Polaris IP, LLC v. Google Inc. et al

Filing 392

SEALED MOTION for Summary Judgment of Invalidity by AOL, LLC., America Online, Inc., Google Inc., Yahoo!, Inc.. (Attachments: # 1 Affidavit of Todd Kennedy, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Affidavit of Bradley Allen, # 18 Exhibit A, part 1 of 2, # 19 Exhibit A, part 2 of 2, # 20 Exhibit B)(Perlson, David) Modified on 7/2/2010 (ch, ). (Additional attachment(s) added on 7/2/2010: # 21 Text of Proposed Order) (ch, ).

Polaris IP, LLC v. Google Inc. et al

Doc. 392 Att. 6

Piccolo, Rosanna
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q So prior to April, 1996, is it the case

that the EZ Reader received electronic messages from a source such as a customer? A Could you please tell me what -- what

paragraph it was again? Q Claim 26. A Q Please restate your question again. Sure. The -- prior to April, 1996, the Oh, sure. It's column 14, number 26,

EZ Reader was receiving electronic messages from a source such as a customer, right? A Q Correct. And is it your understanding that prior

to April of 1996, that the EZ Reader would be interpreting electronic messages using rule-base and case-base knowledge engines? A Q Yes. And is it your understanding that prior

to April, 1996, the EZ Reader would retrieve one or more predetermined responses corresponding to the interpretation of them by the rule-base and case-base knowledge engine for delivery back to the source, i.e., the customer? A Q Yes. And prior to April, 1996, when the EZ

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Reader was being deployed, did Chase always -- did Chase know in advance who the source of the e-mail might be, i.e., which particular customer might be querying the system at any particular time? MR. THOMPSON: THE WITNESS: Objection, form. Could you -- could you

rephrase that question? BY MR. PERLSON: Q Sure. So prior to April of 1996, when

a customer would send an e-mail that would be interpreted by the EZ Reader system, would the EZ Reader system know who that customer would be in advance of receiving the e-mail? A Q I don't believe so. One of the things that you had

mentioned before that the EZ Reader did was -- that sometimes the e-mail would be sent to a person to review and respond and then sometimes it would be responded to automatically; is that correct? A Q Correct. Okay. And was that true in the system

that was deployed prior to April, 1996? A Q Yes. Do you know whether there were any

other consultants other than Brightware that were

Bright Response v. Google, et al

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