Display a loading image while waiting on a document? The only "innovation" that got them the patent was that they claimed displaying a smaller image on a smaller screen was somehow groundbreaking.

Don't wait for a background image to finish downloading before displaying web page text? Who would think waiting was a great idea in the first place?

I don't think either of these is somehow an feat of software engineering that should grant them the ability to extort money from companies creating innovative software in 2011.

A more appropriate question may be whether those methods would be general and obvious in present day if they hadn't been invented 20 years ago.

I would say, yes.