Eolas Technologies Incorporated v. Adobe Systems Incorporated et al
Filing
875
***FILED IN ERROR. SEE DOCUMENT 877 FOR CORRECT PLEADING*** MOTION to Seal Document [DEFENDANTS' MOTION FOR SUMMARY JUDGMENT OF INVALIDITY FOR LACK OF WRITTEN DESCRIPTION by Adobe Systems Incorporated, Amazon.com Inc., CDW Corporation, Citigroup Inc., Google Inc., J.C. Penney Company, Inc., Staples, Inc., The Go Daddy Group, Inc., Yahoo! Inc., YouTube, LLC. (Attachments: # 1 Affidavit, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Text of Proposed Order)(Reines, Edward) Modified on 8/18/2011 (mll, ).
EXHIBIT G
Application
of Doyle
Application
Num
Filed December
For
90/007858
22
Distributed
2005
Method
Hypermedia
for Automatically
External
Invoking
Within
and Display of Embedded Objects
Interaction
Providing
Application
al
et
Document
Hypermedia
Examiner Pokrzywa J.R
Art unit
3992
Declaration
Edward
Felten declare
and the Regents
in the field
Curriculum Vitae which
Edward
Felten
follows
as
have been retained by Eolas
serve as an expert
of
of computer
of the University
science
my technical
recites
of California to
My
and Internet software
expertise
attached
is
hereto
to
as
Exhibit
Qualifications
B.S
am
in
degree
Ph.D
in
Honors
with
graduated
Science
University where
Affairs
am
Professor
Professor
Science
in
was
Computer Science
Computer
appointed
or co-author
have been asked
Office
in
1993
in
as Professor
to
1991 and
in
Princeton
at
Princeton
at
promoted
Professor
of Computer
1985 with
of Washington
was
1999 and
States
Patent
are unpatentable
Patent
Cohen issued
respectfully
disagree
believe
that
patentability over
to
to
publications
These publications
of
Science
Action
in connection
as being anticipated
Cohen
relating
listed
are
the arguments presented
No 5838906 the 906
United
described
Science
of numerous
address
to
the
2007
instead
Science
Computer
in
of
and Internet software
30
M.S
1993 both from the University
in
in
as
to
Computer
and Public
2006
the author
science
July
of
of
2003
in
an
of Technology
Institute
Computer Science and Public Affairs
have taught since 1993
was originally hired
Professor
currently
Associate
received
Physics
Computer
an Assistant
from the California
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the claims
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the cited references
906
in
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my CV
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5367621
declaration
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35 Cohen
describes
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specific multimedia presentations
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accompanying
Cohen Does Not Anticipate
36 The
by
Examiner
Cohen
argues
that the claims
respectfully
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906
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to
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ALT_OBJECT
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44 The
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32
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text
Cohen does
of
tag
embed
The
LDESC tag does
LDESC tag cannot
the
that
why
reason
18
tags
LDESC
tag
58-li emphasis added
at
the
with
8b
8a and
53 The
the
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text
link description
.. Cohen
LDESC tags as
text
files
in accordance
upon
embed
location
in the document
tag appears
document
906
the
of the
the required
at
tags are improved
new multimedia
provide
processing
hypermedia
the location
to
the document
in
distributed
first
and enable interactive
the distributed
in
the
satisfy
at said first location
corresponds
link description
also depict
book
that
appear
BookMaster
of the
prologue
in
tag does not
LDESC
the
Instead
Web
said
in
claim element requires that
This
location
at
page
document
the
52 The LDESC
display
location
first
said object
emphasis added
the
below
hypermedia document
distributed
at
area created
be displayed
object
are the
format because they do not
first
located
.. to display
within
Cohen
of
For the reasons described
text
element wherein said
required
of said object
31
at
LDESC
tags
conclusion
this
tags cannot be the
hypermedia
description
of an object
Patent
1815-
at
of an object nor does
to the first distributed
it
hypermedia
format
text
55 Cohens
more
design
why
that
electronic
Cohen was
books
often repeat
in the document
repeat
in
document
where
the object
suited for use
separately
or inherently
For
solve
Cohen was
Web
Cohen allowed an element
the document
each time
at least
described
prologue
was
on the
this
in
to
Web
to
that
By
be used
where
to
without
there could
pages
single tag
the
be
at
files that
the link tag and
to
having
single link
each place
The claimed 906 design by
individual
larger
given
multi-page
separating
and one small link tag
the
for use with
designed
be repeated
Instead
refers
makes sense
are large
pages
reason the use of
Cohen
Cohen cannot be
prologue
elements on different pages
the full link description
description
better
trying
to
of
tag
small simple link tag
These books unlike
graphic
link description
the link
of having
strategy
detailed link description
problem
is
one reason
is
in
the
contrast
are provided
is
not expressly found
56
Another reason
Cohen and Mosaic
that
Cohen nor Mosaic
had an embed
Cohen Lacks
57
Claim
906
of the
within
Patent
Patent
27-30 Cohen
discloses displaying
59 The
Examiner
single unit
Examiner
of the object
on
screen but there
to
Cohen
in
Cohen
in
any support
window
some
for
discloses displaying
of the object
no disclosure of the
is
32
at
aspects of this longer
Cohen
of the
portion
the notion
supports
as
discusses
and the
that
display area in the browser-
within
window
within
within
window
The Examiner
But none of the material cited by the Examiner
Displaying
906
the object
for the element of
Action
claim
60
take place
element of displaying
of the claim Office
portion
support
controlled
Window
window
browser-controlled
first
the browser-controlled
longer
cites
said
the required
the object
does not point
within
displaying
the display
an area of the browser-controlled
within
happening
neither
that
window
the browser-controlled
display
is
Display within the Browser
requires that
lacks
Claim
format
text
Required
within
area ..
display
at
58 Cohen
the
do not anticipate
In
Cohen
displaying
place
does not necessarily
window
controlled
in
window
the browser-controlled
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separate
window
as
take place
Cohen
disclosure in
Mosaic
with
is
is
inherent in
not
helper
either
the browser-
within
consistent
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with
the display
or on
applications
taking
separate
device
61 One
reason
Claim
that
Cohen and Mosaic
display
is
lack
Browser
Claim
906
of the
associated
with
it
Patent
utilized
1819-22
Cohen
63 The Examiners only
Use of Type Information
wherein
by said browser
lacks
first
this
discussion
the object
and Locate an Executable
requires
that
is
both
within
window
Required
to Identify
external to the
application
at
element of displaying
the require
the
by Cohen and Mosaic
anticipated
area in the browser-controlled
Cohen Lacks
62
not
to
distributed
said object
the
Application
has
type
identify and locate
hypermedia
by
information
an executable
906
document
Patent
element
of this element of Claim
in relation
to
Cohen
is
as follows
See Fig
DATA
graph.exe
graph.exe
Office
Action
reading
the
whereby
at
program
disclosure
1-32
pp
DATA
being the executable
of
executable
the browser
is
..
the external
external
to
application
application
FORMAT
line
utilizing
as being
in
is
specified
However
the Examiner
la of
Cohen
to
the
document
the Examiner
information
as
Fig la wherein
is
apparently
the type information and graph.exe
the type
Nor does Fig
seen
the hypermedia
In this discussion
application
browser
executable
\GOCA
does not point
identify
depict
to
and locate
as
any
the
any steps performed
by
64
Cohen
In
utilize
the book
reader
type information
the
does with
this
information
which invokes
is to
that
it
pass
it
follows
to the operating
reader
system
does not have any kind of
reader
identify and locate
to
not
book
All the
anything
on unexamined
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browser does
to
equates
to identify and locate
the application
or procedure
algorithm
the Examiner
which
be
to
an application
used
65 The
identify and locate
an important
example
as
Web
pages
cause an executable
of
or modify the state
that
that
defined
his
done by the browser
is
step
Claim
in
of the
come from
that
If
choice
Patent
For
to
sources such
untrusted
of such
the author
site
can
be invoked on the users system
to
to gain access
application
906
is
Users often want
security protection
sites
arbitrary
application
can use
then the site author
files
that
hypermedia documents
come from
that
fact
an important
step provides
distributed
display
of the invention
aspect
this
step and the
of the users computer
to
the users private
for example to install
spyware or
virus
66
the browser
Having
executable
application
written
properly
protecting
malicious
application
author
References
locate
67 The
that
is
which the browser does not
in
importance of
68
because
site
is
it
identifying and locating the application
utilize
be run thereby
cannot run
the browser
that
will be
type information
claim element was reinforced
of which
the question
to
author
to
not the
run
identify and
lack this protection
application
this
litigation in which
ifi
problems
security
the
the user from this danger
hostile
on the users computer
the executable
an important
the browser protect
browser will only allow trusted applications
the user against
site
identify and locate
program trusted by the user
lets
by the Eolas
had
references
this
Microsoft
was
claim element
one
Conclusion
For the reasons given
being
is
unpatentable
anticipated
declare
by
that
statements
the references
all
statements
made on
these statements
the like
Section
so
made
conclude
above
incorrect
The
the rejection
that
claims
cited in the Office
made
information
herein
of
are punishable
that
such
27
by
fine
that
2007
statements
to
Edward
Felten
all
be true and further
false
statements
or both under 18
may jeopardize
the patent
Dated September
as
are true and that
willful
or imprisonment
false
and
patent were not
Action
and belief are believed
willful
of claims
my knowledge
were made with the knowledge
1001 and
906
of the
that
and
U.S.C
the validity of
Edward
Dept
Felten
of Computer
Princeton
University
35 Olden
Princeton
Science
Street
NJ 08540
609258-5906
609
258-1771
fax
felten@cs.princeton.edu
Education
Ph.D
in
B.S
in
title
Physics
Engineering
University
and
with Honors
Lazowska
Engineering
Communication
and
California Institute
John
for
Zahorjan
1991
of Washington
University
1993
of Washington
Compilation High-Performance
Advisors Edward
Science
Computer
in
and
Protocol
Programs
Parallel
M.S
Science
Computer
Dissertation
1985
of Technology
Employment
Professor
of Computer
Associate
Professor
Assistant Professor
Senior
University
Secure
Director
Princeton
U.S Dept
case
2003-present
Science Princeton
of Computer
Science Princeton
Computing Analyst Caltech Concurrent
1999-2003
University
University
1993-99
Computing Project California
Institute
1986-1989
of Technology
Internet
Programming Laboratory
University
of Computer
Dept
Science
1996-present
of Justice Antitrust
Division
consulting and
testimony
in
Microsoft
antitrust
1998-2002
Robins Kaplan Miller
Keker
Princeton
Science
of Computer
Van Nest
Electronic
Frontier
Ciresi
Consulting
Foundation
Consulting
in intellectual
Consulting
and
in patent
testimony
property
in intellectual
lawsuit
speech
lawsuit
free
property
free
1998-2003
2002
speech
lawsuits
2001-present
Certus
Ltd
consultant
Cigital
Inc
Technical
Cloakware
Propel.com
Ltd
Technical
Technical
LLC
Java
design and
analysis 2000-2002
Board member 2000-present
Advisory
Advisory
Scientific
Sun Microsystems
Finjan Software
product
Technical
NetCertainty.com
FullComm
in
Advisory
Board member 2000-present
Board member 2000-2002
Advisory
Advisory
Board member 1999-2002
Board member
1999-2001
Board member 1997-present
Board member 1997-2002
Security Advisory
Technical
Advisory
EXHIBIT
Creative
International
consultant
Technologies
Bell Communications
Research
consultant
in
in
product design and analysis
computer
security
research
1997-98
1996-97
Honors and Awards
America 50 Award 2003
Scientific
Alfred
Sloan
Emerson
Electric
University
NSF
Best Paper
ATT
Lawrence
Young
Investigator
1995
award
Ph.D
ACM
Computer
security
SIGMETRICS
Systems
Principles
Conference
1991-93
Fellowship
especially
relating
systems
Operating
and operating
languages
on Operating
Interests
software
Internet
Symposium
1991-93
Fellowship
Mercury Seven Foundation
Research
Princeton
award 1994
1997
award
Award
1996
of Engineering
Paper
Advancement
Keyes Faculty
School
National
Outstanding
1997
Fellowship
to
consumer products
of security
Interaction
systems Distributed computing
Technology law and policy
with programming
Parallel
computing
architecture
and software
Professional
Service
Pro fessional Societies and Advisory Groups
ACM
Advisory
DARPA
ISAT
Co-chair
National
USENIX
IEEE
Reconciling
group 2002-present
2001-2002
Security with Privacy
on Foundations
on Foundations
of Computer
Science
2001-present
on
2004
2003
2001
Management
of Computer
Digital
Rights
Security
Communications Security 2001
Conference
on
Computer
and
Conference
on
Electronic
Commerce 2001
on Security and
Society
on
Technical
USENIX Windows
Society
Privacy
Symposium
Symposium
USEND
Internet
2002-2003
JSAT advisory
Committees
Workshop
Workshop
Internet
on
study committee
General Conference
Workshop
Privacy
and Technology
Science
study committee
Academy
Program
ACM
ACM
ACM
Committee on Security and
Information
Security
in Digital
on Network
and
and
Rights
Management 2001
Distributed
System Security
2001
Privacy 2000
Conference 2000
Systems
Symposium
Conference 2000
on Network
and
Distributed
System Security 2000
IEEE Symposium
on
Security and
ACM
on
Computer
Conference
USENIX
USENIX
1998
Privacy
and
Communications Security 1998
Symposium 1998
Security
Technical
1998
Conference
Symposium
on Operating
Corporate
and
1996
Advisory Boards
Systems Design
Sun Microsystems Java Security Advisory
Cigital
Inc
Technical
Ltd
Cloakware
Propetcom
Fiujan Software
Netcertainty
FullComm
LLC
Faculty
Advisory
Board
Service
Committee on Policy
of the Princeton
University
2002-present
Community
Committee on Athletics
Advisory
Academic
Science
Computer
Board
Board
and Departmental
Advisory
Council
Advisory
Advisory
Scientific
Board
Board
Advisory
Technical
University
Faculty
Advisory
Technical
Council
Board
Advisory
Technical
Technical
Implementation
Executive
2002-present
Committee
1998-2000
Advisor B.S.E program
of 1998
class
approx
25
students
Faculty-Student
Committee on Discipline
1996-98
Faculty-Student
Committee on Discipline
Subcommittee on Sexual Assault and
Harrassment 1996-98
Students Advised
Ph.D Advisees
Minwen
Ji
Ph.D 2001
Researcher
Dirk
at
Ph.D 2000
Balfanz
Researcher
Dan
at
Wallach
Robert
Distribution
File
Ph.D
expected
Systems
using
Ad Hoc
New
Rice
Science
2004
Control for
Web
Dynamic
Content
Collaboration
Center
Dissertation
of Computer
for
Center
Access
Xerox Palo Alto Research
Shillner
Distributed
Data
Dissertation
Ph.D 1998
Professor
Assistant
Dissertation
Compaq Systems Research
Approach
to
Mobile Code
Security
University
Tentative
dissertation
Disk
Shared
Logical
2003
Dissertation
title
Technical
Improving
staff
member
at
Google
Michael
Schneider
Denial
PhD
of Service
Significant Advisory
Drew Dean Ph.D
Stefanos
Pei
expected
University
Network
Defenses
against
Role
1998
Damianakis Ph.D
Cao Ph.D 1996
topic
Attacks
Advisor Andrew
1998
at SRI International
Appel Researcher
Advisor Kai Li President Netrics Inc
Advisor Kai Li
of Wisconsin
On leave
Assistant Professor
at Cisco Systems
of Computer
Sciences
Lujo
Bauer Ph.D 2003
Advisor Andrew
Postdoctoral
Appel
researcher at Carnegie-
Mellon University
Publications
Books and Book
Freedom
to
Securing
Chapters
Tinker
Java
Edward
Java
Edward
Down
Getting
Felten
John
Web
Security
Felten
Scofflaws
Beyond Drew Dean
Browsers and
Dorothy
Internet
In
and
Denning
Gary McGraw
and
Sons New York 1999
Wiley and
and Dirk Balfanz
Wallach
Code
Business with Mobile
to
2004
Publication expected
Edward
Besieged Countering
Peter
eds
Denning
Dan
Felten
Cyberspace
ACM
New York
Press
1997
Java
Applets Holes
Hostile
Security
Tree
Dynamic
Performance
and
Gary McGraw
Antidotes
and Edward
Sons New York 1996
John Wiley and
Felten
Steve
Searching
Otto and
Sabot
Computing Gary
Felten
Edward
ed
In
Addison Wesley
High
1995
Journal Articles
Mechanisms
for
Modular Programming
Secure
The
illinois
DRM
Journal
and
ACM
The
Millennium
Digital
of
Fair
April
Java
Software
Practice
and
and
its
Technology and Policy
View
Skeptical
View
Legacy
Fall
Edward
from the Trenches
2002
Communications of
Felten
the
2003
Known
Security Architecture Formerly
Mechanism
for
Andrew
Appel
94
Act
Copyright
Law
Use
in
2003
Experience 33461-480
Systems Dan
Language-based
ACM
as Stack
on Software
Transactions
Inspection
Wallach
Security
Edward
Engineering
Felten
and
and
Methodology
2000
October
Statically
Scanning
Mutdosch
Gary
Java
Code
McGraw
and
Finding
John
Security Vulnerabilities
Edward
Felten
IEEE Software
Viega
175
Tom
Sept/Oct
2000
Client-Server Computing on the
Angelos Bilas Cezary Dubnicki
February
Fast
RPC
Bilas
and
SHRIMP
and
Multicomputer Stefanos
Edward
Felten
IEEE Micro
Damianakis
1718-18
1997
on
the
SHRIMP
Edward
Computing
February
Virtual
Felten
1997
Memory Mapped Network
IEEE Transactions
on
Parallel
Interface
and
Angelos
Distributed
and Performance
and
Prefetching
ACM
Li
Kai
Transactions
Edward
Dubnicki
Caching
Karlin and
Blumrich Cezary
15121-
Malena Mesarina IEEE Micro
and
Articles
Receiver
via
Anonymity
ACM
Felten
Public
Incomparable
on Computer
Conference
Brent
Keys
Waters
Edward
and
Communications Security
and
2003
November
Obfuscated
an
Attacking
Edward
and
Designs Matthias
Interface
Li
Kai
Anna
Felten
Systems Nov 1996
on Computer
Felten
File
Application-Controlled
Cao Edward
1995
February
Symposium
15
Pei
Memory Mapped Network
Virtual
28
of Integrated
Disk Scheduling
Implementation
by
Cipher
Faults
Injecting
ACM Workshop
Felten
on
Jacob Dan Boneh
Management November
Matthias
Rights
Digital
2002
Genera
and Flexible Access-Control
Edward
Schneider and
Sstem
Web
for the
USENIX
lIt
Felten
Michael
Lujo Bauer
Security
Symposium August
2002
Informed
Batya
Consent
Conference
in the
Mozilla
Browser
Howe
Daniel
Friedman
on System Sciences
Implementing
and Edward
January
Value-Sensitive
Felten
2002
Hawaii
Design
International
Best Paper award
organizational
systems track
Reading
Between
the
Lines Lessons
McGregor Mm
Drew Dean
John
Wallach
Wu
Bede Liu
Adam
Edward
and
SDMI
from the
Ben Swartzlander
Stubblefield
USENIX
Felten
Craver
Scott
Challenge
Dan
Symposium
Security
August 2001
Cookies
Browser Design Toward
Millett Batya
Attacks
Timing
ACM
Conference
An
Archipelago
Internet
6th
ACM
An
Empirical
Edward
of the
Windows
Yuqun Chen
Felten
Douglas
Liviu
International
Iftode
for
Systems
Andrew
SHRIMP
Schneider
and Communications Security
System
on Computer
Study
Online
Consent
Proc of CHI 2001
Felten and Michael
Edward
File
Authentication
Felten
Computing Systems April 2001
on Computer
USENIX
Conference
Proc of 25th
in
Privacy
Island-Based
Services
Proof-Carrying
Alpert
Web
on
Realizing Informed
Friedman and Edward
on Human Factors
Conference
of 7th
Web
and
Lynette
and
Highly
Symposium
August
Nov 2000
Scalable
2000
Appel and Edward
Felten
Communications Security
Nov
System
Matthias
Clark Stefanos
Margaret
Symposium
Available and
Martonosi
on Computer
Proc
Proc of
1999
Blumrich Richard
Cezary
Dubnicki
Shiliner and
Kai
Dainianakis
Robert
Architecture
June
1998
Li
Performance
Measurements
and
Felten
Java
Understanding
of 1998
Li Proc
Kai
for
Stack
SIGMIETRICS Conference
Dan
Inspection
Wallach and
on Security and
IEEE Symposium
Dan
Dean
Oct
Principles
Web
1997 Outstanding
Spoofing An
Dean
Dan
and
Drew
Dirk Balfanz
Symposium
on Operating
Dirk
Felten
National
20th
Proc
Felten
Systems
Award
Paper
Proc of
Edward
Wallach
ACM
Con Game Edward
Internet
Wallach
Conference Oct
Reducing
Proc of 16th
Felten
1998
June
1998
May
Privacy
Extensible Security Architectures for Java
and Edward
Programs Minwen Ji Edward
Multithreaded
of 1998
Information
Balfanz Drew
Systems
Security
1997
Communication
Costs in User-Level
Waiting
Yuqun Chen
and
Edward
Symposium
April
Stefanos
Damianakis
1997
Stream
Sockets
Edward
on
as
Lecture Notes
Bilas
Angelos
Damianakis
23rd Intl
Symposium
Dan
and
Felten
Felten
Wallach
to
Multicomputer Richard
Netscape
Proc of 1996
Iftode
Prefetching
Brian
Karlin and
and
and
Kai Li Proc of
and
1996
Patterson
Anna
Architectural
Proceedings
Clark Stefanos
Liviu
for Parallel
Hugo
Systems Design
From HotJava
SHRIMP
the
Architecture
Gibson
Garth
on Operating
Security
on
Edward
Tonikins
and
1199
Blumrich Douglas
on Computer
Processing
1997
February
Science
Comparison of Algorithms
Felten
Symposium
Java
Matthias
Kimbrel Andrew
Edward
Computing
Computer
in
Parallel
on Communication and
Workshop
Parallel
Cezary Dubnicki
Trace-Driven
Tracy
1st Intl
Intl
Damianakis Cezary Dubnicki
with Message-Passing
Early Experience
Alpert
Stefanos
Network-Based
for
available
SHRIMP
Proc of
Felten
Support
Proc of 11th
Felten
and
Caching
Bershad Pei
Cao
Kai Li Proc of 1996
Implementation
Beyond Drew Dean
IEEE Symposium
Edward
on Security and
Privacy
Parallel
Integrated
Felten
Anna
Software
Liviu
Support
Iftode
Symposium
Protected
Prefetching
Improving
Liviu
DMA
Symposium
for the
High-Performance
Cezary Dubnicki
on
SHRIMP
Edward
Release-Consistent
Iftode
Edward
Conference
1996
Blumrich Cezary Dubnicki
on
Cao
Memory-Mapped Communication Cezary Dubnicki
Felten and Kai Li Proc of Intl Parallel Processing
Edward
April
Pei
SIGMETRICS
for Virtual
User-Level
Symposium
and Caching Tracy Kimbrel
Karlin and Kai Li Proc of 1996
Edward
High-Performance
Felten
Computer
Shared
Network
Virtual
Matthias
and Kai Li Proc of 2nd
Architecture
Memory
Felten
Computer
Interface
and
Feb
using Automatic
Kai Li Proc
Architecture
Feb
Intl
1996
1996
Update
of 2nd Intl
Wei
Multicomputer Bin
Kai Li Parallel
Felten
Anna
Gordon
Clark Edward
Stoll Douglas
and
Prefetching
Caching Strategies Pci
ACM
Karlin and Kai Li Proc of 1995
Best Paper
Multi-Port
and
Cao
Edward
SIGMETRICS
Conference
award
Evaluating
Felten
Symposium Oct 1995
Rendering
of Integrated
Study
Mesh-Connected
Frame Buffer on
Multi-Port
for
Synchronization
and
Implementation
Edward
and
File
Application-Controlled
Li Proc
Virtual
USENIX
of
Technical
Network
Interface
Blumrich Kai Li Richard
and Jonathan
Performance
Issues
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