping things should actually be exposing these things to people and not requiring them to click so they know whatusability back-and-forth conversation on which choice to make.”).

’411 Claim 2

’411 Patent Claim 2 Disclosure 

2. The method for navigating according to claim 1, further comprising: [a] providing pre-defined short-cuts enabling direct access to a given item; and 

Wroblewski, as evidenced by the example citations below, discloses providing pre-defined short-cuts item, as this claim limitation appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 56: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 35 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-28- 

’411 Patent Claim 2 Disclosure 

See also LW_0003; LW_0013. 

At a minimum, it would have been obvious to a POSITA to include pre-defined short-cuts enabling d

Exhibit B-4. See also Wroblewski Tr. at 64 (“Q. Do the breadcrumbs reflect that the user had naviga

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 36 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-29- 

’411 Patent Claim 2 Disclosure 

shown? A. They may have; they may not have. They may have more directly entered the Origin2000 page, but then the breadcrumb there informs them where they are in the context of the navigation. Thdirectly traversed the "User Information," then gone to "Resources," then gone to "Hardware," and thoptions are possible.”).

[b] automatically constructing the Active Path when a pre-defined shortcut 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. 

Wroblewski, as evidenced by the example citations below, discloses automatically constructing the Ashort-cut is executed, with one said active link corresponding to each of the items necessary to access graphical user menu system., as this claim limitation appears to be interpreted by Caddo. 

See e.g.: 

 Wroblewski at 56: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 37 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-30- 

’411 Patent Claim 2 Disclosure 

See also LW_0003; LW_0013.

’411 Claim 3

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 38 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-31- 

’411 Patent Claim 3 Disclosure 

3. 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. 

Wroblewski, as evidenced by the example citations below, discloses that selecting a given active link function associated with the given active link, as this claim limitation appears to be interpreted by CaSee e.g.: 

 Wroblewski at 56: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 39 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-32- 

’411 Patent Claim 3 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 40 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-33- 

’411 Patent Claim 3 Disclosure 

See also LW_0003; LW_0013.

’411 Claim 4

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 41 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-34- 

’411 Patent Claim 4 Disclosure 

4. The method for navigating according to claim 1, wherein selecting a given active link triggers display of information associated with said given active link. 

Wroblewski, as evidenced by the example citations below, discloses that selecting a given active link 

associated with said given active link, as this claim limitation appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 56:  Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 42 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-35- 

’411 Patent Claim 4 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 43 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-36- 

’411 Patent Claim 4 Disclosure 

See also LW_0003; LW_0013.

’411 Claim 6

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 44 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-37- 

’411 Patent Claim 6 Disclosure 

6. The method for navigating according to claim 1, wherein preselecting a given menu item displayed while pre-selecting the given active link triggers the display of subordinate menu items. 

Wroblewski, as evidenced by the example citations below, discloses that pre-selecting a given menu the given active link triggers the display of subordinate menu items, as this claim limitation appears tSee e.g.: 

 Wroblewski at 56:  Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 45 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-38- 

’411 Patent Claim 6 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 46 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-39- 

’411 Patent Claim 6 Disclosure 

See also LW_0003; LW_0013. At a minimum, it would have been obvious to a POSITA to include that pre-selecting a given menu isubordinate menu items. See Exhibit B-2. See also Wroblewski Tr. at 61-62, 75 (“Q. And kind of goearlier. Was it a design choice whether to -- whether, for these drop-down menus, to expand by clickcan implement it one way or the other. Again, coming back to some of the arguments people had abouser to click so you're not popping things up by default," or, "Hey, we should actually be exposing threquiring them to click so they know what's possible." That's kind of the usability back-and-forth conmake.”).

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 47 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-40- 

’301 Claim 1-I 

’301 Patent Claim 1 Disclosure 

1. A method for navigating within a multi-level hierarchical information structure where each level in the information structure 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: 

To the extent the preamble is limiting, this element is satisfied by the disclosure set forth in connectioclaim 1 preamble.

[a] providing a graphical user menu system displaying the items of a given level of the hierarchical information structure and enabling selection thereof; and 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim 1[

[b] dynamically constructing an Active Path as a sequence of active links as items are selected using the graphical user menu system, with one said active link corresponding to each of the items selected, 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; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim 1[

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 48 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-41- 

’301 Patent Claim 1 Disclosure 

[c] each said active link enabling the user to directly browse all items on any given level of the hierarchical information structure including all hierarchically subordinate items without affecting the Active Path. 

Wroblewski, as evidenced by the example citations below, discloses that pre-selecting a given menu 

the given active link triggers the display of subordinate menu items, as this claim limitation appears t

See e.g.: 

 Wroblewski at 56: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 49 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-42- 

’301 Patent Claim 1 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 50 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-43- 

’301 Patent Claim 1 Disclosure 

 LW_0184: 

 LW_0190: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 51 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-44- 

’301 Patent Claim 1 Disclosure 

See also LW_0003; LW_0013.At a minimum, it would have been obvious to a POSITA to include browsing all hierarchically subor

links. See, e.g., Exhibit A-6 at 50-55.

’301 Claim 2

’301 Patent Claim 2 Disclosure 

2. The method for navigating according to claim 1, further comprising: [a] providing pre-defined short-cuts enabling direct access to a given item; and 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

[b] dynamically constructing the Active Path when a pre-defined shortcut is executed, with one said active link corresponding to each of the items necessary to access said given item 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 52 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-45- 

’301 Patent Claim 2 Disclosure 

using said graphical user menu system. 

’301 Claim 3

’301 Patent Claim 3 Disclosure 

3. The method for navigating according to claim 1, wherein rolling over a selected active link triggers the display of sibling items on the hierarchically subordinate levels associated with said selected active link. 

Wroblewski, as evidenced by the example citations below, discloses that rolling over a selected activsibling items on the hierarchically subordinate levels associated with said selected active link, as this 

interpreted by Caddo. See e.g.: 

 Wroblewski at 56:  Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 53 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-46- 

’301 Patent Claim 3 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 54 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-47- 

’301 Patent Claim 3 Disclosure 

 LW_0184: 

 LW_0190: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 55 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-48- 

’301 Patent Claim 3 Disclosure 

See also LW_0003; LW_0013.At a minimum, it would have been obvious to a POSITA to include that rolling over a selected active 

sibling menu items on the hierarchically subordinate levels. See Exhibits B-1 (displaying sibling item

rolling over).

’301 Claim 4

’301 Patent Claim 4 Disclosure 

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. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim 3.

’301 Claim 5

’301 Patent Claim 5 Disclosure 

5. The method for navigating according to claim 1, wherein selecting a given active link triggers 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim 4.

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 56 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-49- 

’301 Patent Claim 5 Disclosure 

display of information associated with said given active link. 

’301 Claim 9 

’301 Patent Claim 9 Disclosure 

9. A method for navigating within a multi-level hierarchical information structure where each level in the structure 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: 

To the extent the preamble is limiting, this element is satisfied by the disclosure set forth in connectioclaim 1 preamble.

[a] displaying a graphic element representing a root of the hierarchical information structure; 

Wroblewski, as evidenced by the example citations below, discloses displaying a graphic element rephierarchical information structure, as this claim limitation appears to be interpreted by Caddo.See e.g.: 

 “The first level is included on all the pages within our site in order to provide our audience 

Your audience will be confident that they can get through your site if they know they can cobe there when they need them.” Wroblewski at 48. 

 Wroblewski at 49: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 57 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-50- 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 58 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-51- 

’301 Patent Claim 9 Disclosure 

 Wroblewski at 52:  Wroblewski at 53: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 59 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-52- 

’301 Patent Claim 9 Disclosure 

See also LW_0003; LW_0013.

[b] browsing the hierarchical information structure by rolling over said graphic element using a pointing device, wherein browsing results in the display of sibling items or hierarchically subordinate items; 

Wroblewski, as evidenced by the example citations below, discloses browsing the hierarchical informsaid graphic element using a pointing device, wherein browsing results in the display of sibling items items, as this claim limitation appears to be interpreted by Caddo.See e.g.: 

 Wroblewski at 53: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 60 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-53- 

’301 Patent Claim 9 Disclosure 

 Wroblewski at 49: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 61 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-54- 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 62 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-55- 

’301 Patent Claim 9 Disclosure 

 Wroblewski at 56:  Wroblewski at 54: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 63 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-56- 

’301 Patent Claim 9 Disclosure 

 Wroblewski at 63: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 64 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-57- 

’301 Patent Claim 9 Disclosure 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 65 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-58- 

’301 Patent Claim 9 Disclosure 

See also LW_0003; LW_0013; Wroblewski Tr. at 74-75. At a minimum, it would have been obvious to a POSITA to include browsing the hierarchical informgraphic to display sibling items or hierarchically subordinate items. See Exhibits B-1 (displaying siband rolling over). See also Wroblewski Tr. at 61-62, 75 (“Q. And kind of going back to what you mechoice whether to -- whether, for these drop-down menus, to expand by clicking or hovering? A. Yeor the other. Again, coming back to some of the arguments people had about, "Well, you should requpopping things up by default," or, "Hey, we should actually be exposing these things to people and noknow what's possible." That's kind of the usability back-and-forth conversation on which choice to m

[c] selecting one of the displayed items; 

Wroblewski, as evidenced by the example citations below, discloses selecting one of the displayed iteappears to be interpreted by Caddo.See e.g.: 

 Wroblewski at 56: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 66 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-59- 

’301 Patent Claim 9 Disclosure 

 Wroblewski at 54: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 67 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-60- 

’301 Patent Claim 9 Disclosure 

 Wroblewski at 63: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 68 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-61- 

’301 Patent Claim 9 Disclosure 

See also LW_0003; LW_0013.

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 69 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-62- 

’301 Patent Claim 9 Disclosure 

[d] dynamically constructing an Active Path as a sequence of active links as items are selected, with one said active link corresponding to each of the items selected, said active links providing direct access to one of a function, corresponding level and item without the need to navigate from the root of the hierarchical information structure; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’301 claim el

[e] each said active link enabling the user to directly browse all items on any given level of the hierarchical information structure including all hierarchically subordinate items without affecting the Active Path. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’301 claim 1[

’517 Claim 1-I 

’517 Patent Claim 1 Disclosure 

1. A method for navigating within a hierarchical menu structure where each level in the menu contains plural items, said method comprising the steps of: 

To the extent the preamble is limiting, this element is satisfied by the disclosure set forth in connectioclaim 1 preamble.

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 70 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-63- 

’517 Patent Claim 1 Disclosure 

[a] providing a graphical user menu system displaying the items of a given level and enabling selection thereof, wherein access of said given level requires sequential access of each of the levels preceding said given level in the hierarchy; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

[b] constructing an Active Path as a sequence of hierarchical active links as items are selected using the graphical user menu system, with one said active link corresponding to each of the items selected, each said active link providing direct access to the hierarchical level from which the corresponding item was selected without using said graphical user menu system; and 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

[c] displaying the Active Path as an alternative to the graphical user menu system for navigating the menu structure after the user has finished selecting items using the graphical user system such that the Active Path is displayed; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 71 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-64- 

’517 Patent Claim 1 Disclosure 

[d] wherein rolling over a given active link with the pointer of a pointing device triggers the display of menu items on the hierarchical level associated with said given active link without disturbing the displayed Active Path. 

Wroblewski, as evidenced by the example citations below, discloses that rolling over a given active ldevice triggers the display of menu items on the hierarchical level associated with said given active lidisplayed Active Path, as this claim limitation appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 56:  Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 72 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-65- 

’517 Patent Claim 1 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 73 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-66- 

’517 Patent Claim 1 Disclosure 

 LW_0184:  LW_0190: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 74 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-67- 

’517 Patent Claim 1 Disclosure 

See also LW_0003; LW_0013.At a minimum, it would have been obvious to a POSITA to include rolling over a given active link wdevice. See Exhibit B-2. See also Wroblewski Tr. at 61-62, 75 (“Q. And kind of going back to what design choice whether to -- whether, for these drop-down menus, to expand by clicking or hovering? one way or the other. Again, coming back to some of the arguments people had about, "Well, you shoyou're not popping things up by default," or, "Hey, we should actually be exposing these things to peclick so they know what's possible." That's kind of the usability back-and-forth conversation on whic

’517 Claim 2

’517 Patent Claim 2 Disclosure 

2. The method for navigating according to claim 1, further comprising: [a] providing pre-defined short-cuts enabling direct access to a given menu item; and 

This element is satisfied by the disclosure set forth in connection with the discussion of ’301 claim el

[b] automatically constructing the Active Path when a pre-defined shortcut is executed, with one said active 

This element is satisfied by the disclosure set forth in connection with the discussion of ’301 claim el

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 75 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-68- 

’517 Patent Claim 2 Disclosure 

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

’517 Claim 3

’517 Patent Claim 3 Disclosure 

3. The method for navigating according to claim 1, wherein rolling over a selected active link triggers the display of sibling items on the hierarchically subordinate levels associated with said selected active link. 

Wroblewski, as evidenced by the example citations below, discloses that rolling over a selected activsibling items on the hierarchically subordinate levels associated with said selected active link, as this interpreted by Caddo. See e.g.: 

 Wroblewski at 56:  Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 76 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-69- 

’517 Patent Claim 3 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 77 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-70- 

’517 Patent Claim 3 Disclosure 

 LW_0184:  LW_0190: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 78 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-71- 

’517 Patent Claim 3 Disclosure 

See also LW_0003; LW_0013.At a minimum, it would have been obvious to a POSITA to include that pre-selecting a given active lmenu items. See Exhibits B-1 (displaying sibling items) and B-2 (pre-selecting and rolling over). Se75 (“Q. And kind of going back to what you mentioned earlier. Was it a design choice whether to -- menus, to expand by clicking or hovering? A. Yeah. You can implement it one way or the other. Agaarguments people had about, "Well, you should require the user to click so you're not popping things should actually be exposing these things to people and not requiring them to click so they know whatusability back-and-forth conversation on which choice to make.”).

’517 Claim 4

’517 Patent Claim 4 Disclosure 

4. The method for navigating according to claim 3, wherein browsing a given active menu item triggers the display of subordinate menu items. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’411 claim 6.

’517 Claim 5

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 79 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-72- 

’517 Patent Claim 5 Disclosure 

5. 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. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’301 claim 4.

’517 Claim 6

’517 Patent Claim 6 Disclosure 

6. The method for navigating according to claim 1, wherein selecting a given active link triggers display of information associated with said given active link. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’411 claim 4.

’836 Claim 1-I 

’836 Patent Claim 1 Disclosure 

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 

To the extent the preamble is limiting, this element is satisfied by the disclosure set forth in connectio

claim 1 preamble. 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 80 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-73- 

’836 Patent Claim 1 Disclosure 

another level, said method comprising the steps of: [a] providing a graphical user menu system displaying the items of a given level of the hierarchical information structure and enabling selection thereof and 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim 1[

[b] 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 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; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim 1[

[c] 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 

This element is satisfied by the disclosure set forth in connection with the discussion of ’301 claim el

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 81 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-74- 

’836 Patent Claim 1 Disclosure 

hierarchically subordinate levels without affecting the Active Path. 

’836 Claim 2

’836 Patent Claim 2 Disclosure 

2. The method for navigating according to claim 1, further comprising: [a] providing pre-defined short-cuts enabling direct access to a given menu item; and 

This element is satisfied by the disclosure set forth in connection with the discussion of ’301 claim el

[b] dynamically constructing the Active Path when a pre-defined shortcut 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. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’301 claim el

’836 Claim 3

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 82 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-75- 

’836 Patent Claim 3 Disclosure 

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. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’301 claim 3.

’836 Claim 4

’836 Patent Claim 4 Disclosure 

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. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’301 claim 4. 

’836 Claim 5

’836 Patent Claim 5 Disclosure 

5. The method for navigating according to claim 1, wherein selecting a given active link triggers 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’411 claim 4.

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 83 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-76- 

’836 Patent Claim 5 Disclosure 

display of information associated with said given active link. 

’836 Claim 7

’836 Patent Claim 7 Disclosure 

7. The method according to claim 1, wherein the multi-level hierarchical information structure is a website. 

Wroblewski, as evidenced by the example citations below, discloses that the multi-level hierarchical as this claim limitation appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 49: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 84 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-77- 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 85 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-78- 

’836 Patent Claim 7 Disclosure 

 Wroblewski at 52:  Wroblewski at 53: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 86 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-79- 

’836 Patent Claim 7 Disclosure 

See also LW

_

0003; LW

_

0013.

’836 Claim 8-I 

’836 Patent Claim 8 Disclosure 

8. A method for navigating websites including a plurality of hierarchically organized web pages, said method comprising: 

To the extent the preamble is limiting, Wroblewski, as evidenced by the example citations below, diswithin a multi-level hierarchical collapsing menu structure where each level in the menu contains pluleast one of a function, a pointer to a location, and a pointer to another level, as this language appears See e.g.: 

 Wroblewski at 53: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 87 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-80- 

’836 Patent Claim 8 Disclosure 

 Wroblewski at 49: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 88 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-81- 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 89 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-82- 

’836 Patent Claim 8 Disclosure 

 Wroblewski at 56:  Wroblewski at 54: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 90 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-83- 

’836 Patent Claim 8 Disclosure 

 Wroblewski at 63: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 91 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-84- 

’836 Patent Claim 8 Disclosure 

See also LW_0003; LW_0013

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 92 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-85- 

’836 Patent Claim 8 Disclosure 

[a] providing a means for navigating the multi-level hierarchical website; 

The Court construed this limitation as a “means plus” limitation governed by §112¶6 with the “functilevel hierarchical website” and the corresponding structure being the “graphical user menu system as ’836 patent. See Claim Construction Order dated April 24, 2021, pg. 3. Wroblewski, as evidenced bdiscloses providing a means for navigating the multi-level hierarchical website, as this claim limitatioconstruction) appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 53: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 93 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-86- 

’836 Patent Claim 8 Disclosure 

 Wroblewski at 49: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 94 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-87- 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 95 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-88- 

’836 Patent Claim 8 Disclosure 

 Wroblewski at 56:  Wroblewski at 54: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 96 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-89- 

’836 Patent Claim 8 Disclosure 

 Wroblewski at 63: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 97 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-90- 

’836 Patent Claim 8 Disclosure 

See also LW_0003; LW_0013

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 98 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-91- 

’836 Patent Claim 8 Disclosure 

[b] dynamically constructing an Active Path 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; wherein a user may directly access any given level of the hierarchical structure by selecting a given said active link; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’301 claim el

[c] 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. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’301 claim el

’880 Claim 1-I 

’880 Patent Claim 1 Disclosure 

1. A method of navigating an information structure comprising: 

To the extent the preamble is limiting, this element is satisfied by the disclosure set forth in connectioclaim 1 preamble and ’301 claim 1 preamble. 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 99 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-92- 

’880 Patent Claim 1 Disclosure 

[a] providing a graphical menu interface displaying the items of a given level of the information structure and enabling selection thereof; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim elelement 1[a]. 

[b] dynamically constructing an active 

path as a sequence of active links after an item of the information structure has been selected; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

element 1[b]. 

[c] upon provisional selection of any said active link, displaying one or more items on a given level of the information structure without affecting the active path; and 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

[d] said active links allowing a user to access an item in the information structure by selecting from the one or more items displayed by one of the active links on the active path. 

Wroblewski, as evidenced by the example citations below, discloses that the active links allow a user information structure by selecting from the one or more items displayed by one of the active links on limitation appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 56: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 100 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-93- 

’880 Patent Claim 1 Disclosure 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 101 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-94- 

’880 Patent Claim 1 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 102 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-95- 

’880 Patent Claim 1 Disclosure 

 LW_0184:  LW_0190: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 103 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-96- 

’880 Patent Claim 1 Disclosure 

See also LW_0003; LW_0013.

’880 Claim 3

’880 Patent Claim 3 Disclosure 

3. The method of claim 1, wherein the one or more active links allow the display of one or more items on a given level of the information structure when a pointer is rolled over one of the active links. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’517 claim el

’880 Claim 4

’880 Patent Claim 4 Disclosure 

4. The method of claim 1, wherein the one or more active links allow the display of one or more items on a given level of the information 

Wroblewski, as evidenced by the example citations below, discloses that one or more active links allo

items on a given level of the information structure when one of the active links is selected, as this cla

interpreted by Caddo. 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 104 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-97- 

’880 Patent Claim 4 Disclosure 

structure when one of the active links is selected. 

See e.g.: 

 Wroblewski at 56: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 105 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-98- 

’880 Patent Claim 4 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 106 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-99- 

’880 Patent Claim 4 Disclosure 

 LW_0184: 

 LW_0190: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 107 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-100- 

’880 Patent Claim 4 Disclosure 

See also LW_0003; LW_0013.

’880 Claim 5

’880 Patent Claim 5 Disclosure 

5. The method of claim 1, wherein the one or more active links allow the display of one or more items on a given level of the information structure when a visual icon associated with one of the active links is selected. 

Wroblewski, as evidenced by the example citations below, discloses that one or more active links allo

items on a given level of the information structure when a visual icon associated with one of the activ

limitation appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 56: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 108 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-101- 

’880 Patent Claim 5 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 109 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-102- 

’880 Patent Claim 5 Disclosure 

 LW_0184: 

 LW_0190: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 110 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-103- 

’880 Patent Claim 5 Disclosure 

See also LW_0003; LW_0013.

’880 Claim 6

’880 Patent Claim 6 Disclosure 

6. The method of claim 1, wherein the active links in the active path allow the display of one or more items on a given level of the information structure without changing the active path. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

’880 Claim 7

’880 Patent Claim 7 Disclosure 

7. The method of claim 1, wherein a user may directly access one or more active links in the active path by selecting the active link. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 111 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-104- 

’880 Claim 8

’880 Patent Claim 8 Disclosure 

8. The method of claim 7, wherein the selection of an active link causes the active path to truncate to the selected active link. 

Wroblewski, as evidenced by the example citations below, discloses that the selection of an active lintruncate to the selected active link, as this claim limitation appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 56: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 112 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-105- 

’880 Patent Claim 8 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 113 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-106- 

’880 Patent Claim 8 Disclosure 

 Wroblewski Tr. at 64-65 (“Q. What happens if the user clicks on one of the links in the brea

to that. ... in most cases, they'd be taken to a different web page containing that informationthat different web page be different? A. Yes. They would reflect where they were in the siteand chain. So if someone clicked on "Resources," they would no longer see the "Hardware" breadcrumb, they would just see the home "User Information," and "Resources" would be bthe "Hardware" and "Origin" part be truncated when -- if they clicked on "Resources"? A. Y

At a minimum, it would have been obvious to a POSITA to include that the selection of an active link truncate to the selected active link. See Exhibit B-3.

’880 Claim 9

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 114 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-107- 

’880 Patent Claim 9 Disclosure 

9. The method of claim 1, further providing pre-defined shortcuts that enable direct access to a given item in the information structure, wherein selection of a predefined shortcut dynamically constructs an active path including one active link corresponding to each item necessary to navigate to the given item in the information structure. 

Wroblewski, as evidenced by the example citations below, discloses that providing pre-defined short

given item in the information structure, wherein selection of a predefined shortcut dynamically constractive link corresponding to each item necessary to navigate to the given item in the information stru

appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 56: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 115 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-108- 

’880 Patent Claim 9 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 116 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-109- 

’880 Patent Claim 9 Disclosure 

See also LW_0003; LW_0013. 

At a minimum, it would have been obvious to a POSITA to include pre-defined short-cuts enabling d

Exhibit B-4. See also Wroblewski Tr. at 64 (“Q. Do the breadcrumbs reflect that the user had naviga

shown? A. They may have; they may not have. They may have more directly entered the Origin2000 page, but then the breadcrumb there informs them where they are in the context of the navigation. Thdirectly traversed the "User Information," then gone to "Resources," then gone to "Hardware," and thoptions are possible.”).

’880 Claim 10-I 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 117 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-110- 

’880 Patent Claim 10 Disclosure 

10. An apparatus for navigating an information structure, the apparatus including a processor configured to: 

To the extent the preamble is limiting, this element is satisfied by the disclosure set forth in connectioclaim 1 preamble and ’301 claim 1 preamble and ’880 claim 1 preamble. 

Wroblewski, as evidenced by the example citations below, discloses a processor, as this claim limitat

Caddo. See e.g.: 

 Wroblewski at 53: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 118 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-111- 

’880 Patent Claim 10 Disclosure 

 Wroblewski at 49: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 119 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-112- 

’880 Patent Claim 10 Disclosure 

 Wroblewski at 56: 

A POSITA would have understood that the webpages in Wroblewski is implemented and designed in contains a processor controlling the computer. 

[a] provide a graphical menu interface displaying the items of a given level of the information structure and enabling selection thereof; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

1[a], and ’880 claim element 1[a]. 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 120 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-113- 

’880 Patent Claim 10 Disclosure 

[b] dynamically construct an active 

path as a sequence of active links after an item of the information structure has been selected; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

1[b], and ’880 claim element 1[b]. 

[c] upon provisional selection of a given one of said active links, display one or more items on a given level of the information structure associated with said provisionally selected active link without affecting the active path; and 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

element 1[c]. 

[d] allow a user to access an item in the information structure by selecting the item from the one or more items displayed by one of the active links on the active path. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim el

’880 Claim 12

’880 Patent Claim 12 Disclosure 

12. The apparatus of claim 10, wherein the one or more active links allow the display of one or more items on a given level of the information 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 3.

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 121 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-114- 

’880 Patent Claim 12 Disclosure 

structure when a pointer is rolled over one of the active links. 

’880 Claim 13

’880 Patent Claim 13 Disclosure 

13. The apparatus of claim 10, wherein the one or more active links allow the display of one or more items on a given level of the information structure when one of the active links is selected. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 4.

’880 Claim 14

’880 Patent Claim 14 Disclosure 

14. The apparatus of claim 10, wherein the one or more active links allow the display of one or more items on a given level of the information structure when a visual icon associated with one of the active links is selected. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 5.

’880 Claim 15

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 122 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-115- 

’880 Patent Claim 15 Disclosure 

15. The apparatus of claim 10, wherein the active links in the active path allow the display of one or more items on a given level of the information structure without changing the active path. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 6.

’880 Claim 16

’880 Patent Claim 16 Disclosure 

16. The apparatus of claim 10, wherein a user may directly access one or more active links in the active path by selecting the active link. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 7.

’880 Claim 17

’880 Patent Claim 17 Disclosure 

17. The apparatus of claim 16, wherein the selection of an active link causes the active path to truncate to the selected active link. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 8.

’880 Claim 18

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 123 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-116- 

’880 Patent Claim 18 Disclosure 

18. The apparatus of claim 10 further configured to provide pre-defined shortcuts to enable access to a given item in the information structure, wherein selection of a pre-defined shortcut dynamically constructs an active path including one active link corresponding to each item necessary to navigate to the given item in the information structure. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 9.

’880 Claim 19

’880 Patent Claim 19 Disclosure 

19. The apparatus of claim 10, wherein two functions are associated with at least one of said active links. 

Wroblewski, as evidenced by the example citations below, discloses that two functions are associated links, as this claim limitation appears to be interpreted by Caddo. See e.g.: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 124 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-117- 

’880 Patent Claim 19 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 125 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-118- 

’880 Patent Claim 19 Disclosure 

 LW_0184:  LW_0190: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 126 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-119- 

’880 Patent Claim 19 Disclosure 

See also LW_0003; LW_0013.

’880 Claim 20

’880 Patent Claim 20 Disclosure 

20. The apparatus of claim 19, wherein execution of said functions is initiated by selecting different portions of said at least one of active link. 

Wroblewski, as evidenced by the example citations below, discloses that execution of said functions portions of said at least one of active link, as this claim limitation appears to be interpreted by CaddoSee e.g.: 

 Wroblewski at 58: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 127 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-120- 

’880 Patent Claim 20 Disclosure 

 Wroblewski at 68: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 128 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-121- 

’880 Patent Claim 20 Disclosure 

 LW_0184:  LW_0190: 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 129 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-122- 

’880 Patent Claim 20 Disclosure 

See also LW_0003; LW_0013.

’880 Claim 22

’880 Patent Claim 22 Disclosure 

22. The apparatus of claim 10, wherein at least two functions are associated with at least one of said active links. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 19.

’127 Claim 1-I 

’127 Patent Claim 1 Disclosure 

1. An apparatus for navigating an information structure, the apparatus including a processor configured to: 

To the extent the preamble is limiting, this element is satisfied by the disclosure set forth in connectioclaim 10 preamble. 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 130 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-123- 

’127 Patent Claim 1 Disclosure 

[a] provide a graphical menu interface displaying the items of a given level of the information structure and enabling selection thereof; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

1[a], and ’880 claim element 1[a]. 

[b] dynamically construct an active 

path as a sequence of active links after an item of the information structure has been selected; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

1[b], and ’880 claim element 1[b]. 

[c] upon provisional selection of a given one of said active links, display one or more items on a given level of the information structure associated with said provisionally selected active link without affecting the active path; and 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

element 1[c]. 

[d] allow a user to access an item in the information structure by selecting the item from the one or more items displayed by one of the active links on the active path; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim el

[e] wherein a function is associated with at least one of said active links. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 19

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 131 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-124- 

’127 Claim 3

’127 Patent Claim 3 Disclosure 

3. The apparatus of claim 1, wherein the one or more active links allow the display of one or more items on a given level of the information structure when a pointer is rolled over one of the active links. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’517 claim el

’127 Claim 4

’127 Patent Claim 4 Disclosure 

4. The apparatus of claim 1, wherein the one or more active links allow the display of one or more items on a given level of the information structure when one of the active links is selected. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 4.

’127 Claim 5

’127 Patent Claim 5 Disclosure 

5. The apparatus of claim 1, wherein the one or more active links allow the 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 5.

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 132 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-125- 

’127 Patent Claim 5 Disclosure 

display of one or more items on a given level of the information structure when a visual icon associated with one of the active links is selected. 

’127 Claim 6

’127 Patent Claim 6 Disclosure 

6. The apparatus of claim 1, wherein the active links in the active path allow the display of one or more items on a given level of the information structure without changing the active path. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

’127 Claim 7

’127 Patent Claim 7 Disclosure 

7. The apparatus of claim 1, wherein a user may directly access one or more active links in the active path by selecting the active link. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

’127 Claim 8

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 133 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-126- 

’127 Patent Claim 8 Disclosure 

8. The apparatus of claim 7, wherein the selection of an active link causes the active path to truncate to the selected active link. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 8.

’127 Claim 9

’127 Patent Claim 9 Disclosure 

9. The apparatus of claim 1 further configured to provide pre-defined shortcuts to enable access to a given item in the information structure, wherein selection of a pre-defined shortcut dynamically constructs an active path including one active link corresponding to each item necessary to navigate to the given item in the information structure. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 9.

’127 Claim 10

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 134 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-127- 

’127 Patent Claim 10 Disclosure 

10. The apparatus of claim 1, wherein two functions are associated with at least one of said active links. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 19

’127 Claim 11

’127 Patent Claim 11 Disclosure 

11. The apparatus of claim 10, wherein execution of said functions is initiated by selecting different portions of said at least one of active link. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 20

’127 Claim 13

’127 Patent Claim 13 Disclosure 

13. The apparatus of claim 1, wherein at least two functions are associated with at least one of said active links. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 19.

’127 Claim 14-I 

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 135 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-128- 

’127 Patent Claim 14 Disclosure 

14. A method for navigating an information structure, comprising: 

To the extent the preamble is limiting, this element is satisfied by the disclosure set forth in connectioclaim 1 preamble and ’301 claim 1 preamble and ’880 claim 1 preamble. 

[a] providing a graphical menu interface displaying the items of a given level of the information structure and enabling selection thereof; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

1[a], and ’880 claim element 1[a]. 

[b] dynamically constructing an active 

path as a sequence of active links after an item of the information structure has been selected; 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

1[b], and ’880 claim element 1[b]. 

[c] upon provisional selection of a given one of said active links, displaying one or more items on a given level of the information structure associated with said provisionally selected active link without affecting the active path; and 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

element 1[c]. 

[d] allowing a user to access an item in the information structure by selecting the item from the one or more items 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim el

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 136 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-129- 

’127 Patent Claim 14 Disclosure 

displayed by one of the active links on the active path; [e] wherein a function is associated with at least one of said active links. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 19

’127 Claim 16

’127 Patent Claim 16 Disclosure 

16. The method of claim 14, wherein the one or more active links allow the display of one or more items on a given level of the information structure when a pointer is rolled over one of the active links. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’517 claim el

’127 Claim 17

’127 Patent Claim 17 Disclosure 

17. The method of claim 14, wherein the one or more active links allow the display of one or more items on a given level of the information 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 4.

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 137 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-130- 

’127 Patent Claim 17 Disclosure 

structure when one of the active links is selected. 

’127 Claim 18

’127 Patent Claim 18 Disclosure 

18. The method of claim 14, wherein the one or more active links allow the display of one or more items on a given level of the information structure when a visual icon associated with one of the active links is selected. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 5.

’127 Claim 19

’127 Patent Claim 19 Disclosure 

19. The method of claim 14, wherein the active links in the active path allow the display of one or more items on a given level of the information structure without changing the active path. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

’127 Claim 20

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 138 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-131- 

’127 Patent Claim 20 Disclosure 

20. The method of claim 14, wherein a user may directly access one or more active links in the active path by selecting the active link. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’411 claim el

’127 Claim 21

’127 Patent Claim 21 Disclosure 

21. The method of claim 20, wherein the selection of an active link causes the active path to truncate to the selected active link. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 8.

’127 Claim 22

’127 Patent Claim 22 Disclosure 

22. The method of claim 14 further configured to provide pre-defined shortcuts to enable access to a given item in the information structure, wherein selection of a pre-defined shortcut dynamically constructs an active path including one active link corresponding to each item necessary

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 9.

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 139 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-132- 

’127 Patent Claim 22 Disclosure 

to navigate to the given item in the information structure. 

’127 Claim 23

’127 Patent Claim 23 Disclosure 

23. The method of claim 14, wherein two functions are associated with at least one of said active links. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 19

’127 Claim 24

’127 Patent Claim 24 Disclosure 

24. The method of claim 23, wherein execution of said functions is initiated by selecting different portions of said at least one of active link. 

This element is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 20

’127 Claim 26

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 140 of 141
Chart A-4 

Final Invalidity Contentions: Pat. Nos. 7,191,411; 7,216,301; 7,640,517; 7,725,836; 8,352,

-133- 

’127 Patent Claim 26 Disclosure 

26. The apparatus of claim 14, wherein at least two functions are associated with at least one of said active links. 

This claim is satisfied by the disclosure set forth in connection with the discussion of ’880 claim 19.

Case 6:20-cv-00245-ADA Document 65-6 Filed 12/14/21 Page 141 of 141