Xerox Corporation v. Google Inc. et al

Filing 122

REDACTED VERSION of 117 Letter by Yahoo! Inc.. (Attachments: # 1 Exhibit A - D)(Tigan, Jeremy)

Xerox Corporation v. Google Inc. et al

Doc. 122 Att. 1

EXHIBIT A

Dockets.Justia.com

EXHIBIT B

REDACTED IN ITS ENTIRETY

EXHIBIT C

REDACTED IN ITS ENTIRETY

EXHIBIT D

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

XEROX CORPORATION, Plaintiff-Counterclaim Defendant, v. GOOGLE INC., YAHOO! INC., RIGHT MEDIA INC., RIGHT MEDIA LLC, YOUTUBE, INC. AND YOUTUBE, LLC, Defendants-Counterclaim Plaintiffs. C.A. No. 10-136-LPS-MPT

PLAINTIFF XEROX CORPORATION'S REVISED INITIAL CLAIM CONSTRUCTIONS Pursuant to Paragraph 13 of the Court's June 15, 2010, Amended Scheduling Order, Plaintiff Xerox Corporation ("Xerox") hereby discloses without prejudice its preliminary proposed constructions for the asserted claims of U.S. Patent No. 6,778,979. Xerox reserves the right to amend or supplement these constructions in response to Defendants' proposed constructions and/or any subsequent development in this action. Claim 1 Claim Language A method for automatically generating a query from selected document content, comprising: defining an organized classification of document content with each class in the organized classification of document content having associated therewith a classification label; each classification label corresponding to a category of information in an information retrieval system; Proposed Construction No construction required

Identifying a set of categories that are defined in an ontology and that can be used to describe the subject matter of document content, each category having a corresponding identifying label, the identifying labels corresponding to categories of information in an information retrieval system.

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automatically identifying a set of entities in the selected document content for searching additional information related thereto using the information retrieval system;

Automatically identifying, in selected document content, one or more items with a recognized meaning (e.g., a person's name, a location, a medical term, or a graphics entity that may include image data, graphics data, audio data or video data). "Selected document content" may be all or part of the content of a document. Automatically performing a semantic analysis on the selected document content to correlate that content with one or more of the categories established in the "defining" step and to assign one or more corresponding identifying labels to the selected document content. Automatically assembling a set of query data to be sent to the information retrieval system, the set of query data including data items corresponding to one or more entities identified in the "automatically identifying" step and one or more identifying labels assigned in the "automatically categorizing" step.

automatically categorizing the selected document content using the organized classification of document content for assigning the selected document content a classification label from the organized classification of content; and automatically formulating the query to restrict a search at the information retrieval system for information concerning the set of entities to the category of information in the information retrieval system identified by the assigned classification label. Claim 2 Claim Language The method according to claim 1, further comprising limiting the query by adding terms relating to context information surrounding the set of entities in the selected document content.

Proposed Construction The set of query data to be sent to the information retrieval system in the "automatically formulating" step of Claim 1 includes additional data items corresponding to contextual data derived from the selected document content surrounding the entities identified in the "automatically identifying" step of Claim 1.

Claim 3 Claim Language The method according to claim 2, wherein the number of terms added is limited to a predefined number. Proposed Construction No construction required.

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Claim 5 Claim Language The method according to claim 1, wherein the organized classification of document content is defined using a hierarchical organization. Claim 10 Claim Language The method according to claim 1, wherein each class in the organized classification of document content has associated therewith a characteristic vocabulary. Claim 18 Claim Language An article of manufacture for use in a computer system, comprising: Proposed Construction A computer program existent (permanently, temporarily, or transitorily) on any computerusable medium such as on any memory device or in any transmitting device. A device or system from which electronic data may be retrieved, including, but not limited to, hard disk drives, floppy disks (or diskettes), optical disks, magnetic tape, semiconductor memories such as RAM, ROM, PROMs, etc. No construction required. Proposed Construction No construction required. Proposed Construction The set of categories established in the "defining" step of Claim 1 includes at least one subcategory of a category.

a memory

instructions stored in the memory for operating a method for automatically generating a query from selected document content, comprising: defining an organized classification of document content with each class in the organized classification of document content having associated therewith a classification label; each classification label corresponding to a category of information in an information retrieval system; automatically identifying a set of entities in the selected document content for searching information related thereto using the information retrieval system;

Same as in Claim 1

Same as in Claim 1

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automatically categorizing the selected document content using the organized classification of document content for assigning the selected document content a classification label from the organized classification of content; and automatically formulating the query to restrict a search at the information retrieval system for information concerning the set of entities to the category of information in the information retrieval system identified by the assigned classification label.

Same as in Claim 1

Same as in Claim 1

Claim 19 Claim Language Proposed Construction The article of manufacture according to Same as Claim 2 claim 18, wherein the instructions stored in the memory further comprise limiting the query by adding terms relating to context information surrounding the set of entities in the selected document content.

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Dated: February 9, 2011 CRAVATH, SWAINE & MOORE LLP /s/ Richard J. Stark Richard J. Stark (admitted pro hac vice) Andrei Harasymiak (admitted pro hac vice) Worldwide Plaza 825 Eighth Avenue New York, NY 10019-7475 [phone] Lawrence C. Ashby (J.D. #468) John G. Day (J.D. #2403) Lauren E. Maguire (J.D. #4261) ASHBY & GEDDES 500 Delaware Avenue, 8th Floor P.O. Box 1150 Wilmington, DE 19899 [phone] Attorneys for Plaintiff Xerox Corporation

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