US 5845299

I'll search for the patent and any related litigation activity.

Interesting — the search surfaced an IPR involving TikTok and this patent. Let me dig into that and get the claim text.

Let me get the actual claim text and double-check for any Federal Circuit activity.

Search scope and caveat

I searched for US 5,845,299 ("5845299") specifically, and excluded near-miss numbers. One important caution up front: my results repeatedly surfaced CAFC and PTAB materials for US 11,208,029 (the "'029 patent," Spero v. Mercedes-Benz USA, No. 2025-1306; Spero v. Volkswagen, No. 2025-1028). That is a different patent (a headlight/glare-reduction patent), not 5,845,299, and I have not conflated them. Statements below about 5,845,299 are grounded in the patent text itself plus PTAB/docket records I could retrieve.

Bibliographic data — US 5,845,299 A

Source: https://patents.google.com/patent/US5845299/en

Abstract (verbatim, from the patent)

"A method and apparatus for a draw-based Web page editor in which the user uses a 'drag and drop' interface to add, delete, and move display elements to define the layout of a Web page. The present invention automatically generates an initial layout for each page. This initial layout contains display elements that represent the links between pages of the site. After the user has defined the layout of the Web page, the user 'publishes' the page. The publish function automatically generates at least one HTML table for the page in accordance with the display elements of the page, yielding a true WYSIWYG page."

Independent claim(s) — plain-language overview

Important limitation on this section: my searches did not return the full printed claim set of 5,845,299, so I cannot authoritatively enumerate how many claims there are or identify every independent claim. What follows for claim 1 is drawn from the specification's own "In accordance with the purpose of the invention… the invention is a method of…" recitation, which the patent uses to state its claimed subject matter and which reads as the text of the method claim. I flag it as high-confidence but not a verbatim reproduction of the printed claim; I will not fabricate additional independent claims.

Claim 1 (method — as recited in the Summary of the Invention):
Four steps performed by a data processing system:

1. Display elements on a screen — display a number of page display elements on a display device, those elements forming a page layout.
2. Detect an add request — receive an indication that the user wants to add a new display element to the page at a first position on the page.
3. Store a position-bearing data structure — add a new "draw data structure" in memory to a plurality of other draw data structures (which correspond to the existing display elements), where the new structure includes data representing that first position.
4. Auto-generate HTML — generate HTML that substantially reflects the displayed layout on a pixel-by-pixel basis in accordance with the draw data structures.

Plain English: it is the core "WYSIWYG drag-and-drop web page builder" claim — you place things on a canvas at exact positions, the system keeps a per-element data object recording that position, and it emits HTML from those objects so the published page looks like what you designed.

Potential additional independent claims (uncertain): the patent's title and abstract speak of "a method and apparatus," and the specification refers to a "computer readable medium" carrying editor instructions (FIG. 1, element 162), which suggests at least one further independent claim of a different statutory type (apparatus/computer-readable-medium). I could not verify this text, so treat it as an inference, not a finding.

Key supporting mechanics (dependent-claim material): HTML is emitted as a table where each cell corresponds to a matrix element derived from unique row/column edges of the draw objects (FIGS. 26–29); banner/navigator/text-button display elements and their draw objects are generated automatically to reflect site hierarchy links; the grid and dividers are excluded from the generated HTML.

Litigation, PTAB, and CAFC findings — as of April 26, 2026

Federal Circuit (2026): I found no CAFC docket or opinion involving US 5,845,299. No appeal by or against a 5,845,299 party appeared in my searches. If a 2026 CAFC docket exists, it did not surface, and I am not aware of one.

*PTAB — the patent appears as prior art, not as the patent at issue:*

• IPR2025-01224, TikTok Inc. (and ByteDance entities, Heliophilia) v. DiStefano Website Innovations, LLC — challenged patent is U.S. Reissued Patent No. RE45,971, claims 1–26 ("Method for creating reciprocal hyperlink arrangements between websites"). US 5,845,299 was filed as Exhibit 1009 and is the "Arora" reference in the petition's Ground 3 (Arnold/Arora renders claims 11 and 17 obvious). The proceeding was terminated by Director discretionary denial on January 9, 2026.
  • https://www.docketalarm.com/cases/PTAB/IPR2025-01224/…/Exhibit-1009-US_Patent_5,845,299/
  • https://ipverse.greyb.com/ptab-web/cases/case-details/IPR2025-01224
  • https://www.docketalarm.com/cases/PTAB/IPR2025-01224/…/Petition_as_filed/
• IPR2025-01061, TikTok Inc. v. DiStefano Website Innovations, LLC — patent at issue is US 11,763,316 B2; Ground 3 again combines Arnold (US 6,016,504) with Arora (US 5,845,299) and Ahlberg. Note the USPTO Director instituted sua sponte Director Review of the institution decision on real-party-in-interest grounds (order referencing a June 3, 2026 briefing deadline), with the proceeding stayed.
  • https://www.uspto.gov/sites/default/files/documents/ipr2025-01061_tiktok_v_destefano_director_review_order.pdf
• IPR2023-00330 (Akamai, re US 8,495,242) — 5,845,299 appears only inside a pasted EAST search-history string, i.e., an examiner-style prior-art search list. Not a substantive challenge to it.

District court:

• DiStefano Website Innovations, LLC v. ByteDance Ltd. et al., No. 2:24-cv-00874-RWS-RSP (E.D. Tex.) and the Western District case 1:24-cv-00763, later refiled/transferred to N.D. Cal. (5:25-cv-10578 / 3:25-cv-10578). The asserted patents are US 11,763,316, RE45,971, 8,996,398, 8,589,222, and 8,412,570 — 5,845,299 is not among them. The W.D. Tex. case was voluntarily dismissed without prejudice (Rule 41(a)(1)(A)(i)) on Oct. 29, 2024; the E.D. Tex. case was transferred to N.D. Cal.
  • https://www.courtlistener.com/docket/72023062/distefano-website-innovations-llc-v-bytedance-ltd/

Bottom line on status: 5,845,299 is expired (as of 2016-07-29) and I found no record of it being asserted by its owner or challenged in an IPR. Its 2025–2026 relevance is as a prior-art reference ("Arora") against other parties' patents, notably the DiStefano/RE45,971 and 11,763,316 families. Earlier, it was cited as background art (category "A") in the European search report for EP 1 187 039 A3.

Uncertainty disclosures

1. Full claim set not verified. I could not retrieve the printed claims of 5,845,299 in my searches, so I cannot state the total claim count, the exact boundary of claim 1, or confirm the existence/content of additional independent (apparatus or computer-readable-medium) claims. The claim-1 overview above is grounded in the patent's Summary of the Invention language and should be verified against the official claim text (USPTO PatentCenter / the patent PDF).
2. Assignee currency is uncertain. Google Patents flags its assignee list as potentially inaccurate and lists both Adobe and Web.com Group; the patent's own front page (as reproduced in PTAB Exhibit 1009) names Rae Technology LLC.
3. CAFC 2026: my search found no 5,845,299 appeal; I cannot rule out an unindexed docket, but I have no evidence of one.
4. A search result referenced a different "529" patent (a lighting ballast, "the '529 Patent") — unrelated to 5,845,299 and excluded.

I'll research litigation involving US Patent 5845299 across patent litigation databases.

The initial searches returned noise (a different "529 patent" for lamp ballasts). Let me search more targeted sources.

Found a key case: Macromedia v. Adobe. Let me get case specifics and check other litigation databases.

Litigation Involving U.S. Patent No. 5,845,299

Confirmed case: the only identified suit asserting the '299 patent

Source grounding: The complaint itself is reproduced at Tech Law Journal: "Document: Complaint for Patent Infringement in Macromedia v. Adobe, 10/19/01" — http://www.techlawjournal.com/courts2001/macromedia_adobe/20011019com.asp. Macromedia's own SEC Form 10-Q confirms the case number and filing: "On October 19, 2001, we filed suit in the United States District Court for the Northern District of California in San Francisco against Adobe Systems, Inc. (Case No. C01-3940-SI)… [alleging] Adobe's GoLive and Photoshop software, infringe U.S. Patent No. 5,845,299 and that certain of Adobe's products, including GoLive, infringe U.S. Patent No. 5,911,145." The July 2002 settlement of the whole dispute series is corroborated by secondary reporting (e.g., https://www.macworld.com/article/[163481](/patent/163481) and the Macromedia history summary noting "In July 2002, Adobe and Macromedia reached an agreement that settled all claims in this series of patent suits").

Important context — related but separate cases (different patents)

The above suit arose inside a broader Adobe–Macromedia patent war. Be careful not to conflate these with '299:

• Adobe Systems, Inc. v. Macromedia, Inc. (D. Del.) — asserted U.S. Patent No. 5,546,528 (reconfigurable tabbed palettes), filed August 10, 2000. Jury verdict May 2, 2002 for Adobe; infringement found willful; $2.8M damages. (Litigation Strategies summary: http://www.litstrat.com/Cases/AdobeII.pdf)
• Macromedia counterclaim verdict, May 10, 2002 — jury found Adobe infringed U.S. Patent Nos. 5,467,443, 5,151,998, and 5,204,969; $4.9M awarded. (VideoMaker news: https://www.videomaker.com/videonews/2002/05/macromedia-wins-49-million-in-patent-counterclaims-trial-against-adobe/)

None of the patents in those two entries is the '299 patent.

Pre-litigation threats (NOT lawsuits)

• Circa 1999, when Adobe acquired GoLive, NetObjects contacted Adobe claiming GoLive infringed these patents; Adobe reviewed and concluded it did not infringe, and NetObjects did not pursue the matter. (Reported in Macworld's coverage of the 2001 suit.)
• In June 2001, NetObjects CEO Samir Arora publicly stated he believed several Web authoring products infringed his patents, naming Microsoft FrontPage and Macromedia Dreamweaver as examples. I found no evidence that these threats ripened into filed litigation.

False positives to disregard

• LBC v. ULT, E.D. Tex. Case No. 7:2009cv00029 — the "‘529 patent" in that ballast/lighting case is not U.S. 5,845,299. Different patent, different field (electronic lamp ballasts).
• PTAB IPR2023-00330 (Akamai Technologies) — 5845299 appears only as a number in a prior-art search history exhibit; not a challenge to or assertion of the '299 patent.
• EP 1,187,039 A3 and WO 2002/010972 A1 — 5845299 appears only as a cited prior-art reference.

Ownership timeline relevant to enforcement

Rae Technology LLC → NetObjects, Inc. (1996) → Rae Technology, Inc. (1997) → NetObjects, Inc. (2001) → Macromedia, Inc. (Dec. 2001) → Adobe Systems Incorporated (Jan. 2006, via Adobe's acquisition of Macromedia). Web.com Group/Web.com Holding Company appears as a current listed assignee on the Google Patents record, though the patent itself expired (anticipated expiration July 29, 2016).

Caveats and limitations

• I was unable to directly query the Unified Patents litigation caselist (portal.unifiedpatents.com), PACER, or Docket Alarm for a complete docket-level sweep of case C01-3940-SI before hitting my research-step limit, so this list may not be exhaustive.
• Based on the sources reached, the October 19, 2001 Macromedia v. Adobe suit is the only confirmed litigation asserting U.S. Patent No. 5,845,299. I found no evidence of any later infringement action by Adobe or Web.com asserting the '299 patent, and no PTAB post-grant proceeding that names '299 as the challenged patent.

If you need a verified full docket (including any co-defendants, transfers, or later-filed cases that my searches may have missed), I'd recommend pulling Case No. C01-3940-SI directly from PACER/Justia Dockets and cross-checking the Unified Patents caselist — I can walk you through those lookups on request.

I'll start by checking the structured ODP data against live sources.

Let me run more targeted searches.

Important lead — let me investigate the TikTok IPR reference carefully.

PTAB proceedings on US 5,845,299 ("Draw-based editor for web pages")

Proceedings overview

Zero. As of the most recent USPTO Open Data Portal ingest, there are no AIA trial proceedings in which US 5,845,299 is the challenged patent — 0 active, 0 with claims canceled, 0 with claims sustained, 0 settled, 0 institution denials. The only PTAB connection my search surfaced runs the other direction: the '299 patent is being used as prior art (Petitioner Ex. 1009) against US RE45,971 in TikTok's IPR2025-01224. That is a signal of defensive value (the disclosure is broad enough to kill other people's patents), not a signal that anyone has attacked the '299 claims. The bottom-line posture for a defendant is therefore not "hardened by surviving IPRs" and not "claims canceled" — it is "never PTAB-tested, but expired on 2016-07-29" (Google Patents status: Expired – Lifetime; "2016-07-29 Anticipated expiration"). A defendant's real question is not claim survival but whether any pre-expiration damages can still be reached.

No AIA trial proceedings on the '299 patent

Because there is nothing to analyze, I am not fabricating proceeding numbers. The requested per-proceeding template is inapplicable:

• Type: n/a — no IPR, PGR, or CBM identified.
• Filed: n/a.
• Status: n/a. The structured ODP block is the canonical source and reports none.
• Notes on why the procedural space is narrow: US 5,845,299 has an effective filing date of 1996-07-29 and was granted 1998-12-01, making it pre-AIA. That means (i) PGR is legally unavailable under 35 U.S.C. § 321 (post-AIA patents only); (ii) CBM review is closed — AIA § 18(f) sunset the transitional program on 2020-09-16, so no new CBM petition can be filed regardless of eligibility; and (iii) IPR was the only realistic AIA vehicle, available from 2012-09-16 until the patent expired on 2016-07-29. A roughly four-year window existed and nobody used it. Absence of PTAB activity here is a weak signal, because the patent's commercial assertion value collapsed with expiry rather than because it survived a gauntlet.
• Caveat on completeness: I could not run a full PTAB E2E / PTAB API docket query keyed directly to patent number 5,845,299 within this session, and the ODP ingest may lag for recently filed papers. If you need a belt-and-suspenders confirmation, search PTAB E2E and the PTAB "Patent Trial and Appeal Board End-to-End" public search for "5,845,299" directly. My searches surfaced no such proceeding.

IPR2025-01224 — TikTok Inc. (and ByteDance Ltd., ByteDance Pte. Ltd., ByteDance Inc., TikTok Ltd., Heliophilia Pte. Ltd.) v. DiStefano Website Innovations, LLC

Not a proceeding on US 5,845,299. The challenged patent is U.S. Reissued Patent No. 45,971 (RE45,971). US 5,845,299 is cited in this case as prior art. I include it because it is the only PTAB event my search surfaced that touches the patent at all, and because it tells you how the '299 disclosure is being deployed.

• Type: Inter Partes Review
• Filed: 2025-07-08
• Status: Discretionary Denial — third-party trackers list the institution decision date as 2026-01-09, recorded as "Director Discretionary Decision: Deny" (ipverse; ExParte PTAB tracker). Flagging this as unverified in primary form — I did not retrieve the denial paper itself, and the same tracker also shows the panel as "Pending Judge Assignment," which is inconsistent with a fully papered denial. Treat the 2026-01-09 denial as likely but confirm on PTAB E2E.
• Judge panel: Not confirmed; only the API/tracker status is available. The petition was filed with the mandatory notices under 37 C.F.R. § 42.8 on 2025-07-29.
• Petition grounds: Ground 1 — Block renders claims 1–29 obvious (§ 103). Ground 2 — Arnold renders claims 1–10, 12–16, 18–29 obvious. Ground 3 — Arnold/Arora renders claims 11 and 17 obvious, where "Arora" is the Arora et al. disclosure. Petitioner's exhibit list expressly includes Ex. 1009 = U.S. Patent 5,845,299 (Docket Alarm, Petition as filed and Exhibit List).
• Institution decision: Reported denial at the Director/ discretionary stage (see status caveat above). Petitioner filed a Sotera stipulation on 2025-07-23 (ptacts.uspto.gov petition record) — conditioning the district court validity case on institution, which is the standard response to Acting Director Stewart's 2025-03-26 interim workload-management memo. The Board also received a Patent Owner claim disclaimer on 2025-10-17, a common patent-owner tactic to moot claims before institution.
• Final Written Decision: None. No FWD issued; no claim of RE45,971 was canceled or sustained in this proceeding.
• Settlement / termination: No settlement identified. The proceeding's reported disposition is discretionary denial, not termination by settlement.
• Appeal: None identified.
• Defensive value for you: Limited and asymmetric. It does not invalidate or sustain any claim of 5,845,299. What it does give you is corroboration that the '299 specification is usable as § 103 prior art by sophisticated petitioners (White & Case, Dr. Andy Cockburn as expert), which matters if you face an assertion on a later Arora-family patent. Note that the district court case it runs parallel to — DiStefano Website Innovations, LLC v. ByteDance Ltd. et al., No. 2:24-cv-00874-RWS-RSP (E.D. Tex., filed 2024-10-29) — asserts five different patents (US 11,763,316; US 8,412,570; US 8,996,398; US 8,589,222; RE45,971), none of which is 5,845,299, and was ordered transferred to N.D. Cal.

Strategic summary

Claim status on 5,845,299. There is no PTAB claim-level record whatsoever: no independent claim canceled, no dependent claim canceled, no claim sustained, and no claim adjudicated. Every claim is UNTESTED at the Board. That is not the same as "valid" or "hardened" — it means the validity of the '299 claims has simply never been adjudicated in an AIA trial, and (given the 2016-07-29 expiry) is unlikely ever to be. If a demand letter cites claims of 5,845,299 today, the strongest response is not an IPR-based invalidity theory but a damages/expiry theory: the 20-year term from the 1996-07-29 filing ran out on 2016-07-29, the patent is recorded as Expired – Lifetime, and any § 286 six-year lookback from a 2025–2026 complaint reaches back only to 2019–2020 — i.e., after expiry. Verify the face of the patent and the file wrapper for any terminal disclaimer, PTA, or § 154(b) adjustment that could move that date; I did not verify the term calculation against the printed patent inside this session.

Estoppel landscape. There is no § 315(e)(2) estoppel attaching to 5,845,299, because estoppel only arises from an IPR that was instituted and reached a final written decision. Nobody instituted. Consequently all prior-art grounds remain available to a defendant in district court or the ITC: every § 102/§ 103 combination over patents and printed publications, plus § 112 and § 101 challenges that IPR cannot even reach. The only estoppel in the neighborhood is contractual/self-imposed: TikTok's Sotera stipulation in IPR2025-01224 binds TikTok and its privies as to RE45,971, a different patent — it creates no estoppel running to 5,845,299. Do not let an opponent conflate the two.

Pattern signals. No repeat petitioner on the '299 patent, because there is no petition. No PTAB appeal by the patent owner on the '299 patent. No defensive aggregator — my search found no Unified Patents or similar entity in the chain for this patent. What the chain does show is corporate ownership churn rather than litigation hardening: Rae Technology LLC → NetObjects, Inc. (1996-10-24) → Rae Technology, Inc./LLC (1997-09-29) → back to NetObjects (2001-09-24) → Macromedia (2001-12-21) → Adobe (2006-01-19), with Web.com Holding Company / Web.com Group appearing in later security-interest records (Google Patents assignment timeline). Separately, the DiStefano patent family that is using this patent as art has been through the PTAB before — the petition cites DiStefano Pat. Tr. III, LLC v. LinkedIn Corp., 784 F. App'x 785 (Fed. Cir. 2019), and IPR2019-00419 (a DiStefano preliminary response is Ex. 1010) — so the '299 disclosure has a track record as an invalidity tool.

Diligence flag on the family. The Google Patents family timeline shows a later filing, US 11/655,432 filed 2007-01-19, which issued as US 8,935,602, tied into this family. If an adverse party is asserting "the NetObjects/Arara web-editor patents" today, the live vehicle is likely a different member of the family with a later term, not the expired '299. I did not verify US 8,935,602's § 120 benefit chain, its term, or its PTAB history — that requires a separate check, and if it claims benefit back to the 1996-07-29 filing its term would also have ended in 2016.

Recommended next steps

1. If your demand letter cites 5,845,299 specifically: lead with expiry, not invalidity. Cite the Google Patents record ("Anticipated expiration 2016-07-29"; status "Expired – Lifetime") and obtain the certified copy plus the file wrapper to confirm no term extension. There is no FWD to quote — none exists — so do not represent otherwise to a court.
2. If you want to kill the claims anyway (e.g., for a pre-2016 accrued-damages defense or a DJ action): an IPR remains legally available even on an expired patent (the patent owner cannot amend claims, and the Board can cancel claims), but expect the patent owner to argue mootness and expect the Board to weigh the § 315(b) one-year bar and the 2025 discretionary-denial practice. There is no prior petitioner estoppel, so you would be writing on a clean slate.
3. Verify the two gaps I could not close in this session: (a) run patent-number "5,845,299" through PTAB E2E / the PTAB public search API to confirm the ODP "no proceedings" result; (b) pull the IPR2025-01224 institution/discretionary-denial paper on PTAB E2E (or CourtListener docket search) to confirm the reported 2026-01-09 denial, since the trackers are internally inconsistent about whether a panel was ever assigned.
4. Map the family before responding to any assertion: identify whether US 8,935,602 (app. 11/655,432, filed 2007-01-19) or app. 09/153,536 (pub. US 2002/0023111 A1) is the asserted instrument, and run that patent number against the ODP/PTAB databases — the '299 clean sheet tells you nothing about the rest of the family.

Sources: US5845299A on Google Patents · IPR2025-01224 docket (Docket Alarm) · TikTok Sotera stipulation via ptacts.uspto.gov · IPR2025-01224 case page (ipverse/greyb) · IPR2025-01224 (ExParte tracker)

I'll reconstruct the ownership chain for US 5845299. First, let me pull what the patent record itself gives me and then hunt for the Assignment Center reel/frame data and correspondent information.

Now let me dig for the actual Assignment Center records (reel/frame, correspondents) and any litigation involving this patent.

US 5845299 — Ownership Chain Reconstruction

Data limitation up front: I was able to retrieve the event-level reassignment history (dates, conveyance types, counterparties) for this patent, but not the USPTO reel/frame numbers or correspondent-of-record fields. Google Patents' legal-events view does not expose reel/frame, and the Assignment Center / assignment.uspto.gov query interfaces were not reachable in this session. I have therefore left every reel/frame as an explicit gap rather than filling it in. This is a material gap for signal 3 (repeat correspondent), which cannot be scored properly without it. Verification starting point: assignmentcenter.uspto.gov and the legacy assignment.uspto.gov/patent; event baseline corroborated at patents.google.com/patent/US5845299A/en and uspto.report/patent/grant/5,845,299.

Inventors

Named on the face of the patent (and identically on the 1998 continuation, US 20020023111 A1):

Notes / anomalies:

• Entity mismatch at filing. The application was filed 1996-07-29 with Rae Tech LLC as applicant, yet the inventors assigned to NetObjects, Inc. three months later (recorded 1996-10-24). The technology had been transferred from Rae Technology to NetObjects in 1995, with Rae as NetObjects' first investor. The filing-through-Rae pattern is worth confirming against the original assignment documents.
• Name discrepancy (do not auto-correct). Third-party biographies of the team refer to co-inventor "Sal Arora" (Samir's brother) on the one utility patent from this period, while the patent and the published application both read "Gagan Arora." Both records of the patent are consistent with each other, so I treat Gagan Arora as the named inventor of record and flag the biography as a probable third-party error or an unverified alternate name.
• No rapid-inventor-departure pattern. I found no evidence that all five inventors left within 12 months of filing. The transfer left the inventors' hands within ~3 months (standard inventor-to-company assignment), but that is the ordinary case, not a fire-sale tell. The true "distress" chronology here is issuance-relative: granted 1998-12-01, portfolio sold 2001 — roughly a 3-year post-issuance window.

Original assignee

Rae Tech LLC is the assignee/applicant listed on the issued patent, with NetObjects, Inc. taking the inventors' interest by assignment recorded 1996-10-24.

• Did they ship a product embodying the claims? Yes, unambiguously. NetObjects Fusion (v1.0, 1996) is a draw-based page editor whose Page view places objects on a pixel grid and whose publish step emits HTML tables — the exact subject matter of claim 1's "draw data structures … generating … at least one HTML table that substantially reflects a layout … on a pixel by pixel basis." Third-party litigation in W.D. Tex. later used NetObjects Fusion 4.0 and its manuals as §102 prior art, and PTAB petitioners used the patent's Arora specification as a primary reference (EX1009, IPR petition 1557964), which independently confirms the product/spec correspondence. Wikipedia's own account of Fusion: "The visualization technology of NetObjects Fusion has been patented."
• Primary line of business: web-authoring software for small/medium business and design professionals; later a SaaS/website-services shift (NetObjects Matrix, GoBizGo). IBM took a majority stake in April 1997 for ~$100M.
• Current status: dissolved / wound down in 2001. Total revenue for the first three quarters of FY2001 was $4.22M against $7.67M of costs; IBM, controlling the board, blocked a Deutsche Bank private placement and decided to sell. Product assets (Fusion, Matrix/MatrixBuilder, GoBizGo) went to Website Pros (now Web.com / Newfold Digital); the seven-patent portfolio went to Macromedia (see Infotoday, Dec 2001: "Macromedia … has purchased the NetObjects portfolio of patents"). The NetObjects name was revived in 2009 as an unrelated re-established company that bought the Fusion product line back from Web.com — it is not a successor to the patent estate.
• Very early IP lien: a Security Agreement to Venture Lending, a division of Cupertino National Bank and Trust was recorded 1996-10-07, three months after filing — ordinary venture-debt securitization of a startup's patent applications, not an NPE tell.

Assignment timeline

All dates below are recordation/event dates as exposed by the patent's legal-events record; execution dates are not exposed in that view except where separately noted. No reel/frame numbers were retrievable — treated as an open gap for every entry.

• Exec. n/a (filing event, not a conveyance) / recorded 1996-07-29 — Reel not retrieved (gap)

  • Conveyance: n/a — application filed
  • Applicant of record: Rae Tech LLC
  • Correspondent: not retrievable
  • Context: original filing; establishes the Rae/NetObjects entity mismatch at the top of the chain.

• Exec. not exposed / recorded 1996-10-07 — Reel not retrieved (gap)

  • Conveyance: Security Agreement
  • Assignor: NetObjects, Inc.
  • Assignee: Venture Lending, a division of Cupertino National Bank and Trust
  • Correspondent: not retrievable — cannot assess recurrence; this is one of the two lien-holder links that a repeat-correspondent analysis would turn on.
  • Context: securitization — venture-debt lien over the startup's pending applications.

• Exec. not exposed / recorded 1996-10-24 — Reel not retrieved (gap)

  • Conveyance: Assignment of assignors' interest
  • Assignors: Samir Arora, Gagan Arora, Rajagopal Lakshminarayan, Gregory Brown, Martin Frid-Nielsen
  • Assignee: NetObjects, Inc.
  • Correspondent: not retrievable
  • Context: routine inventor-to-company assignment, ~3 months post-filing.

• Exec. not exposed / recorded 1997-09-29 — Reel not retrieved (gap)

  • Conveyance: Assignment
  • Assignor: NetObjects, Inc.
  • Assignee: Rae Technology, LLC
  • Correspondent: not retrievable
  • Context: internal reorganization — asset/patent holding moved back up to the Rae entity in the same period as IBM's April 1997 majority investment.

• Exec. not exposed / recorded 1997-09-29 — Reel not retrieved (gap)

  • Conveyance: Assignment
  • Assignor: Rae Technology, LLC
  • Assignee: Rae Technology, Inc.
  • Correspondent: not retrievable — same-day, same-counterparty pair with the preceding entry; if one correspondent filed both, that is the closest thing to a recurrence in this chain, but it is unverified.
  • Context: internal reorganization / entity-form change, same day.

• Exec. not exposed / recorded 2001-09-24 — Reel not retrieved (gap)

  • Conveyance: Assignment
  • Assignor: Rae Technology, Inc.
  • Assignee: NetObjects, Inc.
  • Correspondent: not retrievable
  • Context: internal reorganization — reversal of the 1997 movement as NetObjects was prepared for wind-down and asset sales.

• Exec. not exposed / recorded 2001-12-21 — Reel not retrieved (gap)

  • Conveyance: Assignment
  • Assignor: NetObjects, Inc.
  • Assignee: Macromedia, Inc.
  • Correspondent: not retrievable on the patent side. (The same corporate transaction's trademark recording — not this patent — names correspondent Daniel C. Poliak, Adobe Systems Incorporated Legal Department, 801 North 34th Street, Seattle WA 98103, reel 3205/0270, exec. 2005-12-03. Cited only as an indicator of how the Adobe/Macromedia combination was handled; see signal 3.)
  • Context: fire-sale / distressed portfolio sale — the seven-patent NetObjects portfolio purchased by the maker of the direct competing product, Dreamweaver.

• Exec. not exposed / recorded 2002-02-07 — Reel not retrieved (gap)

  • Conveyance: Assignment
  • Assignor: NetObjects, Inc.
  • Assignee: Macromedia, Inc.
  • Correspondent: not retrievable
  • Context: second record to the same assignee 48 days after the first — either a distinct conveyance or a corrective re-recording of the Dec-2001 portfolio sale. Unresolved without the reel/frame; I will not guess which.

• Exec. 2005-12-03 (per related recording) / recorded 2006-01-19 — Reel not retrieved (gap)

  • Conveyance: Assignment
  • Assignor: Macromedia, Inc.
  • Assignee: Adobe Systems Incorporated
  • Correspondent: not retrievable for this patent; the parallel Macromedia→Adobe trademark record at reel 3205/0270 shows Adobe in-house legal (Daniel C. Poliak) as correspondent — i.e., an operating-company legal department, the inverse of the NPE correspondent pattern.
  • Context: acquisition — Adobe's purchase of Macromedia (deal closed 2005-12-03); bulk IP transfer recorded in Jan 2006.

• Exec. not exposed / recorded 2010-08-09 — Reel not retrieved (gap)

  • Conveyance: Security Agreement
  • Assignor: Web.com Holding Company, Inc.
  • Assignee: Royal Bank of Canada, as administrative agent
  • Correspondent: not retrievable
  • Context: securitization — corporate-level secured financing. Anomaly: this appears in the legal events for this patent even though the recorded patent chain places title with Adobe as of 2006.

• Exec. not exposed / recorded 2011-11-01 — Reel not retrieved (gap)

  • Conveyance: Termination and Release of Security Interest
  • Assignor / beneficiary: Royal Bank of Canada, as administrative agent → Web.com Holding Company, Inc.
  • Correspondent: not retrievable
  • Context: securitization release.

• Exec. not exposed / recorded 2014-10-29 — Reel not retrieved (gap)

  • Conveyance: Security Interest
  • Assignor: Web.com Holding Company, Inc.
  • Assignee: JPMorgan Chase Bank, N.A., as administrative agent
  • Correspondent: not retrievable
  • Context: securitization — refinancing lien; same Web.com attribution anomaly.

• Exec. not exposed / recorded 2015-06-12 — Reel not retrieved (gap)

  • Conveyance: Assignment
  • Assignor: Web.com Holding Company, Inc.
  • Assignee: Web.com Group, Inc.
  • Correspondent: not retrievable
  • Context: internal reorganization inside Web.com — and the strongest single indicator that Web.com, not Adobe, held title to something in this family.

• Exec. not exposed / recorded 2018-10-11 — Reel not retrieved (gap)

  • Conveyance: Release of Security Interest (JPMorgan, reel/frame 034061/0361 per the release text) → Web.com Holding Company, Inc.
  • Correspondent: not retrievable
  • Context: securitization release at the end of the Siris-era Web.com capital structure.

• Not a conveyance: 2016-07-29 anticipated expiration (20-year term from filing); status "Expired – Lifetime." Also on the family page: continuation US 09/153,536 (filed 1998-09-16, abandoned, published as US 20020023111 A1) and a 2007-01-19 child application US 11/655,432 → US 8,935,602 B2.

Family-level hypothesis that must be checked before relying on the terminal owner: the Web.com records (2010, 2011, 2014, 2015, 2018) may be attached in Google Patents' aggregation to the 2007 child application US 11/655,432 / US 8,935,602 B2 rather than to this patent's own reel. If so, the terminal owner of this family is Web.com Group, and the "current assignee" field listing both Adobe Inc and Web.com Group Inc reflects two different family members. This is a hypothesis, not a finding — it needs the reel/frame pulled for each of the five Web.com records to see which patent number each one names.

Timeline diagram

timeline
    title Ownership of US 5845299
    1996 : Filed by Rae Tech LLC
         : Inventors assign to NetObjects Inc
    1997 : Patent moved back to Rae Technology
         : Then to Rae Technology Inc
    2001 : Returned to NetObjects Inc
         : Seven patent portfolio sold to Macromedia
    2002 : Second recording to Macromedia
    2006 : Macromedia acquired by Adobe
    2010 : Web.com security agreement with RBC
    2014 : Web.com security interest to JPMorgan
    2015 : Web.com Holding to Web.com Group
    2016 : Patent reaches end of term

NPE / troll-pattern signals

1. Shell-entity transfer — not present.
The only LLC in the chain is Rae Technology, LLC (recorded 1997-09-29), and it fails every shell test that matters: it predates the patent as a 1992 Apple spin-off that shipped software (Rae Assist) and was NetObjects' first investor ($1.5M), not a licensing vehicle; and it transferred the right back into NetObjects, Inc. on 2001-09-24. The chain's substantive holders are operating companies (NetObjects, Macromedia, Adobe, Web.com). No "IP / Licensing / Ventures" suffix appears anywhere, no registered-agent address appears, and no single-purpose Delaware or Texas LLC appears. The 1997 same-day Rae LLC → Rae Inc. pair is an entity-form change, not a shell hop.

2. Known asserter in the chain — not present.
No link matches the supplied NPE list (Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, Spangenberg entities). Every assignee — NetObjects, Macromedia, Adobe, Website Pros/Web.com, plus lienholders Venture Lending, Royal Bank of Canada and JPMorgan — is an operating company, a bank, or a documented corporate successor. Caveat: I could not query the RPX and Unified Patents asserter directories directly in this session, so this is a "no match found on available evidence" call, not a certified negative.

3. Repeat correspondent across the chain — unclear (cannot be scored).
The correspondent fields are not retrievable for any of the recorded links with the sources available, so recurrence can be neither confirmed nor excluded. The one correspondent I could recover in the same corporate chain is Daniel C. Poliak, Adobe Systems Incorporated Legal Department, 801 North 34th Street, Seattle WA 98103, on the Macromedia→Adobe trademark assignment reel 3205/0270 (exec. 2005-12-03, recorded 2005-12-06, entity Delaware). That is an in-house operating-company legal department, which is the opposite of the NPE pattern. There is no evidence of a repeat outside counsel or a recording firm steering this chain. Do not treat the single Poliak appearance as a finding — and note it is a trademark reel, not this patent's reel.

4. Cascading transfers — present as a factual pattern, but with a non-NPE explanation.
Consecutive recorded links: 1996-10-24 → 1997-09-29 (×2 same day) → 2001-09-24 → 2001-12-21 → 2002-02-07 → 2006-01-19. That is three links inside twelve months (Sep 2001, Dec 2001, Feb 2002) and five inside five and a half years. On its face this is the "chained transfers" shape, but each hop maps to a documented corporate event rather than to an assertion scheme: the 1997 pair to the IBM-majority-era reorganization, the 2001 trio to the NetObjects wind-down and the split sale of product assets (Website Pros) versus patent assets (Macromedia), the 2006 hop to the Adobe/Macromedia merger. There is no evidence of shared correspondent addresses or common principals across the assignees, and — decisively — no assertion followed. Weight: low.

5. Pre-litigation transfer — not present.
I found no infringement suit naming US 5,845,299 as an asserted patent. The only litigation and PTAB appearances I could locate are defensive uses of this patent as prior art — e.g., PTAB petition 1557964 treats the Arora specification as a primary reference (EX1009) against another party's claims, and NetObjects Fusion 4.0 documentation appears in a W.D. Tex. (6:20-cv-00804-ADA) prior-art exhibit list. Being cited against others is not assertion.

6. Bankruptcy fire-sale — unclear.
The 2001-12-21 sale of the seven-patent NetObjects portfolio to Macromedia is functionally a distressed disposal: the seller posted $4.22M of nine-month FY2001 revenue against $7.67M of costs, had a controlling shareholder (IBM) that blocked refinancing, and the buyer was the maker of the direct competing product. But I found no record of a NetObjects Chapter 7 or Chapter 11 filing — the public accounts describe a sale of assets and a cessation of operations, not a bankruptcy proceeding. I am recording this as the substantive equivalent of a fire-sale without the bankruptcy-proceeding predicate, and marking it unclear rather than claiming a filing I cannot cite.

7. Privateering — not present.
There is no evidence the seller retained a financial interest, no evidence of assertion on NetObjects' or IBM's behalf, and no SEC/EFF/Patent Progress coverage suggesting a campaign. If anything the 2001 sale runs the other direction: Macromedia bought seven patents belonging to its "long-term main competitor" and never asserted them — a buy-and-shelve neutralization of a competitor's portfolio, not privateering.

8. Defensive aggregator (anti-NPE) — not present.
Adobe, Web.com and Macromedia are none of RPX, AST, LOT, Unified or OIN. However, the functional outcome is the anti-NPE outcome: the portfolio went to the acquiring competitor, was never asserted, and the patent expired 2016-07-29.

Verdict

Defensive / non-asserting — with the explicit caveat that non-assertion here comes from acquisition by an operating competitor followed by expiration, not from a formal defensive aggregator at the end of the chain.

Justification in three sentences. The chain is a single corporate lineage from a product-shipping original assignee through two operating competitors — NetObjects, Inc. → Macromedia, Inc. (recorded 2001-12-21 and 2002-02-07, the documented seven-patent portfolio sale reported by Infotoday in Dec 2001) → Adobe Systems Incorporated (recorded 2006-01-19, the Macromedia acquisition) — with only venture-debt and bank liens (Venture Lending 1996-10-07; Royal Bank of Canada 2010-08-09 and its release 2011-11-01; JPMorgan 2014-10-29 and its release 2018-10-11) as the non-operating parties, none of which are asserter entities. No NPE-list assignee, no assertion suit, and no repeat NPE correspondent appears anywhere in the record I could reach; the only correspondent recovered in the same transaction chain is Adobe's in-house legal department (Daniel C. Poliak, reel 3205/0270 on the parallel trademark recording, exec. 2005-12-03). Two items keep this short of an unqualified call: the terminal ownership contradiction (Google Patents lists both "Adobe Inc" and "Web.com Group Inc" as current assignees and shows a 2015-06-12 Web.com Holding → Web.com Group assignment, while the patent-level chain ends at Adobe in 2006, plausibly via the 2007 child application US 11/655,432 / US 8,935,602 B2), and the unretrieved reel/frame and correspondent fields — pull those five Web.com records at the Assignment Center and re-run signal 3 before treating this verdict as final.

Verify at: USPTO Assignment Center · legacy assignment search (search patent 5,845,299; note Google Patents' own disclaimer that its listed assignees "may be inaccurate").

I'll research US Patent 5845299 and its cited prior art.

Let me search the USPTO-specific databases and citation records directly.

Let me access the actual patent document's "References Cited" section directly.

Prior-Art Analysis — US Patent 5,845,299

1. Patent identification (verbatim from sourced records)

Sources: https://patents.google.com/patent/[US5845299A](/patent/US5845299A)/en ; https://uspto.report/patent/grant/5,845,299

2. Important sourcing caveat (read before the analysis)

The tool budget for this session was exhausted while I was retrieving 5,845,299's front‑page "References Cited" list. The most complete extract I could retrieve came from the PTAB/IPR exhibit copy of the patent:

• IPR2025‑01224, Exhibit 1009 – U.S. Patent 5,845,299 — https://www.docketalarm.com/cases/PTAB/IPR2025-01224/.../Exhibit-1009-US_Patent_5,845,299/
  • The retrieved snippet shows only the first two U.S. references in the "References Cited" block:
    • 5,634,062 5/1997 Shimizu et al.
    • 5,634,095 5/1997 Wang et al.

I could not verify the remainder of the examiner‑cited list (the snippet truncated immediately after Wang et al.), nor could I confirm the foreign‑patent or non‑patent‑literature citations. Per the operating rules, I will not fabricate the missing entries. I flag clearly below which items are confirmed vs. unverified recollection.

Also note a distinction that matters for your request: "References Cited" (backward, examiner/applicant citations) are the prior art — these are what an anticipation analysis under §102 uses. The 223–228 entries under "Cited By" on Google Patents are forward citations (later patents citing 5,845,299) and are not prior art to it; I have excluded them from the §102 analysis.

3. Confirmed cited references (backward citations)

Reference 1 — U.S. Patent 5,634,062 (Shimizu et al.), issued May 1997

• Full citation: U.S. Patent No. 5,634,062, "…" (Shimizu et al.), issued 1997‑05 (day not captured in the retrieved snippet).
• Date status: Issued May 1997 — after 5,845,299's filing/priority date (1996‑07‑29). It is therefore prior art only under 35 U.S.C. § 102(a)/(e)-type conditions as they existed pre‑AIA (i.e., it could be cited as evidence of another's earlier invention/patent, not as a printed publication "before the invention by applicant"). On its face, with a May‑1997 issue date, it cannot anticipate claim 1 by itself unless it qualifies through a §102(e) date (its own underlying filing) that predates 1996‑07‑29.
• Anticipation assessment: I do not have a verified subject‑matter description for this reference (the snippet supplied only the number/inventor/date). I therefore cannot responsibly state which claim(s) it anticipates. Marked UNVERIFIED – needs full‑text retrieval.

Reference 2 — U.S. Patent 5,634,095 (Wang et al.), issued May 1997

• Full citation: U.S. Patent No. 5,634,095, "…" (Wang et al.), issued 1997‑05.
• Date status: Same as above — issued May 1997, i.e., after the 1996‑07‑29 priority date. It qualifies as prior art, if at all, only via a §102(e) pre‑filing effective date, not as an anticipatory printed publication as of the invention date.
• Anticipation assessment: Subject matter not verified from the retrieved data. Which claims it potentially anticipates cannot be stated without its text. Marked UNVERIFIED.

4. What "anticipates" would require for 5,845,299 (analytical framework)

To anticipate under §102, a single reference would have to disclose every element of the claim at issue. Independent claim 1 (and its companion method/apparatus claims, which the WO search report indicates span claims 1–23) requires, in substance:

1. displaying a plurality of page display elements on a display device forming a page layout;
2. receiving an indication that the user wants to add a new display element at a first position;
3. adding a new "draw data structure" in memory to a plurality of other draw data structures, the new structure including data representing the first position; and
4. generating, in response to an indication to create the Web page, at least one HTML table that substantially reflects the layout of the entire displayed page on a pixel‑by‑pixel basis in accordance with the draw data structures.

(Distinguishing features that any anticipation analysis must confront: the internal draw‑object/draw‑data‑structure model distinct from the display elements; the generation of a single HTML table (or tables) replicating the whole page pixel‑for‑pixel; the auto‑generated banner/navigator/text‑button elements reflecting site hierarchy; and the header/body/footer table‑matrix construction of FIGS. 23–29.)

Sources for claim text: https://uspto.report/patent/grant/5,845,299 ; https://patents.google.com/patent/US5845299A/en

5. Relevance of the two confirmed citations to specific claims

Because both confirmed citations post‑date the priority date, neither is a prima facie §102 printed‑publication anticipation of claim 1 on the dates shown; they could only bear on §102(e) or on §103 obviousness, and only if their disclosures map to the draw‑data‑structure + whole‑page HTML‑table limitations.

6. Additional consideration: the closest sibling art is not a "citation"

The single most relevant related document is the co‑pending application expressly incorporated by reference:

• U.S. Ser. No. 08/687,971 (Arora et al.), "Hierarchical Structure Editor for Web Sites," filed concurrently (1996‑07‑29) — same inventive entity. Under 35 U.S.C. §102(e)/§103, a commonly‑owned or commonly‑invented co‑pending application with a common priority date is generally not prior art to 5,845,299 (and the automatic banner/navigator generation features are attributed to this sibling in the specification), so it should not be treated as anticipatory.

7. Honest bottom line

• Verified cited references: US 5,634,062 (Shimizu et al., May 1997) and US 5,634,095 (Wang et al., May 1997) — only these two were retrievable, and only as bibliographic entries.
• I cannot provide a defensible claim‑by‑claim §102 anticipation mapping for them, because (a) their issue dates post‑date the 1996‑07‑29 priority date, and (b) I did not obtain their disclosure text. Stating which claims they "potentially anticipate" would require fabrication, which I will not do.
• The remainder of the "References Cited" list (U.S. patents, foreign documents, and any NPL) was not retrievable in this session and is therefore not reported here.

Recommended next steps to complete a proper §102 study: pull the full US 5,845,299 front page and "References Cited" (56) block from the USPTO PatentCenter/PatFT full‑text image (or the Google Patents PDF), then retrieve the full text of each cited U.S. reference and test each against claim 1 and its dependents. Note also that 5,845,299 is now the subject of IPR2025‑01224 (TikTok/Bytedance petitioners), whose petition and expert declaration may already contain a validated prior‑art mapping you can cite directly.

If you can supply the patent's front‑page image, the PDF, or the Google Patents citations JSON, I will complete the reference‑by‑reference §102 table (full citation, dates, subject‑matter description, and anticipated claim numbers) as requested.

I'll start by pulling the prior-art record associated with this patent so the analysis is grounded in the actual references of record rather than memory.

Good — I found the prior-art citation record. Let me pull the specific references cited and confirm their disclosures.

Let me get the complete front-page reference list and confirm the identity of the two cited U.S. patents.

Obviousness Analysis — U.S. Patent 5,845,299 ("Draw-based editor for web pages")

Analyst note on evidence base. The Google Patents text supplied in the prompt did not render the "References Cited" table or the literal claim set (the fetch captured the description, abstract, and classifications only). I therefore retrieved the front-page citation record by search. Items below marked [confirmed] were verified against retrieved sources; items marked [not confirmed] I could not verify and I do not rely on them.

I. The record: what was actually before the examiner

U.S. patent references on the face of '299 [confirmed, via PTAB Ex. 1009 reproduction of the '299 front page]:

Foreign reference [confirmed as cited]: WO 94/28480 (12/1994). [not confirmed — subject matter unknown; I do not rely on it.]

Non-patent literature cited [confirmed as cited]: "Adobe PageMill 1.0 … for the HTML-Challenged"; Ceneca press release, "Ceneca pioneers easy-to-use authoring and integrated Site management tools for Worldwide Web" (Aug. 1995); "Silicon Graphics drives internet innovation with powerful authoring tools for 3D world wide web sites" / WebMagic Pro (Aug. 1995); "Vermeer: any server, any time," RELease 1.0 (Sep. 1995); Miller et al., "Create your own web page," PC/Computing (Sep. 1995); Glass, "Pipeline," InfoWorld (Oct. 1995); Mendelson, "HoTMetaL PRO," PC Magazine (Oct. 1995); Collins, "HTML's first lesson," PC Magazine (Oct. 1995); Harvey, "Working on the web: HTML authoring tools," Computer Shopper (Nov. 1995); Hawn, "A preview of Ceneca's hot Web tools," MacWorld (Nov. 1995); Pogue, "Claris Works 4.0," MacWorld; Gralla, Computer Shopper (Dec. 1995); "Netscape readies Navigator 2.0," Seybold Report (Nov. 1995); plus Gladwell (The New Yorker, 7 Apr. 1997) and Jurvis, "WYSIWYG Web design," InformationWeek (28 Oct. 1996).

Two threshold points that matter for § 103:

1. Effective filing date: 29 July 1996. The statutory-bar date is 29 July 1995. None of the 1995 NPL is § 102(b) art; all of it is available only under § 102(a)/(g) as publications before the (presumed) invention date. That is still sufficient to support § 103, but it means the applicant could in principle attempt to swear behind individual items — and, conversely, that the examiner's reliance on these items implies the examiner treated the filing date as the invention date.
2. Gladwell (Apr. 1997) and Jurvis (Oct. 1996) post-date the filing date and are therefore not available as prior art on their face. Jurvis ("WYSIWYG Web design") is only 3 months after filing and is arguably cited as background; neither can carry a § 103 rejection.

Presumed claim scope. Since the literal claims were not retrievable, I use the independent claim as recited verbatim in the Summary of the Invention:

(a) displaying a plurality of page display elements on a display device, the display elements forming a page layout; (b) receiving an indication that the user wants to add a new display element to the page at a first position; (c) adding a new draw data structure in memory for the new display element to a plurality of other draw data structures … where the new draw data structure includes data representing the first position; and (d) generating HTML that substantially reflects the displayed page layout on a pixel by pixel basis in accordance with the draw data structures.

PHOSITA: a software engineer with ~2 years' experience in GUI/object-oriented application or document authoring tools and working familiarity with HTML 2.0/3.0 and Netscape extensions (tables, frames). This is the level the specification itself assumes (C++, Windows 95).

II. Element-by-element mapping of the record art

III. Grounds of rejection

Ground 1 — Wang '095 in view of the 1995 WYSIWYG HTML-authoring art (PageMill; FrontPage/Vermeer; Ceneca; WebMagic Pro)

Wang alone discloses (a)–(c) almost verbatim: a two-level toolbox, drag-and-drop addition of an object at a drop location, persistence of those objects as data structures with page associations, and cross-page linking. What Wang lacks is step (d).

The NPL supplies (d). Adobe PageMill 1.0 was expressly reviewed as an authoring product "for the HTML-Challenged" (Aug. 1995); Vermeer's product was described in Sep. 1995 as working with "any server, any time" (i.e., authoring → HTML → publish); Ceneca's Aug. 1995 press release claimed "easy-to-use authoring and integrated Site management"; SGI's WebMagic Pro (Aug. 1995) was billed as a "powerful authoring tool" for web sites. Each therefore teaches that a non-programmer composes a page on screen and the tool emits the HTML.

Motivation (KSR / MPEP 2143): both references are in the same field (visual, direct-manipulation composition of a document/page by a non-programmer), and both address the same problem the '299 Background identifies — hand-coding markup is "exacting." Converting Wang's builder from emitting application code to emitting markup is the substitution of one known output formalism for another in a known pipeline; it changes no principle of operation and yields the predictable result of a web page matching the authored layout. The burst of at least four independent 1995 products doing exactly this confirms the solution was "obvious to try" in a mature field, not a leap. The claimed "draw data structure containing X/Y position" is also the ordinary data model of any WYSIWYG canvas — indeed the '299 Appendix A is just a C++ struct with x, y, width, height.

Ground 2 — Ground 1 further in view of the HTML-table practice (Netscape table extensions; the background's own admission)

The specification's Background concedes that "Netscape Communications Corp. has specified additional HTML features that extend HTML forms and tables." The 1995 HTML-authoring surveys of record (Harvey, Computer Shopper Nov. 1995; Mendelson, PC Magazine Oct. 1995) describe the then-standard toolkit, and HTML tables were the known mechanism for holding alignment across browsers — which is precisely the problem the patent's Background flags ("some browsers will automatically center a page title, while others may left justify"). One of ordinary skill, seeking layout stability, would predictably reach for tables. This ground supports the dependent claims directed to header/body/footer tables and to the "number and size of cells … reflects the number and placement of display elements."

Ground 3 — Shimizu '062 in view of the 1995 site-authoring art (claims to auto-generated navigation/structural links)

The claims/embodiments covering a page layout automatically populated with banner, navigator buttons and text buttons reflecting home/parent/sibling/child relationships, and structural links resolved by walking the page hierarchy at display/preview/publish time (FIG. 33: link stored as "next sibling link," node identified later), map directly onto Shimizu '062: link information "put into an order" where individual items can be "reference[d], add[ed], delete[d] and switch[ed]," displayed in list form, and directly manipulable on screen. Ceneca's claimed "integrated Site management tools" supplies the site-level framing. Motivation: storing relationships rather than hard-coded URLs is the express purpose of '062, and it is the only way to keep a multi-page site consistent — the second problem the '299 Background identifies (changing one link forces manual edits on multiple pages).

Ground 4 — Wang + Shimizu + the WYSIWYG/site-management NPL (full combination)

A single rejection treating Wang '095 as the page-composition engine, Shimizu '062 as the relationship/link model, and PageMill/Ceneca/FrontPage/WebMagic as the HTML-and-site-publishing layer covers (a)–(d) plus the structural-link and site-management dependent claims. All three are in the same art area, all were before the examiner, and no reference teaches away from integrating object-based page composition with markup generation.

IV. Where the rejection is weakest (and where a patent owner would fight)

1. "Pixel by pixel" + the matrix algorithm (FIGS. 26–29). None of the record art appears to disclose deriving unique row/column edges from draw-object bounding boxes, discarding duplicates, and emitting a table with variable ROWSPAN/COLSPAN cells sized to those edges. If "pixel by pixel" is construed to require the exact layout-preserving conversion (and note the specification's own caveat, "assuming that the browser supports Netscape version 3.X"), the broad WYSIWYG references are not enough — a petitioner would need a reference or expert testimony showing this conversion was known or obvious, and would have to avoid using the '299 specification itself as the roadmap (In re McLaughlin).
2. The two-stage model→publish architecture (draw objects persisted independently, HTML regenerated on publish, preview by writing HTML and invoking an external browser) is a design choice a court could see as an ordinary engineering decision — but its obviousness must be argued, not assumed.
3. Stacked pages / DataList / DataField (multiple HTML pages generated from database records with next/previous data-page links). Nothing in the cited record addresses database-to-HTML series generation. This is the strongest nonobviousness redoubt on the current record.
4. Image hotspots and transparent-color substitution (a new image is generated at publish time). Not addressed by the cited art; it would have to be met with image-map/MAP-tag art not of record.
5. Evidence limits. I confirmed only titles/snippets for the two U.S. patents and only citation lines for the NPL; the cited patents' full texts, and therefore their precise § 102(a)/(e) dates and enablement scope, are unverified here. A real petition needs the full documents. Also note that if any of the NPL items cannot be shown to be publicly accessible as of its stated 1995 date, that ground collapses.

V. Secondary considerations

• Forward citation: ~223–228 U.S. documents cite '299 [confirmed from the Google Patents "Cited By" counts]. That reflects technical prominence in the field but, standing alone, carries little weight for § 103 without nexus to a claimed feature.
• Assignment history: Rae Technology → NetObjects → Macromedia (2001/2002) → Adobe Systems (2006); Web.com entities also appear as assignees/security-interest holders. Corporate acquisition of the portfolio is weak, non-nexus evidence.
• Status: expired — anticipated expiration 29 July 2016 ("Expired – Lifetime"). The patent is now being used offensively as prior art against later patents (e.g., it is Exhibit 1009 in IPR2025-01224, TikTok v. Heliophilia, filed 8 July 2025) [confirmed].
• No teaching away appears anywhere in the cited record; the 1995 market was converging on WYSIWYG authoring, which cuts against nonobviousness.

VI. Bottom line

On the record as cited by the examiner, the independent claim as recited in the Summary is likely obvious over Wang '095 + any one of the 1995 WYSIWYG HTML-authoring references (PageMill being the cleanest, with Vermeer/FrontPage as backup), with Shimizu '062 added for the structural-link and auto-generated-navigation subject matter and the HTML-table practice added for the table-based dependent claims. The combinations are supported by same-field/same-problem reasoning, predictable results, and strong contemporaneous industry convergence (KSR, MPEP 2143–2144).

Conversely, claims specifically requiring the edge-sorting matrix that produces the ROWSPAN/COLSPAN table (FIGS. 26–29) and claims to stacked/data pages are the ones I could not render obvious from the cited references, and I would not assert they are without additional art I have not seen.