- Invalidate based on OLE 2.0 design specs.
- They disclaimed reliance on '696 reissue. As near as I can tell, the reissue of the '686 patent failed in the PTO, and the judge precluded each side from using that information at trial.
- Failure to provide an adequate written description (Sect. 112 para. 1)
- Argue non-infringement based on IE/Windows relationship.
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