PA Advisors, LLC v. Google Inc. et al

Filing 255

REPLY to #248 Claim Construction Brief filed by Google Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E (part 1), #6 Exhibit E (part 2), #7 Exhibit E (part 3), #8 Exhibit E (part 4), #9 Exhibit F, #10 Exhibit G, #11 Exhibit H, #12 Exhibit I, #13 Exhibit J, #14 Exhibit K, #15 Exhibit L)(Cannon, Brian)

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

TO THE HONORABLE COMMISSIONER OF PATENTS AND TRADEMARKS Washington, DC 20231 Dear Sir:

Transmitted herewith for filing is the Provisional Patent Application in the name of Ilya Geller entitled "Internet Search V e hic1e" Enclosed are: Specification, Abstract - 1 pp. 0 sheets of Informal Drawings Containing 0 Figures 3. Verified Statement Claiming Small Entity Status - 1 p. 4. Reply Postcard for Affixation of Application Number 5. Filing Fee in the Amount of $75.00
1. 2.

Correspondence Address: 314 Philadelphia A v e . Takorna Park, MD 20912

This is a vehicle that will reliably distill an ever-expanding pool of objects, words, and numbers from the Internet into a manageable format for each particular user. Instead of impersonal search engines I offer individual search vehicles. But inasmuch as there are some similarities between people and items on the Internet that are reflected in the frequency of occurrences of combinations of nouns-verbs-adjectives they can be grouped according to these similarities:

This particular invention is a `searchvehicle'that is automatically particularized for each particular user. In this way this `vehicle' will figure out each particular person's search profile and will provide a larger search base which accepts an unlimited number of search terms. Each person's profile may either be saved on that person's computer or if they move around a lot, they may choose to have their profile saved at the search engines site. The engine will accept searches in regular language rather then being limited to boolean as the standard search engines. Additionally the database will be open and constantly changing `open sets of constantly changing objects'. The information gathered by the engine will be analyzed and filed statistically. The actual data will not be saved.
The Philosophical basis for the Engine: If all languages reflect the dialectical nature of human beings then all languages contain the following components. abstract ideas will be denoted by nouns; ethical components will be denoted by verbs; Esthetical components will be denoted by adjectives; The frequency of occurrences of the different combinations of nouns-verbs-adjectives in any complete sentences in the reasonably big number of each person's texts will be unique for each individual. Consequently, the stock of unique Combinations of nouns-verbs-adjectives will reflect the intellectual, cultural and psychological peculiarities of each person. This information when used correctly will allow each search to be tailored for that person. The engine will function in the following manner. (Please note: `the unique' denotes each particular person's profile.)

1. First, the text content of each item of the Internet has to be matched with the search string that has been extracted from the search text;

2. Second, the stock of combinations of nouns-verbs-adjectives that reflects the intellectual, cultural and psychological peculiarities of each person should be matched. Next, for each item on the Internet the unique for the Internet stock of combinations of nouns-verbs-adjectives can be established as well and, accordingly, each item on the Internet should have its unique representation. If it has its unique representation this representation can be used on the standardized map of the Internet; where the standard is the frequency of occurrences of combinations of nouns-verbs-adjectives in complete sentences in a reasonably big text. The standardization of the Internet allows the utilization of it.

'.
3. Users will be grouped into open sets of virtual demographic 'families';
4. Items of the Internet will be grouped into virtual collections that are called 'countries', 'cities', etc. This method allows me to create general profiles with 'favorites' for all members of virtual 'families' and to address them directly to the most popular destinations on the Internet. These most popular destinations on the Internet are listed in profiles for each 'country', 'city', etc. Unfortunately, today individuals are limited in their ability to exchange the information about their favorites. In my case users will be able to exchange information and this will significantly decrease the time of search.

Detailed Description: In a particular search, it is understood that the user will input text which is meaningful to 1) them in normal English or later in any number of languages.
2) From this meaninghl text which is input, the user's psychological profile, e.g. type of behavior, life experience, level of education, etc. can then be derived. This unstable profile is open in nature and will reflect changes as feedback is received.
3) This collection of words should be fixed within the user's combinations of words and is composed into an onspher which should not be limited by definition. This view of the user's table may be stable but is constantly evolving as an open system.
4) The program will extract nouns, verbs, and adjectives and save words which were used according to alphabetic order and each vsam cluster will have internal indexes that will simplify

the work with them.
~

j

-.. . ..
r;2

,: I

;.*...
t1 3 ii 1

+a=.

2 2

5 ) The program will then note the frequency of occurrence of certain combinations of words.

.-

I

Users will be grouped into open sets of virtual demographic families and will reference a geographic map of virtual cities and countries which will contain information on similarities of the profile and input meaningful text. device.
7)

6)

This personal data will then be stored both on a user's hard drive and on your storage
The information on this map of the internet will be stored on your storage device.

There will be varying models of the search vehicle. They will depend upon the t m ie 8) required to complete the search. The price will depend on the quantity of chains of nouns-verbsadjectives to be used.
An over all formula for the patent would be where:

The entire series of changes of open sets is included in the below:

...
The loss of changes engender integration of open sets into closed sets. This integration is followed by disintegration of closed collections into open ones without any cause or any change.

This disintegration engenders the disintegration of closed sets (where closed sets are the limiting factor) (such sets include 'families', 'countries', 'cities', etc) into 'open sets of constantly changing items'.

Jkt4-14-99

8 9 ~ 4 5CIM

MRS.O.PRITSKER

AttQrney'8 Docket No. 1878gl297116

IN THE UNITED STATES PATENT AND TRADEHARX OFFXCE IN THE APPLICATION OF: I l y e GeLler

THE HONORABLE COMMISSIORER OF PATLhTS AN9 TRADEMARKS WASBINGTOA, DC 20231
Sir:

--"7----r:,i

1.c :

,: ' .

'>,,

*

Attached, as p a r t o f t h i s power o f a t t w n s y , for the a u t h o r i z a t i o n o f t h e above-named attorney($) t o a c c e p t and follow inalructivns from my representatLve(s),

--------------~-~--~~~~---~--~---~------~---------~---~the below naaced inventor, I hereby declare t h a t I quaLtT?
an independent inventor 0s defined in 37 CFR 1 . 9 f o r purposes of paying reduced fees under section 41 l a ) and (L) of TLtle 3 5 , United S t a t e s Code, to the Patent and ~ r e d a m e r kOffice M i t h reesrd t o t h e invention enSltled h l o w and in:
as
A6

-xL_-- . - the specification f i i e d herewith. P-save not a s s i g n e d , armbed, conveyed, or licensed and am under no o b l i g a t i o n under contract ar law to a s s i g n , grant, convey or l i c e n s e , any rights in the inventtan to any person who could not be classified as an independent inventor under 37 CFK 1 . 9 t t khat person had made the inventlbn, or t o any concern whlch would not qualify a8 i small business Concern uiadsr 37 CPR 1.Q ( d ) ~r B l nvnprofit argaaieation under 37 CfR 1.9 ( e ) . Each person, concern or ox&aaieatictn to which I have ess i g n e d , $ r a n t e d . conveyed, or llcensed 61 am under an obligalion under c e n t t a c t or l a w t o assign, rant, COhVey, or license any rights in the invention is listed below: no such person, concsrn or OtganfZatfOn --x---I acknowledge t h e duty t o f i l e , in Lhfi; application or patent, n o t i f i c a t i o n o f any change in s t a t u s resulting f.n lass o f entitlemeht t o emall entity s t a t u s p r i o r t o paying, or at t h e time o f . p a y i n g , t h e e a r l i e s t of t h e issue fee or any maintenance f e e due a f t e r the d a t e oh whioh s t a t u e &$ 8 small busine$$ e n t i t y is 00 b h g e r appropriate. (37 CFR 1.28 (b)). 1; hereby d e c l a r e t h a t a l l 8 t a t e m e a t e msde h e r e i n of my own knowledge are t r u e and t h a t alL statements made on infoxmation and b e l i e f are believed t o be true; and further that t h e s e s t a t e m e n t s itre made with t h o knowledge that willful Eaiso statements and the l i k e S Q medo bfe punishable by f i n e or Imprisonment, Or b o t h , under S e c t i o n l a a l of TitLe 18 of the United States Code, and t h a t such wil.I.ful EaLse statements may jeopardize the v a l i d i t y of the application, any patent t6suirig thereon, ox any p a t e n t to which this varlfied statement is d i r e c t s d .

Attorney's Dockot No, 1678d1297116
ACKNOHLEOMENT OF

REVtEM OF PAPERS

ABO

DUTY 09 CANDOR

I hereby rrtate tb8L I have reviewed and understend the cantents of the above-identified s p e c i f h a t i o n , including t h e claims, a6 amended by any amendment, referred t o above.
1 acknowlsdge t h e duty t o disclose information which is m a t e r i a l t o t h e examinotiou of t b f s application in accordasce with T i t l e 3 7 , Code of PederaL Regulations l.S6(a). I further acknowledge the duty to d i s t l o s e m i t e r i a l information aa d s f i n e d In T i t l e 37, Code of Federal Re$ulntlohb 1 , 5 6 ( a ) , wbjch occurred between the t i l i n e d a t e oL t h e P F ~ O ~ applfcetion and the national o f PCT i a t e r n e t i o n a ? filing d a t e o f this coatinuation-in-p8rt application.

I h e r e b y claim Loraim priority benefits under T i t l e 35, Uirited S t a t a s Code, S e c t i o n 119 of any foreign application(s) f o r patent or i h V m t O r ' S certificate listed below aad have also idenLified below any LorsiGn srplicatron for p a t e n t ar inventoz's c e r t i f i c a t e s hevlng a f i l i n g d a t e before t h a t of t h e application oh which priority Is claimed:

DECLARATION
I hereby d e c l a r e t h a t a l l sCatemont.6 made herein a f m y own knowledge are t r u e and t h a t a l l s t a t e m e n t s made on lnformation and b e l i e f are believed t o b e true; and further t h a t these s t a t e m e n t s were made with the knowledge that, w i l l f u l felss st.atef6~ntsand the l i k e s o made ere punishable by f i n e or imprisonment, ar b o t h , under Section 1001 of Title 28 of the United S t a t e s Code and t h a t tuch w i l l f u l alse s t a t e m e n t s may jeopardize the validity o f t h e application or any petent issued tbereon.
SIGNATURES

ACKNOWLEDGMENT OF a v t w OF PAPERS a r DUTY OP ma
cant,ent.s

CANDOR

claims, as amended by any amendment r e f e r r e d t o above.

I bareby s t a t e t k a t 1 have reviewed and undeX6Lend the of the above-identified specification, includihg t h e

I acknowledge the duty t o d i s c l o e e information which is m a t e r i a l t o t h e examinatiob of t h i s application in accordance with T i t l e 3 7 , Code of Federal X e g u l e t i o a s 1.56Ca). I further acknowledge the duty to d i s c l o s e material information 39 d a f i n e d In T i t l a 3 7 , Code of Federal Regulntlons 1 . 5 6 ( a ) , which occurred between the f i l i n e date of t h e pcior application end t h e n a t i o n a l or PCT i n t e r n a t i o n a l filing d a t e o f t h i s continuation-in-part,
application.

?&
3E ! a *.:: e;.

-2in

I hereby claim foreign priority b e n e f i t s under Title 35, United S t a t e s Code, S e c t i o n 119 of any foreign applicationts) f o r patent or inventor's certificate listed below and have also identified below any foreign appLication for patent or inventoK's c e r t i f i c a t e s having a f i l l n 8 date before t h a t of t h e applscstion 0 0 which priority 1s claimed:
DECLARATION
1 h e r e b y d e c l a r e t h u t a 1 1 statements made herein of my own knowledge are t r u e and t h a t a l l strtements made on information end b e l i e f are believed t o b e t r u e ; an3 further that t h e s e s t a t e m e n t s were made with t h e knowledge t h a t w i l l f u l f 0 l s e st.&tefAcntb and the l i k e 6 0 made ere punIshebfe by fine or faprfeonment, 6r b o t h , under Section 1001 of T i t l e I3 of t h e United S t a t e s Code and t h a t such w i l l f u l f a l s e s t a t e m e n t s may jeopardize the validity of the application or any patent issued tbsreon.

4':

2.

I. =

1.5 V?
i

r:2,
e:
:
i I.::l

__.

*=.
I :

---

STGNATURES

F'. 84

ADDED PAGE TO POHER OP hTTORNEY FOR AUTRORXZATION OF ATTORNEY(S] TO ACCEPT AND FOLLOW INSTRUCTlONS PROM REFRESENTATZVE
hereby authorizes the U.S. attorneyis) named herein to a c c e p t and follow lnatructions f r m A t Legal Services Lieberman Law o f f i c e s , P . O . .BOX 39118, IW, Washington, n.c. 20026

The undersi6ned

tb

this declaration and power of attorney

-

Inventor's

Name

i -

-I-

regarding t h i s application w i t h o u t direct communication between the U . S . attorneyts) and the undersigned, in the event of a change in t h e persorite) from whom inetructlans may be taken, the U.S. att.orney(s) w i l l b e 60 notified by the undersltped.

as to any a c t i o n s t o be taken in t h e Patent and

Trademark Office

f' I

T' 3
0!?

s : *