Software Rights Archive, LLC v. Google Inc. et al

Filing 213

RESPONSE to Motion re 198 Opposed MOTION Granting Defendants Leave to Amend and Supplement Invalidity Contentions filed by Software Rights Archive, LLC. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Affidavit, # 9 Text of Proposed Order)(Kaplan, Lee)

Software Rights Archive, LLC v. Google Inc. et al

Doc. 213 Att. 2

Exhibit 2

Dockets.Justia.com

INVALIDITY CLAIM CHART FOR US PATENT No. 5,832,494

BASED ON

DE BR, P. AN POST, R.D.J., "lNORMTIONRETRIEVAL IN THE WORLD-WIDE WEB: MAKIG CLIENT-BASED SEARCIDG FEASffLE." IN COMPUTER NETWORKS AN ISDN SYSTEMS VOL. 27, PP. 183-192 (1994) ("DEBRA, 1994")

1. A method of analyzing a database with indirect relationships, using links and nodes, comprising the
See, e.g., DeBra, 1994, at Abstract, pp. 183-84, 185

steps of:

Finding specific infoniiation in the World Wide Web (W or Web for short) is becoming increasingly difficult. (DeBra, 1994, Abstract)
The World-Wide Web ... is a fast growing wide-area hypermedia dataase. It contains

infoniiation on many related and unrelated topics.... However, a hyperteÀi document like the WW, distributed over hundreds or even thousands ofloosley coupled sites can only be searched by retrieving documents and scanning them for related information, and also
scanning them for extracting links pointig to other documents. ... (S)everal tyes of

solutions have been proposed and implemented: (1) specially designing metahyperdocuments ... (2) robot-based searchable indecies ... (3) client-based search tools, most notably our fish search (DeBra, 1994, p. 183-84)

2.2 The schools offish metaphor. The algorithm simulates a school fish, breeding and searching for food. .. Tn the físh-search each URL corrcsponds to a fish. Whcn a docwnent is retrieved the fish breeds a number of children, depending on whether the document is relevant (contrns food) and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stonger. If a document is not relevant the fish become weaker and fewer children are produced. Aftr following a number oflins in a direction without finding a relevant document the search stops....
the search .... Thc fish are simulatcd by means of a list of URLS. The average number of children produced each time is called width. The number of steps made (by a fish or its offspring) without finding a relevant docmuent is called depth. Each time a relevant document is found a selection of the embedded links are added to the front of ths list. (DeBra, 1994, i 85)
2.3 The implementation of

1

(lal Selecting a node for analysis;

See, e.g., DeBra 1994, at p. 185

2.2 The schools offish metaphor. The algorithm simulates a school fish, breeding and searching for food... In the fish-search each URL corresponds to a fish. When a document is retreved the fish breeds a number of children, depending on whether the document is relevant (contans food) and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. Aftr following a number oflinks in a direction without finding a relevant document the search stops....
the search .... The fish are simulated by means of a list of URLS. The average number of children produced each time is called width. The number of steps made (by a fish or its offspring) without finding a relevant document is called depth. Each time a relevant document is found a selection of the embedded links are added to the front of this list. (DeBra 1994, 185)
2.3 The implementation of Furter, disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination with the state of the time of

the reference and its the art at

the alleged invention, as evidenced by substatial other references identified

in Defendants' P. R. 3-3 statement and accompanying charts. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the state of the time of

(lb) Generaing candidate clusterlinks for the selected node, wherein the step of generating comprises an analysis of one or more indirect relationships in the

the reference and its

datase;

the art at the alleged invention, as evidenced by substatial other references identified in Defendants' P. R. 3-3 sttement and accompanying charts. Rather than repeat those disclosures here, they are incorporated by reference into this char.
the reference and its

(Ic) Deriving actal clustr links from the candidate

Disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination with the state of the tie of

cluster links;

the art at the alleged invention, as evidenced by substatial other references identified
in Defendants' P. R. 3-3 statement and accompanying chars. Rather than repeat those

2

disclosures here, they are incorporated by reference into this char.

(ld.l identifying one or more nodes for display; and
See, e.g., DeBra 1994, at p. 185

The result of a search is a: list of (relevant documents), with the "relevance score" of each document.

the actu cluster lins.
"

(le.l displaying the identity of one or more nodes using I See, e.g., DeBra 1994, at Fig. 1, p. 185

l.~~'r~i;

¡ ¡¡~æ.s..m s:,"-.,,~r,~l.,

;ä~Mr t;~~

I

r.1

f

i

¡~~~::ir::~~5'~~if=~::il

~~~~ ~ .. .1
j
¡;:¡¡.

..~:...;""..~:. ~.+.v:.."."":.....""""":"'¡"~,,............, .0;' ...... ~iI...:. .,...""..:-... .:.:~it...:.........,¡~ ..... f.

The result of a search is a list of (relevant documents), with the "relevance score" of each document.

3

2. The method of clai 1 wherein each link is given a
See, e.g., DeBra" 1994, at p. 185

lengt, the step of generating the candidate cluster

lins comprises the steps of:

2.2 The schools offish metaphor. The algorith simulates a school fish, breeding and searching for food '" Eah tie a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer
children are produced. Afer tòllowing a number OflUiks in a directon wi.thout finding a relevant document the search stops ....
2.3 The implementation of the search .... The fish are simulated by means of a list of URLS. TIie average number of children produced each time is caled width. The number of steps made (by a fish or its offspring) without fiding a relevant document is called

depth. Each time a relevant document is found a selection oftlie embedded links are
added to the front of

ths list. (DeBra 1994, 185)

(2aJ Choosing a number as the maximum number of link lengths that wil be examined; and
See, e.g., DeBra" 1994, at p. 185

2.2 The schools offish metaphor. The algoritInn simulates a school fish, breeding and searching for food ... Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. Aftr following a number oflinks in a direction without finding a relevant document the search stops .... the search .... The fish are simulated by means ofa list of URLS. The average number of children produced each time is called width. The number of steps made (by a fish or its offspring) without finding a relevant document is called depth. Each time a relevant document is found a selection of the embedded links are added to tiie front of this list. (DeBra, 1994, 185)
2.3 The implementation of

(2bl exaining only those lins which are less than the I See, e.g., DeBra 1994, at p. 185 ma'Ómum number of link lengts.
2.2 The schools of fish metaphor. The algorithm simulates a school fish, breeding and searching for food ... Each time a relevant document is found the fish and its children become stroniier. If a document is not relevat the fish become weaker and fewer

4

children are produced. Aftr following a number of links in a direction without finding a relevant document the search stops ....

the search .... The fish are simulated by means of a list of URS. The average number of children produced each time is caled width. The number of steps made (by a fish or its offspring) without finding a relevant document is called depth. Each time a relevant document is found a selection of the embedded links are added to the frnt of ths list. (DeBra 1994, 185)
2.3 TIie implementation of

3. The metod of claim 1 wherein the step of deriving actual cluster links comprises the step of:

See, e.g., DeBra 1994, atp. 185
2.2 The schools offish met.1.phor. The algorithm simulates a school fish, breeding and

selecting the top rated candidate clu&ter links, wherein

the top rated candidate cluster links are those which are searching for food... In the fish-search each URL corresponds to a fish. When a most closely lined to the node under analysis. document is retrieved the fish breeds a number of children, depending on whether the document is relevant (contans food) and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stonger. If a document is not relevant the fish become \veaker and fewer children are produced. Aftr following a number of lins in a direction without finding a relevant document the search stops ....
the search .... The fi.sh are simulated by means of a list of URLS. The average number of children produced each time is called width. The number of steps made (by a fish or its offspring) without fInding a relevant document is called depth. Each time a relevant document is found a selection of the embedded links are added to the front of ths list. (DeBra 1994, 185)
2.3 The implementation of Furter, disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination with the state of the time of

the reference and its

the art at the alleged invention, as evidenced by substantial other references identified

in Defendants' P. R. 3-3 statement and accompanying chars. Raher than repeat those

disclosures here, they are incorporated by reference into this chart.

5

5. The method of claim 1 wherein the step of generating the candidate cluster links comprises the step of:

See, e.g., DeBra, 1994,atp. 185
2.2 The schools offish metaphor. The algorithm simulates a school fish, breeding and searching for food... hi the fish-search each URL corresponds to a fish. When a
document is retreved the fish breeds a number of children, depending on whether thc

eliminating candidate cluster links, wherein the number of candidate cluster links is limitcd and the closest candidate cluster links are chosen over the remaining links.

document is relevant (contans food) and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. Aftr following a number oflinks in a direction without finding a relevant document the search stops ....
the search .... The fish are simulated by means of a list of URLS. The average number of children produced each time is called width. The number of steps made (by a fish or its offspring) without finding a relevant docuttent is called depth. Each time a relevant document is found a selection of the embedded links arc added to the front of this list. (DeBra, 1994, 185)
2.3 The implementation of Furter, disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination with the stte of the time of

the reference and its the art at

the alleged invention, as evidenced by substatial other references identified

in Defendants' P. R. 3-3 statement and accompanying charts. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with tlie state of the time of

7. The method of claim 1, wherein one or more nodes provide extrnal connections to objects externl to the database, the method furer comprising the steps of:

the reference and its the art at

the alleged invention, as evidenced by substatial other references identified in Defendants' P. R. 3-3 sttement and accompanying charts. Rather than repeat those disclosures here, they are incorporated by reference into this char.

(7aJ Activating the desired node; and

Disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination with the state of the time of

the reference and its the art at

the alleged invention, as evidenced by substatial other references identified
in Defendants' P. R. 3-3 statement and accompanving chars. Raer than repeat those

6

disclosures here, they are incorporated by reference into this char.

(7b) Accessing thc external object linked to the node.
Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the stte of the time of in Defendants' P. R. 3.3 statement and accompanying chars. Rather

the reference and its the art at

the alleged invention, as evidenced by substantial other references identified than repeat those

disclosurs here, they are incorporated by reference into this char.

the reference and its 8. The method of claim 7, wherein the external object Disclosed either expressly or inherently in the teachings of is an independent application which can be executed in incorporated disclosures taen as a whole, or in combination with the state of the ar at background, the method furter comprising the step of: the time of the alleged invention, as evidenced by substatial other references identified

in Defendants' P. R. 3-3 statement and accompanying chars. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

(8a) executing the independent application.

Disclosed either expressly or inherently in the teachings of

the reference and its

incorporated disclosures taen as a whole, or in combination with the state oftlie art at the time of the alleged invention, as evidenced by substantial other references identified
in Defendants' P. R. 3-3 statement and accompanying charts. Rather than repeat those disclosurs here, they are incorporated by reference into this chart.

9. The method of clai 8, wherein one or more nodes
tlie time of

Disclosed cithcr expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the state of

the reference and its
the ar at

provide links to more than one independent application which can be executed as an extension, the method

further comprising the stps of:

the alleged invention, as evidenced by substatial other references identified in Defendants' P. R 3-3 statement and accompanying chars. Rather than repeat those

disclosures here, they are incorporated by reference into this char.

iii dependent applications (9a) displaying a list of linked to the node, wherein the step of accessing

See, e.g., DeBra 1994, at Fig. 1, p. 185

accesses an independent application. .

7

¡ Íl~";'~~"

I~!I~ ~l '' f
I

!ç:~.:l CMi.fr¿")rd;;~:: (.'..~.:f
!?-s:L

.~l

The result of a search is a list of (relevant documents), witl tle "relevance score" of each document.
Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with tle stte of

the reference and its

10. The method of claim 8, wherein the connection provides the independent applicaton access to tle information stored within the database.

the ar at the time oftle alleged invention, as evidenced by substatial other references identified

in Defendants' P. R. 3-3 statement and accompanying chars. Rather than repeat tlose

disclosures here, tley are incorporated by reference into this char.
Disclosed either expressly or inherently in tle teachings ofthe reference and its
incorporated disclosures taen as a whole, or in combination with the stte ofthe ait at
the time of

11. The method of claim 7, wherein the external

connection is to anotlier computer, wherein

information is located tlat can be accessed, the step of

the alleged invention, as evidenced by substatial otler references identified

accessing furter comprising the step of:

in Defendants' ,Po R. 3-3 statement and accompanying charts. Rather than repeat those

disclosures here. tlev are Incomorated bv reference into this chart.

8

Disclosed either expressly or inherently in the teachings oftlie reference and its
incorporated disclosures taen as a whole, or in combination with the state of the time of

(1Ia) accessing the information located within the computer.

the ar at

the alleged invention, as evidenced by substantial other references identified in Defendants' P. R. 3-3 sttement and accompanying charts. Rather than repeat those disclosures here, they are incorporated by reference into this chart.

12. A method for determining the proximity of an object in a stored database to another object in the stored database using indircct relationships, lùiks, and a display, comprising:
See, e.g., DeBra 1994, at p. 185

2.2 The schools offish metaphor. The algorithm simulates a school fish, breeding and searching for food... In the fish-search each URL corresponds to a fish. When a document is retreved the fish brceds a numbcr of childrn, depending on whcther thc document is relevant (contains food) and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. After following a number of links in a direction without finding a relevant document the search stops ....
2.3 The implementation of the search .... .The fish are simulated by means of a list of URLS. The average number of children produced each time is called width. The number of stcps madc (by a fish or its offspring) ",'thout finding a relevant document is callcd

depth. Each time a relevant document is found a selection of the embedded links are
added to the front of

this list. (DeBra 1994, 185)

Further, disclosed either expressly or inherently in the teachigs of

incorporated disclosures taken as a whole, or in combination with the state of the time of

the reference and its the art at the alleged invention, as evidenced by substatial other references identified

in Defendants' P. R. 3-3 statement and accompanying charts. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

(I2a) Selecting an object to determine the proximity of I See, e.g., DeBra, 1994, at p. 185 other objects to the selected object;

9

2.2 The schools offish metaphor. The algoritl simulates a school fish, breeding and

searching for food .., In the fish-search each URL corresponds to a fish. When a document is retrieved the fish breeds a number of children, depending on whether the document is relevant (contans food) and also depending on the number oflinks (URs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become ,veaker and fewer children are produced. Aftr follo"ving a number of links in a direction without finding a relevant document the search stops ....
2.3 The implementation of

the search .... The fish are simulated by means of a list of

URLS. The averae number of children produced each time is called width. The number

of steps made (by a fish or its offspnng) without finding a relevant document is called depth. Each time a relevant document is found a selection of the embedded links are added to the front of ths list. (DeBra, 1994, 185)

Furter, disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the stte of the time of the alleged invention, as

the reference and its

the art at

evidenced by substatial other references identified in Defendants' P. R. 3-3 statement and accompanying charts. Rather than repeat those

disclosures here, they are incorporated by reference into this chart.
Disclosed either expressly or inherently in the teachings of incorporated disclosures takèn as a whole, or in combination with the stte of the time of

(12bJ generating a candidate clustr lin set for the

the reference and its
the ar at

selected object, wherein the generating step includes an analysis of one or more indirect relationships in the database;

the alleged invention, as evidenced by substatial other references identified in Defendants' P. R 3-3 staement and accompanying charts. Rather than repeat those

disclosures here, they are incorporated by reference into this char.

the reference and its (12c J Denvig an actual cluster link set for the selected Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with tlie state oftlie art at object using the generated candidate cluster link set; the time of the alleged invention, as evidenced by substantial other references identified and in Defendants' P. R. 3-3 sttement and accompanying charts. Rather than repeat those disclosures here, they are incorporated by reference into this chart.

10

Disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination with the stte of the time of

the objects in the (12dJ Displaying one or more of dataase, referred to in the actual clustr link set, on a display.
disclosures here, they are incorporated by reference into this char.

the reference and its the art at

the alleged invention, as evidenced by substantial other references identified in Defendats' P. R. 3-3 statement and accompanying chars. Rather than repeat those

13. The method of 12 wherein a set of direct lins exists for the database, and wherein the step of generating a candidate cluster link set comprises:
See, e.g., DeBra, 1994, at p. 185

2.2 The schools offish metaphor. The algorith simulates a school fish, breeding and
searching for food ... In the fish-search each UR corresponds to a fish. When a

recursively analyzing portions of

the set of direct links

for indirect links.

document is retrieved the fish breeds a number of children, depending on whether the document is relevant (contains food) and also depending on the number oflins (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. After following a number of links in a direction without finding a relevant document the search stops ....
2.3 The implementaion of the search .... The fish are simulated by means of a list of URS. The average number of children produced each time is called width. The number of stps made (by a fish or its offspring) \vithout fiding a relevant document is called depth. Each time a relevant document is found a selection of the embedded links are added to the front of ths list. (DeBra 1994, 185)

Furter, disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the state of the time of

the reference and its the art at

the alleged invention, as evidenced by substatial other references identified

in Defendants' P. R. 3-3 statement and accompanying chars. Rather than repeat those

disclosures here, they are incorporated by reference into this char.

14. A method for representing the relationship between I See, e.g., DeBra 1994, at p. 185 nodes using stored direct links, paths, and candidate cluster links, comprising tlie steps of:

orithm simulates a school fish, breeding and

11

searching for food ... In the fish-search each UR corresponds to a fish. \V'hen a

document is retrieved the fish breeds a number of children, depending on whether the document is relevant (contains food) and also depending on th.e number oflinks (URLs)
embedded in the dociuent. Each time a relevant document is found the fish and its

children become stronger. If a document is not relevant the fish become weaker and
fewer children are produced. Aftr follo\ving a number of links in a direction without finding a relevant document the search stops ....
2.3 The implementaion of

the search .... The fish ar simulated by means of a list of

URS. The averae number of children produced each tie is called width. The number

of stps made (by a fish or its offspring) without fiding a relevant document is called depth. Each time a relevant document is found a selection of the embedded links are added to the front of this list. (DeBra, 1994, 185)
Furter, disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the state of the time of

the reference and its

the art at the alleged invention, as evidenced by substatial other references identified

in Defendants' P. R. 3-3 sttement and accompanying chars. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

(14aJ initializing a set of candidate cluster links;
the time of

Disclosed either expressly or inherently in the teachings of

the reference and its

incorporated disclosures taken as a whole, or in combination with the state of the art at
the alleged invention, as evidenced by substantial other references identifìed

in Defendats' P. R. 3-3 statement and accompanying chars. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

( 1 4b J Selecting the destination node of a path as the

See, e.g., DeBra, 1994, at p. 185

selected node to analyze;
2.2 The schools of fish metaphor. The algorith simiùates a school fish, breeding and

searching for food... In the fish-search each UR corresponds to a fish. . When a document is retreved the fish breeds a number of children, depending on whether the document is relevant (contains food) and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant document is found the fish and its

12

children become stronger. If a document is not relevant the fish become \',¡eaker and fewer children are produced. Aftr following a number of links in a direction without finding a relevant document the search stops ....
2.3 The implementation of the search.... The fish ar simulated by means of a list of URLS. The averae number of children produced each time is called width. The number

of steps made (by a fish or its offspring) without finding a relevant document is called depth. Eah time a relevant document is found a selection of the embedded links are added to the front of ths list. (DeBra, 1994, 185)

Furter, disclosed either expressly or inherently in the teachings of

the reference and its

incorporated disclosures taen as a whole, or in combination with the state ofthe art at the time of the alleged invention, as evidenced by substatial other references identified
in Defendants' P. R. 3-3 statement and accompanying charts. Rather than repeat those

disclosures here, they are incorporated by reference into this chart.

(14cJ retrieving the set of direct links from the selected I See, e.g., DeBra 1994, at p. 185

node to any other node in the datase;

2.2 The schools offish metaphor. The algorithm simulates a school fish, breeding and searching for food... In the fish-search each UR corresponds to a fish. When a document is retrieved the fish breeds a number of childrn, depending on whether the
document is relevant (contains food) and also depending on the number of

links (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and

fewer children are produced. Aftr followig a number of links in a direction without finding a relevant document the search stops....
2.3 The implementation of

the search .... The fish are simulated by means of a list of URLS. The average number of children produced each time is called width. The number of steps made (by a fish or its offspring) without finding a relevant document is called
depth. Each time a relevant document is found a selection of added to the front of

the embedded link ar

this list. (DeBra, i 994, 185)
Disclosed either expressly or inherently in the teachings of

the reference and its

13

retrieved direct links;
incorporated disclosures taken as a whole, or in combination with the stte of the time of

the art at the alleged invention, as evidenced by substantial other references identified in Defendats' P. R. 3-3 staement and accompanying chars. Rather than repeat those disclosures here, they are incorporated by reference into this chart.

(1 4e) repeating steps b through d for each path; and

See, e.g., DeBra 1994, at p. 185

2.2 The schools of fish metaphor. The algorith simulates a school fish, breeding and searching for food... In the fish-search each UR corresponds to a fish. When a document is retreved the fish breeds a number of children, depending on whether the
document is relevant (contains food) and also depending on the number of

links (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. Aftr following a number of links in a direction without finding a relevant document the search stops ....

2.3 The implementaon of

the search .... The fish are simulated by means ofa list of URS. The average number of children produced each time is called width. The number of steps made (by a fish or its offsprig) without finding a relevant document is called
depth. Each time a relevant document is found a selection of the embedded links are

added to the front of this list. (DeBra, 1994, 185)

Further, disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the state of the time of

the reference and its
the ar at

the alleged invention, as evidenced by subst:lItial other references identified

in Defendants' P. R. 3-3 statement and accompanying charts. Rather th repeat those
disclosures here, they are incorporated by reference into this char.

(14f) Storing the determined weights as candidate

See, e.g., DeBra 1994, at p. 185

cluster lis.

2.2 The schools offish metaphor. The algorithm simulates a school fish, breeding and
searching for food. .. . Tn the fish-search each URL corresponds to a fish. When a

14

document is retreved the fish breeds a number of children, depending on whether the document is relevant (contains food) and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. After following a number oflinks in a direction without finding a relevant document the search stops ....
2.3 The implementaion of

the search.... The fish are simulated by means ofa list of URS. The average number of children produced each time is called width. The nuniber of steps made (by a fish or its offsprig) without finding a relevant document is called depth. Each time a relevant docuent is found a selection of the embedded links are added to the front of this list. .... The result of a search is a list of (relevant) documents, with the "relevance score" of each document. (DeBra, 1994, 185)
Disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination with the stte of the time of

15. The method of claim 14 furer comprising the step

of deriving the actal cluster lins wherein the actual

the reference and its the art at

cluster links arc a subsct of

the candidate cluster links.

the alleged invention, as evidenced by substatial other references identified

in Defendants' P. R. 3-3 statement and accompanying charts. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

16. The method of claim 15 wherein the step of

Disclosed either expressly or inherently in the teachings of

deriving comprises the step of choosing the top raed

candidate cluster lins.

the reference and its incorporated disclosures taen as a whole, or in combination with the state ofthe art at the alleged invention, as evidénced by substatial other references identified the time of in Defendants' P. R. 3-3 sttement and accompanying charts. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

18. A method of analyzing a database having objects and a first numerical representation of direct relationships in the database, comprising the steps of:

See, e.g., DeBra 1994, at Abstract, pp. 183,184, 185
Finding specific information in the World Wide Web (W or Web for short) is becoming increasingly difficult. (DeBra, 1994, Abstrat) The World-Wide Web... is a fas growig wide-area hypennedia datase. It contains
infonnation on manv related and unrelatcd tooics.... However. a hvoert:x1: document like

15

the WWW, distributed over hundreds or even thousands of loosley coupled sites can only be searched by retrieving documents and scanning them for related information, and also
scanning them for extracting links pointig to other documents. _.. (SJeveral tyes of

solutions have been proposed and implemented: (1) specially designing metahyperdocuments ... (2) robot-based searchable indecies ... (3) client-based search tools, most notably our fish search (DeBra, 1994, p. 183-184)

Documents are retrieved (over the Internet) and scaned for relevant information at the receiving (client end). (3) The retreved documents are scaned to find links to (URLs of) otherWW-documents. (DeBra, 1994, p. 184) When a document is retrieved the fish breeds a number of children, depending on whether the document is relevant (contais food), and also depending on the number oflinks
(URLs) embedded in the document. Each time a relevant document is found the fish and

its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. After following a numer of lins in a direciton without finding a relevant document the search stops invetsigating that direction (the fish die) . The fish are simulated by mean of a list of URs. The averae number of children produced each tie is called width. lHe number of steps that can be made (by a fish or its offspring) wihtout finding a relevant document is called depth. (DeBra, 1994, p. 185)
See, e.g., DeBra 1994, at p. 185

(l8a) generating a second numerical representation using the first numerical representation, wherein the second numerical representation accounts for indirect relationships in the database;

2.2 The schools offish metaphor. The algorithm simulates a school fish, breeding and searching for food... In the fish-search each URL corresponds to a fish. When a document is retrieved the fish breeds a number of children, depending on whether the document is relevant (contans food) and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. Aftr following a number of links in a direction without finding a relevant document the search stops.... 2.3 The implementation of the search .... The fish are simulated by means of a list of URS. The average number of children produced each time is called width. The number of steos made (bv a fish or its offsoring) without finding a relevant document is called

16

depth. Each time a relevant document is found a selection of

added to the front of this list. (DcBra i 994, 185)
Furter, disclosed either expressly or inherently in the teachings of

the embedded links are

the reference and its the art at the time of the alleged invention, as evidenced by substatial other references identified in Defendants' P. R. 3-3 sttement and accompanying charts. Rather than repeat those disclosurcs here, they are incorporated by reference into this chart.
incorporated disclosures taen as a whole, or in combination with the state of

(18b J storing the second numerical representation;

See, e.g., DeBra 1994,atp.185
2.2 The schools of fish metaphor. The algorithm simulates a school fish, breeding and searching for food '" In the fish-search each URL corresponds to a fish. When a document is retreved the fish breeds a number of children, depending on whether the document is relevant (contans food) and also depending on the number oflinks (URLs)
embedded in the document. Each tie a relevant document is found the fish and its

childrcn becomc strongcr. If a documcnt is not relevant thc fish become wcaker and fewcr children are produccd. Aftr following a number of lins in a direction without finding a relevant document the search stops ....
2.3 The implementation of

the search .... The fish are simulatd by means of a list of

URLS. The average niuher of children produced each time is called width. The number
depth. Each time a relevant docuent is found a selection of

of steps made (by a fish or its offspring) witliout finding a relevant document is called the embedded links are addcd to the front of this list. (DcBra, 1994, 185)

Furter, disclosed cither expressly or inherenty in the teachigs ofthc reference and its
incorporated disclosures taken as a whole, or in combination with the stte of the time of

the ar at

the alleged invention, as evidenced by substantial other references identified
in Defendants' P. R. 3-3 statement and accompanying chars. Raher than repeat those
disclosures here, they are incorporated by reference into this char.

17

Disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination with the stte of the time of

(18c) identifying at leas one object in the database, wherein the stored numerical representation is used to identify objects; and
disclosures here, they are incorporated by reference into this char.

the reference and its the art at

the alleged invention, as evidenced by substantial other references identified in Defendats' P. R. 3-3 statement and accompanying charts. Rather than repeat those

(18d) displaying one or more identified objects from the database.
Disclosed either expressly or inherently in the teachings of

the reference and its

incorporated disclosures taen as a whole, or in combination with the state oftlie art at the time of the alleged invention, as evidenced by substantial other references identified in Defendants' P. R. 3-3 sttement and accompanying charts. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

19. The method of claim 18 wherein the step of generating a second numerical representation comprises:
See, e.g., DeBra, 1994, at p. 185

selecting an object in the databas for analysis;

2.2 The schools offish metaphor. The algorithm simulates a school fish, breeding and searching for food... hi the fish-search each URL corresponds to a fish. When a document is retreved the fish breeds a number of children, depending on whether the document is relevant (contans food) and also depending on the number oflinks (URLs)
embedded in the document. Each tie a relevant document is found the fish and its

children become stronger. If a docmnent is not relevant the fish become weaker and fewer children are produced. Aftr following a number oflinks in a direction without .finding a relevant document the search stops ....
2.3 The implementation of

the search .... The fish are simulated by means of a list of URLS. The average number of children produced each time is called width. The number of steps made (by a fish or its offspring) without finding a relevant document is called depth. Each time a relevant document is found a selection of the embedded links are added to the front of this list. (DeBra, 1994, 185)
Furter, disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination with the stte of the time of

the reference and its the art at

the alleged invention, as evidenced by substantial other references identified
in Defendants' P. R. 3-3 statement and accomoanving chars. Raer than reoeal those

18

disclosures here, they are incorporated by reference into this char.

(19aJ analyzing the direct relationships expressed by the first numerical representation for indirect relationships involving the selected object; and

See, e.g., DeBra, 1994, at p. 185

creating a second numerical representation of

and indirect relationships involving the selected object. searching for food. .. In the fish-search each URL corresponds to a fish. When a document is retreved the fish breeds a number of children, depending on whether the document is relevant (contans food) and also depending on the number oflinks (URLs) embedded in the document. Eacli time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become \veaker and fewer children are produced. Aftr following a number of links in a direction without finding a relevant document the search stops ....
2.3 The implementation of

the direct 2.2 The schools offish metaphor. The algorith simulates a school fish, breeding and

the search .... The fish ar simulated by means ofa list of

URLS. The averae number of children produced each time is called width. The number

of steps made (by a fish or its offspring) without fiding a relevant document is called depth. Each time a relevant document is found a selection of the embedded links are added to the front of ths list. (DeBra 1994, 185)
Furter, disclosed either expressly or inherently in the teachings of

the reference and its

incorporated disclosures taen as a whole, or in combination with the state ofthe art at the time of the alleged invention, as evidenced by substantial other references identified in Defendants' P. R. 3-3 sttement and accompanying chars. Rather than repeat those disclosures here, they are incorporated by reference into this chart.
Disclosed either expressly or inherenty in the teachings of incorporated disclosures taen as a whole, or in combination with the state of the time of

the reference and its
the ar at

20. TIie method of 18 ""herein the step of identifyng at least one object in the database comprises:

searching for objects in a datbase using the stored

the alleged invention, as evidenced by substatial other references identified
in Defendants' P. R. 3-3 statement and accompanying charts. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

numerical representation, wherein direct and/or indirect relationships are searched.

21. The method of claim 18 wherein the displaying

Disclosed either expressly or inherently in the teachings of incomorated disclosures taen as a whole, or in combination with the stte of

the reference and its
the ar at

19

step compnses:
the time of in Defendants' P. R. 3-3 sttement and accompanying charts. Rather

generating a graphical display for representing an

object in the datbase.
See, e.g., DeBra 1994, at Abstract, pp. 183-84

the alleged invention, as evidenced by substatial other references identified than repeat those disclosures here, they are incorporated by reference into this chart.

23. A method ofrepreseiiting data in a computer

datase with relationships, comprising the steps of:
Finding specific information in the World Wide Web (WWW or

Web for short) is

becoming increasingly difcult. (DeBra 1994, Abstract)

TIie World-Wide Web ... is a fas growing ,vide-area hypermedia datase. It contains information on many related and unrelated topics.... HO\vever, a hyperteÀi document like the WW, distributed over hundreds or even thousands of loosley coupled sites can only be searched by retneving documents and scanning them for related information, and also

scaning them for extacting links pointig to other documents. ... (S)everal tyes of
solutions have been proposed and implemented: (1) specially designing metahyperdocuments ... (2) robot-based searchable iiidecies ... (3) client-based search tools, most notably our fish search (DeBra, 1994, pp. 183-84)
See, e.g., DeBra, 1994, at p. 185

(23a) assigning nodes node identifications;

2.2 The schools offish metaphor. The algonthm simulates a school fish, breeding and searching for food. .. Tn the fish-search each URL corresponds to a fish. When a document is retrieved the fish breeds a niunber of children, depending on whether the document is relevant (contans food) and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stonger. Ifa document is'not relevant the fish become weaker and fewer children are produced. Aftr following a number oflins in a direction without finding a relevant document the search stops ....
the search .... The fish are simulated by means of a list of URLS. The average number of children produced each time is called width. The number of steps made (by a fish or its offspnng) without finding a relevant dociunent is called depth. Each time a relevant document is found a selection of the embedded links are
2.3 The implementation of added to the front of

ths list. ... When addiri URL's to the list, the algorithm checks

20

whether the URL already ocurs in the list. ... The esult of a search is a list of (relevant)
documents... DeBra, 1994, 185)

(23b J generatig links, wherein each lin represents a relationship between two nodes and is identified by the
See, e.g., DeBra 1994, at

Abstrct, pp. 183-84

two nodes in which the relationslp exists;
Finding specific infonnation in the World Wide Web ry¡WW or

Web for short) is

becoming increasingly diffcult. (DeBra, 1994, Abstract)
The World-Wide Web ... is a fas growing \'\'Íde-area hypermedia datbase. It contains

information on many related and unrelated topics.... However, a hyperte"-i document like the WWW, distributed over hundreds or even thousands ofloosley coupled sites can only be searched by retrieving documents and scanning them for related information, and also

scaiing them for extracng links pointig to other documents. ... (SJeveral tyes of
solutions have been proposed and implemented: (1) specially designing met:1.-

hyperdocuments ... (2) robot-based searchable indecies ... (3) client-based search tools, most notably our fish search (DeBra, 1994, pp. 183-84)

Further, disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the state of the time of

the reference and its
the ar at

the alleged invention, as evidenced by substatial other references identified

in Defendants' P. R. 3-3 statement and acompanying charts. Rather than repeat those

disclosures here, they are incorporated by reference into this char.
See, e.g., DeBra, 1994, at p. 185

(23cJ allocating a weight to each link, wherein the
the relationship

weight signies the strngt of

represented by the link relative to the strngt of other

relationships represented by other link; and

2.2 The schools offish metaphor. The algorith simulates a school fish, breeding and searching for food .., Tn the fish-search each URL corresponds to a fish. When a document is retrieved the fish breeds a number of children, depending on whether the
document is relevant (contans food) and also depending on the number of links (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are oroduced. Aftr following a number of links in a direction without

21

finding a relevant document the search stops ....
2.3 The implementaon of the search .... The fish ar simulated by means of a list of .URLS. The average number of children produced each time is called width. Thc numbcr of steps made (by a fish or its offspring) without findùig a relevant document is called depth. Each time a relevant document is found a selection of the cmbedded links are added to the front of this list. ....

The result of a search is a list of (relevant) documents, with the "relevance score" of each document. (DeBra, 1994, 185)
See, e.g., DeBra 1994, at Fig. 1, p. 185

(23dJ displaying a node identification.

! .,. ..... .. ,-¡: .--..--~~----_.l

r ~~:' r,." ¡.'!. . ~ '. ~
, ..Ah_."'.......M'__"'. ~-'~~---~"". ~

. "x.""...~. .. ',"i;~;m;i.im ...:4'*'1_",.. ¡ _~...."" i
L f,~~~ ;'Mr.f:'" f""il.'!~."" t ¡

t~-i~~C~~1 ~I
¡:

f
l'

~~~ ~ L~.f
~~L~~~!~~~~~~~I=t~~.='!~;;
¡¡jol.

The result of a search is a list of (relevant documents), with the "relevance score" of each document.

22

See, e.g., DeBra 1994, at p. 185

24. The method of claim 23, wherein the data in the database is objects, wherein the nodes represent objects and each object is assigned a node identification, and wherein the relationships that exist
searching for food '" In the fish-search each UR corresponds to a fish. When a

2.2 The schools of fish metaphor. The algorith simulates a school fish, breeding and

comprise direct relationships between objects, furter

comprising the step of:

searching generated lins, wherein nodes are located

by searching the generated links.

document is retreved the fish breeds a number of children, depending on whether the document is relevant (contains food) and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant docwnent is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. Aftr following a number of links in a direction without finding a relevant document the search stops ....
2.3 The implementation of

the search .... The fish ar simulated by means of a list of

URLS. The averae number of children produced each time is called width. The number

of steps made (by a fish or its offspring) without finding a relevant document is called depth. Each time a relevant document is fowid a selection of the embedded links are
added to the front of this list. .,. When adding URL's to the list, the algorith checks

whether the URL already ocurs in the list. ... The esult of a search is a list of (relevant)
documents... DeBra, 1994, 185)
Furter, disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with tlie stte of the time of

the reference and its

the art at the alleged invention, as evidenced by substantial other references identified

in Defendants' P. R. 3-3 sttement and accompanying charts. Ratherth repeat those

disclosures here, they are incorporated by reference into this chart.
Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or iii the time of

the reference and its
combination with the state of

25. The method of claim 23 furter comprising the step of: generating link sub-tyes, comprising the steps of:

the ar at

the alleged invention, as evidenced by substatial other references identified in Defendants' P. R. 3-3 statement and acompanying charts. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

(25a) identifying each link sub-type with a nan1e; and

Disclosed either expressly or inherently in the teachings of incomorated disclosures taken as a whole, or in combination with the state of

the reference and its

the ait at

23

the time of the alleged invention, as evidenced by substatial other references identified
in Defendants' P. R. 3-3 statement and accompanying chars. Rather than repeat those

disclosures here, they are incorporated by reference into this chart.
Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the state of the time of

subtyes.
disclosures here, they are incorporated by reference into this char.

(25b) Providing a comment to one or more link

the reference and its
the ar at

the alleged invention, as evidenced by substatial other references identified

in Defendants' P. R. 3-3 statement and accompanying chars. Rather than repeat those

Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the stte of the time of

31. The metliod of claim 23 wherein attributes are assigned to nodes.

the reference and its the art at

the alleged invention, as evidenced by substatial other references identified in Defendants' P. R. 3-3 sttement and accompanying charts. Rather than repeat those disclosures here, they are incorporated by reference into this chart.

32. The method of claim 3 i furter comprising the step Disclosed either expressly or inherently in the teachings of the reference and its incorporated disclosures taken as a whole, or in combination with the state of of: generating node sub-types wherein the node subthe ar at the time of the alleged invention, as evidenced by substatial other references identified types are assigned information.
in Defendants' P. R. 3-3 statement and accompanying charts. Rather than repeat those
disclosures here, they are incorporated by reference into this char.

33. A method of representing dat in a computer
the data,

See, e.g., DeBra, 1994, at Abstract, pp. 183-84

datase and for computerized searching of

wherein relationships exist in the database, comprising:

Finding specific information in the World Wide Web (WWW or Web for short) is becoming increasingly diffcult. (DeBra, 1994, Abstract) The World.Wide Web... is a fast growing wide-area hyperniedia database. It contains infoimatIon on many related and unelated topics.... However, a hypertext document like the WW, distrbuted over hundreds or even thousands of loosley coupled sites can only be searched by retrieving documents and scanning them for related infonnatioii, and also scaning them for extacting links pointig to other documents. ... (S)everal types of solutions have been orooosed and imolemented: (1) soeciallv designing meta-

24

hyperdocuments ... (2) robot~based searchable indecies ... (3) client-based search tools, most notably our fish search (DeBra, 1994, p. 183-84)
See, e.g., DeBra 1994, at pp. 184, 185

dataase;

(33a) assigning links to represent relationships in the

Documents are retrieved (over the Internet) and scaned for relevant information at the receiving (client end). (3) The retrieved documents are scaned to find links to (URLs of) otherWW-documents. (DeBra, 1994, p. 184)
When a document is retrieved the fish breeds a number of children, depending on whether the document is relevant (contains food), and also depending on the number oflinks (URLs) embedded in the document. Eah time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. After following a numer of lins in a direciton without finding a relevant document the search stops invetsigating that direction (the fish die) .

The fish are simulated by means of a list of URLs. The averae number of children produced each tie is called width. me number of steps that can be made (by a fish or its offspring) witout finding a relevant document is called depth. (DeBra, 1994, p. 185)
See, e.g., DeBra, 1994, at pp. 184, 185

(33b) generatig node identifications based upon the assigned links, wherein node identifications are generated so that each link represents a relationship between two identified nodes;

Documents are retrieved (over the Internet) and scanned for relevant information at the receiving (client end). (3) The retreved documents are scaned to find links to (URLs of)

otherWW-documents. (DeBra, 1994, p. 184)
When a document is retrieved the fish breeds a number of children, depending on whether the document is relevant (contains food), and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant document is found the fish and its c1u1dren become stonger. If a document is not relevant the fish become weaker and fewer children are produced. Afer followmg a numer of links in a direciton without finding a relevant document the search stops invetsigating tht direction (the fish die) . The fish are simulated by means of a list of URLs. The average number of children roduced each time is called width. me number of steos that can be made (bv a fish or

25

its offspring) wihtout finding a relevant document is called depth. (DeBra, 1994, p. 185)
See. e.g., DeBra, 1994, at pp. 184, 185

(33c) storig the links and node identifications,

wherein the links and nodes may be retreved;

Documents are retrieved (over the Internet) and scaned for relevant information at the receiving (client end). (3) TIie retreved documents are scanned to find links to (URLs of) other WW-documents. (DeBra, 1994, p. 184)
When a document is retrieved the fish breeds a number of children, depending on whether
the document is relevant (contas food), and also depending on the number of links

(URLs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. Aftr following a numer of lins in a direciton without finding a relevant document the search stops invetsigating that direction (the fish die) . The fish are simulated by means of a list of URLs. The average number of children produced each time is called width. THe number of steps that can be made (by a fish or its offspring) wihtout fmding a relevant document is called depth. (DeBra, 1994, p. 185)

26

(33d) searching for

node identifications using the

See, e.g., DeBra 1994, atp. 185
2.2

stored links; and

The schools offish metaphor. The algorith simulates a school fish, breeding and searching for food '" In the fish-search each URL corresponds to a fish. When a

document is retreved the fish brceds a numbcr of children, depending on whcther the

document is relevant (contans food) and also depending on the number oflinks (URLs) embedded in the document. Each time a relevant document is found the fish and its children become stronger. If a document is not relevant the fish become weaker and fewer children are produced. Aftr following a number of links in a direction without finding a relevant document the search stops ....
2.3 The implementation of

the search .... The fish are simulated by means of a list of

URLS. The averae number of children produced each time is called width. The number

of stcps madc (by a fish or its offpring) without finding a relevant document is callcd
depth. Each time a relevant document is found a selection of the embedded links are
added to the front of

this list. (DeBra 1994, 185)
-.

Further, disclosed either expressly or inherently in the teachings of the reference and its
incorporated disclosures taken as a whole, or in combination with the stte of the tie of in Defendants' P. R. 3-3

the ar at

the alleged invention, as evidenced by substatial other references identified
statement and accompanying charts. Raer tha repeat those

disclosures here, they are incorporated by reference into this char.

(33e) displaying node identifications, wherein the displayed node identifications are located in the

See, e.g., DeBra 1994, at Fig. 1, p. 185

searching stp.

27

1~!ää ~~
f
ï

¡~l
r

l

¡r':~;;.~¡ r~1!T.t"'ir'ii~~l
P..L

The result of a search is a li.st of (relevant documents), with the "relevance score" of each document.

Defendants reserve the right to revise this contention chart concerning the invalidity of the assertd claiins, any findings as to the priority date of

the assertd claims, as appropriate, for example depending

upon the Court's constction of

the asserted claims, and/or positions that Plaintiff or its expert witness(es) may tae concerning claim interpretation, constction, infingement, and/or invalidity issues.

Plaintiffs Infringement Contentions are based 011 an 'apparnt construction of the claim terms. Defendants disagree with these apparent

constructions. Nothing stated herein shall be treated as an admission or suggestion that Defendants agree with Plaintiff

of any of

regarding either the scope the asserted claims or the claim constctions advanced by Plaintiff in its Inngement Contentions or anywhere else, or that any of
the clai ternis herein IDider 35 U.S.c. §

Defendants' accused technology meets any limitations of the claims. Nothing stted herein shall be consted as an admission or a waiver of any
any claim tenn. Defendants also reserve all their rights to challenge any of

parcular constrction of

112, including by aruing that they are indefinite, not supportd by the written description and/or not enabled. Accordingly, nothing stted herein

shall be construed as a waiver of any arguent available imder 35 U.S.C. § 112.

28