iLOR, LLC v. Google, Inc.

Filing 12

MOTION for Preliminary Injunction by iLOR, LLC (Attachments: # 1 Memorandum in Support Part 1# 2 Memorandum in Support Part 2# 3 Proposed Order # 4 Exhibit A# 5 Exhibit B# 6 Exhibit C# 7 Exhibit D# 8 Exhibit E# 9 Exhibit F# 10 Exhibit G# 11 Exhibit H# 12 Exhibit I# 13 Exhibit J# 14 Exhibit K# 15 Exhibit L# 16 Exhibit M# 17 Exhibit N# 18 Exhibit O# 19 Exhibit P# 20 Exhibit Q# 21 Exhibit R# 22 Exhibit S# 23 Exhibit T# 24 Exhibit U# 25 Exhibit V# 26 Exhibit W# 27 Exhibit X# 28 Exhibit Y# 29 Exhibit Z# 30 Exhibit AA# 31 Exhibit BB# 32 Exhibit CC# 33 Exhibit DD# 34 Exhibit EE# 35 Exhibit FF# 36 Exhibit GG# 37 Exhibit HH# 38 Exhibit II# 39 Exhibit JJ# 40 Exhibit KK# 41 Exhibit LL# 42 Exhibit MM# 43 Exhibit NN# 44 Exhibit OO# 45 Exhibit PP# 46 Exhibit QQ# 47 Exhibit RR# 48 Exhibit SS# 49 Exhibit TT# 50 Exhibit UU)(Faller, Susan)

iLOR, LLC v. Google, Inc.

Doc. 12 Att. 22

Case 5:07-cv-00109-JMH

Document 12

Filed 08/27/2007

Page 1 of 4
Page 1 of 4

Searchviews )) Print )) 5 Questions with PreFound.com CEO Steve Mansfield

- Searchviews - http://www.searchviews.com 5 Questions with PreFound.com CEO Steve Mansfield
Posted By Reprise Media On May 24,2006 (§1:33 pm In Interviews I No Comments

Today, Searchviews revives a long dormant feature - the 5 Questions interview. For the grand re-opening, we were pleased to have the chance to quiz Steve Mansfield, CEO of (1)

PreFound.com, a site that marries the functionality of traditional web search with "the human touch,l a social community that enhances the relevance of search results via tagging, rating
and sharing. From his perch in 'Silicon Holler' (Lexington, Kentucky), Steve talks about the evolution of social search, how to handle competition from the big guys, and the discreet
pleasures of the graphic noveL.

search engine results that are organized according to community behavior - a departure from the shared search results you launched the service with - and now

1. Recently, PreFound started offering links to an external page featuring 'traditional'

you're talking about integrating both types of results on the same page. Why is

and-butter when it launched?

PreFound de-emphasizing the shared results, which seemed to be the site's bread-

We're really not de-emphasizing our User Shared Search Results (USSR's) and I would say they are still our bread-and-butter. We believe that users know what machines don't, and that is the
best way to reduce (2) search chaff and give searchers the best results possible. But, we do want to extend the service we can offer to users by adding Traditional Search Results (TSR's), in order to present the searcher with relevant results regardless of what they are searching for. Of course, even with TSR's, we want to keep the search "social", so we partnered with Eurekster to provide "community-based" ordered search results, instead of the old page ranking

systems of the major search engines.
While USSR's work great for tons of searches, they are primarily "reference" related, meaning they are the most relevant for searches looking for applicability to a subject or person. TSR's can be less specific and non-reference in nature, making them good for searches that are looking for a single answer or something extremely obscure. We felt the best way to give our

users the best pOSSible service was to start with USSR's, and if that doesn't give them the
results they're looking for, then we'll offer them community-organized TSR's. It's an evolution of

our service.

favor of relevance particular to their locations that might not be of interest to people searching elsewhere. Does PreFound have a plan to combat this tendency toward local drift, and to promote better mainstream relevance in general?

capacity to 'scale' as well as other types of search - for instance, it looks like members of geographically specific communities have the clout to skew the results in

2. Critics question whether the kind of search championed by PreFound has the

l .J ~~

EXHIBIT

http://ww.searchviews.com/index.php/archives/2006/05/5-questions-wIt -pre oun com-c... /24/2007
Dockets.Justia.com

Case 5:07-cv-00109-JMH

Document 12

Filed 08/27/2007

Page 2 of 4
Page 2 of 4

Searchviews )) Print )) 5 Questions with PreFound.com CEO Steve Mansfield

This also applies to our TSR's. Since all our TSR SERP's are organized anonymously and directly by our PreFound.com community, it's Important to have enough users to actually affect the ordering of the results. So again, we are going to build scale to make all this a reality.

Finally, I should say that we are going to evolve even beyond that. PreFound.com will always offer USSR's and TSR's in combination, encompassing links to all types of media (video, audio,

graphics, text links, etc.) from a single search query, instead of from different search engines like all the big sites. But, more importantly, in the next few months you will see PreFound.com
offer tools that will organize these results by demographic, location, interests, participation in communities and sub-communities, etc. Users will be able to control how much or how little

these elements will "weigh" the results they see from a special control paneL. So, PreFound.com is moving fast to offer next-generation social search tools in order to attract the scale of users we need.

wil be. You recently co-hosted the Kentucky Derby Roundtable on social networks
and social search with blog powerhouse Six Apart in attendance. Is a deal with something like Livejournal in the offing, and even if nothing like that is imminent, how would such a partnership play out?

3. You've talked about partnering with established social networks, the assumption being that the stronger (and bigger) the community is, the better PreFounds results

We deeply appreciated Ben and Mena Trott's participation in the Roundtable. We learned a lot
about their vision, and we at PreFound.com believe that blog posts are the ultimate "social

search result". In the next few weeks I'm doing a whirlwind tour of San Francisco and Los Angeles talking to established social networks about extending their service into social search.
The interest is certainly there, and there are a lot of good reasons for it. For one, social networks, like all Internet business models, have to find new and better ways of monetizing

their usership. By extending into Search, these social networks can add an additional revenue
stream (sponsored search links) that is tried and true. Another motivation is giving their users a

search experience that is "of the people, by the people and for the people". As I discussed
earlier, a social search experience using a community of scale (for example, Live Journal has 10 million users), we can doubtless offer them search results with a relevance unheard of even a

few months ago.
How it will look will depend on many factors, but imagine being on your social network site and deciding you want to do a search. Instead of leaving the property and going to Google, you instead use the web search box offered by your social network/PreFound.com. Utilzing the technology I've discussed earlier, you would just enter your search query in the box provided and then be presented with search results (USSR's and TSR's) organized by your demographics, location, interests, participation in communities and sub-communities, etc., all controlled by you, to get hyper-relevant results, all organized anonymously and directly by you and the social

network you are using. It's a whole new paradigm in Search.
4. A couple weeks back, Google debuted a couple of services that must have looked

awfully familiar to PreFound, namely Co-op and Notebook. What do PreFound and its
PFfinder application bring to the table that these Google products overlook, and did

Google do anything that made you go 'hmm, that's not such a bad idea?'
We really looked at it as a (3) validation of what we've been saying since January. When Google
said, "Google Co-op is about sharing expertise. You can contribute your expertise and benefit when others do the same. Help other users find information more easily by creating 'subscribed links' for your services and labeling web pages around the topics you know best," it was like

PreFound.com wrote the script.

This is validation that Social Search is the Search of the future. Now that Google has entered
the space and people like Alan Eustace say out loud, "Machine algorithms aren't good at it", when referring to machine-based algorithms and "For the time being, the human judgment is

still much better,l we here at PreFound.com have gone from being viewed as a search outsiders

http://ww.searchviews.com/index. php/ archives/2006/05/ 5-questions-with -prefoundcom-c... 8/24/2007

Case 5:07-cv-00109-JMH

Document 12

Filed 08/27/2007

Page 3 of 4
Page 3 of 4

Searchviews )) Print )) 5 Questions with PreFound.com CEO Steve Mansfield

to looking like prophets. Virtually anything Google throws out into the marketplace is seen as

brilliant, so this is going to make our work at PreFound.com exponentially easier.
It should also be noted that Google Co-op is extremely immature technology. It requires XML skills that are beyond even relatively skilled programmers. So that is not going to be

competitive with PreFound.com anytime soon.
With Google Notebook, the (4) same types of things apply. Our PFfinder tool is five years more mature than Google Notebook and does a number of things that Google Notebook doesn't,

including browsing related tools, a "fly-out" menu with three iterations in addition to commands
in the right-mouse click menu, instant gathering of web page links in addition to the links on the

page itself, instant emailing of gathered links, the ability to save Groups of links to a users' personal computer and not on a web page, adding graphics to links that didn't have them or changing the graphic of links that do, etc. Additionally, PFfinder includes patent pending
technology that crawls the pages that you are saving and automatically tags them with consistent and usable tags (which users can edit). So, we feel strongly we have a mature,

competitive toolkit out there.
Finally, I should also say that I believe that competition is good, as long as you're prepared for

it. If no other companies are trying to do what you are trying to do, then there is probably a
reason. Competition gives you a way to contextualize your technology, so now we can say that

PreFound.com has a similar vision to something Google is doing. But we have to be prepared for competition. That's why PreFound.com didn't bring this iteration of our technology to the public
until we had two issued patents and a robust patent portfolio in our war chest. And we are extremely diligent in analyzing our competition related to patent law.

With all that said, some of things that Google and Yahoo are doing convinced us that we should
start integrating TSR's into our SERP's sooner rather than later. We are coming around to the

idea that offering both (like those guys) is a good idea.

s. PreFound is social, which by its nature is about people and their interests. Do you have anyone passion in particular for which you would say, "PreFound has the most

relevant result on this topic, hands down?"

That's kind of funny, because one of my hobbies that my kids always tell me not to discuss with anyone is my interest in comics and graphic novels. They feel like I should keep my nerdy-ness to myself. Doing a search for "graphic novels" on PreFound.com will give some really great user-shared results. This one is my favorite: (5) http://www.prefound.com/view.php?
cp id=274170

Sometimes, it just takes the human touch. And as we grow, it's just going to get better and

better.

Wow. We'd like to thank Steve for taking the time out to so thoroughly answer our 5

Questions. Interested in participating in a future 5 Questions at Searchviews? Please (6) drop us a line.

Article printed from Searchviews: http://www.searchviews.com

with-prefoundcom-ceo-steve-mansfield.php
URLs in this post:

URL to article: http://www.searchviews.com/index.php/archives/2006/0S/S-questions-

(1) PreFound.com,: http://www.Prefound.com

http://ww.searchviews.com/index. php/ archives/2006/05/ 5-questions- with-prefoundcom-c... 8/24/2007

Case 5:07-cv-00109-JMH

Document 12

Filed 08/27/2007

Page 4 of 4
Page 4 of 4

Searchviews )) Print )) 5 Questions with PreFound.com CEO Steve Mansfield

(2) search chaff: http://www.prefoundbIOg.com/2006/04/Lcall-em_search_chaff.html
http://www.prefoundblog.com/2006/0s/google_introduces_coop_prefoun.htm I
(3) validation of what we've been saying:
things apply.:

http://www.prefoundblog.com/2006/0s/google_notebook_vs_prefound_pf.htm I (5) http://www. prefound.com/view .php?cp_id=274170: http://www.prefound.com/view.php? cp_id=274170 (6) drop us a line.: mailto:blogcontactC§reprisemedia.com

(4) same types of

http://ww.searchviews.com/index. php/archives/2006/05/5-questions-with-prefoundcom-c... 8/24/2007