US 7543267

Patent Overview — US7543267B2

Title: Drag and drop creation and editing of a page incorporating scripts

Patent number: US7543267B2 (application US10/680,238; earlier publication US20040066410A1)

Inventors: Gregory S. Lindhorst, Stephen J. Millet, John P. Shewchuk

Original assignee: [Microsoft Corp.](/litigations/by-plaintiff/Microsoft%20Corp.) Current assignee listed as Microsoft Technology Licensing LLC (per the source's reassignment entry dated 2014-12-09, which the source itself notes is not a legal conclusion).

Key dates from the source: Priority date 1998-12-31; filing date 2003-10-08; publication date 2009-06-02; legal status "Expired – Fee Related," adjusted expiration 2020-04-08.

Purpose and plain-language scope (as supported by the excerpt): The patent addresses authoring of text and computer-executable code, particularly techniques for automatically generating HTML script. The excerpt describes web-development problems: server-side scripting (e.g., Active Server Pages) required separate files, suffered near-duplication, and demanded tedious sequential coding to link calling and called pages, manage control flow, and preserve page state (such as via hidden form elements). The described approach treats web page script files and components according to an event-driven model and more generally as objects with exposed methods and properties, so that at development time the appearance is common whether the associated script or components ultimately run on the client or the server. Script files and even simple HTML pages are referenced as objects to provide a simplified naming structure (simplified namespace), obviating sequential coding otherwise needed to cross-reference code and page content. ASPs can appear to other files as objects with methods (e.g., in JavaScript, Livescript, or JScript) and properties stored server-side, with proxies transmitted to the client as needed. Design-time controls (DTCs) let developers place scripts in documents via wizard-like interfaces; the developer uses a DTC to attach object identification information including method and property data. The title indicates drag-and-drop creation and editing of a page incorporating scripts.

Source: https://patents.google.com/patent/[US7543267](/patent/US7543267)/en

What the excerpt does not establish: It is explicitly an excerpt with omitted text. It does not supply the claims, full written description, or drawings. It therefore does not establish the precise claimed scope, claim limitations, or embodiments not mentioned above. It also does not establish the full contents of the incorporated U.S. application Ser. No. 08/959,300, nor any litigation, validity, or prior-art conclusions.

I'll search for litigation records involving US Patent 7,543,267.

Let me search more specifically for litigation databases and the patent's assertion history.

Let me check specific litigation databases directly.

Litigation Search: US Patent 7,543,267

Bottom line: No litigation involving US Patent 7,543,267 is known. Based on my searches of publicly available patent-litigation resources, I found no district court case, ITC Section 337 investigation, CAFC appeal, PTAB proceeding (IPR/PGR/CBM), or other adversarial proceeding in which US 7,543,267 has been asserted, challenged, or otherwise placed at issue.

What was searched

• Google Patents landing page for US7543267 (which links out to Global Dossier / USPTO assignment records)
• Unified Patents litigation portal results referencing the number
• uspto.report, FreePatentsOnline, and Justia records for the patent
• RPX Insight litigation-document results
• General web queries combining the patent number with "litigation," "infringement," "complaint," "lawsuit," and "defendant"
• Fintiv / §314(a) petition discussions that enumerate related civil actions for patents they discuss

None of these produced a case caption, docket number, or filing for this patent.

Patent facts confirmed from the records (for identification purposes)

• Patent: US 7,543,267 B2 — "Drag and drop creation and editing of a page incorporating scripts"
• Application: 10/680,238; Filed: 2003-10-08; Granted: 2009-06-02
• Priority date: 1998-12-31 (continuation of App. Ser. No. 09/223,565)
• Inventors: Gregory S. Lindhorst, Stephen J. Millet, John P. Shewchuk
• Original assignee: [Microsoft Corp.](/litigations/by-plaintiff/Microsoft%20Corp.); current assignee: Microsoft Technology Licensing LLC (reassignment recorded 2014-12-09)
• Legal status: Expired – Fee Related; adjusted expiration 2020-04-08
• Source: https://patents.google.com/patent/US7543267/en and https://uspto.report/patent/grant/7543267

A lapsed, never-asserted Microsoft continuation patent is consistent with the absence of any litigation record.

Similar-number hits that I excluded (per your instruction not to return near numbers)

Several search hits contained the digits "267" or superficially similar numbers but are different patents/proceedings and are not about US 7,543,267:

• The Re '267 / 6,574,267 C1 patent in the GBT litigation (RPX Insight doc) — unrelated reissue patent.
• The '326 patent discussed in PTAB Fintiv papers (e.g., Intellectual Ventures v. American Airlines, 4:24-cv-980 (E.D. Tex.)) — a different patent, not 7,543,267.
• 7,555,357 (Stratasys v. Bambu) and 7,543,288 — different numbers entirely.
• JP 7543267 B2 (Eneos, a refrigerant composition) — an unrelated Japanese patent that happens to share the digits.

Caveats / confidence

• I could not access the Unified Patents litigation case list or PACER directly in this session; my conclusion rests on the aggregated public sources above. If you have Docket Alarm, Lex Machina, or PACER access, a direct docket search for "7,543,267" would be the definitive confirmation, but those are paid/full-text tools and no free source surfaced a hit.
• I have high confidence there is no known litigation, and no evidence that this patent was ever asserted. I did not find any affirmative statement that it was litigated.
• If you are looking for litigation involving the patent family (the sibling applications/patents referenced in the specification — e.g., the "Page Object Model" / "Transporting Objects Between A Client and A Server" family), that is a separate question; let me know and I can search the specific family members. I would not assume any family member was litigated either.

I'll verify the structured block against live sources before writing anything.

Let me check the CBM/trial-tracker angle specifically, since this is a 1998-filing Microsoft software patent — exactly the profile CBM petitioners targeted.

One more targeted pass to make sure I'm not missing a CBM or an early IPR filed by a defendant.

Proceedings overview

Total AIA trial proceedings on US 7,543,267: zero (0). The USPTO Open Data Portal structured block — the canonical source for this task — returns no AIA trial proceedings for this patent, and independent web searching surfaced no IPR, PGR, or CBM petition naming 7,543,267 (Petitioner–Patent Owner pairs, trial-tracker entries, briefing excerpts, or FWD citations). The breakdown is therefore 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denials. Bottom line for a defendant: there is no PTAB-based invalidation on the record for this patent — it has not been tested, narrowed, or killed at the Board, so you cannot buy a cancellation order off the shelf and you have no § 315(e) estoppel shelter. The meaningful defensive levers here are the patent's expired status and the § 101 / § 112 exposure of a 1998-priority software claim set, not a prior IPR outcome.

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No per-proceeding sections follow, because there are no proceedings to describe. Fabricating placeholder IPR numbers or judge panels would be worse than useless to you. Below is what I actually verified, what I ruled out, and how to re-confirm.

Verification performed (2026-10-01)

False-positive alert — do not confuse these

Web search for the string "Re '267" surfaces a live NPE campaign by GBT (reissue patent asserted against HTC, Huawei, Lenovo, and LG over 3G/UMTS devices). That is U.S. Patent No. 6,574,267 C1, an unrelated patent with a coincidentally similar number. I verified the digits; it is not 7,543,267. If a vendor's claim chart or a "patent risk" database flags "'267" litigation activity against this patent, that is almost certainly a number-collision error and should be corrected before it drives any budget decision.

What the public record does show for 7,543,267

• Title: Drag and drop creation and editing of a page incorporating scripts
• Inventors: Gregory S. Lindhorst, Stephen J. Millet, John P. Shewchuk
• Original assignee: Microsoft Corp.; current assignee: Microsoft Technology Licensing LLC (reassignment recorded 2014-12-09)
• Priority date: 1998-12-31 (continuation of Ser. No. 09/223,565, filed 1998-12-31); the application itself was filed 2003-10-08
• Granted: 2009-06-02
• Classification: G06F8/34 — graphical or visual programming
• Legal status: Expired – Fee Related, with an adjusted expiration of 2020-04-08 logged 2020-04-08
• Related family members named in the specification: Ser. No. 09/223,773 ("A System for Converting Event-Driven Code into Serially Executed Code"), Ser. No. 09/223,558 ("Transporting Objects Between A Client and A Server"), Ser. No. 09/223,774 ("Page Object Model"), and Ser. No. 08/959,300 ("Method and Apparatus for Automatic Generation of Text and Computer-Executable Code")

I have not independently verified the claim set of 7,543,267 line-by-line, so I am deliberately not quoting claim numbers or claim language. The claims are untested by any adversarial tribunal on the record I can find.

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Strategic summary

Claim status: all claims UNTESTED; none canceled, none confirmed. Because no IPR, PGR, or CBM was ever instituted, there is no claim-level disposition to report — no independent claim canceled, no dependent claim sustained, no certificate of correction or reexamination certificate narrowing the set. This cuts both ways. It means the patent owner cannot point to a PTAB win as a validity imprimatur (there is none), and you cannot point to a cancellation order. The entire validity fight remains open and would have to be litigated from scratch — in district court, before a jury, or in a first-ever IPR that you would have to file yourself. Note the practical obstacle to that last option: the patent's adjusted expiration is 2020-04-08, so the term has already run. Filing an IPR against an expired patent is generally uneconomic — you would spend six figures to un-cancel claims that are no longer enforceable going forward.

Estoppel landscape: no § 315(e)(2) estoppel exists. Estoppel attaches only to a petitioner whose IPR was instituted and reached a final written decision. With zero institutions here, no party is estopped from raising any ground, before the Board or in court. Every prior-art combination, every § 102/§ 103 theory, every § 112 written-description or enablement attack, and § 101 subject-matter eligibility are all fully available to you. Conversely, you get no benefit from someone else's work product — you would be building any invalidity case from zero, with no PTAB record, no adopted claim constructions, and no expert declarations to borrow. The flip side of an institution-free history is that you also lose the inherent estoppel protection a defendant enjoys when another party already killed the claims.

Pattern signals: none. No petitioner has filed once, let alone repeatedly; the patent owner has never had occasion to defend at the Board, so there is no track record of aggressive or passive PTAB appeal behavior; and there is no defensive aggregator (Unified Patents, RPX, or similar) in the chain. That absence is itself the most important signal in this report: a patent that was never asserted and never challenged across its entire enforceable life strongly suggests it was never commercially relevant to Microsoft's licensing program. Well-asserted patents attract IPRs almost mechanically; 7,543,267 attracted none, and no litigation against it surfaced either. It reads as a dormant, expired portfolio asset that has now passed out of its enforceable window.

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Recommended next steps

1. Confirm the negative directly at the source. The structured absence is your best evidence, but a defendant's invalidity opinion should re-run it: search the patent number at PTAB E2E (https://ptacts.uspto.gov/ptacts/) and USPTO Patent Center (https://patentcenter.uspto.gov/), and check the Google Patents page at https://patents.google.com/patent/US7543267/en for any newly surfaced post-grant activity. A CourtListener sweep on the number (https://www.courtlistener.com/?q=%227%2C543%2C267%22) covers the Federal Circuit side.

2. Lead with expiration, not invalidity. The record shows Expired – Fee Related, adjusted expiration 2020-04-08. If anyone asserts this patent today, the § 286 six-year damages lookback (35 U.S.C. § 286) combined with a term that ended in 2020 should collapse the damages window to zero or near-zero for conduct after that date. Get the face of the patent, the maintenance-fee payment history, the term-adjustment calculation, and any PTA/terminal-disclaimer entries from Patent Center and confirm the expiry date independently — do not rely on a third-party status field alone.

3. If you are nevertheless forced to litigate validity, the highest-yield grounds are § 101 (a 1998-priority "drag and drop … page incorporating scripts" claim set is squarely in the software-eligibility crosshairs post-Alice) and § 112 (the specification's prose is loose in places and the claims may not be coextensive with the disclosed page-object/DTC implementation). On prior art, the field is wide open: the specification itself cites Visual InterDev 1.0, FrontPage 97/98, Visual Basic, Active Server Pages, DTCs, and the incorporated Ser. No. 08/959,300 (which issued as U.S. Pat. No. 6,035,119 to Massena et al.) — all admissible as prior art or as admissions, with no § 315(e) estoppel limiting what you may combine.

4. Because no trial exists, there are no PTAB milestones to calendar — no institution-decision deadline, no oral hearing date, no statutory one-year FWD due date under 35 U.S.C. § 316(a)(11). Anyone telling you otherwise is describing a different patent, most likely the 6,574,267 confusion flagged above.

Caveat on scope: I found no record of this patent being asserted in district court either. I did not exhaust every litigation database, so treat "never asserted" as a strong inference from available sources rather than a certified fact.

I'll reconstruct the assignment record for US 7543267. Let me verify the recorded assignments and correspondent details from authoritative sources before drafting.

Let me look for the specific reel/frame and correspondent details for the Microsoft → Microsoft Technology Licensing assignment.

I found a candidate reel/frame for the Microsoft→MTL transfer. Let me pin down whether that reel applies specifically to US 7543267 and capture the correspondent.

I hit the tool-call limit while trying to independently confirm the exact reel/frame and correspondent for this patent's single recorded transfer. Here's the reconstruction based on the sources I did retrieve. I flag explicitly where a data point is unconfirmed rather than asserting it.

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Inventors

Source: Google Patents US7543267 and uspto.report/patent/grant/7543267 both list the three inventors; the specification itself is a Microsoft Visual InterDev/FrontPage authoring-tool disclosure (DTCs, Page Object DTC, ASP), consistent with all three being Microsoft employees at filing.

Pattern note: I could not determine any inventor's departure date from Microsoft, so I cannot confirm or rule out the "all inventors left within 12 months" pre-fire-sale pattern. No such evidence surfaced — treat as not established, not as a negative finding. The application is a 1998-priority family (priority 1998-12-31) continued in 2003, which is normal Microsoft prosecution behavior.

Original assignee

Microsoft Corporation (Redmond, WA), per Google Patents legal events and the printed front page.

• Product embodying the claims: Yes — the specification expressly names Microsoft's own authoring tools as the editors implementing the invention: "Visual InterDev 98 and FrontPage 98 (by the Microsoft Corporation)" (see also the Page Object DTC / design-time control discussion). This is the company's own commercial product line, not a paper patent.
• Primary line of business: Software (desktop and web-development tooling; operating systems; developer platforms).
• Current status: Operating (publicly traded, NASDAQ: MSFT). Not acquired, dissolved, or in bankruptcy. The patent itself was moved internally to Microsoft's captive licensing subsidiary in 2014 (below). Google Patents lists current assignee as Microsoft Technology Licensing LLC (assignment recorded 2014-12-09), while uspto.report's cached record still shows "Microsoft Corporation" — the latter is stale.

Assignment timeline

Only one post-issuance assignment is surfaced by the sources I retrieved. Google Patents' legal-events table for US7543267 lists exactly one reassignment event:

• 2014-10-14 (executed/effective) / recorded 2014-12-09 — Reel 034543/0001 (see caveat)
  • Conveyance: Assignment — "Assignment of Assignor's Interest"
  • Assignor: Microsoft Corporation
  • Assignee: Microsoft Technology Licensing, LLC (One Microsoft Way, Redmond, WA 98052)
  • Correspondent: Not captured in the records I was able to retrieve — I will not guess a name. For this 2014 Microsoft→MTL wave the correspondent of record is widely a Microsoft in-house Law & Corporate Affairs contact, but I could not verify it for this patent, so I am marking it unverified rather than asserting it.
  • Context: Internal corporate reorganization — transfer of the patent portfolio into Microsoft's wholly-owned captive licensing/holding subsidiary; not a third-party or fire-sale transfer.

⚠ Reel/frame caveat (important): The reel 034543/0001 value I found comes from an INPADOC record for a sibling Microsoft patent (US2007182999) that shows the same effective date (2014-10-14), recordation date (2014-12-09), and assignor/assignee with notation ASSIGNOR:MICROSOFT CORPORATION; REEL/FRAME:034543/0001. Microsoft recorded this transfer as a large multi-reel batch, so 034543/0001 is the correct reel family and matches the date on US7543267's legal-events entry, but I did not independently resolve the specific reel/frame captioning on the US7543267 document itself. Verify the exact reel/frame at the Assignment Center (see below).

No other assignments found. In particular:

• No recorded inventor→Microsoft assignment is surfaced by Google Patents' legal events (initial assignments from that era exist for many Microsoft patents but are not shown here). If one exists, it is pre-issuance and routine.
• No Acacia / Marathon / IV / Wi-LAN / Mosaid / Vringo / Pendrell / Uniloc / Raniere-type transfer, and no defensive-aggregator transfer (RPX / AST / LOT / OIN / Unified). None.

Google Patents legal events (non-assignment): grant 2009-06-02; adjusted expiration 2020-04-08; status "Expired - Fee Related." Note the "Fee Related" expiry — the patent lapsed through non-payment of maintenance fees, a strong indicator the owner attached no assertion value to it.

Timeline diagram

timeline
    title Ownership of US 7543267
    1998 : Priority application filed by Microsoft
    2003 : Continuation filed by Microsoft
    2009 : Patent granted to Microsoft
    2014 : Assigned to Microsoft Tech Licensing LLC
    2020 : Patent lapsed for fee non-payment

NPE / troll-pattern signals

1. Shell-entity transfer — Not present. The only transfer is Microsoft Corporation → Microsoft Technology Licensing, LLC (reel 034543/0001, recorded 2014-12-09). This is a captive, 100%-owned Microsoft subsidiary — an internal reorganization, not a move to an unrelated licensing-only shell. No third-party, no single-member Delaware/Texas LLC, no registered-agent address.

2. Known asserter in the chain — Not present. No assignee in the chain matches Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, or any Spangenberg-linked entity. MTL does not appear on Unified Patents' or RPX's high-frequency-plaintiff lists (it is a defendant-side petitioner in IPRs, e.g. Microsoft v. Global Technologies, IPR2016-00663).

3. Repeat correspondent across the chain — Unclear / insufficient data. With only a single recorded assignment and the correspondent field not captured, there is no basis to test recurrence. Not scored as present.

4. Cascading transfers — Not present. A single recorded event; no chained LLCs, no <24-month cascade, no shared correspondent address across links.

5. Pre-litigation transfer — Not present. No infringement suit naming this patent was located in the sources checked, and the patent lapsed in 2020 for fee non-payment — inconsistent with a chain arranged to enable assertion.

6. Bankruptcy fire-sale — Not present. Microsoft was (and is) solvent; no Chapter 7/11, no Kodak/Nortel-style sale.

7. Privateering — Not present. No evidence MTL licensed this patent to a third-party NPE to assert against Microsoft competitors; MTL is captive and Microsoft historically asserts its own portfolio directly.

8. Defensive aggregator (anti-NPE) — Not present. The chain does not terminate at RPX, AST, LOT, Unified, or OIN. (The practical outcome is nonetheless a non-asserted, lapsed patent.)

Verdict

Insufficient data (no external ownership event and no assertion record — the chain is a single captive reorganization by the original operating company).

Justification: The only non-original event is the Microsoft Corporation → Microsoft Technology Licensing, LLC assignment effective 2014-10-14 / recorded 2014-12-09 (reel 034543/0001, batch value confirmed via sibling patent INPADOC; verify caption at the Assignment Center). That is an internal captive-subsidiary reorg of a solvent operating company, not a transfer to an asserter. Zero NPE signals are present, and the patent lapsed for fee non-payment around 2020-04-08, which is inconsistent with an NPE holding pattern. Because the record contains no third-party or assertion evidence and none of the supplied NPE categories fits cleanly, the honest classification is Insufficient data — with the affirmative finding that this is not an NPE scenario; the closest substantive characterization is a non-asserted operating-company patent held by Microsoft's captive licensing arm.

Verify at: USPTO Assignment Center — https://assignmentcenter.uspto.gov/ (search patent number 7543267; also indexed at https://assignment.uspto.gov/patent/index.html). Cross-check Google Patents legal events: https://patents.google.com/patent/US7543267/en.

Confidence limits (stated honestly): (a) the exact reel/frame captioning for US7543267 is inferred from a sibling Microsoft patent's INPADOC record and the matching 2014-12-09 date, not directly read off this patent's assignment notice; (b) the correspondent of record on the 2014 recording was not captured and I am not asserting a name; (c) I did not locate a litigation record for this patent, so the "no assertion" finding is based on absence of evidence in the sources retrieved, not on an exhaustive court docket review.

I'll research the specific prior-art citations for US 7,543,267. Let me search multiple sources.

I have partial citation lists. Let me get the complete "References Cited" list from the USPTO/Justia record.

Let me retrieve the complete "References Cited" list, including foreign documents and other publications.

I've reached the tool-call limit for this session, so here is my analysis based on the records I was able to retrieve. I'll flag clearly where the record is incomplete or where I'm reasoning rather than quoting.

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Prior Art Analysis — US Patent 7,543,267 B2

1. Document identification and scope notes

Before anything else, two disambiguation points, because the digits "7543267" match more than one document:

• The subject of this analysis is US 7,543,267 B2, application 10/680,238, "Drag and drop creation and editing of a page incorporating scripts," filed 2003-10-08, granted 2009-06-02, priority 1998-12-31 (continuation of Ser. No. 09/223,565). Inventors Lindhorst, Millet, Shewchuk; original assignee Microsoft. Source: https://patents.google.com/patent/US7543267/en and https://uspto.report/patent/grant/7543267.
• JP 7543267 B2 (Eneos, "refrigerant working-fluid composition"), registration date 2024-08-23, is a completely different document that merely shares the digits. Do not conflate the two. (Confirmed via the Eneos JP gazette PDF at the patentimages host.)

Important limitation on claim mapping: The authoritative full text you supplied me is cut off mid-description (it ends in Section V at the paragraph beginning "It will be appreciated that the network connections shown are exemplary…"). The granted claims of US 7,543,267 are not in the text I was given, and I was unable to retrieve the patent's claim set (or the examiner's PTO-892 "Notice of References Cited" form) within this session. Because your operating rules bar me from fabricating claim text or claim numbers, I will not invent specific claim numbers for an anticipation mapping. I give the best-available reference analysis below and explain precisely what would be needed to complete a claim-by-claim § 102 chart.

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2. The "(56) References Cited" list of US 7,543,267

These are the U.S. Patent Documents listed on the face of the patent (the examiner's/ applicant's cited art). I assembled them from the Justia and FreePatentsOnline records of the patent, which reproduce the printed front page. Numeric order in the printed patent is ascending; I've regrouped chronologically by issue date for readability. Inventor names and issue dates are as printed; titles are given where the sources exposed them, and are marked [title not retrieved] where my sources gave only number/date/inventor.

Coverage caveat: My sources truncated the tail of the list (the 6,625,803 entry and anything after it) and I could not retrieve the patent's Foreign Patent Documents or Other Publications subsections (the "(56)" section of a U.S. front page frequently also carries foreign documents and NPL). So treat the table above as complete only through 6,615,253, and treat any foreign/NPL citations as "not retrieved." The definitive source is the printed front page of US 7,543,267 and the examiner's PTO-892.

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3. Brief descriptions of the most germane references

Grouping the cited art by its relationship to the '267 disclosure (drag-and-drop authoring of web pages whose placed objects generate client-side and/or server-side script, using design-time controls and a page-object model):

A. Design-time controls / automatic code generation (closest to the disclosed subject matter)

• US 6,035,119 (Massena et al., 2000-03-07) — "Method and apparatus for automatic generation of text and computer-executable code." This is the patent that issued from Ser. No. 08/959,300, which the '267 specification expressly incorporates by reference and repeatedly calls out as the design-time-control (DTC) disclosure. It is the single most closely related cited reference because the '267 invention's mechanism for turning placed objects into client/server script at save time is built on the DTC concept.
• US 6,064,812 (Parthasarathy et al., 2000-05-16) — developing automation clients using a graphical data-flow program (graphical generation of programmatic clients/wrappers).
• US 6,332,210 (Barkataki et al., 2001-12-18) — creating and using system-independent software components (component abstraction/synthesis).

B. Web authoring, WYSIWYG editing, and in-place editing

• US 5,845,299 (Arora et al., 1998-12-01) — commonly associated with WYSIWYG web-page authoring/site-building.
• US 5,956,736 (Hanson et al., 1999-09-21) — associated with HTML/web-page editing.
• US 5,818,447 (Wolf et al., 1998-10-06) — in-place editing of a message/document via a separate program (relevant to the "edit the object where it sits on the page" aspect).
• US 5,875,322 and 5,644,739 (House; Moursund) — GUI/editor interactions.
• US 6,163,878 (Kohl, 2000-12-19) and US 6,006,230 (Ludwig et al., 1999-12-21) — designing/generating/storing applications and database-application development/deployment.

C. Client/server scripting, event-driven model, and object transport (the "single object across spaces" theme)

• US 6,304,893 (Gish, 2001-10-16) — client-server event-driven message framework: directly relevant to the '267 premise of presenting an event-driven programming model over a serial-execution server.
• US 6,272,673 (Dale et al., 2001-08-07) — automatically establishing connections between executable components of a hypertext-based application (relevant to page-to-page method wiring).
• US 6,223,345 (Jones et al., 2001-04-24) — building client and server application packages (relevant to generating both client and server code).
• US 6,138,150 (Nichols et al., 2000-10-24) — remotely controlling resources via a web browser.
• US 6,243,737 (Flanagan et al., 2001-06-05) — direct transaction access to host-system information.
• US 6,275,935 (Barlow et al., 2001-08-14) — locking interactive objects (relevant to state/session handling of placed objects).

D. The Bowman-Amuah / Underwood "netcentric environment services patterns" cluster (Accenture family)

• US 6,289,382; 6,332,163; 6,339,832; 6,434,568; 6,434,628; 6,438,594; 6,477,580; 6,477,665; 6,601,192; 6,615,199; 6,615,253 (Bowman-Amuah) and US 6,523,027 (Underwood) — a large family about multi-tier client/server "environment services patterns," distributed service interfaces, server-side data retrieval for client-side applications, and abstraction factories. These were almost certainly cited as § 102(e) art (their U.S. filing dates precede the '267 priority date even though they issued in 2002–2003). They are numerically the bulk of the list but are the least on-point to the specific drag-and-drop-page-authoring subject matter; they speak to distributed-tier architecture generally.

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4. Which references are "most relevant," and the § 102 issue

The most relevant cited references, in my assessment, are:

1. US 6,035,119 (Massena et al.) — because the '267 patent's disclosure is expressly layered on the design-time-control technology of Ser. No. 08/959,300, of which the '119 patent is the granted counterpart.
2. US 6,304,893 (Gish) — client/server event-driven framework, the core conceptual claim of the '267 summary ("treats web page script files… according to an event-driven model" while the server executes serially).
3. US 6,272,673 (Dale et al.) — auto-wiring executable components in a hypertext application (page-as-object method linking).
4. US 5,845,299 (Arora et al.) and US 5,956,736 (Hanson et al.) — WYSIWYG/HTML authoring, relevant to the drag-and-drop page-creation aspect.
5. US 5,818,447 (Wolf et al.) — in-place editing (relevant to editing an object in place on the page).

Why a strict § 102 "anticipation" mapping is not appropriate to state as fact here:

• These references are in the patent's (56) "References Cited" section, i.e., art the examiner considered and allowed the claims over. Anticipation under § 102 requires a single reference disclosing every limitation of a claim. Because the examiner issued the patent, the record affirmatively shows none of these references was found to anticipate the granted claims as written. Labeling any of them an "anticipating" reference would contradict the prosecution outcome.
• The references become most useful, if at all, for an obviousness (§ 103) or validity-reexamination-style analysis, or for mapping to the broadest independent claim — not for a § 102 anticipation statement.
• Priority-date nuance: With a 1998-12-31 effective date, the pre-1999 documents (Moursund through Arora, etc.) are classic § 102(b)/(a) art, whereas the 2000–2003-issued references (notably the entire Bowman-Amuah cluster and Underwood) can only be prior art under § 102(e) — i.e., as U.S. applications filings that predate 1998-12-31. Any anticipation theory built on those must rest on their filing dates, not their issue dates.

What I would need to give you a defensible claim-by-claim § 102 chart: (a) the granted claim set of US 7,543,267 (independent claim(s) 1, and the system/method/computer-readable-medium counterparts), and (b) the tail of the (56) list plus any foreign/NPL citations, ideally from the examiner's PTO-892 and the specification's cited references. With the claims in hand I can element-by-element map each reference and state which claim (if any) is arguably anticipated versus merely relevant.

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5. Additional "prior art" cited in the specification body (not the front page)

Distinct from the front-page (56) list, the '267 specification itself cites or discusses:

• U.S. Ser. No. 08/959,300, "Method and Apparatus for Automatic Generation of Text and Computer-Executable Code," filed 1997-10-28 (incorporation-by-reference; = the Massena et al. '119 patent family).
• Related sibling applications incorporated/identified: Ser. No. 09/223,773 ("A System for Converting Event-Driven Code into Serially Executed Code"), Ser. No. 09/223,558 ("Transporting Objects Between A Client and A Server"), and Ser. No. 09/223,774 ("Page Object Model"), all filed 1998-12-31.
• Commercial products as background art: Microsoft Visual InterDev 1.0/98, Front Page 97/98, ASP, ActiveX, Java applets, Adobe PDF, DHTML.

If your interest is invalidity of the '267 claims, these sibling applications and the '119 DTC patent are as important as — often more important than — the foreign/multi-tier references in the (56) list, because they are the same inventors'/assignee's own disclosure and are incorporated by reference.

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6. Bottom line and confidence

• Confirmed: US 7,543,267 B2 is a Microsoft continuation patent (app. 10/680,238), granted 2009-06-02, priority 1998-12-31, now Expired – Fee Related (adjusted expiration 2020-04-08) — so it cannot be asserted going forward regardless of prior art.
• Provided: the front-page cited-art list through US 6,615,253, with the caveats that the tail (from 6,625,803) and any foreign/NPL citations were not retrievable in this session, and that titles marked "not retrieved" are blanks I did not fill in rather than guesses.
• Not provided (by design): specific claim-number–to–reference anticipation mappings, because the granted claim text was not in the materials I was given and I could not retrieve it. I have high confidence in the reference list as printed above through 6,615,253 and low/unknown confidence beyond that point.
• Recommendation: For a formal § 102/§ 103 analysis, pull (i) the granted claims of 7,543,267, (ii) the printed front page / PTO-892, and (iii) the file history (Application 10/680,238, and its parent 09/223,565) from USPTO PatentCenter or Global Dossier. If you supply the claim set, I can build the element-by-element chart.

I'll first try to ground this analysis in actual prior-art references, since the task asks me to use prior-art results and I must not fabricate references.

I now have actual claim text and a cited-references list. Let me retrieve the remaining claims and the full prior-art citation list.

Let me retrieve the remaining claims (13 onward) and confirm the full cited-references list.

Obviousness Analysis — US 7,543,267 B2 under 35 U.S.C. § 103

A. What I am working from — and two corrections to the earlier sections

Correction 1 (important). The previously generated Patent summary stated that verbatim claim text could not be retrieved and therefore inferred claim scope from the title/abstract. That gap is now closed: I retrieved the issued claim text from the Justia rendering of US 7,543,267 (https://patents.justia.com/patent/[7543267](/patent/7543267)#5). I treat that as current ground truth per the operating rules. The earlier inference was partly right (independent claims are system/system/method rather than a single category) but the actual claim language is substantially more specific than the earlier section implied. The earlier summary's statement that claim scope was unverified should be disregarded going forward.

Correction 2. The "prior art section" on the Google Patents page as fetched did not include the citation list (the fetched text truncated before the References Cited block). I supplemented with the FreePatentsOnline "References Cited" listing for the same patent (https://www.freepatentsonline.com/7543267.html). References below are sourced from that list; I flag where I only have a title/date and not the disclosure text.

What follows is a functional-level §103 analysis. I have the claim language and the identity/date of the cited references, but I do not have verbatim text of the prior-art references themselves (no column/line citations). Where I map a reference to an element, I say so explicitly and do not invent passage cites.

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B. Governing law and effective filing date

• This is a pre-AIA patent (priority 1998-12-31; continuation of Ser. No. 09/223,565). 35 U.S.C. § 103(a) (pre-AIA) applies, with the Graham v. John Deere framework, and KSR Int'l v. Teleflex (2007) controlling on motivation/manner-of-combination.
• Critical date: December 31, 1998. All prior art must predate that date (assuming the issued claims are supported by the 1998 disclosure — they recite only subject matter the 1998 spec plainly describes: drag-and-drop, DTCs, page objects, ASP). Everything identified below predates it.
• Level of ordinary skill (PHOSITA): a software developer with roughly a bachelor's degree in CS/EE (or equivalent) and ~1–2 years of experience building web and/or IDE-based client/server applications in 1998 — i.e., someone fluent in HTML, ASP/server-side scripting, and a component-based visual IDE (Visual Basic being the archetype).

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C. The prior-art universe

C.1 References on the face of the patent (examiner-considered)

C.2 Non-patent prior art (not on the face of the patent — the stronger attack surface)

• Component-based visual IDEs — Visual Basic (1991–1997), Borland Delphi (1995), C++Builder (1997), PowerBuilder: toolbox/palette of components, drag-and-drop onto a design surface, Object Inspector / property pages for configuring properties, methods and events, and automatic code generation. This is the single most damaging body of art for claims 1–5.
• Netscape Visual JavaScript (1997) / LiveWire Pro (1996): drag-and-drop assembly of components onto a page with property editors, generating client-side JavaScript and server-side (LiveWire) JavaScript — i.e., client and server script from one visual design.
• Microsoft Active Server Pages (1996) and server-side includes; Java RMI (JDK 1.1, 1997) and DCOM (1996) — remote components exposed as local objects via proxy/stub objects; directly relevant to the "page as object" claims.
• Microsoft Visual InterDev 1.0 (1997), FrontPage 97/98 — acknowledged in the specification's own Background as prior art.

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D. The claims at issue (verbatim, as retrieved)

Key limitations, condensed:

• Claim 1 (system): UI with (a) a first display portion representing a page to be sent server→client via browser and receiving dragged-and-dropped objects; (b) a second display portion representing a library of the objects for dragging/dropping into the first, the objects executable on at least one of the server and client; (c) a third display portion for configuring a method of an object after it is dragged/dropped; and (d) a component for automatically creating client and server scripts for a dragged/dropped object, one script executable to send an event, the other to handle the event; "wherein the user interface represents the client and server runtime environments as a single unified environment."
• Claim 2: a fourth display portion selecting whether another object is scripted for server or client.
• Claim 3: the component is a design-time control (DTC) that creates client and server script after the page is saved to the server.
• Claim 4: the DTC captures user inputs for configuring the method.
• Claim 5: client script sends events to server; server script handles client events.
• Claim 6 (system): two pages in the UI, each receiving drag-and-drop; "the user interface represents the second page as a page object"; configure an object on page 1 to include a call to a method of page 2; system automatically generates code for page 1 to invoke page 2's method in response to a client event.
• Claims 7–10: event = call from page 1 to the page-2 object; server storage of the scripted page; second page is an ASP; DTC used to generate the script for objects dropped on the second page.
• Claim 11 (method): drag objects from a library display onto a page display; capture user inputs via a DTC to configure method/property/event; designate via the DTC whether the event occurs at server or client; save to server; and in response to saving, use the DTC to automatically create client and server scripts (one sends the event, the other handles it) depending on the designation.
• Claim 12: the saved object represents a second page transmitted server→client (text truncated at the retrieval point).

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E. §103 grounds

Ground 1 — Claim 1: Huber in view of Massena

(Note: Huber + Massena are both on the face of the patent, so this ground must overcome the presumption that the examiner already considered the combination. Steps 2–3 below are nonetheless textually supported.)

• (a) "first display portion … receiving dragged and dropped objects" — Huber's stated premise ("…using drag-and-drop metaphor") is a design surface onto which client/server application objects are dragged. Its title and claim-1-adjacent function (automated client/server development) map to a display portion representing a page to be sent to a client.
• (b) "second display portion representing a library of the objects" — the conventional toolbox/palette of a client/server builder; Huber's drag-and-drop metaphor necessarily requires a source area holding the draggable objects.
• (c) "third display portion for configuring a method" — Massena discloses design-time controls with property sheets/method configuration that "capture user inputs." The '267 specification itself says DTCs "take advantage of OLE design-time capabilities (including direct manipulations, property sheets, and persistence) to capture user inputs." This is an express admission that Massena teaches element (c).
• (d) "component for automatically creating client and server scripts … one to send an event, the other to handle the event" — Massena is titled "automatic generation of text and computer-executable code," and Huber is directed to automated client/server development. The two-script split (client emits event / server handles event) is the ordinary client/server event round-trip of any 1998 ASP + DHTML application.
• (e) "single unified environment" — this is presented to the designer, i.e., an authoring-time representation. Huber (client/server builder) and Gish (event-driven client/server framework) each present one development view over a client/server split. At minimum, this element is a design-time presentation choice with no structural weight beyond the component elements already recited.

Motivation to combine (KSR): Both references are in the same field (automated application authoring) and address the same problem — eliminating hand-coding of client/server logic. Massena's DTC is expressly described in the '267 spec as the very mechanism for attaching object information to a web page and generating client/server script. A PHOSITA seeking a drag-and-drop web authoring tool would predictably reach for the known DTC architecture to supply the configuration and code-generation pieces. KSR rationale: (i) combining known prior-art elements according to known methods to yield predictable results; (ii) use of a known technique (DTC property sheets) to improve a similar device (a client/server drag-and-drop builder) in the same way.

Ground 2 — Claim 1 (alternative): Huber in view of Gish and Dale

• Gish supplies the event-driven client/server message framework — the "unified environment" and the event send/handle split.
• Dale supplies "mechanism for automatically establishing connections between executable components of a hypertext-based application" — i.e., automatically wiring client and server executable components of a web page, which is the "automatically creating client and server scripts" element.

Motivation: Dale and Gish are directed to the same problem (integrating client- and server-side executable components of web applications), so a PHOSITA designing a drag-and-drop web authoring tool would consult them for exactly the auto-wiring and event-routing functionality claimed. Again a predictable combination of familiar elements.

Ground 3 — Claims 2–5: add Massena (and general IDE art)

• Claim 2 ("fourth display portion … scripting another object for said server or for said client") — a per-object server/client designation control. This is the routine "target/where does this code run" choice in a client/server builder; Massena's property sheets, plus ordinary client/server development practice, supply it.
• Claim 3 (component is a DTC that creates scripts after the page is saved) — squarely Massena: the '267 spec concedes "a design-time control … operates only in an editor … Once the web site is saved, the design-time control may create (among other things) script for the client/server/ASPs." This is an express admission mapping directly onto claim 3.
• Claim 4 (DTC captures user inputs for configuring the method) — Massena again ("OLE design-time capabilities … to capture user inputs").
• Claim 5 (client script sends events, server script handles them) — the canonical ASP/DHTML round-trip of the era; also Gish.

Conclusion on claims 3–4: these are the weakest claims in the patent, because they recite as an element the very design-time-control technology the specification simultaneously admits was known and incorporates by reference (Ser. No. 08/959,300 → US 6,035,119). A §103 ground built on Massena alone or Massena + Huber is textually strong for claims 3 and 4.

Ground 4 — Claims 6–12: page-as-object — Huber/Massena + distributed-object art (Java RMI, DCOM) + ASP + Dale

• Claim 6's core ("user interface represents the second page as a page object"; auto-generating code for page 1 to invoke a method of page 2 on a client event) is the combination of (i) auto-connection of web executable components (Dale, Huber) and (ii) the well-known remote-method-invocation paradigm — Java RMI (1997) and DCOM (1996) — in which a remote component appears as a local object with exposed methods and a generated proxy/stub. The proxy-object idea is precisely the "page object" construct. ASP server-side scripting (1996) supplies the server-page platform.
• Claim 7 (event = call to the page-2 object) and claim 8 (server-side storage of the scripted page) are conventional consequences of the same combination; server storage of scripted files is inherent in ASP.
• Claim 9 ("the second page is an active server page") is met by ASP itself — Microsoft Active Server Pages existed in 1996 and is acknowledged in the '267 Background.
• Claim 10 (DTC generates script for objects dropped on the second page) — Massena, per Ground 3.
• Claim 11 (method) — the combination of Huber (drag/drop from a library onto a page display) + Massena (DTC capturing user inputs, configuring method/property/event, generating client and server script on save) + ordinary client/server practice (designating whether the event fires on server or client). The '267 spec concedes the DTC performs exactly this placement decision: "the DTC can place the appropriate code in the correct location, alleviating this tedious coding task from the designer." That is an admission that maps onto claim 11's "utilizing the design-time control to automatically create client and server scripts … depending on the designation."
• Claim 12 — the "object represents a second page" variant; same combination as claim 6.

Motivation to combine: the 1996–1998 industry convergence on distributed objects for the web (DCOM, Java RMI) and remoted method invocation gives an explicit, contemporaneous motivation to represent a web page as an object with callable methods. The '267 Background itself frames the problem ("There is currently no way to incorporate the functionality of a destination ASP into a current page"), so the problem was recognized and being solved by others at the critical date — the classic KSR "design incentive" rationale.

Ground 5 — Claims 1, 2, 11: the non-cited visual-IDE art alone or as primary

Claims 1–5 recite, at bottom, the standard component-palette IDE interaction model that existed in Visual Basic/Delphi/PowerBuilder years before 1998:

• toolbox/palette (second display portion) → drag onto a form/design surface (first display portion) → Object Inspector / property sheet (third display portion) configuring properties, methods and events → automatic generation of executable code.

Substituting "web page rendered by a browser" for "form," and emitting HTML/JavaScript/ASP for the client/server targets, is the sort of substitution a PHOSITA would make as a matter of ordinary design choice once web authoring became commercially important. Netscape Visual JavaScript (1997) is particularly damaging because it combined the drag-and-drop component palette with client and server JavaScript generation from one visual design — an express "single unified environment" for the designer.

KSR rationales available here: (1) combination of familiar elements according to known methods; (2) simple substitution of one known element for another (form → web page; compiled code → HTML/script); (3) "the improvement is a predictable use of prior-art elements according to their established functions."

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F. Consolidated motivation-to-combine statement

For each ground above, the motivation rests on one or more of the KSR-recognized rationales:

1. Same field / same problem: all references address automated generation of client and server code for interactive applications, and eliminating tedious hand-scripting of client/server control flow — the exact problem the '267 Background articulates.
2. Predictable result: combining a known drag-and-drop builder with a known DTC/property-sheet code generator yields nothing more than the expected aggregation of each reference's known function.
3. Express design incentive in the art: the patent's own Background enumerates the recognized shortcomings (separate ASP files, hidden-field state management, tedious sequential coding, no way to call a destination ASP) and the industry was actively addressing them (interdev/FrontPage, LiveWire, RMI/DCOM) — evidence of a known need with known solutions.
4. Applicant's own admission: the specification incorporates Ser. No. 08/959,300 (→ US 6,035,119, Massena) as describing the DTC technology that is claimed in claims 3, 4, 10 and 11. That admission materially strengthens Ground 3.

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G. Where these grounds are weak (patent-owner defenses to anticipate)

I want to be candid about the limits, because a §103 analysis that ignores them is not useful:

1. Huber and Massena were on the face of the patent. The examiner presumably considered them and still allowed. Any ground relying only on face-cited references must explain what the examiner missed — e.g., a motivation-to-combine that the examiner did not articulate, or a reference (like Massena's identical identity to the incorporated Ser. No. 08/959,300) whose significance as an admission was not developed.
2. Huber's date/scope. Huber issued 1998-09-01 (after the 1998-12-31? no — before; but its filing date and whether it discloses web pages as opposed to non-web client/server apps must be verified). If Huber is directed to non-web client/server tooling, the "page to be sent from server to client using a browser" limitation requires the Netscape Visual JavaScript / DTC combination, not Huber alone.
3. "Represents … as a single unified environment" (claim 1) and "represents the second page as a page object" (claim 6) are presentation/mental limitations. A patent owner can argue the prior art does not disclose this. A §103 attack should argue these elements are non-structural design-time representations with no patentable weight, or are inherently met by any builder that hides the client/server split (Huber, Gish, Visual JavaScript).
4. Bowman-Amuah references have post-critical-date issue dates; do not rely on them without confirming pre-1998 priority.
5. I have not verified the disclosure text of Huber, Dale, Gish, Kohl, Parthasarathy or Barlow, nor any non-patent literature exhibit text. Element mappings above are functional and grounded in titles/dates plus the '267 specification's own admissions. A real §103 petition would require the actual passages, marked exhibits, and a declaration from a PHOSITA.

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H. Bottom line

• Strongest grounds: claims 3, 4, 10, 11 (and claim 5) over Massena (US 6,035,119) — the Ser. No. 08/959,300 DTC reference the patent itself incorporates and describes — alone or in view of Huber. The specification's own description of DTC operation ("once the web site is saved, the design-time control may create … script for the client/server/ASPs") is an admission that tracks the claim language almost verbatim.
• Next strongest: claim 1 (and 2) over Huber + Massena, with Netscape Visual JavaScript (1997) as the "unified environment / client-and-server-from-one-design" reference; alternatively Huber + Gish + Dale.
• Claims 6–9 and 12: Huber/Massena + Dale (auto-connection of web executable components) + distributed-object art (Java RMI 1997 / DCOM 1996) + ASP (1996), on the rationale that representing a remote page as a callable object with generated proxies was a known, industry-standard approach.
• In all cases, the motivation to combine is preserved by the KSR rationales in Section F and, critically, by the problem statements in the patent's own Background.

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I. Confidence and unresolved items

• High confidence: the claim language (Justia) and the identity/date of the face-cited references (FPO / Google Patents). The claim language is consistent with the Google Patents "prior art keywords" (page, server, client, objects, display portion), which corroborates claim 1's "first/second/third display portion" vocabulary.
• Unresolved: (a) verbatim claims 13 onward — I could not retrieve them; my analysis covers claims 1–12 only; (b) the tail of claim 12; (c) verbatim disclosure text of the prior-art references — no column/line cites available to me, so element mappings are functional; (d) whether WO 2004/086222 A3's search report (which cites US 5,802,514 A (Huber) as a "Y" reference against claims 15–27, 29–31 of that application) belongs to this family — I observed this in search results but could not verify it is the same family, so I have not relied on it; it is noted only as a corroborating signal that Huber is the key drag-and-drop/code-generation reference in this space.
• Do not treat any of the above as an invalidity opinion. It is a technical analyst's §103 roadmap, and the element mappings must be re-verified against the actual reference texts and file histories (particularly the prosecution history of App. 10/680,238 and of US 6,035,119) before being relied upon.