DOW JONES REUTERS BUSINESS INTERACTIVE, LLC v. ABLAISE LTD. et al

Filing 21

DOW JONES REUTERS BUSINESS INTERACTIVE, Document 21-3 LLC v. ABLAISE LTD. Filed 04/04/2007 et al Case 1:06-cv-01015-JR

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Doc. 21 Att. 2

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

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DOW JONES & COMPANY, ENC. ) 200 Liberty Street ) New York, New York 1028 1 ) Plaintiff, 1 )
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Civil Action No. 1:06CV01014 Judge James Robertson

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ABLAISE LTD. ("Ablaise") 40 Queen Anne Street London W 1G 9EL United Kingdom
and

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GENERAL INVENTIONS INSTITUTE A, MC., ("GIIA") Craigmuir Chambers P.O. Box 7 1 Town Road Tortola, British Virgin Islands Defendants.

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1 DOW JONES REUTERS BUSMESS INTERACTIVE, LLC ) 200 Liberty Street 1 New York, New York 10281
Plaintiff,
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Civil Action No. 1:06CV01015 Judge James Robertson

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ABLAISE and GIIA Defendants.

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AFFIDAVIT OF ANDREW M. NTCRIE IN SUPPORT OF ABLAISE LTD. AND GEMERAIL INVENTIONS INSTITWX A, INC.'§ RESPONSIVE MAJXMAN BRIEF

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I, Andrew M. Ritchie, being first duly sworn, on oath state:
1. I am one of the named inventors of U.S.Patent N s 6,295,530 and 6,961,737. I have o. been working in the field of computer networks and internet technologies for 20 years, 1 am a computer consultant and have been an employee of ICL (International Computers Limited), lnformk SoRware, British Airways, Motorola Cellular, and Logical Networks,

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Ltd. I am one of the founding members of both Point4 Consulting Ltd. and Ablaise Ltd., which are described in more detail below.

The Genesis of the Inventions

2. In the spring of 1994, before the Internet was widely used, I was approached by a
businessman interested in creating an online version of the Freemans catalogue. Freemans was a very large r t i company in the United Kingdom that maintained a eal catalog similar to that of Sears in the United States.
3. I began to work on a technical design for Freeman'swebsite, and I planned to make a

single webpage for each item in the catalogue. But I quickly realized that creating a

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single webpage for each and every item in the catalogue would mean that I would need to hand write nearly 10,000 web pages. I subsequently decided to automate the process of creating the web pages, so that I would have a program automaticaliy create all the pages.
. But in 1994, hard drive space was very expensive, so that was not an ideal solution.

4. Despite these initial obstacles, I eventually came up with the idea to create a program that

would automatically create a web page after a person clicked on a link to request the
page. After recognizing that a program could be built to generate web pages "on the fly,"

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I thought about how I could extend that capability to provide web pages to users in a way
that had never before been possible. It was at t i point that I decided that the program hs could utilize identification information sent from a browsing device to customize a web page it created on the fly to fit the needs and preferences of the user requesting the page.

This ability to change the formatting of pages based on identifiers sent from the browser
became the basis for the `530 and `737 patents.

Paint4 Consulting Ltd.

5. In October 1994, I founded a web development company called Point4 Consulting Ltd.

a along With three friends. One of the co-founders w s Jon Bradshaw, the co-inventor listed
on the `530 and `737 patents. Mr. Bradshaw had extensive software development experience based on his experience with network applications and TCPm implementations for ICL, the United Kingdom's largest computer manufacturer.
6, I discussed my idea of dynamically creating web pages that included both content and

formatting correspondingto user preferences with Mr. Bradshaw, During the winter of 1994 to 1995, Mr. Bradshaw and I developed an internet application called Virtual Database Online (VDL). VDL was a simple prototype that allowed a server to create web pages on-the-fly in response to identifiers that identified the content and/or format prefened by the user.

7. After the creation of the VDL system, Mr. Bradshaw and I began designing and writing
web applications that created web pages on-the-fly for numerous business. Point4 created on-the-fly web applications far many high profile businesses in the United Kingdom,

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including the Electronic Telegraph, Cellnet, M3-V Networks Europe, Sony Computer Entertainment Europe, United Airlines, IPC magazines, and many others.
8. In fact, the Telegraph received severd awards for the online version of its newspaper

based on Point4`s on-the-fly web site creation technology.
9. In October 1999, we sold Point4 to Nettec Ltd,, but Mr. Bradshaw and I always retained

ownership of the patents. Mr. Bradshaw and I licensed the patents to Nettec for three
years.

Ablaise Ltd.

10. As inventors of the claimed inventions in the `530 and `737 patents, Mr. Bradshaw and I
realized that many companies were using the technology that we invented to provide custom-formatted web pages to users, AEter selling our Point4 business to Nettec, we decided to create Ablaise Ltd. (with essentiallythe same shareholdersas Point4) in order
to enforce our intellectual property rights.
t 1. In April 2002, Mr. Bradshaw and I assigned ownership of the `530 patent and the

pending application that led to the `737 patent to our new company, Ablaise Ltd.
12. Ablaise Ltd. is now actively enforcing its rights against many large corporations. As part

of this effort, Ablaise has alrmdy successfully licensed its invention to organizations
inchding: Dell, Citigroup, and E*Trade Financial.

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SUBSCRIBED and sworn to before me this day of fif'6IL ,2007.

Andrew M. Ritchie

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MARTIN AfWXONY CHARLTON Notary Pubilo of Landon, England M y Commlssfon expires Wfth life.

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