Rockstar Consortium US LP et al v. Google Inc

Filing 200

Joint Claim Construction Chart Pursuant to Patent Rule 4-5(d) by Google Inc. (Attachments: # 1 Appendix A - U.S. Patent No. 7,236,969, # 2 Appendix B - U.S. Patent No. 7,469,245, # 3 Appendix C - U.S. Patent No. 7,672,970, # 4 Appendix D - U.S. Patent No. 7,895,178, # 5 Appendix E - U.S. Patent No. 7,895,183, # 6 Appendix F - U.S. Patent No. 7,933,883, # 7 Appendix G - Ordering Agreements and Disputes, # 8 Appendix H - Antecedent Basis Agreements and Disputes)(Anderson, Carl)

APPENDIX F:
JOINT CLAIM CONSTRUCTION CHART FOR U.S. PATENT NO. US 7,933,883
Asserted Claims
(Disputed terms in
bold)
1. A method for
operating an advertising
machine implemented
on at least one computer
to provide
advertisements via a
communications link to a
data processing device of
a user, the method
comprising: creating
user profile data for the
user; storing the user
profile data; receiving
from the data
processing device via
the communications
link a search request that
includes a search
argument; searching at
least one database
having data network
related information
using the search
argument to generate
search results; selecting

Terms for
Construction

Rockstar’s Proposed
Construction

Google’s Proposed
Construction

“advertising machine”

See ‘969 (17)

See ‘969 (17)

“[the] user profile
data”

See ‘969 (2)

See ‘969 (2)

“user”

See ‘969 (1)

See ‘969 (1)

“data processing device See ‘969 (6)
[of a/the user]”

See ‘969 (6)

“communications link”

See ‘245 (1)

See ‘245 (1)

“search argument” /
“the received search
argument”

See ‘969 (1)

See ‘969 (1)

“database”

See ‘969 (1)

See ‘969 (1)

1

Court’s Construction

Asserted Claims
(Disputed terms in
bold)
at least one
advertisement from an
advertisement database
relating to the search
argument using the user
profile data; and
transmitting the search
results together with the
at least one
advertisement via the
communications link to
the data processing
device.

2. The method of claim
1, wherein the user
profile data includes
prior purchasing
information regarding
the user.
3. The method of claim
1, wherein storing the
user profile data
comprises storing the
user profile data in a user
profile database of the
advertising machine.

Terms for
Construction

Rockstar’s Proposed
Construction

Google’s Proposed
Construction

“data network related
information”

See ‘969 (1)

See ‘969 (1)

“search result[s]”

See ‘969 (1)

See ‘969 (1)

“advertisement”/
“particular
advertisement”

See ‘969 (1)

See ‘969 (1)

“advertisement
database” /
“database having
advertisement
information”
“[the] user profile
data”

See ‘969 (1)

See ‘969 (1)

See ‘969 (2)

See ‘969 (2)

“user”

See ‘969 (1)

See ‘969 (1)

“[the] user profile
data”
“user”

See ‘969 (2)

See ‘969 (2)

See ‘969 (1)

See ‘969 (1)

“database”

See ‘969 (1)

See ‘969 (1)

“advertising machine”

See ‘969 (17)

See ‘969 (17)

2

Court’s Construction

Asserted Claims
(Disputed terms in
bold)
4. The method of claim
1, wherein storing the
user profile data
comprises storing the
user profile data on the
data processing device.

Terms for
Construction

Rockstar’s Proposed
Construction

Google’s Proposed
Construction

See ‘969 (2)

See ‘969 (2)

“user”

See ‘969 (1)

See ‘969 (1)

“data processing device See ‘969 (6)
[of a/the user]”

See ‘969 (6)

“[the] user profile
data”
“prior searching
history / prior search
history”

See ‘969 (2)

See ‘969 (2)

See ’245 (7)

See ’245 (7)

“user”

5. The method of claim
1, wherein the user
profile data is based
upon prior search
history of the user.

“[the] user profile
data”

See ‘969 (1)

See ‘969 (1)

See ‘969 (2)

See ‘969 (2)

See ‘969 (1)

See ‘969 (1)

6. The method of claim
“[the] user profile
1, wherein the user
data”
profile data is based
upon user interests
selected from the group
consisting of social
interests, family
interests, political
“user”
interests, technological
interests, geographical
interests, environmental
interests, and educational
interests.

3

Court’s Construction

Asserted Claims
(Disputed terms in
bold)
7. The method of claim
1, further comprising
updating the user
profile data based upon
the search argument.

Terms for
Construction

Rockstar’s Proposed
Construction

Google’s Proposed
Construction

“[the] user profile
data”
“user”

See ‘969 (2)

See ‘969 (2)

See ‘969 (1)

See ‘969 (1)

“search argument” /
“the received search
argument”
“[the] user profile
data”

See ‘969 (1)

See ‘969 (1)

8. The method of claim
See ‘969 (2)
1, further comprising
updating the user
“user”
See ‘969 (1)
profile data using data
obtained via interaction
with the data processing “data processing device See ‘969 (6)
[of a/the user]”
device.

See ‘969 (2)

9. The method of claim
1, further comprising
sorting the search
results based upon the
user profile data.

Plain and ordinary
meaning.

separate the search
results into groups

See ‘969 (1)
See ‘969 (2)

See ‘969 (1)
See ‘969 (2)

See ‘969 (1)
Plain and ordinary
meaning.

See ‘969 (1)
indefinite

10. The method of claim
1, wherein searching at
least one database
having data network
related information
using the search
argument to generate

“sorting the search
results”
’883 (9)
“search result[s]”
“[the] user profile
data”
“user”
“distinct differing
databases”
’883 (10, 28)
“database”

In the alternative,
“different databases”
See ‘969 (1)

4

See ‘969 (1)
See ‘969 (6)

See ‘969 (1)

Court’s Construction

Asserted Claims
(Disputed terms in
bold)
search results and
selecting at least one
advertisement from an
advertisement database
relating to the search
argument using the user
profile data comprise
accessing distinct
differing databases.

20. An advertising
machine implemented on
at least one computer
and operable to provide
advertisements via a
communications link to a
data processing device of
a user, the advertising
machine comprising: a
communications

Terms for
Construction

Rockstar’s Proposed
Construction

Google’s Proposed
Construction

“data network related
information”

See ‘969 (1)

See ‘969 (1)

“search argument” /
“the received search
argument”
“search result[s]”

See ‘969 (1)

See ‘969 (1)

See ‘969 (1)

See ‘969 (1)

“advertisement”/
“particular
advertisement”
“advertisement
database” /
“database having
advertisement
information”
“[the] user profile
data”
“user”

See ‘969 (1)

See ‘969 (1)

See ‘969 (1)

See ‘969 (1)

See ‘969 (2)

See ‘969 (2)

See ‘969 (1)

See ‘969 (1)

“advertising machine”

See ‘969 (17)

See ‘969 (17)

“communications
interface”

See ’245 (9)

See ’245 (9)

“data processing device See ‘969 (6)
[of a/the user]”

See ‘969 (6)

5

Court’s Construction

Asserted Claims
(Disputed terms in
bold)
interface operable to
interface with the data
processing device of the
user via the
communications link; a
database search engine
operable to: receive from
the data processing
device via the
communications
interface a search request
that includes a search
argument; and search at
least one database
having data network
related information
using the search
argument to generate
search results; an
associative search
engine operable to:
create user profile data
for the user; store the
user profile data; and
select at least one
advertisement from an
advertisement database
relating to the search

Terms for
Construction

Rockstar’s Proposed
Construction

Google’s Proposed
Construction

“user”

See ‘969 (1)

See ‘969 (1)

“communications link”

See ‘245 (1)

See ‘245 (1)

“database search
engine”

See ’969 (17)

See ’969 (17)

“search argument” /
“the received search
argument”

See ‘969 (1)

See ‘969 (1)

“database”

See ‘969 (1)

See ‘969 (1)

“data network related
information”

See ‘969 (1)

See ‘969 (1)

“search result[s]”

See ‘969 (1)

See ‘969 (1)

“associative search
engine”

See ‘969 (17)

See ‘969 (17)

6

Court’s Construction

Asserted Claims
(Disputed terms in
bold)
argument using the user
profile data; and the
advertising machine
operable to transmit the
search results together
with the at least one
advertisement via the
communications link to
the data processing
device.

Terms for
Construction

Rockstar’s Proposed
Construction

Google’s Proposed
Construction

23. The advertising

See ‘969 (2)

See ‘969 (2)

“advertisement”/
“particular
advertisement”

See ‘969 (1)

See ‘969 (1)

“advertisement
database” /
“database having
advertisement
information”
“advertising machine”

See ‘969 (1)

See ‘969 (1)

See ‘969 (17)

See ‘969 (17)

“[the] user profile
data”
“user”

See ‘969 (2)

See ‘969 (2)

See ‘969 (1)

See ‘969 (1)

“advertising machine”

See ‘969 (17)

See ‘969 (17)

“associative search
engine”

See ‘969 (17)

See ‘969 (17)

“[the] user profile
data”
“user”

See ‘969 (2)

See ‘969 (2)

See ‘969 (1)

See ‘969 (1)

“database”

21. The advertising
machine of claim 20,
wherein the user profile
data includes prior
purchasing information
regarding the user.
22. The advertising
machine of clam 20,
wherein the associative
search engine is
operable to store the
user profile data in a
user profile database of
the advertising machine.

“[the] user profile
data”

See ‘969 (1)

See ‘969 (1)

“advertising machine”

See ‘969 (17)

See ‘969 (17)

7

Court’s Construction

Asserted Claims
(Disputed terms in
bold)
machine of claim 20,
wherein the associative
search engine is
operable to transmit the
user profile data via the
communications
interface to the data
processing device for
storage.

Terms for
Construction

Rockstar’s Proposed
Construction

Google’s Proposed
Construction

See ‘969 (17)

See ‘969 (17)

“[the] user profile
data”
“user”

See ‘969 (2)

See ‘969 (2)

See ‘969 (1)

See ‘969 (1)

“communications
interface”

See ’245 (9)

See ’245 (9)

“data processing device See ‘969 (6)
[of a/the user]”
24. The advertising
machine of claim 20,
wherein the user profile
data is based upon prior
search history of the
user.

“associative search
engine”

See ‘969 (6)

See ‘969 (17)

See ‘969 (17)

“[the] user profile
data”
“prior searching
history / prior search
history”

See ‘969 (2)

See ‘969 (2)

See ’245 (7)

See ’245 (7)

“user”
25. The advertising
machine of claim 20,
wherein the user profile
data is based upon user

“advertising machine”

See ‘969 (1)

See ‘969 (1)

“advertising machine”

See ‘969 (17)

See ‘969 (17)

8

Court’s Construction

Asserted Claims
Terms for
(Disputed terms in
Construction
bold)
interests selected from
“[the] user profile
the group consisting of
data”
social interests, family
interests, political
interests, technological
“user”
interests, geographical
interests, environmental
interests, and educational
interests.
28. The advertising
machine of claim 20,
wherein the at least one
database having data
network related
information and the
advertisement database
comprise distinct
differing databases.

Rockstar’s Proposed
Construction

Google’s Proposed
Construction

See ‘969 (2)

See ‘969 (2)

See ‘969 (1)

See ‘969 (1)

“advertising machine”

See ‘969 (17)

See ‘969 (17)

“database”

See ‘969 (1)

See ‘969 (1)

“data network related
information”

See ‘969 (1)

See ‘969 (1)

“advertisement
database” /
“database having
advertisement
information”
“distinct differing
databases”

See ‘969 (1)

See ‘969 (1)

See ’883 (10)

See ’883 (10)

9

Court’s Construction