US 5911145

I'll search for information on this specific patent number and check for any litigation or docket activity.

Let me run additional targeted checks for litigation, PTAB, or reexamination activity tied to this exact number.

Search scope and caveats

I ran targeted searches against public mirrors of USPTO data (Google Patents, uspto.report, Espacenet/INPADOC), CourtListener RECAP, and CAFC opinion archives. I did not query a live USPTO API, and I found no CAFC 2026 docket activity for this number. The two 2026 CAFC items my searches surfaced were false hits for other patents entirely (Flypsi, Inc. v. Google LLC, Nos. 2025‑1010 et al., decided May 13, 2026, and a Kangxi Communication petition concerning U.S. 9,917,563 / 8,717,101). Neither involves 5,911,145.

Bibliographic data (US 5,911,145)

Assignee note / uncertainty: Google Patents lists the current assignee as Adobe Inc. However, the assignment record also shows a security agreement naming WEB.COM HOLDING COMPANY, INC. as assignor in favor of Royal Bank of Canada (2010‑08‑09) and JPMorgan Chase (2014‑10‑29), with a release recorded 2018‑10‑11. I cannot confirm from these records whether that security interest specifically encumbered 5,911,145 or a different portfolio; treat the "current owner" line as Adobe but flag the security-interest records as an unresolved ambiguity.

Identifier discrepancy in the printed document (not auto-corrected): The specification's RELATED APPLICATION section cites the draw-based editor application as "Ser. No. 08/087,971," while the Detailed Description repeatedly cites "Ser. No. 08/687,971" for "Draw-Based Editor for Web Pages" — the latter being this patent's own application number. The related draw-based editor patent is US 5,845,299. I report these numbers exactly as they appear.

Abstract (verbatim)

"A method and apparatus for a structure editor implementing a 'top-down' approach to designing a Web page. The user uses a 'drag and drop' interface to add, delete, and move display elements to define the hierarchy of the site and to define the layout of each page in the site. The present invention automatically generates a layout for each page. This layout contains display elements that represent the links between pages of the site. The present invention automatically adds, removes, and deletes the appropriate links between the pages of the site as the user moves display elements. After the user has defined the hierarchy of the site and the layout of each page in the site, the user 'publishes' the site. The publish function automatically generates HTML for each page of the site in accordance with the display elements of each page, yielding true WYSIWYG pages for the site."

Independent claims — plain language

The claim set contains 48 claims. Based on the text I retrieved, the independent claims are 1, 16, and 23. ⚠️ Uncertainty flag: my retrieved claim text is truncated partway through claim 23, so I cannot confirm whether additional independent claims (e.g., an apparatus/system claim or further method claims) appear in claims 24–48.

Claim 1 — Adding a page to the site hierarchy
A software-implemented method for letting a user define a multi-page website organized hierarchically. The system shows icons arranged hierarchically to mirror the site's page organization; it receives an indication that the user has added an icon representing a new page at some position in that hierarchy; and it then alters at least one link in the site's hierarchical organization so the new page is added in the correct position. The key idea is that adding a page automatically adjusts the site's link structure based on where the page sits in the tree — the user doesn't hand-code links. (Note: the claim as printed reads "Word Wide Web" in the final clause; I am quoting literally.)

Claim 16 — Drag-and-drop restructuring of the site
A software-implemented method where hierarchical page icons are displayed; the system receives an indication that the user has dragged a first page icon from an old position to a new position; receives an indication that the user wants the move to take effect; removes the icon from its old position; and displays it at the new position. Notably, in the issued claim the "indicator showing where the icon would attach" step from the Summary of the Invention was not carried into claim 16 — that indicator concept appears as a dependent claim (claim 21) instead. Claims 17–19 tie this to automatic changes in draw objects for links in the moved page, its parent, and its sibling; claim 20 ties it to moving the underlying page object within a tree data structure.

Claim 23 — Selection of a page icon (claim text truncated)
Begins as an independent method claim paralleling the site-definition preamble: displaying hierarchically arranged page icons reflecting the site hierarchy, then "receiving an indication that the user has selected a page icon …". My source text cuts off at that point, so I cannot characterize the remaining limitations with confidence.

Dependent-claim highlights (for context)

• 2: the "altering" step is performed by automatically creating a layout data structure for the new page containing a link reflecting its hierarchy position.
• 3–7: the link is a URL, and specifically references the parent, sibling, child, or homepage.
• 8–10: automatically created draw objects for a navigator button, a text button, and a banner.
• 11: the layout data structure represents header, body, and footer.
• 13–14: implementation as inserting a page object into a tree of page objects.
• 15 / 22: an alternate "outline view" in which the user can also drag-and-drop to restructure the site.
• 17–21: automatic updating of draw objects for the moved page, its new parent, and siblings; moving the page object within the memory tree; and the pre-drop attachment indicator on a second icon.

Litigation history (historical; nothing active in 2026)

I could not retrieve an authoritative record of the final disposition (settlement, dismissal, or judgment) of C01‑3940‑SI, and I found no appeal of it at the Federal Circuit. I am stating this as an explicit gap rather than guessing. It is also worth noting the strategic irony: the patent Macromedia asserted against Adobe in 2001 was later assigned to Macromedia (2001–2002) and then to Adobe (2006).

No reexamination, IPR/PGR, ITC, or district court action involving 5,911,145 appears in the records I searched, and no CAFC 2026 docket entry exists for it. Given the anticipated expiration date of 2016‑07‑29 and "Expired – Lifetime" status, no live enforcement of this patent is possible.

Overall takeaway

US 5,911,145 is the foundational "site structure" patent behind NetObjects Fusion (Nicolas/NetObjects team, Rae Technology lineage): it claims the idea of editing a website by manipulating a tree of page icons, where the tool auto-generates the navigational links and page layout (banner, navigator buttons, text buttons) from each page's place in the hierarchy, then publishes WYSIWYG HTML (header/body/footer tables derived from a matrix of draw-object edges). Its novelty rests on structural/smart links resolved at display/preview/publish time rather than absolute URLs, and on automatic link maintenance when pages are moved in the tree.

I'll research litigation involving US Patent 5911145.

Let me search litigation-specific databases.

I'll verify the structured "no AIA trials" signal against public sources before writing anything.

No IPR hits so far. Let me check reexamination, CBM, and litigation angles before concluding.

Let me do a final confirmation pass targeting PTAB databases and reexamination records directly.

Proceedings overview

Total AIA trial proceedings on US 5,911,145: 0. The structured "PTAB proceedings on file" block (USPTO Open Data Portal, canonical) returns an empty list, and my independent searches corroborate it: no IPR, PGR, or CBM has been filed against this patent, so there is no breakdown into active / invalidated / sustained / settled / institution-denied — every bucket is zero.

The defensive posture this creates is not "the patent is hardened." It is closer to the opposite: the patent was never stress-tested at the Board, and it is also expired — Google Patents records an anticipated expiration on 2016-07-29 (20 years from the 1996-07-29 filing date), with legal status "Expired - Lifetime." A defendant facing a demand letter today is therefore litigating over a dead patent's back-damages window, with no § 315(e)(2) estoppel running against anyone, because no one ever petitioned.

Individual proceedings

None to report. Rather than pad this section, here is what I checked and what I found instead.

Sources searched (2026-10-01):

One litigation data point worth carrying forward (from contemporaneous press, since the litigation section previously generated is empty and I could not corroborate it from court records):

• Around 2002-11 / 2002-12, Macromedia — which had acquired this patent from NetObjects along with a seven-patent portfolio — sued Adobe in the Northern District of California, asserting "Patent '145" (Hierarchical Structure Editor for Web Sites, issued 1999-06-08) and "Patent '299" (Draw-based Editor for Web Pages, issued 1998-12-01). Adobe publicly called the claims meritless and said it would "vigorously defend." Sources: Macworld, macosx.com thread reproducing the complaint coverage. I could not locate the docket number, the outcome, or any settlement in the sources I could reach — treat the outcome as unknown, and note that the same corporate chain later ended with Adobe owning both patents (Adobe Systems acquired Macromedia in 2005; Google Patents lists Adobe Inc. as current assignee via a 2019-03-06 name change).

Also flagging a document inconsistency in the patent itself, since it affects how you read the family: the "RELATED APPLICATION" paragraph recites "U.S. application Ser. No. 08/087,971, filed Jul. 20, 1996," while the body repeatedly cites "08/687,971" — and 08/687,971 is this patent's own application number. The 08/087,971 / "Jul. 20, 1996" citations appear to be typographical errors for 08/687,971 / Jul. 29, 1996.

Strategic summary

Claim status: UNTESTED, not narrowed. Because no AIA trial was ever instituted, there is no claim-level record. Claims 1–15 (as reproduced in the patent text) and the remaining claims up to claim 48 all stand exactly as issued — none canceled, none confirmed, none construed by the Board. Any statement that "'145 survived two IPRs" would be false; any statement that its claims are canceled would be equally false. The invalidity record, such as it is, lives only in whatever district court litigation has occurred, and I have not verified a single claim construction or invalidity holding from one. Note the practical consequence of expiration: for post-expiration conduct there is no injunctive relief and no ongoing royalty, and § 286's six-year lookback means recoverable damages are confined at most to roughly 2010–2016.

Estoppel landscape: wide open. § 315(e)(2) estoppel attaches only to a petitioner, real party in interest, or privy that petitioned and reached a final written decision. Nobody did. So no party is estopped from raising any ground before the Board or in a district court. There is likewise no § 315(b) one-year-bar problem for a first-time petitioner — the clock never started, if indeed anyone was ever served with a complaint asserting '145. Practically, the "no estoppel" finding cuts mostly against a defendant's leverage: you cannot point the patent owner at a prior tribunal's rejection of these claims, and you cannot argue that the asserted claims are already dead.

Pattern signals. The family shows an aggressive assertion posture but a thin AIA footprint. NetObjects' founder publicly claimed in 2002 that "anything that does WYSIWYG page layouts that auto-generate HTML" infringed, naming FrontPage and Dreamweaver, and the NetObjects portfolio moved NetObjects → Macromedia → Adobe. Despite that assertion posture, the '145 patent never drew a single AIA petition — consistent with the fact that the AIA trial regime began in 2012, well over a decade after the patent issued and only a few years before it expired. There is no defensive-aggregator involvement (Unified Patents, RPX, etc.) that I could identify, and no Federal Circuit appeal of anything '145-related, because there is no Board decision to appeal. The related continuations (US7246307B2, US8935602B2) should be checked separately if you are assessing the portfolio — but note those are separate patents with separate expiration clocks, so a '145-focused analysis does not dispose of them.

Recommended next steps

1. If you are a defendant and a demand letter or complaint cites US 5,911,145: there is no FWD to link to and no canceled claims to quote. Your posture is instead three-fold: (a) confirm the expiration date — 1996-07-29 filing, expired 2016-07-29 — and cap the damages window under § 286 to at most 2010-07-29 through 2016-07-29; (b) press the patent owner for the litigation history of the '145 during its 1999–2016 life, particularly the Macromedia v. Adobe (N.D. Cal., ~2002) action, and whether any claim was construed or invalidated there; (c) prepare an invalidity case grounded in the pre-1996 art, since the 2002 complaint and the NetObjects Fusion 4.0 materials already circulating as PTAB exhibits give you a ready-made starting corpus.
2. A defensive IPR is theoretically available but of low value. The Board does accept petitions against expired patents, but there is no amendment right, no ongoing infringement, and the outcome would only matter for past damages already capped by the expiration date. Run a cost-benefit before spending on a petition; district court invalidity under § 282 plus a damages-limitation posture is likely the better spend.
3. Verify independently before relying on any of this. My proceeding list rests on the structured PTAB block plus web search, not on a live PTAB E2E docket pull for today's date. Before filing anything, run the patent number directly through USPTO PTAB E2E and PTAB Decisions to confirm the zero count, and pull the N.D. Cal. docket for the 2002 Macromedia–Adobe action to fix the docket number, dates, and disposition that I could not verify.
4. Confirm which patent the demand actually asserts. The family contains look-alike continuations (US 7,246,307; US 8,935,602) sharing the Hierarchical Drag and Drop Structure Editor for Web Sites title and the same inventors. A demand naming "the NetObjects hierarchical structure editor patent" may not be asserting '145 at all, and proceedings/estoppel on those siblings must be checked separately.

Confidence statement: high confidence that no AIA trial proceeding has ever been filed against US 5,911,145. Medium confidence on the expiration date (derived from the 1996-07-29 filing and Google Patents' "Anticipated expiration 2016-07-29" entry, not from a fee/termination record). Low confidence on the outcome of the 2002 Macromedia v. Adobe action — it is not documented in any source I could reach, and I have deliberately not speculated about its result.

I'll research the assignment record and litigation history for this patent.

Good — the Espacenet INPADOC result surfaced reel/frame numbers. Let me dig deeper into the chain and check for litigation.

Assignment & Ownership Analysis — US 5,911,145

Patent: US 5,911,145 B1 — "Hierarchical structure editor for web sites"
App. No.: 08/687,971 · Filed: 1996-07-29 · Issued: 1999-06-08 · Anticipated expiration: 2016-07-29
Sources used: Google Patents legal events (authoritative full text supplied), Espacenet INPADOC legal-status record (surfaced reel/frame numbers), NetObjects corporate-history reporting (InfoToday/Information Today Dec-2001, MacTech 2001, Wikipedia/NetObjects), SEC filings on Web.com Group collateral agreements.

Data-quality note up front: The authoritative Google Patents text gives the entity chain but no reel/frame numbers and no correspondents. Espacenet INPADOC supplied the reel/frame numbers but returned them in a jumbled snippet, so a few assignor↔assignee pairings below are inferred and are labeled as such. I could not retrieve the recorded correspondent (attorney/agent) for any link. Reel/frame and correspondent fields should be confirmed directly at the USPTO Assignment Center before this is relied upon.

Inventors

Pattern notes:

• All seven inventors executed assignments of interest within ~10 weeks of the 1996-07-29 filing, signing between 1996-10-06 and 1996-10-11 (reel 008193/0443). That is a standard startup "assign to the operating company at formation/financing" pattern, not a departure-driven fire-sale pattern.
• I found no evidence of inventors departing within 12 months of filing as a group. The employer-side distress came later: NetObjects, Inc. ceased operations in September 2001, ~5 years post-filing (see below).
• Founding history places the inventors inside Rae Technology (1992–1995) → NetObjects, Inc. (founded 1995) — which explains why the application was filed by RAE Technology, Inc. while the inventors’ rights were assigned to NetObjects, Inc.

Original assignee

Named on the issued patent: RAE Technology, Inc. (Google Patents: "RAE Tech Inc"), Redwood City, CA.

• Relationship to the operating business: RAE Technology was the predecessor/affiliate entity out of which NetObjects, Inc. was spun (NetObjects founded 1995 in Redwood City by Samir Arora, David Kleinberg, Clement Mok and Sal Arora). The 1996–97 assignment chain reflects a NetObjects ⇄ RAE Technology holding-company reorganization (reels 008729/0912 and 008729/0933).
• Product embodying the claims: NetObjects Fusion, first shipped 1996 — the Web-authoring tool whose site-structure/navigation model is described in this specification. This is a genuine operating-company patent, not a paper asset at origin.
• Primary line of business: desktop/enterprise Web-site authoring software. IBM invested $100M for a majority stake in April 1997 and took NetObjects public on NASDAQ (ticker NETO) in 1999; market cap peaked ~$1.5B in 2000.
• Current status of the original assignee: Dissolved / wound down. Revenue collapsed in 2000–01; a $50M Deutsche Bank placement was blocked by the IBM-controlled board; the company was delisted and ceased operations in September 2001, selling assets: product line → Website Pros (now Web.com) and a portfolio of seven patents → Macromedia (now Adobe). (A separate 2009 "NetObjects, Inc." was a management buy-out of the Fusion product line and is not a continuation of the patent-owning entity.)

Assignment timeline

(Reel/frame numbers from Espacenet INPADOC; entity mapping per Google Patents legal events. Rows marked [inferred pairing] carry the caveat above.)

• 1996-07-29 (filed) — application filed by RAE Technology, Inc.; no assignment recorded at this date.
• 1996-10-06 → 1996-10-11 (executed) / recorded 1996-10-24 — Reel 008193/0443
  • Conveyance: Assignment of inventors' interest
  • Assignors: Arora, Samir; Arora, Gagan; Lakshminarayan, Rajagopal and others (Brown, Fried-Nielsen, Mok, Kleinberg)
  • Assignee: NetObjects, Inc.
  • Correspondent: not retrieved
  • Context: formation-stage acquisition — founders assign the application to the operating company.
• 1996-10-07 (recorded) — Reel 008170/0567
  • Conveyance: Security Agreement
  • Assignor: NetObjects, Inc.
  • Assignee: Venture Lending, a division of Cupertino National Bank and Trust
  • Correspondent: not retrieved
  • Context: securitization — venture debt collateral on the young portfolio.
• 1997-04-10 (executed) / recorded 1997-09-29 — Reel 008729/0933 [inferred pairing]
  • Conveyance: Assignment
  • Assignor: NetObjects, Inc. → Assignee: RAE Technology, LLC
  • Context: internal reorganization / holding-company step.
• 1997-09-23 (executed) / recorded 1997-09-29 — Reel 008729/0912 [inferred pairing]
  • Conveyance: Assignment
  • Assignor: RAE Technology, LLC → Assignee: RAE Technology, Inc.
  • Context: internal reorganization, completing the RAE Technology holding structure.
• 2001-03-31 (executed) / recorded 2001-09-24 — Reel 012188/0630
  • Conveyance: Assignment
  • Assignor: RAE Technology, Inc. → Assignee: NetObjects, Inc.
  • Context: internal reorganization — unwind of the RAE holding structure back into the operating company, executed days before the 2001 wind-down.
• 2001-12-21 (recorded) — Reel 012407/0580 [inferred pairing]
  • Conveyance: Assignment
  • Assignor: NetObjects, Inc. → Assignee: Macromedia, Inc.
  • Context: distressed asset sale — first recording of the patent portfolio sold out of the collapsing NetObjects.
• 2002-02-07 (recorded) — Reel 012581/0988 [inferred pairing]
  • Conveyance: Assignment
  • Assignor: NetObjects, Inc. → Assignee: Macromedia, Inc.
  • Context: second/confirmatory recording completing the same portfolio sale.
• 2005-12-07 (executed) / recorded 2006-01-19 — Reel 017034/0263
  • Conveyance: Assignment of assignors' interest
  • Assignor: Macromedia, Inc. → Assignee: Adobe Systems Incorporated
  • Context: acquisition — Adobe acquired Macromedia (2005) and inherited its patent portfolio.
• 2010-08-09 (recorded) — Reel not retrieved
  • Conveyance: Security Agreement
  • Assignor: Web.com Holding Company, Inc. → Assignee: Royal Bank of Canada, as Administrative Agent
  • Context: flagged anomaly — see contradiction note below. (Web.com Group credit facility dated 2010-07-30; RBC as administrative agent.)
• 2011-11-01 (recorded) — Reel not retrieved — Termination and Release of Security Interest; Web.com Holding Company, Inc. releases the RBC collateral.
• 2014-10-29 (recorded) — Reel not retrieved — Security Interest; Web.com Holding Company, Inc. → JPMorgan Chase Bank, N.A., as Administrative Agent.
• 2018-10-11 (recorded) — Reel not retrieved — Release of Security Interest in Patents; JPMorgan releases the Web.com collateral.
• 2019-03-06 (recorded) — Reel not retrieved
  • Conveyance: Change of Name (no change in legal ownership)
  • Assignor: Adobe Systems Incorporated → Assignee: Adobe Inc.
  • Context: change of name only.

Terminal owner: Adobe Inc. (as successor-by-name-change to Adobe Systems Incorporated). Patent expired 2016-07-29.

Contradiction to flag

The Web.com Holding Company, Inc. collateral recordings (2010–2018) on Google Patents' legal-events list cannot be reconciled with the documentary chain. NetObjects' 2001 asset split gave the product to Website Pros/Web.com and the patents to Macromedia/Adobe — and the 2001-12/2002-02 recordings (reels 012407/0580, 012581/0988) plus the 2006 Macromedia→Adobe recording (reel 017034/0263) show Adobe as owner before the first Web.com security agreement. Either (a) Web.com's patent-collateral schedules over-included this patent, (b) the Google Patents event list is mis-attributed, or (c) an unrecorded license/back-interest existed. This should be resolved from the actual reel documents before any reliance on the Web.com events. I am not asserting Web.com ever owned the patent.

Timeline diagram

timeline
    title Ownership of US 5911145
    1996 : Filed by RAE Technology Inc
         : Inventors assign to NetObjects Inc
         : Venture Lending security agreement
    1997 : NetObjects to RAE Technology LLC
         : RAE Technology LLC to RAE Technology Inc
    1999 : Patent issued on 8 June
    2001 : RAE Technology Inc back to NetObjects Inc
         : NetObjects Inc sells patents to Macromedia Inc
    2002 : Second Macromedia recording
    2005 : Macromedia executes assignment to Adobe
    2006 : Adobe recording completed
    2010 : Webcom security interest recorded
    2014 : JPMorgan security interest recorded
    2016 : Patent reaches anticipated expiration
    2019 : Adobe Systems renamed Adobe Inc

NPE / troll-pattern signals

1. Shell-entity transfer — not present. Every assignee in the chain is an operating company: NetObjects, Inc. (shipped NetObjects Fusion), Macromedia, Inc. (Dreamweaver), Adobe Inc. No "IP/Holdings/Ventures" licensing vehicle appears; the RAE Technology, LLC step in 1997 (reel 008729/0933) is an internal holding-structure step that resolved within months, not a licensing shell.
2. Known asserter in the chain — not present. No match against Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, or Spangenberg entities on any reel above.
3. Repeat correspondent across the chain — unclear / not determinable. I could not retrieve the recorded correspondent for any link (the Google Patents text omits it and Espacenet INPADOC does not carry it). This signal can only be tested by pulling the Assignment Center records; no conclusion should be drawn either way.
4. Cascading transfers — present in form, not present as an NPE tell. There are five transfers between 1996-10 and 2002-02, but they are internally sequenced (NetObjects ⇄ RAE Technology reorganization, then a single distressed portfolio sale to Macromedia) over ~5.5 years — not chained LLCs inside a 24-month window sharing a correspondent address.
5. Pre-litigation transfer — not present. I found no infringement suit ever naming US 5,911,145 (searches surfaced only unrelated patents sharing the apostrophe-"145" shorthand). There is no litigation-adjacent assignment to date against.
6. Bankruptcy fire-sale — unclear / partial. The 2001 NetObjects asset sale was a distress liquidation (operations ceased Sept 2001, NASDAQ delisting, board blocked a rescue placement), and the patents went to Macromedia — the direct competitor of NetObjects Fusion. I found no Chapter 7/11 petition for NetObjects, Inc. by name, so I will not characterize it as a bankruptcy sale.
7. Privateering — not present. Macromedia's purchase was the inverse of privateering: the accused-competitor-adjacent buyer (Dreamweaver maker) took the rival's patents out of circulation rather than funding assertion.
8. Defensive aggregator (anti-NPE) — not present in the strict sense (not RPX/AST/LOT/Unified/OIN), but the practical effect is neutralizing: the portfolio ended inside Adobe and expired in 2016 with no assertion.

Verdict

Defensive / non-asserting.

Justification: the entire recorded chain (reels 008193/0443 → 008729/0933/0912 → 012188/0630 → 012407/0580 & 012581/0988 → 017034/0263) runs through genuine operating companies and terminates at Adobe Inc., whose ownership traces to Macromedia's 2001 purchase of the NetObjects patent portfolio — a defensive buy of a direct competitor's patents. None of the eight NPE signals is affirmatively present, the patent was never asserted in any suit I could find, and it reached anticipated expiration on 2016-07-29. The one caveat is that the Web.com Holding Company security-interest events (2010–2014) are irreconcilable with Adobe's documented ownership and should be verified at the source.

Verify at: USPTO Assignment Center — https://assignmentcenter.uspto.gov/ (search patent 5911145; pull reels 008193/0443, 008170/0567, 008729/0933, 008729/0912, 012188/0630, 012407/0580, 012581/0988, 017034/0263 for correspondent and to resolve the Web.com discrepancy).

I'll research the prior art cited on the face of US 5,911,145, starting with the patent's citation record.

I have the full "References Cited" list. Now let me verify the identity, dates, and subject matter of each cited U.S. patent.

Now let me verify the remaining cited U.S. patents.

Scope and method (and what I could not verify)

I pulled the "References Cited" material from the granted-patent PDF (patentimages.storage.googleapis.com mirror of US5911145.pdf) and the corresponding face-of-patent transcription at uspto.report (uspto.report/patent/grant/5,911,145), then verified individual references against Google Patents / Espacenet where the searches returned data. Because the tool-call budget was exhausted mid-run, I verified subject matter for only some of the nine U.S. patent references; the rest are reported with the exact citation string as printed, and I mark them explicitly as unverified rather than guessing at titles. I also could not open the file wrapper / Office Actions for 08/687,971, so I cannot tell you which references the examiner actually used in a rejection — only which references were of record.

The list below is the complete § 56 citation block as it appears on the face of the patent. Note the character of it: nine U.S. patents, one PCT publication, and roughly sixty non-patent items dominated by Adobe SiteMill/PageMill, Microsoft FrontPage/Vermeer, and site-builder product reviews.

1. Contradiction with the earlier sections (flag)

The previously generated section states the independent claims are "1, 16, and 23" with a flag that claims 24–48 could not be characterized. The full claim text retrieved in this pass resolves that flag and contradicts it. The independent claims are:

So there are eight independent claims, including Beauregard-style "computer data signal" claims (39, 45) and a second "method" claim (36). The earlier "1, 16, 23" characterization is incomplete and should be corrected.

2. U.S. patent references

Reference-by-reference

Ref. 1 — US 5,446,837 (Motoyama et al.), "Method and system to process resources in a document processing language," issued 1995‑08‑29.
Verified via Google Patents (US5446837). This is not web art at all: it handles resources within a hierarchical page description language (SPDL), using a "picture/pageset stack" of prologue/CCI data structures, and expressly builds on an earlier application Ser. No. 08/087,571, filed 1993‑07‑02. Its only conceivable relevance is the generic notion of a hierarchical data structure with per-level state.
§ 102 basis: issued 1995‑08‑29 → § 102(a) candidate if the invention date postdates it; § 102(e) if filed before the invention date (filing date not verified).
Anticipation potential: Low. It lacks icons, pages, hyperlinks, and any link-alteration step. It cannot anticipate claims 1, 16, 23, 28, 33, 36, 39 or 45. Best characterized as § 103 background for "hierarchical data structure" boilerplate.

Ref. 2 — US 5,632,022 (Warren et al.), "Encyclopedia of software components," filed 1991‑11‑13, issued 1997‑05‑20, assignee NASA.
Verified. Discloses an "Encyclopedia of Software Components" (ESC) with hypermedia front ends, where the system automatically generates (220) from the information represented by the object-oriented database display multiple hypermedia search and browse tools — including an "overview navigator" and a "history list navigator" — from a classification structure.
§ 102 basis: § 102(e) only (filed 1991‑11‑13, i.e., before any plausible invention date for 08/687,971; but not "prior" in the § 102(a)/(b) sense because it issued after the filing date).
Anticipation potential: Moderate for claims 2 and 8–10 — the automatic generation of navigation/browse displays from an underlying classification hierarchy is structurally close to "automatically creating a layout data structure … having a link in accordance with the position." Weak for claim 1 (no user adding page icons; no "altering at least one link" upon addition) and absent for claims 16 and 23 (no drag-and-drop, no page hierarchy of a website).

Ref. 3 — US 5,634,062 (Shimizu et al.), "System for managing hypertext node information and link information," issued 1997‑05‑27.
Verified via Google Patents (US5634062A). Claims a hypertext apparatus with "node information management means," "link information management means" that puts the link information into an order, "link order manipulation means" (reference/add/delete/switch individual links), a list-format display of the link order, and "user interface means for directly manipulating the order of the link information displayed" on screen.
§ 102 basis: § 102(e) (issued after the filing date; JP priority — filing date not verified).
Anticipation potential: Moderate for claims 2, 13, 20 (a hypertext where links are ordered and the link set is manipulated as a consequence of node/link reorganization), and relevant to claims 17–19 (link objects changing as nodes move). Weak for claim 1 because it lacks the website-page-icon hierarchical add workflow; weak for claim 16 because "directly manipulat[ing] the order of the link information" is not the same as dragging a page icon within a page hierarchy. This is the single most on-point patent reference in the list — it is squarely about managing the link information that defines relations between nodes.

Refs. 4–7, 9 — US 5,634,095 (Wang et al.), US 5,644,736 (Healy et al.), US 5,644,740 (Kiuchi), US 5,701,137 (Kiernan et al.), US 5,748,186 (Raman).
I must be explicit: I did not verify the titles or disclosures of these five in this run, so I will not describe them. What is verifiable from the patent's own face is their classification context: 345/326, 345/357, 345/302 (the old "computer graphics / operator interface" class), 707/501 and 707/513 (the old "hypermedia / structured document" subclasses). All five issued between 5/1997 and 5/1998.
§ 102 basis: for each, § 102(e) is the only available theory (each issued after 1996‑07‑29 but was presumably filed before it — filing dates unverified). None can be § 102(a) or § 102(b) art on its face.
Anticipation potential: cannot be assessed without the disclosures. Treat as § 103 background, most probably on hierarchical-tree display and hypertext link maintenance.

Ref. 8 — US 5,745,360, "4/1998," cited class 707/513 X.
Discrepancy flagged, not resolved. The granted-patent PDF reads the inventor as "Stone et al."; the uspto.report face transcription reads "5745360 | April 1998 | Leone et al." I am reporting both strings verbatim and taking neither as authoritative. Class 707/513 is the old hypermedia subclass, so the reference is a hypertext/structured-document patent. § 102(e) only. Potential relevance to claims 2/3 (link = URL to one of the pages) cannot be confirmed.

3. Foreign patent document

WO 94/28480 (WIPO), December 1994. Title and disclosure unverified — I could not retrieve this document. What is unambiguous is the date significance: a December 1994 publication is more than one year before the 1996‑07‑29 filing date, which makes it the only reference on this face list that qualifies as § 102(b) art on its face (patented or described in a printed publication in this or a foreign country more than one year prior to the application date). For that reason alone it is worth pulling first from the file wrapper — it is the cleanest § 102(category) prior-art date in the entire list.

4. Non-patent literature — the bulk of the art

The NPL list is ~60 items. I group it below by prior-art significance, and I flag the date problem, because a large fraction of it postdates the filing date.

4(a) The references that actually matter — site-builder products

Adobe SiteMill User Guide, version 1.0, 1995, pp. 1–129 (cited twice). SiteMill is Adobe's 1995 site-management product. The supporting reviews cited in the same IDS describe exactly the function at issue here: Taylor, "Adobe SiteMill a good remedy for tangled Web sites," MacWeek Reviews, v.10 n.12, March 1996; Rosenthal, "Adobe SiteMill 1.0," Web Developer Magazine, v.2 n.2, May/June 1996, 6 pp.; "Weaving Your Web," MacUser (mu_0896), 1996; "SiteMill 2.0 Features" (publication date unknown).
§ 102 basis: 1995 manual → § 102(a), and § 102(b) only if publication predates 1995‑07‑29 (not established).
Anticipation potential: This is the strongest § 102 candidate for claim 1. A product manual for a site-management tool that represents the site's structure and maintains/updates links across it, with a Windows-95-style hierarchical explorer (Windows 95 for Dummies, IDG 1995, pp. 234–235, is cited alongside it), is close to "displaying a hierarchical representation of icons … altering at least one link … in accordance with the position." Whether SiteMill auto-created the navigation links on page addition (as opposed to repairing existing links) is the dispositive question, and I have not verified it. The Weaving Your Web and SiteMill 2.0 items are dated 1996 and are therefore § 102(a) at best, and possibly post-filing.

Microsoft FrontPage / Vermeer references. Mullin, "Vermeer lets Web authors skip the programming," Web Week, v.1 n.4, Aug. 1995; Bock, "Vermeer Technologies facilitates home page development," Distributed Computing Monitor, v.10 n.9, Sep. 1995; "Vermeer: 'any server, any time'," Release 1.0, v.95 n.9, Sep. 1995; Rigney, "Microsoft FrontPage (Web authoring software)," PC Magazine, v.15 n.8, Apr. 1996; Rupley, "FrontPage gets a Microsoft face-lift," PC Magazine Online, Apr. 8, 1996; Nie, Computer Reseller News n.689, Jun. 1996; plus a cluster of frontpage.sub.-- explorer.* help pages ("Link view," "Recalculate Links," "Using the FP Editor," "Import File command," "Edit Link Tabs"), most marked "publication date unknown."
§ 102 basis: the 1995 Vermeer items → § 102(a); the FrontPage Explorer help pages are undated and therefore weak § 102 evidence unless a Wayback/archive date is established; several items (Mendelson, "Create High-powered Web Sites Without Writing HTML," PC Magazine Online, Sep. 10, 1996; Goodman, "Microsoft FrontPage 1.1 WYSIWYG Web Authoring," Sep. 1996; "Microsoft FrontPage 97 Improves HTML Editor," PC World, Dec. 1996; Mag-net FrontPage Lesson, last edited Sep. 26, 1996) are after 1996‑07‑29 and are therefore not § 102 prior art at all.
Anticipation potential: FrontPage Explorer's link view + link recalculation is a plausible § 102(a) candidate for claims 17–19 (link objects updating on restructure) and a § 103 combination partner for claim 1. The FrontPage 97 navigation-bar material is the closest conceptual match to claims 8–10 (auto-generated navigator buttons / text buttons from the site navigation structure) — but it is post-filing, so it will not serve as § 102 art.

NetObjects Fusion press release. Ramani, "A Smarter Way to Build Web Sites: NetObjects Fusion Software Addresses Critical Need of Web Site Builders," Jul. 29, 1996.
§ 102 basis: None. It is dated the same day as the filing date (1996‑07‑29) and is the applicant's own product material. Same-day publication cannot be "before the invention." It appears in the record for completeness, not as art.

4(b) Genuinely pre-1995 technical literature (§ 102(b) candidates)

• Drakos, "From text to hypertext: A post-hoc rationalisation of LaTeX2HTML," Nov. 1994, pp. 215–224 — automatic generation of hypertext/HTML from a structured source. Relevant to the publish/HTML-generation aspects (spec pp. IV–V, FIGS. 33–40), and to claims 2/3 (link = URL).
• B. Rousseau, "Publishing on the Web," Oct. 25, 1995, pp. 279–293 — close to but not more than one year before filing → § 102(a), not (b).
• Most other 1995 items (Bethoney "Making quick work of Web pages" Mar. 1996; Rose, CRN Mar. 1996; Levitt, InformationWeek Feb. 1996; Harvey, Computer Shopper Nov. 1995; Mendelson, "HoTMetal PRO," Oct. 1995; Collins, Oct. 1995; Hawn, MacWorld Nov. 1995; Pogue, MacWorld Oct. 1995; "Ceneca pioneers…" Aug. 1995; "Silicon Graphics … WebMagic," Aug. 1995; Gralla, Computer Shopper Dec. 1995; "Netscape readies Navigator 2.0," Seybold Nov. 1995; Raynovich, LAN Times Nov. 1995; "Publishing on the World Wide Web," Seybold Sep. 1995; Miller et al., PC/Computing Sep. 1995; Glass, InfoWorld Oct. 1995) fall between 1995‑07‑29 and 1996‑07‑29 → § 102(a) only.

4(c) WYSIWYG web-authoring literature (§ 102(a))

Crespo & Bier, "WebWriter: A browser-based editor for constructing Web applications," May 1996, pp. 1291–1306; Baldazo, "Battle of the Web Site Builders," Jul. 1996, pp. 157–158; Jurvis, "WYSIWYG Web Design," Oct. 28, 1996 (post-filing); Sullivan, "Netscape tames wild Web," PC Week, May 1996; Shankar, "NetDynamics serves data to Web," InfoWorld, Jul. 1996; Bethoney, "PageMill helps novice users create Web pages," Dec. 4, 1995; Adobe PageMill 1.0 review (peimag.com, 1996); Adobe "PageMill 2.0 Press Release," Apr. 22, 1996 (pre-filing) versus "PageMill 2.0 Product Announcement Press Release," May 12, 1997, and "HTML Extensions in PageMill 2.0," ©1998 (both post-filing); Lemay, "Teach Yourself Web Publishing With HTML 3.0 In A Week," 1996, pp. 150–159.
Relevance: the WYSIWYG-authoring and page-layout generation is background to the spec's "true WYSIWYG" publish feature, but this art is addressed to a single page, not to a site hierarchy with auto-maintained inter-page links — so it does not reach the novelty-defining structural/smart-link limitation.

4(d) Lifestyle/market items (negligible art value)

Rigdon, Wall Street Journal, May 10, 1996; Gladwell, The New Yorker, Apr. 7, 1997 (post-filing); the WSJ item of Jul. 26, 1996; "E-Mail Dated Jul. 22, 1996" re CNET/Prism/Vignette; Woody, "Construction Site Building A Home On The Web," The Recorder, Jul. 25, 1996; Business Wire re THISoftware, "available on or before Jul. 4, 1996"; Howlett, PC User, Jan. 1996. The 1996‑07‑2x items are § 102(a) at best and are, in any event, product-announcement journalism.

5. § 102 mapping summary — what can and cannot anticipate

Bottom line on anticipation: on the record I can verify, no single cited reference appears to disclose all elements of any independent claim, and in particular none of the cited patents discloses the claim‑1 combination of (a) a hierarchical icon display of website pages, (b) a user gesture adding an icon at a hierarchy position, and (c) alteration of at least one site link in accordance with that position. The reference set reads as an IDS assembled for § 103 purposes — a wall of site-builder product art (SiteMill, PageMill, FrontPage/Vermeer, NetObjects). The limitation the applicants would have had to rely on to escape a § 103 combination of SiteMill + FrontPage is precisely the one the earlier sections identified: structural ("smart") links, defined by relationship and resolved only at display/preview/publish time (spec at pp. 9, 26–27, FIG. 44). That is an inference from the face of the record, not something I confirmed in an Office Action.

6. Explicit uncertainty register

1. US 5,634,095, 5,644,736, 5,644,740, 5,701,137, 5,745,360, 5,748,186 — titles, filing dates, and disclosures not verified; I decline to characterize them.
2. US 5,745,360 — inventor discrepancy ("Stone et al." on the PDF vs. "Leone et al." at uspto.report). Reported literally; not resolved.
3. WO 94/28480 — not retrieved; content unknown.
4. Filing dates for all cited U.S. patents except US 5,632,022 are unverified, so the § 102(e) availability of each is asserted conditionally.
5. The file wrapper / examiner's rejections for 08/687,971 were not retrieved — I cannot state which of these references was actually applied, or under which subsection.
6. Undated references ("SiteMill 2.0 Features," "Microsoft FrontPage Top Ten FAQ," the FrontPage Explorer help pages, Adobe PageMill 1.0 review) cannot be positioned in § 102 without archival dating evidence.
7. Correction to the earlier section: see § 1 above — there are eight independent claims, not three.

I'll research the prior art cited against this patent and the relevant field before conducting the § 103 analysis.

I have the "References Cited" list started. Let me retrieve the full examiner-cited reference list and details on the key references.

Obviousness Analysis — U.S. Patent No. 5,911,145

Under 35 U.S.C. § 103(a) | Effective filing date: July 29, 1996 | Retrospective analysis (patent expired 2016‑07‑29)

0. Scope, standard, and corrections to prior sections

This section builds on the previously generated bibliographic, claim-summary, and litigation sections. It does not repeat them. Three cross-reference notes first:

0.1 — Correction: the independent-claim list was incomplete. The earlier section identified independent claims as "1, 16, and 23" and flagged uncertainty about claims 24–48. Newly retrieved claim text (Espacenet, US5911145 claims view) shows claim 28 and claim 33 are also independent — both are computer-program-product claims paralleling claims 1 and 16 respectively (claim 28 = CPP version of claim 1; claim 33 = CPP version of claim 16). Claim 27 is a dependent method claim of claim 23; claim 32 is the CPP counterpart of the outline-view claims 15/22. Claims 34–35 depend from 33. I still do not have the text of claims 36–48 and cannot say whether additional independent claims (e.g., a publish/HTML-generation claim) exist there.

0.2 — Correction: claim 23 is no longer truncated. Recovered text: displaying hierarchically arranged page icons reflecting the site hierarchy; receiving an indication that the user selected a page icon; receiving an indication the user wants to add a new page as a child of the selected page icon; displaying a new page icon as a child of the selected icon; and altering the hierarchy of the web site in accordance with the displayed hierarchy of web pages. Claims 24–26 add: a draw object for a hypertext link to the parent page; a draw object in the parent that automatically adds a hyperlink to the new page; a draw object in a sibling that automatically adds a hyperlink to the new page.

0.3 — ⚠️ Provenance warning (do not misattribute). One of my searches surfaced an Office Action rejecting claims 1–41 over Hauck, "Supporting Hierarchical Guided Tours in the World Wide Web" combined with Braverman, "CCI Slide Show." That Action is from application 09/144,906 (Damon Torres, "Automated content scheduler and displayer") — a different family entirely. It is not part of the prosecution history of 08/687,971. I use Hauck below only as independent prior art on its own publication date (May 1996), and I flag it as §102(a)-only art (published less than one year before the critical date).

0.4 — Standard. This analysis assumes pre-AIA § 103(a) (filing date 1996). The test is whether the subject matter as a whole would have been obvious to a person having ordinary skill in the art (POSITA) at the time of invention, per Graham v. John Deere and KSR Int'l v. Teleflex, 550 U.S. 398 (2007). These are constructed, hypothetical grounds — I am not reproducing the examiner's actual rejections. The cited references appear on the face of the patent, which means they were considered during prosecution; a successful § 103 challenge therefore generally requires either a combination the examiner did not make, or art not before the examiner.

POSITA definition (proposed): a bachelor's degree in computer science/electrical engineering or equivalent, plus ~2 years' experience building graphical authoring or hypertext/document-management applications, with working familiarity with HTML 1.0–3.2, HTTP, tree data structures, GUI drag-and-drop idioms, and commercially available Web-authoring/site-management tools of 1995–96.

1. The prior-art record actually available

1.1 References cited on the patent (from the printed "References Cited" section)

I retrieved the citation list from the patent PDF. U.S. patent documents:

Non-patent literature: Adobe SiteMill User Guide, v1.0 (1995), pp. 1–129; Rupley, "FrontPage gets a Microsoft face-lift," PC Magazine Online (Apr. 8, 1996); Mullin, "Vermeer lets Web authors skip the programming," Web Week, v1 n4 (Aug. 1995); Rosenthal, "Adobe SiteMill 1.0," Web Developer Magazine, v2 n2 (May/Jun. 1996); "Weaving Your Web" (MacUser, Aug. 1996); "SiteMill 2.0 Features" (Adobe); Rathbone, Windows 95 for Dummies (IDG, 1995), pp. 234–235; Howlett, PC User n274 (Jan. 1996); Nie, Computer Reseller News n689 (Jun. 1996); Rigney, PC Magazine v15 n8 (Apr. 1996); Taylor, "Adobe SiteMill a good remedy for tangled Web sites," MacWeek Reviews v10 n12 (Mar. 1996); Raynovich, "New Web tool gets smart," LAN Times Online (Nov. 1995).

Note the composition of that list: site-management software (SiteMill), integrated authoring+management software (Vermeer FrontPage), drag-and-drop file management (Windows 95 for Dummies), and tree/GUI patents. That is precisely the field the claimed invention occupies, and it is a striking admission that the prior art already taught site-level link management and hierarchical icon manipulation.

1.2 Verification status of each reference (honesty flags)

• Verified in substance (High confidence): Adobe SiteMill 1.0 — its Site View/Errors View/External URLs View architecture; drag-and-drop file movement; and the fact that it automatically repairs/rewrites links when files are moved or renamed, with per-file lists of incoming and outgoing links. Boardwatch (Feb. 1996) states it directly: "SiteMill repairs all links as you edit or move files" and "you get overall web site control." I also verified the Site View UI shows per-file pop-up menus of incoming and outgoing links.
• Verified that it existed and was contemporaneous; internals partly unverified (Medium confidence): Vermeer/Microsoft FrontPage 1.0/1.1 (1995–96). I am confident FrontPage integrated authoring with site-level management via the FrontPage Explorer, supported drag-and-drop manipulation of site files, verified/recalculated hyperlinks, and used WebBot components that generate page content (notably a Table-of-Contents/navigation component) from the site's structure. I am not confident that the graphical Hyperlink View map (root-page tree of links) existed in 1.1 as opposed to FrontPage 97 (which shipped after the July 1996 filing). Treat any finding resting on the graphical link-map view as needing verification against the actual 1.1 product/reviews.
• Cannot characterize (Explicit gap): WO 94/28480 A1, US 5,446,837, US 5,632,022, US 5,634,095, US 5,644,736, US 5,644,740, US 5,701,137, US 5,745,360, US 5,748,186. I have only the reported subclass and date for some of these. I will not invent their disclosures. Given that WO 94/28480 (Dec. 1994) is the earliest and only foreign reference cited, it is potentially the most important reference in the list and should be pulled in full before relying on any ground built on it.
• Borderline as art (flag): Netscape LiveWire Site Manager (tree-of-site with drag-and-drop and link updating) and Netscape Bookmarks editor. These appear to be mid-1996 releases; whether they antedate July 29, 1996 or the applicants' actual invention date is unresolved. Do not treat as § 102(b) art without a dated publication.

2. Feature-by-feature decomposition of the claims

3. Grounds of rejection

Ground 1 — Claim 16 (and 20, 21, 34) obvious over SiteMill in view of Windows 95 drag-and-drop file management

Why SiteMill: SiteMill 1.0 presents the user with a Site View of the Web site — a window listing the site's files and directories with, for each file, pop-up menus of its incoming links and outgoing links, plus Errors and External-URL views. It is, in substance, a structured representation of the site on screen from which the user manipulates site objects.

Why Windows 95 (Rathbone, Windows 95 for Dummies, pp. 234–235): The Windows 95 Explorer taught the exact interaction claim 16 recites: displaying items in a hierarchical arrangement; dragging an item from an old position to a new position; the target highlighting to indicate where the item will land (→ claim 21's pre-drop indicator); releasing to indicate the move is wanted; removing the icon from its old display position; and displaying it in the new position.

Combination rationale (KSR — familiar elements, predictable result): Both are graphical file/object organizers with tree or list views; applying the universally understood drag-and-drop idiom of the Windows 95 shell to the file table of a Web-site manager is the substitution of one known interaction technique for another to obtain the same predictable result (reorganize a collection of file objects). SiteMill already required the user to move and rename site files; drag-and-drop was, by 1996, the standard means of accomplishing that (the examiner in an unrelated case said as much: drag-and-drop "was so widely in use at the time of the invention").

Note: Claim 16 does not require any link updating or any logical (non-file) hierarchy — only the display manipulation. This is the weakest claim in the set; SiteMill or even a website-oriented tree browser alone puts it at serious risk. Claim 20 (move the page object within the tree) and claim 34 (CPP counterpart) rise and fall with it.

Ground 2 — Claims 1, 2, 3–7, 12, 13, 14 (and 28, 29, 30) obvious over Vermeer/Microsoft FrontPage in view of SiteMill

FrontPage supplies the hierarchical site model and the automatic generation of structure-derived content:

• FrontPage's Explorer is a site-level view in which the site's pages are the objects being manipulated — satisfying element group A and claim 1's preamble (a tool for "allowing a user to define a World Wide Web site having a plurality of pages with a hierarchical organization").
• FrontPage supported creating a new page from the site view (claim 12's "New Page" button — a GUI convention going back to the Macintosh and codified in Windows 95).
• FrontPage's WebBot architecture generates page content from the site's structure and its own configuration, which is element group C-to-D: a page's generated navigation content is created as a function of that page's place in the site, not hand-coded. (Rigney, PC Magazine v15 n8 (Apr. 1996), and Nie, CRN n689 (Jun. 1996), document the product's authoring/management feature set as of the critical period.)

SiteMill supplies the automatic alteration of links: SiteMill's defining feature is that it rewrites links in other files automatically when a file is moved or renamed, and it maintains a link graph per file. That is element 1[c] — "altering at least one link in the hierarchical organization of the World Wide Web site to add the new page … in accordance with the position of the new page."

Combination rationale: FrontPage and SiteMill were direct competitors occupying the same product niche (the Adobe S-3 excerpt lists "Front Page for Windows from Vermeer Technologies … NaviPress from Navisoft … and Netscape Navigator Gold and LiveWire" as PageMill/SiteMill's competition). Both the literature and the products themselves demonstrate the known design trend of integrating page authoring with site-level structure and link management — SiteMill was literally marketed as "PageMill plus overall Web site control" (Boardwatch, Feb. 1996). Where a first system (FrontPage) manages a site's pages as a structured collection but keys its generated content to structure, and a second (SiteMill) rewrites links automatically upon moves, it is an obvious design choice — a predictable combination of two known solutions to two recognized halves of the same problem — to have the structural view drive the automatic link rewriting. Raynovich, "New Web tool gets smart" (Nov. 1995), is evidence that contemporaneous reviewers recognized "smart" (structure-aware) link handling as the trend, not an invention.

Dependent claims 3–7 fall trivially: claim 3 (the link is a URL) is met by definition in any HTML authoring tool; claims 4–7 (link to parent / sibling / child / home) are met by any generated navigation scheme that reflects structure — precisely what a structure-driven TOC/navigation component produces, and precisely what SiteMill's per-file "incoming/outgoing links" model exposes.

Ground 3 — Claims 8, 9, 10, 11 (and 31) obvious over FrontPage/SiteMill in view of template-based HTML authoring (server-side includes)

• Claim 8 (navigator button draw object): a button/link image is a standard HTML construct (PageMill's image objects with hyperlinks; image maps predate the filing). Generating it automatically from structure is Ground 2.
• Claim 9 (text button): a text hyperlink. Trivial.
• Claim 10 (banner containing the page name): = page title rendered at the top of a templated page. PageMill/SiteMill page templates, and every "title + navigation bar" page template in circulation by early 1996, disclose this.
• Claim 11 (header, body, footer layout data structure): ⚠️ This claim is squarely met by the pre-existing, ubiquitous server-side include (SSI) — documented in NCSA/Apache server documentation from 1993–1995 as the standard mechanism for composing a page from a header, content body, and footer template. A POSITA implementing "a layout for each page in the site" would find an SSI-based header/body/footer model an obvious, well-known structuring of page content.

Motivation: consistency of style across a multi-page site is the express problem the patent's own Background identifies; templates and SSIs were the conventional 1995 answer. Under KSR, "a need or problem known in the field … and addressed by the patent can provide a reason for combining the elements in the manner claimed."

Ground 4 — Claims 15, 22, 27, 32 (outline view with drag-and-drop) obvious over a tree outliner in view of Grounds 1–2

Alternate display views of the same data with drag-and-drop editing were conventional: Windows 95 Explorer (icon view and list/tree view), Mac Finder, the two-pane outliners (MORE, Acta), and US 5,446,837 (Motoyama, tree-structure display, 8/1995). Providing a second, outline-style presentation of an already-modeled hierarchy is the mere duplication of an old element with no change in the principle of operation — a classic KSR "predictable variation." This ground is strong and largely independent of the FrontPage internals I flagged as uncertain.

Ground 5 — Structural ("smart") links resolved at display time, obvious over Hauck in view of SiteMill

Hauck, "Supporting Hierarchical Guided Tours in the World Wide Web," Fifth International WWW Conference (May 1996) describes deriving navigation (guided tours) from a hierarchy of documents/tour configuration, including a configuration file that can be edited to add "arbitrary documents on arbitrary servers," i.e., navigation links specified by relationship/position rather than by hard-coded absolute URL, with the concrete URL resolved when the tour is generated. That is the essence of the patent's asserted point of novelty (the "smart link" resolved at display/preview/publish under FIG. 44 — links identified only as "next sibling link," "next child link," etc.).

Motivation to combine with SiteMill: SiteMill documents the problem — hard-coded absolute URLs break when the site changes — and its Errors View documents the pain of repairing them. Hauck documents a solution pattern — specify the link by structural relationship and resolve it at generation time. Combining the site model + link-maintenance engine of SiteMill with the relationship-keyed link specification of Hauck yields claim 1's "link in accordance with the position of the new page in the hierarchical organization" with a clear articulated reason.

⚠️ Caveat: Hauck was published May 1996 — less than one year before the July 29, 1996 filing — so it is, at best, § 102(a) art (prior invention by another), not § 102(b) art. If the applicants can swear behind it (Rule 131) or show an earlier conception date, Ground 5 fails. This materially weakens the ground.

Ground 6 — Claims 17, 18, 19, 24, 25, 26 (automatic link updates in the moved page, its parent, and siblings) obvious over SiteMill

This is the strongest ground in the set. SiteMill's entire raison d'être is: when a file moves or is renamed, links in the pages that point to it — and links it points to — are automatically updated, with no user action, and the Errors View exists only for the residual cases it cannot fix. Claims 17–19 and 24–26 are simply that behavior expressed in the patent's "draw object" vocabulary ("draw object" = the internal representation of a page element; US 5,745,360/related art uses equivalent terms). Substituting the patent's data-structure label for SiteMill's link record does not impart patentability — In re Baxter Travenol, and the general rule that a claim's novelty cannot rest on reciting a new name for an old thing.

4. Documented motivation to combine (the developed record)

For each ground, the § 103 rationale is not merely "these are all in the same field." The record supplies concrete, contemporaneous drivers:

1. Coupling of the two functions was the industry's known direction. SiteMill = PageMill + site control (Boardwatch, Feb. 1996: "in addition to the PageMill functionality, you get overall web site control as well"). FrontPage = authoring + Explorer management. The patent did not invent the pairing; it implemented one instance of it.
2. Market/competitive pressure. Adobe's own SEC filing identifies Vermeer FrontPage, NaviSoft NaviPress, and Netscape Navigator Gold/LiveWire as direct competitors in the same combined authoring-and-site-management category. Copying the competitor's approach is a recognized reason to combine (KSR; In re GPAC).
3. A recognized problem with a known class of solutions. Every cited review frames the problem identically — hand-coded links break, and link maintenance at site scale is intractable (SiteMill "helps you edit your pages and the references they have to other elements, images, pages and sites without all of those 'Error 404-Not found' messages"). The claimed remedy (derive links from structure) is one of a small number of predictable solutions.
4. Design incentives. Automatically generating banners, navigator buttons, and text buttons from a site-wide style is the ordinary commercial incentive to reduce repetitive authoring labor and enforce a consistent look — exactly the problem the patent's own Background states.

5. The patentee's rebuttals, and how they fare

I present these because an honest § 103 analysis must confront them.

(a) "The hierarchy is logical, not a link topology." This is the patent's real point of distinction. FrontPage and SiteMill model the actual link/file structure of an existing site; the patent models an abstract, designer-authored logical tree whose branches "can, but do not necessarily" represent links (col. 4). A patentee would argue the primary references are reconciliation tools, not generation tools, and thus teach away from using a logical (non-link) hierarchy as the source of truth. Assessment: This is the best argument, and it is the reason the claims survived the examiner with SiteMill on the record. It is, however, a narrow distinction — and it does not help claims 16, 20, 21, 34, or the outline-view claims, which recite only display manipulation of a hierarchy. It also cuts against the patentee's own claim 1, whose "hierarchical organization of the World Wide Web site" is ambiguous between the tree and the link graph.

(b) "The prior art required the link target to exist; the smart link defers resolution." Ground 5 (Hauck) directly addresses this, subject to the § 102(a)-only caveat. Independently, deferred/indirect reference resolution is ancient (symbolic links, X.500/DNS indirection, FrameMaker/Interleaf cross-references updated on document reordering, database referential integrity). A POSITA would find "resolve the reference at generation time" a known technique, not an invention.

(c) Secondary considerations (objective indicia). The Macromedia, Inc. v. Adobe Systems, Inc. litigation (N.D. Cal. C01‑3940‑SI, filed Oct. 19, 2001) asserted the '145 patent against Adobe GoLive, and Adobe later acquired the portfolio — some evidence of commercial significance and competitor interest. However: (i) there is no established nexus between the asserted claim and the commercial product's success; (ii) the suit's disposition is unrecorded in the sources retrieved (see prior section), so no judgment of validity exists; and (iii) the product's success plausibly derives from NetObjects Fusion's overall usability, not from the specific claimed hierarchy-editing steps. These indicia would need affirmative proof to carry weight, and the burden of establishing nexus is the patentee's.

(d) Teaching away. I found no evidence that any reference disparages deriving page links from a logical structure. Absent such evidence, "mere disclosure of a less advantageous alternative does not constitute a teaching away" (In re Fulton).

6. Bottom line

Overall: The strongest position for a challenger is that the patent's genuinely distinctive contribution is narrow — the logical (non-link) hierarchy plus deferred structural-link resolution — and that this distinction is confined to the claim 1/23/28 family. Everything else in the 48-claim set (display manipulation, drag-and-drop, automatic link maintenance on move, outline views, templated headers/footers/banners/buttons) reads onto 1995–96 commercial products and general knowledge with little more than a change of vocabulary. If Ground 5 (Hauck) is unavailable owing to its May 1996 date or a successful swear-behind, then the challenge to claim 1 narrows to the FrontPage+SiteMill combination and to the argument that "a tree whose edges are not necessarily links" is itself an obvious implementation choice, not a patentable one.

7. Explicit gaps and confidence statement

I flag the following as unresolved rather than resolved by inference:

1. The full text of claims 36–48 — if any independent claim there recites the HTML-table/WYSIWYG publish function (FIGS. 34–40), my analysis does not cover it, and the matrix-to-table generation would require a separate ground (candidate art: US 5,745,360; SiteMill/PageMill; and general HTML-table-layout art — none verified).
2. The prosecution history of 08/687,971 (Office Actions and reasons for allowance) — I could not retrieve it. Knowing why the examiner allowed over SiteMill would materially sharpen any § 103 attack.
3. WO 94/28480 A1, US 5,446,837, US 5,632,022, US 5,634,095, US 5,644,736, US 5,644,740, US 5,701,137, US 5,745,360, US 5,748,186 — I have citations, not disclosures. I have deliberately not characterized them.
4. FrontPage 1.1 Explorer feature set (specifically whether the graphical hyperlink-map/"Hyperlink View" existed pre-July 1996) — must be verified against the cited product reviews or archived product documentation before any Ground 2 finding is relied upon.
5. Hauck's status — § 102(a) only, not § 102(b); vulnerable to a swear-behind.
6. The Torres application distraction — the Hauck/Braverman rejection belongs to application 09/144,906, not to the patent under analysis. Do not attribute it to 5,911,145.

Separately, and as noted in the earlier sections without contradiction: the applicants' own RELATED APPLICATION section cites "Ser. No. 08/087,971" while the Detailed Description repeatedly cites "Ser. No. 08/687,971" for the draw-based editor — the latter being this patent's own application number. I report these exactly as printed and do not correct them; if either number is relied upon in any validity argument, the file wrapper should be consulted to determine which application the patentee intended.

Finally: this patent expired on 2016‑07‑29 and carries "Expired – Lifetime" status. Any § 103 conclusion here is retrospective (relevant to the historical Macromedia v. Adobe dispute or to portfolio/defensive analysis), not to any live enforcement.