IconFind, Inc. v. Google, Inc.

Filing 66

SECOND AMENDED ANSWER to 1 Complaint with Jury Demand, COUNTERCLAIM against IconFind, Inc. by Google, Inc.. (Attachments: # 1 Exhibit 1, # 2 Appendix A, # 3 Appendix B, # 4 Appendix C, # 5 Appendix D, # 6 Appendix E, # 7 Appendix F, # 8 Appendix G, # 9 Appendix H, # 10 Appendix I, # 11 Appendix J, # 12 Appendix K)(Malecek, Michael)

APPENDIX G
U.S. Pat. No. 7,181,459
1. A computer implemented method
of categorizing a network page,
comprising:

Pirolli in view of Khare
Pirolli discloses a computer implemented method/system for
categorizing web pages:
“A system for analyzing the topology, content and usage of linked
collections of documents such as those found on the World Wide
Web (hereinafter the Web) to facilitate information searching or
improving design of a web locality is disclosed. Documents found
on the Web are typically referred to as Web pages. The system
provides for (a) categorization based on feature vectors that
characterize individual page information and (b) prediction of
need (or relevance) of other Web pages with respect to a
particular context, which could be a particular page or set of
pages, using a spreading activation technique.” Pirolli at col. 1, l.
65 – col. 2, l. 8.
Khare discloses using metadata such as Platform for Internet
Content Selection (“PICS”) to categorize the rights management
of an Internet web page:
“The World Wide Web Consortium is dedicated to 'Realizing the
Full Potential of the Web'. One of the core principles behind that
commitment is 'automatability': enabling rich meta-data and
context to be associated with Web content so computers and
humans can effectively find, communicate, and use information.
Intellectual Property Rights (IPR) are an example of "rich"
information.” Khare at § 1.
“Rights Declaration. We need deterministic statements of the
rights being claimed, and distribution mechanisms for binding
these declarations to the information objects. We believe that
machine-readable meta-data formats & transport mechanisms,
such as PICS, are an ideal way to capture rights declarations. [See
attached <draft-reagle-PICS-copyright-00.txt>]”. Khare at § 2.1.
The motivation to combine the references may be found in the
common knowledge of those skilled in the art, the prior art as a
whole, and/or the nature of the purported problem itself. Pirolli
and Khare both disclose systems that categorize network pages
Therefore, the motivation to combine the references in inherent in
the references.

[a] providing a list of categories,
wherein said list of categories

-1-

Pirolli discloses providing a list of categories that can be used to
classify web pages:

GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

include a category for transacting
business and a category for
providing information, and wherein
said list of categories include a
category based on copyright status
of material on a page;

“In order to perform categorizations each Web page at the Web
locality is represented by a vector of features constructed from the
above topology, meta-information, usage statistics and paths, and
text similarities. . .
The present invention assumes that categories are designed by
someone (application designer, webmaster, end user), in contrast
to being automatically induced. These categories might be, for
instance, socially defined genres (personal home page; product
description), or personally defined categories of interest.” Pirolli
at col. 8, ll. 8-40.
Pirolli discloses that the categories can include an organization
home page (i.e., category for transacting business) and content
(i.e., category for providing information):
“FIG. 6 is a table illustrating the Web categories defined in the
currently preferred embodiment of the present invention: . . .
organizational home page 602: These are pages that represent the
entry point for organizations and institutions, usually found as the
default home page for servers, e.g., http://www.org/ . . .
content 608: These are pages whose purpose is not to facilitate
navigation, but to deliver information. ” Pirolli at col. 9, ll. 11-41.
Khare discloses that PICS labels can be used to categorize the
copyright status of a web page:

[b] assigning said network page to
one or more of said list of
categories;

-2-

“This document presents an alternative expression mechanism for
the copyright status of Web resources. Specifically it employs the
Platform for Internet Content Selection (PICS)[2] label format to
associate web resources with their copyright and usage
information. This in turn can be used by search engines, proxy
servers, agents, clients, and users for content selection or to aid in
rights compliance. This document employs the copy control
system described in [1].” Khare at Using PICS for Copyright
Notice and Control, Abstract.
Pirolli discloses assigning a web page to one or more categories:
“In the currently preferred embodiment, a set of functional
categories is defined. Each functional category was defined in a
manner that has a graded membership, with some pages being
more typical of a category than others, and Web pages may
belong to many categories.” Pirolli at col. 9, ll. 7-10.

GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

“For the classification of Web pages in the web locality,
classification characteristics are provided, step 103. The
classification characteristics are predetermined "rules" which are
applied to the feature vectors of a page to determine the category
of the page. For example, it may be desirable to have a
classification of web pages as index types (contain primarily links
to other pages) or content types (contain primarily information).
The classification characteristics are then applied to the feature
vectors representing the Web pages, step 104. When the
classification characteristics are applied to the respective feature
vectors, lists of pages in the particular classes are created.”
Pirolli, col. 5, ll. 13-24.
Khare also discloses that PICS labels can be used to assign
network pages to categories:
“This document presents an alternative expression mechanism for
the copyright status of Web resources. Specifically it employs the
Platform for Internet Content Selection (PICS)[2] label format to
associate web resources with their copyright and usage
information. This in turn can be used by search engines, proxy
servers, agents, clients, and users for content selection or to aid in
rights compliance. This document employs the copy control
system described in [1].” Khare at Using PICS for Copyright
Notice and Control, Abstract.
“Detached labels can easily associate copyright information
with any web referenceable resource including audio and visual
content.” Khare at Using PICS for Copyright Notice and Control,
§ 2.3.
[c] providing a categorization label
for the network page using the
copyright status of material on the
network page; and

-3-

Pirolli discloses labeling network pages using “classification
characteristics”:
“For the classification of Web pages in the web locality,
classification characteristics are provided, step 103. The
classification characteristics are predetermined "rules" which are
applied to the feature vectors of a page to determine the category
of the page. For example, it may be desirable to have a
classification of web pages as index types (contain primarily links
to other pages) or content types (contain primarily information).
The classification characteristics are then applied to the feature
vectors representing the Web pages, step 104. When the
classification characteristics are applied to the respective feature
vectors, lists of pages in the particular classes are created.”

GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

Pirolli, col. 5, ll. 13-24.
Khare discloses that PICS labels can be used for copyright status:
“This document presents an alternative expression mechanism for
the copyright status of Web resources. Specifically it employs the
Platform for Internet Content Selection (PICS)[2] label format to
associate web resources with their copyright and usage
information. This in turn can be used by search engines, proxy
servers, agents, clients, and users for content selection or to aid in
rights compliance. This document employs the copy control
system described in [1].” Khare at Using PICS for Copyright
Notice and Control, Abstract.
“In [1], Daviel specified a system in which a Web document has
"Print", "Save", and "Quote" variables associated with it, where
({0 = disallowed}, {1 = conditionally allowed}, {2 =
unconditionally allowed}). These permissions are associated with
a document by encoding them in an HTTP header, or HTML
META tag. PICS is a more effective means of associating Web
resources with their copyright status and control information as
demonstrated in section 2.3.” Khare at Using PICS for Copyright
Notice and Control, § 2.1.
[d] controlling usage of the network
page using the categorization label
and the copyright status of the
network page.

-4-

Khare discloses that labels can be used to control usage of the
Web page:
“[H]ere is one possible course of events for Web [Rights
Management], based on the hypothesis that each layer will
stabilize in succession:
1. Rights Notification. Simple rights notification based upon a
standard meta-data labeling format. PICS is already converging as
the meta-data format for content rating. Many browsers can
provide advisory notice that a site is labeled in some system
(RSAC, SafeSurf~~, etc) and the corresponding ratings for that
page.
2.Application-specific Rights Management. The next step is a
series of applications which protect rights within a single context.
For example, an OS might only print or display fonts based on the
embedded label -- as already occurs with embedded TrueType
fonts. Browsers could be programmed to always consult a
'blacklist' of copyright-infringing resources run by a trusted third
party. Rights labels could reflect ACLs and protections already
enforced by underlying security mechanisms. Finally, we already
have interest in high-value lock-box enveloped data with rights
labels, such as Cryptolopes.

GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

3.General-purpose Rights Management. In some sense, rights
management can converge with trust management -- RM is the
asking of "permission to take specified actions upon a given
resource." Just as with PICS, users will start asking for
customizable, portable enforcement policies. The policy language
and policy-enforcement engines will become cross-application
services.
4.Automated Settlement Models. Finally, automated policy
engines can interface with an electronic payments infrastructure to
actively seek out and settle rights. New social and business
models will drive the development of micropayments, aggregation
services, and other players which will make many kinds of rights
easily and inexpensively clearable.” Khare at § 2.3.
“In [1], Daviel specified a system in which a Web document has
"Print", "Save", and "Quote" variables associated with it, where
({0 = disallowed}, {1 = conditionally allowed}, {2 =
unconditionally allowed}). These permissions are associated
with a document by encoding them in an HTTP header, or HTML
META tag. PICS is a more effective means of associating Web
resources with their copyright status and control information as
demonstrated in section 2.3.” Khare at Using PICS for Copyright
Notice and Control, § 2.1.
“Multiple distribution methods (embedded within the document,
transported by the server, or distributed from a label bureau)
improve copy status and control management. Organizations can
control the use and access to their IPR from their server or proxy.
Organizations can also create "audit" spiders to understand the
distribution and use of their content on the Internet.” Khare at
Using PICS for Copyright Notice and Control, § 2.3.
“The benefits of using PICS labels for copyright status and
control include:
1. Detached labels can easily associate copyright information
with any web referenceable resource including audio and visual
content.
2. Multiple distribution methods (embedded within the document,
transported by the server, or distributed from a label bureau)
improve copy status and control management. Organizations can
control the use and access to their IPR from their server or
proxy. Organizations can also create "audit" spiders to
understand the distribution and use of their content on the
Internet.”

-5-

GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

Khare at Using PICS for Copyright Notice and Control, § 2.3.
6. The method of claim 1, wherein
said plurality of categories based on
the copyright status of material on a
page comprise categories related to
public domain, fair use only, use
with attribution, and permission of
copyright owner needed.

Khare discloses the copyright status of the web page is assigned
to the web page:
“In [1], Daviel specified a system in which a Web document has
"Print", "Save", and "Quote" variables associated with it, where
({0 = disallowed}, {1 = conditionally allowed}, {2 =
unconditionally allowed}). These permissions are associated with
a document by encoding them in an HTTP header, or HTML
META tag. PICS is a more effective means of associating Web
resources with their copyright status and control information as
demonstrated in section 2.3.” Khare at Attachment: “Using PICS
for Copyright Notice and Control”, § 2.1.
It is inherent that the PICS system disclosed in Khare includes the
recited categories.

9. The method of claim 1, wherein
said categories include: a plurality
of categories based on the copyright
status of the material on a page.

Khare discloses that PICS labels can be used to categorize the
copyright status of a web page:
“This document presents an alternative expression mechanism for
the copyright status of Web resources. Specifically it employs the
Platform for Internet Content Selection (PICS)[2] label format to
associate web resources with their copyright and usage
information. This in turn can be used by search engines, proxy
servers, agents, clients, and users for content selection or to aid in
rights compliance. This document employs the copy control
system described in [1].” Khare at Using PICS for Copyright
Notice and Control, Abstract.
“In [1], Daviel specified a system in which a Web document has
"Print", "Save", and "Quote" variables associated with it, where
({0 = disallowed}, {1 = conditionally allowed}, {2 =
unconditionally allowed}). These permissions are associated with
a document by encoding them in an HTTP header, or HTML
META tag. PICS is a more effective means of associating Web
resources with their copyright status and control information as
demonstrated in section 2.3.” Khare at Using PICS for Copyright
Notice and Control, § 2.1.

16. The method of claim 1, further
comprising providing an indicium
for each of said categories.

Khare discloses using a META tag (i.e., an indicium) to create a
label:
“He uses the copy control system in [1] to create the following

-6-

GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

label:
(PICS-1.1 "http://www.wipo.org/v1.5"
by "Mark Twain"
labels on "1994.11.05T08:15-0500"
for "http://www.twain.com/story.html"
full "http://www.twain.com/IP-notice.html"
ratings (print 1 save 1 quote 2))”
Khare at Using PICS for Copyright Notice and Control, § 2.2.
“This document presents an alternative expression mechanism for
the copyright status of Web resources. Specifically it employs the
Platform for Internet Content Selection (PICS) [2] label format to
associate web resources with their copyright and usage
information. This in turn can be used by search engines, proxy
servers, agents, clients, and users for content selection or to aid in
rights compliance.” Khare at Using PICS for Copyright Notice
and Control, Abstract.
“We argue that PICS is an effective method of communicating
intellectual property information about Web content.” Khare at
Using PICS for Copyright Notice and Control, § 1.
17. The method of claim 16,
wherein said indicium comprises an
icon.

Pirolli discloses using visualizations (i.e., icons) to provide an
overview of categories:
“Information Visualization could be used to provide an interactive
overview of web localities that facilitates navigation and general
assessment. Visualizations have been developed that provide new
interactive mechanisms for making sense of information sets with
thousands of objects.” Pirolli at col. 12, ll. 56-61.
Khare discloses describing categories with icons:
“Many Rating Systems: systems provide multiple axes with
rational points (some points can be described with text and icons)”
Khare at Using PICS Labels for Trust Management.

19. The method of claim 1, further
comprising providing a
categorization code that can be used
to label the page with the
categorization label that indicates
the categories to which the page is
assigned.

-7-

Khare discloses using metadata (i.e., a categorization code) to
create a label:
“He uses the copy control system in [1] to create the following
label:
(PICS-1.1 "http://www.wipo.org/v1.5"
by "Mark Twain"
GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

labels on "1994.11.05T08:15-0500"
for "http://www.twain.com/story.html"
full "http://www.twain.com/IP-notice.html"
ratings (print 1 save 1 quote 2))”
Khare at Using PICS for Copyright Notice and Control, § 2.2.
Resnick discloses indicating each of the categories using the
META tags: “PICS specifies three ways to distribute labels. The
first is to embed labels in html documents, using the META
element in the document header. The general format is <META
http-equiv=”PICS-Label” content=’labellist’>. Other document
formats could be similarly extended.” Resnick at p. 91, col. 1 (“A
Tour of the PICS Specification”).
The “labellist” is described at Resnick at p. 90, cols. 1-2.
20. The method of claim 19,
wherein said categorization code
comprises an indicium for each of
said categories.

Khare discloses using a META tag (i.e., an indicium) to create a
label with multiple categories of copyright status:
“He uses the copy control system in [1] to create the following
label:
(PICS-1.1 "http://www.wipo.org/v1.5"
by "Mark Twain"
labels on "1994.11.05T08:15-0500"
for "http://www.twain.com/story.html"
full "http://www.twain.com/IP-notice.html"
ratings (print 1 save 1 quote 2))”
Khare at Using PICS for Copyright Notice and Control, § 2.2.

21. The method of claim 20,
wherein said indicium comprises
two letters.

Khare does not limit the metadata to less than two letters.

22. The method of claim 20,
wherein said categorization label
includes the indicia for each
category to which a page is
assigned.

Khare discloses using a META tag (i.e., an indicium) to create a
label with multiple categories of copyright status:
“He uses the copy control system in [1] to create the following
label:
(PICS-1.1 "http://www.wipo.org/v1.5"
by "Mark Twain"
labels on "1994.11.05T08:15-0500"

-8-

GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

for "http://www.twain.com/story.html"
full "http://www.twain.com/IP-notice.html"
ratings (print 1 save 1 quote 2))”
Khare at Using PICS for Copyright Notice and Control, § 2.2.
27. The method of claim 19, further
comprising making said
categorization label recognizable by
a search engine.

Khare discloses that PICS labels can be used by search engines:

28. The method of claim 1, further
comprising making said categories
to which a page is assigned
recognizable by a search engine.

Khare discloses that PICS labels can be used by search engines:

29. The method of claim 1, wherein
said list of categories is provided on
a graphical user interface.

Khare discloses that PICS labels can be used by search engines,
which inherently have a graphical user interface:

“This in turn can be used by search engines, proxy servers, agents,
clients, and users for content selection or to aid in rights
compliance.“ Khare at Using PICS for Copyright Notice and
Control, Abstract.

“This in turn can be used by search engines, proxy servers, agents,
clients, and users for content selection or to aid in rights
compliance.“ Khare at Using PICS for Copyright Notice and
Control, Abstract.

“This in turn can be used by search engines, proxy servers, agents,
clients, and users for content selection or to aid in rights
compliance.“ Khare at Using PICS for Copyright Notice and
Control, Abstract.
30. A computer implemented
method for categorizing a network
page, comprising:

Pirolli discloses a computer implemented method/system for
categorizing web pages:
“A system for analyzing the topology, content and usage of linked
collections of documents such as those found on the World Wide
Web (hereinafter the Web) to facilitate information searching or
improving design of a web locality is disclosed. Documents found
on the Web are typically referred to as Web pages. The system
provides for (a) categorization based on feature vectors that
characterize individual page information and (b) prediction of
need (or relevance) of other Web pages with respect to a
particular context, which could be a particular page or set of
pages, using a spreading activation technique.” Pirolli at col. 1, l.
65 – col. 2, l. 8.
Khare discloses using metadata such as Platform for Internet
Content Selection (“PICS”) to categorize the rights management

-9-

GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

of an Internet web page:
“The World Wide Web Consortium is dedicated to 'Realizing the
Full Potential of the Web'. One of the core principles behind that
commitment is 'automatability': enabling rich meta-data and
context to be associated with Web content so computers and
humans can effectively find, communicate, and use information.
Intellectual Property Rights (IPR) are an example of "rich"
information.” Khare at § 1.

[a] providing a list of categories,
wherein said list of categories
include a category for transacting
business and a category for
providing information, and wherein
said list of categories include a
plurality of categories based on the
copyright status of material on a
page;

“Rights Declaration. We need deterministic statements of the
rights being claimed, and distribution mechanisms for binding
these declarations to the information objects. We believe that
machine-readable meta-data formats & transport mechanisms,
such as PICS, are an ideal way to capture rights declarations. [See
attached <draft-reagle-PICS-copyright-00.txt>]”. Khare at § 2.1.
Pirolli discloses providing a list of categories that can be used to
classify web pages:
“In order to perform categorizations each Web page at the Web
locality is represented by a vector of features constructed from the
above topology, meta-information, usage statistics and paths, and
text similarities. . .
The present invention assumes that categories are designed by
someone (application designer, webmaster, end user), in contrast
to being automatically induced. These categories might be, for
instance, socially defined genres (personal home page; product
description), or personally defined categories of interest.” Pirolli
at col. 8, ll. 8-40.
Pirolli discloses that the categories can include an organization
home page (i.e., category for transacting business) and content
(i.e., category for providing information):
“FIG. 6 is a table illustrating the Web categories defined in the
currently preferred embodiment of the present invention: . . .
organizational home page 602: These are pages that represent the
entry point for organizations and institutions, usually found as the
default home page for servers, e.g., http://www.org/ . . .
content 608: These are pages whose purpose is not to facilitate
navigation, but to deliver information.” Pirolli at col. 9, ll. 11-41.
Khare discloses that PICS labels can be used to categorize

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GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

network pages based on the copyright status of material on the
page:

[b] providing a categorization code
for labeling the network page with a
categorization label, wherein said
categorization label indicates a set
of categories and subcategories to
which the network page is assigned,
and wherein said categorization
label indicates the copyright status
of material on the network page;
and

[c] controlling usage of the network
page using the categorization label
and the copyright status of the
network page.

-11-

“This document presents an alternative expression mechanism for
the copyright status of Web resources. Specifically it employs the
Platform for Internet Content Selection (PICS)[2] label format to
associate web resources with their copyright and usage
information. This in turn can be used by search engines, proxy
servers, agents, clients, and users for content selection or to aid in
rights compliance. This document employs the copy control
system described in [1].” Khare at Using PICS for Copyright
Notice and Control, Abstract.
Khare discloses using a system for categorizing web pages (i.e., a
categorization code) used to provide the copyright status of the
web page in a label:
“This document presents an alternative expression mechanism for
the copyright status of Web resources. Specifically it employs the
Platform for Internet Content Selection (PICS)[2] label format to
associate web resources with their copyright and usage
information. This in turn can be used by search engines, proxy
servers, agents, clients, and users for content selection or to aid in
rights compliance. This document employs the copy control
system described in [1].” Khare at Using PICS for Copyright
Notice and Control, Abstract.
“In [1], Daviel specified a system in which a Web document has
"Print", "Save", and "Quote" variables associated with it, where
({0 = disallowed}, {1 = conditionally allowed}, {2 =
unconditionally allowed}). These permissions are associated with
a document by encoding them in an HTTP header, or HTML
META tag. PICS is a more effective means of associating Web
resources with their copyright status and control information as
demonstrated in section 2.3.” Khare at Using PICS for Copyright
Notice and Control, § 2.1.
Khare discloses that PICS labels can be used to control usage of
the Web page:
“In [1], Daviel specified a system in which a Web document has
"Print", "Save", and "Quote" variables associated with it, where
({0 = disallowed}, {1 = conditionally allowed}, {2 =
unconditionally allowed}). These permissions are associated with
a document by encoding them in an HTTP header, or HTML
META tag. PICS is a more effective means of associating Web
resources with their copyright status and control information as
demonstrated in section 2.3.” Khare at Using PICS for Copyright

GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

Notice and Control, § 2.1.
“The benefits of using PICS labels for copyright status and
control include:
1. Detached labels can easily associate copyright information
with any web referenceable resource including audio and visual
content.
2. Multiple distribution methods (embedded within the document,
transported by the server, or distributed from a label bureau)
improve copy status and control management. Organizations can
control the use and access to their IPR from their server or
proxy. Organizations can also create "audit" spiders to
understand the distribution and use of their content on the
Internet.”
Khare at Using PICS for Copyright Notice and Control, § 2.3.

31. A computer implemented
method of categorizing a network
page, comprising:

Pirolli discloses a computer implemented method/system for
categorizing web pages:
“A system for analyzing the topology, content and usage of linked
collections of documents such as those found on the World Wide
Web (hereinafter the Web) to facilitate information searching or
improving design of a web locality is disclosed. Documents found
on the Web are typically referred to as Web pages. The system
provides for (a) categorization based on feature vectors that
characterize individual page information and (b) prediction of
need (or relevance) of other Web pages with respect to a
particular context, which could be a particular page or set of
pages, using a spreading activation technique.” Pirolli at col. 1, l.
65 – col. 2, l. 8.
Khare discloses using metadata such as Platform for Internet
Content Selection (“PICS”) to categorize the rights management
of an Internet web page:
“The World Wide Web Consortium is dedicated to 'Realizing the
Full Potential of the Web'. One of the core principles behind that
commitment is 'automatability': enabling rich meta-data and
context to be associated with Web content so computers and
humans can effectively find, communicate, and use information.
Intellectual Property Rights (IPR) are an example of "rich"
information.” Khare at § 1.

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GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

[a] providing a list of categories,
wherein said categories include a
category based on the copyright
status of material on a page, and
wherein the copyright status
comprises categories related to
public domain, fair use only, use
with attribution, and permission of
copyright owner needed;

“Rights Declaration. We need deterministic statements of the
rights being claimed, and distribution mechanisms for binding
these declarations to the information objects. We believe that
machine-readable meta-data formats & transport mechanisms,
such as PICS, are an ideal way to capture rights declarations. [See
attached <draft-reagle-PICS-copyright-00.txt>]”. Khare at § 2.1.
Pirolli discloses providing a list of categories that can be used to
classify web pages:
“In order to perform categorizations each Web page at the Web
locality is represented by a vector of features constructed from the
above topology, meta-information, usage statistics and paths, and
text similarities. . .
The present invention assumes that categories are designed by
someone (application designer, webmaster, end user), in contrast
to being automatically induced. These categories might be, for
instance, socially defined genres (personal home page; product
description), or personally defined categories of interest.” Pirolli
at col. 8, ll. 8-40.
Khare discloses that PICS labels can be used to categorize
network pages based on the copyright status of material on the
page:
“This document presents an alternative expression mechanism for
the copyright status of Web resources. Specifically it employs the
Platform for Internet Content Selection (PICS)[2] label format to
associate web resources with their copyright and usage
information. This in turn can be used by search engines, proxy
servers, agents, clients, and users for content selection or to aid in
rights compliance. This document employs the copy control
system described in [1].” Khare at Using PICS for Copyright
Notice and Control, Abstract.
It is inherent that the categories listed in Khare include the
claimed categories.
Pirolli discloses assigning a web page to one or more categories:

[b] assigning said network page to
one or more of a plurality of said list
of categories;
In the currently preferred embodiment, a set of functional
categories is defined. Each functional category was defined in a
manner that has a graded membership, with some pages being
more typical of a category than others, and Web pages may
belong to many categories. Pirolli at col. 9, ll. 7-10.
Khare also discloses that PICS labels can be used to assign

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GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

network pages to categories:
“This document presents an alternative expression mechanism for
the copyright status of Web resources. Specifically it employs the
Platform for Internet Content Selection (PICS)[2] label format to
associate web resources with their copyright and usage
information. This in turn can be used by search engines, proxy
servers, agents, clients, and users for content selection or to aid in
rights compliance. This document employs the copy control
system described in [1].” Khare at Using PICS for Copyright
Notice and Control, Abstract.
“Detached labels can easily associate copyright information
with any web referenceable resource including audio and visual
content.” Khare at Using PICS for Copyright Notice and Control,
§ 2.3.
[c] providing a categorization label
for the network page using the
copyright status of material on the
network page; and

Khare discloses that PICS labels can be used for copyright status:
“This document presents an alternative expression mechanism for
the copyright status of Web resources. Specifically it employs the
Platform for Internet Content Selection (PICS)[2] label format to
associate web resources with their copyright and usage
information. This in turn can be used by search engines, proxy
servers, agents, clients, and users for content selection or to aid in
rights compliance. This document employs the copy control
system described in [1].” Khare at Using PICS for Copyright
Notice and Control, Abstract.
“In [1], Daviel specified a system in which a Web document has
"Print", "Save", and "Quote" variables associated with it, where
({0 = disallowed}, {1 = conditionally allowed}, {2 =
unconditionally allowed}). These permissions are associated with
a document by encoding them in an HTTP header, or HTML
META tag. PICS is a more effective means of associating Web
resources with their copyright status and control information as
demonstrated in section 2.3.” Khare at Using PICS for Copyright
Notice and Control, § 2.1.

[d] controlling usage of the network
page using the categorization label
and the copyright status of the
network page.

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Khare discloses that PICS labels can be used to control usage of
the Web page:
“In [1], Daviel specified a system in which a Web document has
"Print", "Save", and "Quote" variables associated with it, where
({0 = disallowed}, {1 = conditionally allowed}, {2 =
unconditionally allowed}). These permissions are associated with

GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G

a document by encoding them in an HTTP header, or HTML
META tag. PICS is a more effective means of associating Web
resources with their copyright status and control information as
demonstrated in section 2.3.” Khare at Using PICS for Copyright
Notice and Control, § 2.1.
“Multiple distribution methods (embedded within the document,
transported by the server, or distributed from a label bureau)
improve copy status and control management. Organizations can
control the use and access to their IPR from their server or proxy.
Organizations can also create "audit" spiders to understand the
distribution and use of their content on the Internet.” Khare at
Using PICS for Copyright Notice and Control, § 2.3.
“The benefits of using PICS labels for copyright status and
control include:
1. Detached labels can easily associate copyright information
with any web referenceable resource including audio and visual
content.
2. Multiple distribution methods (embedded within the document,
transported by the server, or distributed from a label bureau)
improve copy status and control management. Organizations can
control the use and access to their IPR from their server or
proxy. Organizations can also create "audit" spiders to
understand the distribution and use of their content on the
Internet.”
Khare at Using PICS for Copyright Notice and Control, § 2.3.

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GOOGLE’S INVALIDITY CONTENTIONS - APPENDIX G