IP Innovation LLC et al v. Google, Inc.

Filing 1

COMPLAINT for Patent Infringement against Google, Inc. ( Filing fee $ 350 receipt number 1335423.), filed by IP Innovation LLC, Technology Licensing Corporation. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Civil Cover Sheet # 6)(Ward, Thomas)

EXHIBIT D

Claim Chart for US Patent 5675819 v Google CONFIDENTIAL ­ SETTLEMENT DOCUMENT Claim 1. A method, using a processor and memory, for generating a thesaurus of word vectors
thesaurus ­ A thesaurus is a data structure that defines semantic relatedness between words. It is typically used in information retrieval to expand search terms with other closely related words. Even if the thesaurus is not explicitly computed, the mapping performed by query expansion explicitly defined a thesaurus. (col. 1, ll. 51-56). word vector ­ The word vectors represent global lexical cooccurrence patterns and relationships between word neighbors. (Abstract).

Google Search Appliance uses a processor and memory for generating a thesaurus of word vectors. The Google Search Applicance further enables and induces its users to use and further develop such thesaurus features.

http://www.google.com/enterprise/gsa/features.html

Page 1 of 7

Claim Chart for US Patent 5675819 v Google CONFIDENTIAL ­ SETTLEMENT DOCUMENT

http://www.google.com/press/guides/gsa_overview.pdf

Page 2 of 7

Claim Chart for US Patent 5675819 v Google CONFIDENTIAL ­ SETTLEMENT DOCUMENT based on lexical co-occurrence of words within documents of a corpus of documents, the corpus stored in the memory, the method comprising: retrieving into the processor a retrieved word from the corpus;
lexical co-occurrence ­ Lexical co-occurrence is more informative both qualitatively and quantitatively. Two terms lexically cooccur if they appear in text within some distance of each other, i.e., a window of k words. Qualitatively, the fact that two words often occur close to each other is more likely to be significant than the fact that they occur in the same documents. Quantitatively, there are more co-occurrence events than occurrence-in-document events in a given document collection. For a word occurring n times in the document collection and for a definition of cooccurrence as occurring in a window of k words, there are nk co-occurrence events. However, there are only n occurrence-in-document events. If the goal is to capture information about specific words, lexical co-occurrence is the preferred basis for statistical thesaurus construction. (col. 4, ll. 2842). corpus of documents ­ ...in a corpus of computer science documents... (col. 1, ll. 39-40). ...in a corpus of legal documents... (col. 2, ll. 14).

Google Search Appliance as used on Procter & Gamble's website (www.pg.com) searches all documents and websites on Procter & Gambles webservers (corpus of documents). Here the search term was Crest toothpaste.

retrieved word ­ A query consisting of the terms "tank" and "water" retrieves only words relevant to the "receptacle" sense of the word "tank." (col. 13, ll. 6-9).

http://pg-googleit-01.isc.savvis.net/search?entqr=0&access=p&sort=date%3AD%3AL %3Ad1&output=xml_no_dtd&ie=UTF-8&btnG=Google+Search&client=pgqa_front end&q=crest+toothpaste&ud=1&site=ALL_PG_SITES&spell=1&oe=UTF8&proxystylesheet=pgqa_frontend&ip=67.167.8.250&start=60

Page 3 of 7

Claim Chart for US Patent 5675819 v Google CONFIDENTIAL ­ SETTLEMENT DOCUMENT recording a number of times a co-occurring word co-occurs in a same document within a predetermined range of the retrieved word; repeating the recording step for every co-occurring word located within the predetermined range for each occurrence of the retrieved word in the corpus;
predetermined range ­ ordinary meaning

Google ranks pages according to word matches.

http://www.google.com/press/guides/gsa_overview.pdf When the search term Crest toothpaste was typed into Procter & Gamble's search engine, the first result contained the term Crest toothpaste 6 times. The second result contained the term Crest toothpaste 5 times. http://pg-googleit-01.isc.savvis.net/search?q=crest+toothpaste&btnG=Google+Search &site=ALL_PG_SITES&entqr=0&output=xml_no_dtd&sort=date%3AD%3AL%3Ad1&ie= UTF-8&client=pgqa_frontend&ud=1&spell=1&oe=UTF-8&proxystylesheet=pgqa_frontend The search also produces documents with the words Crest and toothpaste within a few words of each other.

http://pg-googleit-01.isc.savvis.net/search?entqr=0&access=p&sort=date%3AD%3AL %3Ad1&output=xml_no_dtd&ie=UTF-8&btnG=Google+Search&client=pgqa_front end&q=crest+toothpaste&ud=1&site=ALL_PG_SITES&spell=1&oe=UTF8&proxystylesheet=pgqa_frontend&ip=67.167.8.250&start=60

Page 4 of 7

Claim Chart for US Patent 5675819 v Google CONFIDENTIAL ­ SETTLEMENT DOCUMENT generating a word vector for the word based on every recorded number; repeating the retrieving, recording, recording repeating and generating steps for each word in the corpus, and storing the generated word vectors in the memory as the thesaurus. The Google Search Appliance is capaable of searching repeatedly and continuously, with the resulting word vectors being stored in memory for use (among other things) in search engine reports and metrics analysis:

The Google Search Appliance further enables the customizing and control of all aspects of creating collections and managing crawls:

Page 5 of 7

Claim Chart for US Patent 5675819 v Google CONFIDENTIAL ­ SETTLEMENT DOCUMENT

Page 6 of 7

Claim Chart for US Patent 5675819 v Google CONFIDENTIAL ­ SETTLEMENT DOCUMENT http://www.google.com/press/guides/gsa_overview.pdf

Page 7 of 7