HYPERPHRASE TECHNOLOGIES, LLC v. GOOGLE INC.

Filing 105

Second AFFIDAVIT of W. Bruce Croft, PH.D. filed by Defendant GOOGLE INC. re: 100 MOTION for Summary Judgment filed by GOOGLE INC. (Attachments: # 1 Exhibit Table of Contents for Exhibits Attached to the Second Declaration of W. Bruce Croft, PH.D. and Exhibits) (Peterson, James)

HYPERPHRASE TECHNOLOGIES, LLC v. GOOGLE INC.

Doc. 105

Case: 3:06-cv-00199-jcs

Document #: 105

Filed: 02/29/2008

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN HYPERPHRASE TECHNOLOGIES, LLC and HYPERPHRASE INC., Plaintiffs, v. GOOGLE INC., Defendant. SECOND DECLARATION OF W. BRUCE CROFT, PH.D Civil Action No. 06 C 0199 S

I, W. Bruce Croft, am an expert retained by Defendant Google Inc. in connection with the above captioned matter. I submit this declaration in connection with Google's Motion for Summary Judgment of Invalidity.

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Exhibit 1 is a true and accurate copy of the body of my supplemental expert

report in this matter, dated February 11, 2008, demonstrating invalidity of all remaining asserted claims. All opinions, views and conclusions expressed in this report are mine, and I adopt them for purposes of this motion. 2. A true and accurate copy of selected claim charts from my supplemental expert

report in this matter are attached. All opinions, views and conclusions expressed in these claim charts are mine, and I adopt them for purposes of this motion: (a) Exhibit 2(a) is a true and accurate copy of an invalidity claim chart from my supplemental expert report for U.S. Patent No. 5,742,768 to Gennaro et al., entitled System and Method For Providing and Displaying A Web Page Having an Embedded Menu (filed Jul. 16, 1996).

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Case: 3:06-cv-00199-jcs

Document #: 105

Filed: 02/29/2008

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(b) Exhibit 2(b) is a true and accurate copy of a supplemental invalidity claim chart from my supplemental expert report for Graham, Ian S., HTML Sourcebook: A Complete Guide to HTML, pp. 167-68 (John Wiley & Sons. Eds., Mar. 1995), ISBN: 0-471-11849-4. (c) Exhibit 2(c) is a true and accurate copy of a supplemental invalidity claim chart from my supplemental expert report for Myka, A. & Güntzer, U. Automatic Hypertext Conversion of Paper Document Collections, in Selected Papers From the Digital Libraries Workshop on Digital Libraries: Current Issues, Lecture Notes In Computer Science, Vol. 916. Springer-Verlag, London. pp. 65-90 (N. R. Adam et al. eds.: Springer-Verlag, London) (May 19-20, 1994). (d) Exhibit 2(d) is a true and accurate copy of a supplemental invalidity claim chart from my supplemental expert report for Thistlewaite, Paul, Automatic Construction and Management of Large Open Webs, Info. Proc. & Mgmt., Vol. 33, No. 2, pp. 161-73 (Mar. 1997). (e) Exhibit 2(e) is a true and accurate copy of an invalidity claim chart from my supplemental expert report for the web pages from http://cs.nyu.edu/faculty/grishman/NEtask20.book_3.html#HEADING4 illustrating the MUC-6 Named Entity Task Definition, (Version 2.0, 31 May 95), for the Proc. of the 6th Message Understanding Conf. (MUC-6), Columbia, Maryland, held on Nov. 6-8 1995. Posted on June 2, 1995 and printed on February 27, 2008. (f) Exhibit 2(f) is a true and accurate copy of an invalidity claim chart from my supplemental expert report for Aberdeen, J. et. al., MITRE: Description of the

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Case: 3:06-cv-00199-jcs

Document #: 105

Filed: 02/29/2008

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