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. 3

Exhibit 3

Dockets.Justia.com

INALIDITY CLAl CHAT FOR U.S. PATENT No. 5,832,494 BASED ON "COMPARNG Two ALGORITHMS FOR

DOCUMENT RETRIEVAL

USING CITATION LINKS," JULIE BICHELER AND EDWAR EATON (1977) ("BICHTELER & EATON, 1977)

1. A method of analyzing a database with indirect Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic pattrn relationships, using links and nodes, comprising the discovery algorith' which finds clusters of related documents in a collection, stps of: where thc operational definition of 'rclatcd' is that the documcnts in a cluster must exhibit similar citation patterns. Thus, it makes use of thc notion of bibliographic coupling, first defined by Kessler (2): two documents have one unit of coupling between them if they each cite a third document.").
See also Background.
Bichteler & Eaton, e.g., at 192 ('The algorith itself operaes only on a lin table

Selecting a node for analysis;

which indicatcs for each document whether or not it posscsses each of a set of attributes. The attributes may represent citations. . . .").
See also Background and Methodology.

Generating candidate cluster lins for the selected

node, wherein the stp of generating comprises an.

Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic pattern discovery algorith' which fids clusters of related documents in a collection,
where the operational defiition of 'relatd' is that the documents in a cluster must

analysis of one or more indirect relationships in the database;

exhibit similar citation pattrns. Thus, it makes use of the notion of bibliographic coupling, first defincd by Kessler (2): two documents have one unit of coupling between them if they each cite a third document. . . . The algorith itself operates only on a lin table which indicates for each document whether or not it possesses each of a set of atributes. The attrbutes may represent citations. . . . The actual attributes are provided by one or more documents, which can be understood to be an initial seed point or points for the cluster or clusters to be formed. The algorithm can be applied again usin the documents in an initial cluster to provide new attibutes; if more than one cluster of documents is found initially, the algorithm can be applied to each."). See also Background and Methodology.
Bichteler & Eaton, e.g., at 193 ("Although the Schiminovich algorithm is a successful retrieval procedure, it does seem to require a minimum of two passes through the file representing the document collection, one pass each cycle.")

Derivig actual clustr links from the candidate

cluster links;

sf-2631576

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See also Background, Purpose, and Methodology.
Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the state of

identifying one or more nodes for display; and
the reference and its

the art

at the time oftJie alleged invention, as cvidenced by substatial other references identified in Defendants' P. R. 3-3 sttement and accompanying char. Rather than

repeat those disclosures here, they are incorprated by reference into this char.
Disclosed either expressly or inherently in the teachings of

displaying the identity of one or more nodes using
incorporated disclosures taen as a whole, or in combintion with the state of

the act cluster links.

the reference and its the art at the time of the alleged invention, as evidenced by substatial other references idcntified in Defendants' P. R. 3-3 statement and accompanying char. Ratherthan
repeat those disclosures here, they are incorporated by reference into ths char.
Disclosed either expressly or inherently in the teachings of

2. The method of clai 1 \vherein each link is given

a lengt, the step of generatig the candidate cluster

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

links comprises the steps of:

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 statement and accompanying char. Rather than

repeat those disclosures here, they are incorprated by reference into this char. Choosing a number as thc maxmum number of link Disclosed either cxpressly or inherently in the teachings ofthc reference and its lengths that will be exained; and incorporated disclosures taen as a whole, or in combination with the state of the art at the time oftJie alleged invention, as evidenced by substantial other references
identified in Defendants' P. R. 3-3 &1:tement and accompanying charts, Rather than

repeat those disclosures here, they are incorprated by reference into this char.
Disclosed either expressly or inherently in thc teachings ofthe rcference and its

cxaining only thosc links which are less than the
link lengths.
at the timc of

maxmum number of

incorporated disclosures taen as a whole, or in combination with the state ofthe art
the alleged invention, as evidenced by substatial other references identified in Defendants' P. R. 3-3 sttement and accompanying char. Rather than

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

3. The method of claim i wherein the step of deriving actul cluster links comprises the step of:

the reference and its
the art

selectig the top rated candidate cluster lins,

the aleged invention, as evidenced by substatial other references

identified in Defendants' P. R. 3-3 statement aiid accompanying char. Ratherthan

wherein the top rated c-adidatc clustcr links are those which are most closely linkcd to the nodc

repeat those disclosures here, they are incorporated by reference into ths chart.

under analysis.

sf-2631576

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

5. The method of claim 1 wherein the step of generating the candidate cluster links compnses the step of:
the reference and its the art the alleged invention, as evidenced by substatial other references

identified in Defendants' P. R. 3-3 statement and accompanying cha. Ratherthan

eliminating cadidate cluster links, wherein the number of candidate cluster links is limited and the closest candidate cluster links are chosen over the remaining links.
Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in c-ombination with the state of at the time of

repeat those disclosures here, they are incorpraed by refèrence into ths chart.

the reference and its

7. The method of claim 1, wherein one or more nodes provide external connectons to objects external to the database, the method furter compnsing the stps of:
Disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination witli the state of at the time of

the ar the alleged invention, as evidenced by substantial other references

identified in Defendants' P. R. 3-3 sttement and accompanying char. Rather tlian

repeat those disclosures here, they are incorporated by reference into this char.
the reference and its

Activating the desired node; and

the art 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 incorprated by reference into ths chart.
Disclosed either cxpressly or inherently in the teachings of

Accessing thc extrnal object lined tö the node.

the refèrence and its incorporated disclosurs taken as a whole, or in combination with the state of the ar

at the time of

the alleged invention, as evidenced by substantial other references identified in Defendants' P. R. 3-3 sttement and accompanying char. Rather thn
the reference and its

repeat those disclosurs here, they are incorprated by reference into this char.
Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combintion with the state of

8. The method of

claim 7, wherein the extrnal

object is an independent application which can be executed in background, the method furter

the art

coinpnsing the stp of:

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

repeat those disclosures here, they are incorprated by reference into this char.
Disclosed either expressly or inherently in the teachigs of

executing the independent application.

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 statement and accompanying chars. Rather than
incorporated disclosurs taen as a whole, or in combination with the state of

repeat those disclosurcs here, thcy are incorprated by retèrence into this chart.

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9. The method of claim 8, wherein one or more nodes provide links to more than one independent
Disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination with the state of at the time of

the reference and its

applicaton which can be executed as an extnsion,

the art

the method fuer comprising the steps of:

the alleged invention, as evidenced by substatial other references identified in Defendants' P. R. 3-3 statement and accompanying char. Ratherthan

repeat those disclosures here, they are incorpraed by reference into this char.
Disclosed either expressly or inherently in the teachings of

displaying a list of independent applications linked to the node, wherein the step of accessing accesses an independent application.

incorporated disclosures taen as a whole, or in combination with the st:1.te of the art at the time oftlie alleged invention, as evidenced by substantial other references
identified in Defendants' P. R. 3-3 sttement and accompanying char. Ratlier than

the reference and its

repeat those disclosures here, they are incorprated by reference into this char.
Disclosed either expressly or inherently in the teachings of

10. The method of claim 8, wherein the connection provides the independent application access to the information stored within the database.
incorporated disclosures taen as a whole, or in combination with the state of

the reference and its the ar 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 disclosures here, they are incorporated by reference into this char.

11. The method of claim 7, wherein the external Disclosed either expressly or inherently in the teachings of the reference and its connection is to another computer, wherein incorporated disclosures taen as a \-"hole, or in combination with the state of the ar information is located that can be accessed, the step at the time of the alleged invention, as evidenced by substatial other references of accessing fiirter comprising the step of: identified in Defendants' P. R. 3-3 statement and accompanying cha. Ratherthan repeat those disclosures here, they are incorpraed by reference into ths chart, accessing the informaton located within the Disclosed either expressly or inherently in the teachings of the reference and its computer. incorporated disclosures taen as a whole, or in combination with the state of the ar
at the time of

the alleged invention, as evidenced by substatial other references

12. A method for determining the proximity of an object in a stored database to another object in the stored database using indirect relationships, links, and a display, comprising:

identified in Defendants' P. R. 3.3 statement and accompanying char. Ratlier thn repeat those disclosures here, they are incorprated by reference into this chart. Bichteler & Eaton, e.g" at 192 ("Schiminovich has proposed a 'bibliographic pattern discovery algorithm' which finds clusters of related documents in a collection, where the operational definition of 'related' is that the documents in a cluster must exhibit similar citation patterns. Thus, it makes use of the notion of bibliographic coupling, first defined by Kessler (2): two documents have one unit of coupling between them if they each cite a third document."). See also Background.

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Selecting an object to determine the proximity of other objects to the selected object;

Bichteler & Eaton, e.g., at 192 ("The algorithm itself operaes only on a link table which indicates for each document whether or not it possesses each of a set of
atributes. The atributes may represent citations. . . .").

See also Background and Methodology.

generating a candidate cluster link set for the selected object, wherein the generating step

includes an analysis of one 01' more indirect

relationships in the database;

Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic pattern discovery algorith' which finds clusters of related documents in a collection, where the operational defiition of 'related' is that the docwnents in a cluster must exhibit similar citation patterns. Thus, it makes use of the notion of bibliographic coupling, first defined by Kessler (2): two documents have one unit of coupling between them if they each cite a third document. . . . The algorith itself operates only on a lin table which indicates for each document whether or not it possesses each of a set of attributes. The atributes may represent citations. . . . The actual attributes are provided by one or more documents, which can be understood to be an initial seed point or points for the cluster or clusters to be foimed. The algorithm can be applied again using the documents in an initial cluster to provide new attbutes; if more than one cluster of documents is found initially, the algorithm can be applied to each."). See also Background and Methodology.

Deriving an actu cluster lin set for the selected

Bichteler & Eaton, e.g., at 193 ("Although the Schiminovich algorithm is a object using the generated candidate cluster link set; successful retrieval procedur, it does seem to require a minimum oft\\'o passes and through the file representing the document collection, one pass each cycle.")
See also Background, Purpose, and Methodology.
the objects in the
at the time of Disclosed either expressly or inherently in the teachings of incorporated disclosurs taken as a whole, or in combination with the state of

Displaying one or more of

the reference and its
the art

datase, referred to in the act clustr lin set, on

a display.

the alleged invention, as evidenced by substatial other references identified in Defendants' P. R. 3.3 sttement and accompanying char. Rather than

repeat those disclosures here, they are incorprated 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 at the time of

the reference and its

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

13. The method of 12 wherein a set of direct links exists for the database, and wherein the step of generating a candidate cluster link set comprises: recursively analyzing portions of the set of direct

links for indirect lins.

repeat those disclosures here, they are incorprated by reference into this char.

sf.2631576

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14. A method for representing the relationship between nodes using stored direct links, paths, and
discovery algorith' which fids clusters of

cadidate cluster links, comprising the steps of:
the notion of bibliographic coupling, first defined by Kessler (2): two documents have one unit of coupling between them if they each cite a third document."). exhibit similar citation pattrns. Thus, it makes use of

Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic pattern related documents in a collection,

where the operational defiition of 'relatd' is that the documents in a cluster must

See also Background.

initializing a set of candidate cluster links;
Bichteler & Eaton, e.g., at

192 ("Schiminovich has proposed a 'bibliographic patern discovery algorithm' which finds clusters of related documents in a collection, where the operational definition of 'related' is that the documents in a cluster must exhibit similar citation patterns. Thus, it makes use of the notion of bibliographic coupling, first defined by Kessler (2): two documents have one unit of coupling betvveen them if they each cite a third document. . . . The algorith itself operates only on a link table which indicates for each document whether or not it possesses
each of a set of attbutes. The attbutes may represent citations . . . . The actual
atbutes are provided by one or more documents, which can be understood to be an

initial seed point or points for the cluster or clusters to be formed. The algorithm can be applied again using the documents in an initial cluster to provide new attbutes; if more than one clusterof documents is found initially, the algorithm can be applied to each."). See also Background and Methodology.
Bichteler & Eaton, e.g., at 192 ("The algorith itslf operates only on a lin table

Selecting the destination node ofa path as the selected node to analyze;

which indicates for each document whether or not it possesses each of a set of attributes. The attributes may represent citations. . . .").
See also Background and Methodology.
Bichtcler & Eatn, e.g., at 192 ('The algorith itslf operates only on a lin table
which indicates for each document

retrieving the set of direct lins from the selected node to any other node in the database;

whether or not it possesses each of a set of

attbutes. The attributes may represent citations. . . .").

See also Background and Methodology.
the path using the
Disclosed either expressly or inherently in the teachings of incorporated disclosurs taen as a whole, or in combination with the state of at the time of

Determining the weight of

the reference and its

retrieved direct links;

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

sf-2631576

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identified in Defendants' P. R. 3-3 sttement and accompanying char. Rather th

repeat those disclosures here, they are incorprated by reference into this char.
Disclosed either expressly or inherently in the teachings of incoiporated disclosures taen as a whole, or in combination with the state of at the tie of

repeatng steps b through d for each path; and

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

identified in Defendants' P. R. 3-3 sttement and accompanying char. Ratherthan
repeat those disclosures here, they are incorporated by reference into ths char.
Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the state of at the time of

Storig the determined weights as candidate cluster

links.

the reference and its

the ar

the alleged invention, as evidenced by substtial other references identified in Defendants' P. R. 3-3 statement and accompanying char. Ratherthan

repeat those disclosures here, they are incorprated by reference into ths chart.
Disclosed either expressly or inherently in the teachings of

15. The method of clai 14 fuer comprising the

stp of deriving the acal clustr links wherein the

the reference and its incorporated disclosures taen as a whole, or in combination with the state of the art

actual cluster links are a subset of

the candidate

at the time oftJie alleged invention, as evidenced by substatial otJier retèrences
identified in Defendants' P. R. 3-3 sttement and accompanying chart. Rather thn

cluster links.

repeat those disclosurs here, they are incorprated 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 at the tie of

16.. The method of claim 15 wherein the stp of

deriving comprises the step of choosing the top

the reference and its the art

rated candidate cluster lins.

the alleged invention, as evidenced by substtial other references identified in Defendants' P. R. 3-3 stement and accompanying char. Rather than

repeat those disclosures here, they are incorprated by reference into this char.

18. A method of analyzing a dat.'lbase having Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic pattern objects and a first numerical representation of direct discovery algorith' which finds clusters of related documents in a collection, relationships in the database, comprising the steps where the operational defiition of 'relatd' is that tlie documents in a cluster must
exhibit similar citation pattrns. Thus, it makes use of the notion of

of:

bibliograhic

coupling, first defined by Kessler (2): two documents have one unit of coupling between them if they each cite a third document."). See also Background.
discovery algorithm' which finds clusters of

generatig a second numerical representation using

the first numerical representation, wherein the second numerical renresentation accounts for

Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic patern related docwnents in a collection, where the onerational defiition of 'related' is that the documents in a cluster must

sf-2631S76

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indirect relatonships in the datbase;
exhibit similar citation patterns. Thus, it makes use of the notion of bibliographic coupling, first defined by Kessler (2): two documents have one unit of coupling between them if they each cite a third document. . . . The algorith itself operates only on a link table which indicates for each document whether or not it possesses

each of a set of atributes. TIie atbutes may represent citations. . . . The actual
attributes are provided by one or more documents, which can be understood to be an initial seed point or points for the cluser or clusters to be formed. The algorith can be applied again using the documents in an initial cluster to provide new attbutes; if more than one cluster of documents is found initially, the algorith can be applied to each.").
See also Background and Methodology.

storing the second numerical representation;
conducted. ")

Bichteler & Eaton, e.g., at abstrct ("(SJearches on the AIP SPIN data base were

identifyng at leas one object in the database,

Bichteler & Eaton, e.g., at abstrt ("lSJearches on the AIP SPIN data base were
conducted. ")
Disclosed either expressly or inherently in the teachings of

wherein the stored numerical

representation is used

to identify objects; and
incorporated disclosurs taen as a whole, or in combination with the state of

displaying one or more identified objects from the

datase.

the reference and its the art at the time of the alleged invention, as evidenced by substtial other references identified in Defendants' P. R. 3-3 statement and accompanying char. Ratherthan

repeat those disclosures here, they are incorprated by reference into this char.
Bichteler & Eaton, e.g., at 192 (''Te algorithm itself operates only on a link table which indicates for each docwnent whether or not it possesses each of a set of
attributes. The atributes may represent citations. . . .o).

19. The method of claim 18 wherein the step of

generatig a second numerical representation

comprises:

selecting an object in the database for analysis;

See also Background and Methodology.
discovery algorithm' which finds clusters of

analyzing the direct relationships expressed by the first numerical representation for indirect relationslùps involving the selected object; and creating a second numerical representation of the direct and indirect relationships involving the

selected object.

Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic pattern related docwnents in a collection, where the operational definition of 'related' is that the docwnents in a cluster must exhibit similar citation patterns. Thus, it makes use of the notion of bibliographic coupling, first defined by Kessler (2): two docunients have one unit of coupling between them if they each cite a third document. , . . The algorith itself operates onlv on a link table which indicates for each document whether or not it Dossesses

sf-2631576

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eah of a set of attributes. The attributes may represent citations. . . . The actual attributes are provided by one or morc documents, which can bc understod to be an

initial seed point or points for the cluster or clusters to be fonned. Thc algorithm can be applied again using the documents in an initial cluster to provide new attrbutes; if more than one cluster of documents is found initially, the algorith can be applied to each.").
See also Background and Methodology.

Bichteler & Eaton, e,g., at abstract ("(SJcarches on the AlP SPIN data base wcre
conducted, ")

20. Thc method of 18 wherein the stcp of "idcntifying at least one object in the database comprises:

searching for objects in a database using the stred numerical representaon, wherein direct and/or
Discloscd either cÀ-pressly or inherently in the teachings ofthc reference and its

indirect relationships are searched.

21. The method of claim 18 wherein the displaying step comprises:
at the time of

incorporated disclosures taen as a wholc, or in combination with thc state ofthc art
the alleged invention, as evidenced by substatial other references identified in Defendants' P. R. 3-3 statement and accompanying charts. Rather than

generating a graphical display for representing an

object in the datbase.

repeat those disclosures here, they are incorporaed by reference into this chart.

23. A method of

representing data in a computer Bichteler & Eaton, e.g., at 192 ("Schimiovich has proposed a 'bibliographic pattern database ""i.th relationships, comprising the steps of: discovery algorith' which finds clusters of related documents in a collection, whcre the operational definition of 'related' is that the documents in a cluster must exhibit similar citation patterns. Thus, it makes use of the notion of bibliographic coupling, first dcfined by Kessler (2): two documents have one unit of coupling between them if they each cite a third document.").
See also Background.

assigning nodes node identifications;

Bichteler & Eaton, e.g., at 192 ("The algorith itself operates only on a link table which indicates for each document whether or not it possesses each of a set of
attributes. The atributes may represent citations. . . .").

See also Background and Methodology.
discovery algorithm' which finds clusters of

generating links, wherein each link represents a relationship between two nodes and is identified by

Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic pattern related docuents in a collection, where the overational definition of 'related' is that the documents in a cluster must

sf-2631576

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,.._..,

the two nodes in which the relationship exists;
exhibit similar citation patterns. Thus, it makes use of the notion of bibliographic coupling, first defined by Kessler (2): two documents have one unit of coupling between them if they each cite a third document. . . . The algorith itself operates only on a link table which indicates for each docwnent whether or not it possesses

each of a set of atributes. The atbutes may represent citations. . . . The actual
attributes are provided by one or more documents, which can be understood to be an initial seed point or points for the cluster or clusters to be formed. The algorith can be applied again using the documents in an initial cluster to provide new attbutes; if more than one cluster of documents is found initially, the algorith can be applied to each.").

See also Background and Metodology.
Disclosed either expressly or inherently in the teachings of incorporated disclosures taen as a whole, or in combination with the state of at the time of

allocating a weight to each li, wherein the weight
the relationship representd

the reference and its

signifies the strngt of

by the link relative to the stngt of other relationships represented by other links; and
Disclosed either expressly or inherently in the teachings of

the ar

the allegea invention, as evidenced by substatial other references identified in Defendants'P. R. 3-3 sttement and accompanying char. Rather than

repeat those disclosures here, they are incorprated by reference into this char.
incorporated disclosures taèn as a whole, or in cumbination with the state of at the time of

displaying a node identification.

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

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

24. The method of claim 23, wherein the data in the Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic pattrn datase is objects, wherein the nodes represent discovery algorith' which fmds clusters of related documents in a collection, object and each object is assigned a node where the operational definition of 'related' is tht the documents in a cluster must identification, and wherein the relationships that exhibit similar citation patterns. Thus, it makes use of the notion of bibliographic exist comprise direct relationships between objects, coupling, first defined by Kessler (2): two documents have one unit of coupling furter comprising the stp of: between them if they each cite a third document."). searching generated links, wherein nodes are See also Background.

located by searching the generaed links.

Bichteler & Eaton, e.g., at abstrct ("(SJearches on the AlP SPIN data base were
conducted.") _
Disclosed either expressly or inherently in the teachings of incoroorated disclosures taen as a whole, or in combination witli the state of

the reference and its

the art

sf-2631576

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steps of:

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

repeat those disclosures here, they are incorprated by reference into this char.
Disclosed either expressly or inherently in the teachigs of incorporated disclosures taen as a whole, or in combination with the state of at the time of

identifing each lin sub-type with a name; and

the reference and its

the art

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 incorprated by reference into ths chart,
Disclosed either expressly or inherently in the teachings ofthe reference and its incorporated disclosurs taen as a whole, or in combination with the state of the art
at the time of the alleged invention, as evidenced

Providing a comment to one or more link subtypes.

by substatial other references

identified in Defendants' P. R. 3-3 sttement and accompanying char. Ratlier thn repeat those disclosures here, they are incorprated by reference into this char.
Disclosed either expressly or inherently in the teachings of

31. The method of claim 23 wherein attnbutes ar

assigned to nodes.
at the time of

the reference and its incorporated disclosures taen as a whole, or in combination with the state of the art

the alleged invention, as evidenced by substantial other references

identified in Defendants' P. R. 3-3 statement and accompanying charts. Raer tlian

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

32. The method of claim 31 furter compnsing the

the reference and its

step of: generating node sub-types wherein the node sub-types are assigned infonnation.

the art

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 incorprated by reference into this chart.
Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic pattern discovery algonth' which finds clusters of related documents in a collection, where the operational definition of 'related' is tht the documents in a cluster must exhibit similar citation patterns. Thus, it makes use of the notion of bibliographic coupling, first defined by Kessler (2): two documents have one unit of coupling between them if they each cite a third document.").
See also Background.

33. A method of representing data in a computer database and for computerized searching of the data, wherein relationships exist in the database, compnsing:

aSsigning links to represent relationships in the

datase;

Bichteler & Ean, e.g., at 192 ("Schiminovich has proposed a 'bibliographic patern discovery algonth' which fids clusters of related documents in a collection,

sf-2631576

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'related' is that the documents in a cluster must exhibit similar citation patterns. Thus, it makes use of the notion of bibliographic coupling, first defined by Kessler (2): two docwuents have one unit of coupling between them if they each cite a third document."). See also Background.
where the operational definition of

Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic pattrn assigned links, wherein node identifications are discovery algorith' which finds clusters of related docuents in a collection, generated so that each link represents a relationship where the operational definition of 'related' is that the documents in a cluster must between two identified nodes; exhibit similar citation pattrns. Thus, it makes usc of the notion of bibliograhic coupling, first defined by Kessler (2): two documents have one unit of coupling between them if they each cite a third document. . . . TIie algorith itself operates only on a lin table which indicates for each document whether or not it possesses each of a set of atributes. The attrbutes may represent citations . . . . The actual
attributes are provided by one or more documents, which can be undersood to be an

generating node identifications basd upon the

initial seed point or points for the cluser or clusters to be formed. The algorith can
be applied again using the docwucnts in an initial cluster to provide new attbutes;

if more than one cluster of documents is found initially, the algorith can be applied to each."). See also Background and Methodology.

storing the links and node identifications, wherein the links and nodes may be retreved;
conducted. ")

Bichteler & Eaton, e.g., at abstrt ("(SJearches on the AIP SPIN data base were
Bichteler & Eaton, e.g., at 192 ("Schiminovich has proposed a 'bibliographic pattern discovery algorithm' which finds clusters of related documents in a collection, where the operational definition of 'related' is that the documents in a cluster must exhibit similar citation patterns. Thus, it makes use of the notion of bibliographic coupling, first defined by Kessler (2): two documents have one unit of coupling between them if they each cite a third document. . . . The algorith itself operates only on a lin table which indicates for each document whether or not it possesses
each of a set of atributes. The atbutes may represent citations . . . . The actual

searching for node identifications using the stored links; and

attributes are provided by one or more docwuents, which can be understood to be an initial seed point or points tòr the cluster or clusters to be tòimed. The algorith can be applied again using the documents in an initial cluster to provide new attbutes;
if more than one cluster of docwuents is found initial

lv, the algorith can be applied

sf-2631576

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to each.").

Bichteler & Eaton, e.g., at abstrat ("(S)earches on the AIP SPIN data base were
conducted. ")
Disclosed either expressly or inherently in the teachings of incorporated disclosures taken as a whole, or in combination with the state of at the time of

the reference and its

displaying node identifications, wherein the displayed node identifications are located in the searching step.

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

the art

repeat those disclosures here, they are incorporated by reference into this char,
the asserted claims as appropriate, for example, depending
the assertd claims, and/or positions that Plaintiff or its

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

upon the Court's constructon of

expert witness(es) may take concerning claim interpretation, construction, infringement, and/or invalidity issues.

Plaitiffs Infrngement Contentions are based on an apparent construction of

constnictions. Nothing stated herein shall be treated as an adission or suggeston that Defendants agree with Plaintiff regarding either the scope

the claim terms. Defendants disagree with these apparent

of any of

the assertd claims or the claim constctions advanced by Plaitifin its Infrngement Contentions or anywhere else, or that any of

Defendants' accused technology meets any limitations of the claims. Nothing stated herein shall be construed as an adission or a waiver of any

parcular construction of any claim term. Defendants also reserve all their rights to challenge any of

the claim tenn.s herein under 35 U.S.C. § 1.12, including by arguing that they are inde.finite, not suppoited by the written description and/or not enabled. Accordingly, nothing stted herein

shall be constnied as a waiver of any argument available under 35 V.S.c. § 112.

sf-263

1576

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