Personalized User Model LLP v. Google Inc.

Filing 137

REDACTED VERSION of 133 Declaration of Jennifer D. Bennett in Support of Plaintiff Personalized User Model, L.L.P.'s Responsive Claim Construction Brief by Personalized User Model LLP. (Attachments: # 1 Exhibit 1-12)(Tigan, Jeremy)

Personalized User Model LLP v. Google Inc.

Doc. 137

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE PERSONALIZED USER MODEL, L.L.P., Plaintiff, v. GOOGLE, INC., Defendant. ) ) ) ) ) ) ) ) )

C.A. No. 09-525 (LPS) PUBLIC VERSION

DECLARATION OF JENNIFER D. BENNETT IN SUPPORT OF PLAINTIFF PERSONALIZED USER MODEL, L.L.P.'S RESPONSIVE CLAIM CONSTRUCTION BRIEF MORRIS, NICHOLS, ARSHT & TUNNELL LLP Karen Jacobs Louden (#2881) Jeremy A. Tigan (#5239) 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899-1347 [phone] [e-mail] [e-mail] Attorneys for Personalized User Model, L.L.P.

OF COUNSEL: Marc S. Friedman SNR Denton US LLP 1221 Avenue of the Americas New York, NY 10020-1089 [phone] Mark C. Nelson SNR Denton US LLP 2000 McKinney Ave., Ste. 1900 Dallas, TX 75201-1858 [phone] Jimmy M. Shin Jennifer D. Bennett SNR Denton US LLP 1530 Page Mill Road, Ste. 200 Palo Alto, CA 94304-1125 [phone]

Confidential Version Filed: December 13, 2010 Public Version Filed: December 20, 2010

Dockets.Justia.com

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE PERSONALIZED USER MODEL, L.L.P., Plaintiff, v. GOOGLE, INC., Defendant. ) ) ) ) ) ) ) ) )

C.A. No. 09-525 (LPS)

DECLARATION OF JENNIFER D. BENNETT IN SUPPORT OF PLAINTIFF PERSONALIZED USER MODEL, L.L.P.'S RESPONSIVE CLAIM CONSTRUCTION BRIEF I, Jennifer D. Bennett, declare: 1. I am an attorney duly licensed to practice in the State of California, admitted to

practice pro hac vice before this Court, and an associate with the law firm of SNR Denton US LLP, counsel for Plaintiff Personalized User Model, L.L.P. ("P.U.M.") in this action. I make this declaration in support of P.U.M.'s Responsive Claim Construction Brief. 2. Attached as Exhibit 1 is a true and correct copy of

http://googleblog.blogspot.com/2009/12/personalized-search-for-everyone.html. 3. Attached as Exhibit 2 is a true and correct copy of

http://www.google.com/ads/preferences. 4. Attached as Exhibit 3 is a true and correct copy of

http://www.google.com/support/news/bin/answer.py?hl=en&answer=82464. 5. Attached as Exhibit 4 is a true and correct copy of selected pages from The

American Heritage Dictionary of the English Language (1978). 6. Attached as Exhibit 5 is a true and correct copy of Hertz, A. Krogh, R. Palmer,

Introduction to the Theory of Neural Computation (Addison-Wesley 1991).

7.

Attached as Exhibit 6 is a true and correct copy of Vladimir S. Cherkassky and

Filip M. Mulier, Learning from Data: Concepts, Theory, and Methods (1998). 8. Attached as Exhibit 7 is a true and correct copy of REDACTED 9. Attached as Exhibit 8 is a true and correct copy of REDACTED

http://en.wikipedia.org/wiki/Machine_learning. 10. Attached as Exhibit 9 is a true and correct copy of selected pages from the file

history of U.S. Patent No. 6,981, 040, Bates numbered PUM0067572-78, and PUM0068507-12. 11. Attached as Exhibit 10 is a true and correct copy of selected pages from THE

COMPUTER DESKTOP ENCYCLOPEDIA (Freedman 2d ed. 1999). 12. Attached as Exhibit 11 is a true and correct copy of REDACTED 13. Attached as Exhibit 12 is a true and correct copy of selected pages from Peter M. REDACTED

Lee, Bayesian Statistics: An Introduction (1989). I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this __13th___ day of __December_______, 2010, at San Francisco, California _/s/ Jennifer D. Bennett_____________ Jennifer D. Bennett

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CERTIFICATE OF SERVICE I hereby certify that on December 20, 2010, I caused the foregoing to be electronically filed with the Clerk of the Court using CM/ECF which will send electronic notification of such filing to all registered participants. Addit io nally, I hereby certify that true and correct copies of the foregoing were caused to be served on December 20, 2010, upon the following individuals in the manner indicated: BY E-MAIL Richard L. Horwitz David E. Moore POTTER ANDERSON & CORROON LLP 1313 N. Market St., 6th Floor Wilmington, DE 19801 BY E-MAIL Brian C. Cannon QUINN EMANUEL URQUHART & SULLIVAN, LLP 555 Twin Dolphin Dr., 5th Floor Redwood Shores, CA 94065 Charles K. Verhoeven David A. Perlson Antonio R. Sistos Eugene Novikov QUINN EMANUEL URQUHART & SULLIVAN, LLP 50 California Street, 22nd Floor San Francisco, CA 94111

/s/ Jeremy A. Tigan
______________________________________ Jeremy A. Tigan (#5239)