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`EXHIBIT B
`EXHIBIT B
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`Case 1:20-cv-00518-GBW Document 1-2 Filed 04/16/20 Page 2 of 64 PagelD #: 62
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`DECLARATION OF DR. RICARDO VALERDI
`DECLARATION OF DR. RICARDO VALERDI
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`Case 1:20-cv-00518-GBW Document 1-2 Filed 04/16/20 Page 3 of 64 PageID #: 63
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`I.
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`INTRODUCTION
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`1.
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`I, Ricardo Valerdi, have been asked by Ameranth, Inc. ("Ameranth") to opine on the
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`technological innovations described in U.S. Patent 9,747,651 ("'651 patent") dated August 29, 2017.
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`I have been also asked to opine on the state of the art of computer technology at the time of the '651
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`patent and how improvements disclosed in the '651 patent improved the state of the art of computer
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`technology at the time of the '651 patent.
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`II.
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`EXPERIENCE AND QUALIFICATIONS
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`2.
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`The details of my education, work experience, research, and publications (including
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`publications authored in the last 10 years) are summarized in my curriculum vitae ("CV") attached
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`hereto as Attachment A of this declaration.
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`3.
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`I received a Bachelor of Science degree in Electrical Engineering from the University
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`of San Diego, a Masters in Systems Architecture and Engineering from the University of Southern
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`California, and a Ph.D. in Industrial and Systems Engineering from University of Southern
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`California.
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`4.
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`I am a Full Professor, with tenure, at the University of Arizona in the Department of
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`Systems & Industrial Engineering. Previously, I was on the faculty at the Massachusetts Institute of
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`Technology in Cambridge, MA and was a Visiting Professor at the United States Military Academy
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`in West Point, NY.
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`5.
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`I have provided consultant services for the United States Government (i.e.,
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`Department of Defense and Department of Energy), and other governments and major contractors
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`in the areas of product development. I also teach university classes – cost estimation and sports
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`analytics – and have supervised dozens of graduate students in engineering and given presentations
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`on product development and related topics in Mexico, Costa Rica, Brazil, Spain, Italy, England,
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`India, China, and Australia.
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`1
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`6.
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`My industry experience includes a variety of engineering roles at Motorola (in the
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`wireless communications division) and SpaceX (in the space rocket production department). My
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`experience at Motorola included the development of voice and data systems connected via wireless
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`communication networks. This is similar to the '651 patent in the areas of wireless computing,
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`handheld and remote communications to databases, fixed and free format messaging, and audio
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`quality validation over fixed and mobile wireless networks.
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`7.
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`I am a Senior Member of the Institute of Electrical and Electronics Engineers (IEEE),
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`the largest engineering professional society in the world.
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`8.
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`I have received numerous awards for my research including the Frank Freiman Award
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`for Lifetime Achievement in Cost Estimation and Parametric Modeling (highest award given by the
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`International Cost Estimating & Analysis Association), Distinguished Visiting Fellowship at the
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`Royal Academy of Engineering (United Kingdom), and elected as a Foreign Member of the Mexican
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`Academy of Engineering. I have received best paper awards in the Defense Acquisition Research
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`Journal, Conference on Predictive Models in Software Engineering, and Symposium of the
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`International Council on Systems Engineering.
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`9.
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`I have over 100 publications in journals, magazines, and conferences relating to a
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`broad range of technologies including cybersecurity, autonomous systems, virtual reality, and
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`electronic medical records.
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`10.
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`Of most relevance to this matter are the following publications:
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`Ryan, T., Valerdi, R., Total Cost of Ownership: An Approach for Estimating UAS
`Costs, in Operations Research for Unmanned Systems, Cares, J. R. and Dickmann, J.
`Q. (Eds.), Wiley, 2016.
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`This article describes various attributes of intelligent systems (e.g., military unmanned drones) that
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`drive their total ownership costs.
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`2
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`Latt, L. D., Monreal, J., Smith, K., Mertz, J., Patterson, J., Valerdi, R., Head, K. L.,
`"Impact of electronic medical record implementation on orthopaedic clinic
`workflow," 127th Meeting of the American Orthopaedic Association, Montréal,
`Canada, June 18-21, 2014.
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`This article describes a mobile application connected to a database utilized for storing time motion
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`data of physicians in an orthopaedic clinic.
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`Thebeau, D., Reidy, B., Valerdi, R., Gudagib, A., Kurra, H., Al-Nashifb, Y., Hariri,
`S., Sheldon, F., "Improving cyber resiliency of cloud application services by applying
`Software Behavior Encryption (SBE)," Conference on Systems Engineering
`Research, Redondo Beach, CA, March 21-22, 2014.
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`This article describes in part an intelligent algorithm for improving computer security using a moving
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`target defense strategy.
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`Hess, J., Agarwal, G., Cowart, K., Deonandan, I., Kenley, C. R., Mikaelian, T. and
`Valerdi, R., "Normative and Descriptive Models for Test & Evaluation of Unmanned
`and Autonomous Systems of Systems," 20th INCOSE Symposium, Chicago, IL, July
`2010.
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`This article describes a framework for testing intelligent systems with emergent behaviors (e.g.,
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`military unmanned drones).
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`Deonandan, I., Valerdi, R., Lane, J. and Macias, F., "Cost and Risk Considerations
`for Test and Evaluation of Unmanned and Autonomous Systems of Systems," 5th
`IEEE International Conference on Systems of Systems Engineering, Loughborough,
`UK, June 2010.
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`This article describes in part an intelligent decision support system for testing military unmanned
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`drones.
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`III. COMPENSATION
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`11.
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`The rate of compensation for my work in this case is $650 per hour. My
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`compensation is based solely on the amount of time that I devote to activity related to this matter
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`and is in no way affected by any opinions that I render or the outcome of any particular matter.
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`IV. MATERIALS CONSIDERED
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`12. My opinions, expressed herein, and preparation of this declaration are based on the
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`information I have reviewed in the materials listed in Attachment B of this declaration.
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`V.
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`SUMMARY OF OPINIONS
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`13.
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`The technologies described and claimed in the '651 patent contain at least the
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`following three inventive concepts that enhance computer technology: (1) being able to understand
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`and convert both fixed format1 and free format messaging - unstructured data2 such as in an e-
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`mail/text message or via voice to text conversion (Claim 1: a; Claim 2: a; Claim 3: a), (2) being able
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`to concurrently handle both free and fixed format messaging through a variety of communication
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`conversions (Claim 1: f and g; Claim 2: f and g; Claim 3: f, g, and h), and (3) being able to make
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`and execute intelligent decisions by accessing and applying intelligent automated assistant
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`technology (Claim 1: a and f; Claim 2: a and f; Claim 3: a and f).
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`14.
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`As will be shown below, the prior art did not have the ability to perform the above
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`unconventional inventive concepts captured in the cited claim elements. It was not until the
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`inventions – and their non-conventional combinations disclosed, taught, and claimed in the '651
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`patent – that these non-conventional combinations exist.
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`1 Fixed format messages are comprised of structured data, which have clearly defined patterns making them easily
`understood by computers. As an example in the hospitality industry, structured data may be the day of the week (e.g.,
`"Wednesday").
`2 Unstructured data are comprised of information that do not have a pre-defined format. Handling unstructured data is
`not trivial. Many difficulties arise because unstructured data is cumbersome to analyze due to the unpredictable lengths
`and meanings of number and letters. Unstructured data exponentially increases the number of possible combinations
`that must be anticipated, quickly surpassing Moore's Law (that computing power doubles approximately every two
`years). Furthermore, unstructured data leads to the same word contain multiple meanings (e.g., may vs. May). The
`increased complexity and unpredictability of unstructured data results in an increased need for computing power and
`more sophisticated natural language processing algorithms. As an example, unstructured data may be a sentence with
`instructions (e.g., "I would like my reservation to be for my husband and I, we are celebrating our anniversary on
`Wednesday next week and would like a table by the window.")
`4
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`VI.
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`LEVEL OF ORDINARY SKILL IN THE ART
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`15.
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`In determining the characteristics of a hypothetical person of ordinary skill in the art
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`of the '651 patent, I considered several things, including the type of problems encountered in the art,
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`the solutions to those problems, the speed with which innovations are made, the sophistication of
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`the technology, and the education level of active workers in the field. Finally, I reflected on my
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`experience in and around the year 2005 and considered the scientists and engineers whom I had
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`collaborated with and with whom I had worked.
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`16.
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`I determined that a person with a level of ordinary skill in the art for the '651 patent
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`in or around 2005 would have been someone with a minimum of a Bachelor's degree in Engineering
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`(e.g., Computer Engineering or Software Engineering) or equivalent experience. Typical work
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`experience in complex computer systems, for instance in the industrial automation industry, for such
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`a person would be between 5-15 years in a technical role.
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`17.
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`In addition, a person of ordinary skill in the art (POSITA) would need some exposure
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`to hospitality applications and their functionality in order to leverage industry-specific ontologies.3
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`The POSITA's understanding of the ontology of operations for the particular hospitality application
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`being developed and deployed would be needed to (1) intelligently program and (2) set up the
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`system.
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`18.
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`The specific skillset needed to build this type of system is in the areas of software
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`development, communication conversions, database design, Application Programming Interfaces,
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`computer networking, and wireless communications.
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`3 An ontology is a set of concepts and categories in a subject area or domain that shows their properties and the relations
`between them. In the hospitality industry, this might include date/time/place/party size/party name. See for example:
`Snae, C., & Bruckner, M. (2008, February). FOODS: a food-oriented ontology-driven system. In 2008 2nd IEEE
`International
`Conference
`on
`Digital
`Ecosystems
`and
`Technologies
`(pp.
`168-176).
`https://doi.org/10.1109/DEST.2008.4635195
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`
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`VII. BACKGROUND
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`19.
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`One of the earliest digital food orders was a pizza from Pizza Hut4 in 1994, followed
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`shortly by waiter.com5 in 1995 yet these primitive ordering systems did not include any wireless
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`handheld computers. Ameranth introduced remote wireless handheld ordering in September 1999.6
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`This was followed by GrubHub's look-up website for restaurants in 2004.7 The Pizza Hut and
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`GrubHub solutions were simple, fixed format, menu-based food ordering systems with very limited
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`capabilities and lacked the ability to process, understand, and execute unstructured data.
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`20.
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`The field of speech and voice recognition was also in a primitive stage in the early
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`2000s. While IBM and DARPA8 successfully demonstrated speech recognition computers in the
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`1960s and 1970s, these computers could only understand a limited number of words in English and
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`required a lot of processing power and memory. In the 1980s, computers with faster processors
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`arrived which cleared the way for the development of speech recognition systems for consumers. In
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`1990, Dragon Dictate was the first speech recognition product available to consumers, which sold
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`for $9,000 per copy and required extensive training in order to recognize different voices.9 Dragon
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`Dictate was inadequate in its early years because of its inability to filter out environmental noise,
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`resulting in a high error rate.10 In some cases, the Dragon software had a lower accuracy and required
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`more editing time than a human transcription service.11
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`
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`4 https://www.huffpost.com/entry/pizza-hut_n_3894981
`5 https://www.paloaltoonline.com/weekly/morgue/restaurants/1995_Dec_29.EATOUT29.html
`6 U.S. Patent 6,384,850 filed in September 1999 and issued in 2002. See: McNally, Keith R., William H. Roof, and
`Richard Bergfeld. "Information management and synchronous communications system with menu generation." U.S.
`Patent 6,384,850, issued May 7, 2002.
`7 https://www.businessinsider.com/grubhubs-ceo-on-the-shock-of-outgrowing-three-offices-in-a-few-short-years-2012-2
`8 Defense Advanced Research Projects Agency is part of the U.S. Department of Defense
`9 https://www.pcworld.com/article/243060/speech_recognition_through_the_decades_how_we_ended_up_with_siri.html (see page
`2 of article)
`10 Hawley, M. S. (2002). Speech Recognition as an Input to Electronic Assistive Technology. British Journal of
`Occupational Therapy, 65(1), 15–20. https://doi.org/10.1177/030802260206500104
`11 Singh, M., Pal, T. R., (2011). Voice Recognition Technology Implementation in Surgical Pathology: Advantages and
`Limitations. Archives of Pathology & Laboratory Medicine 135(11), 1476-1481 https://doi:10.5858/arpa.2010-0714-
`OA
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`21.
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`The first interactive voice response system, VAL from Bell South, was released in
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`1996 but was plagued with problems of accuracy. Similar problems existed in early versions of
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`Microsoft's Vista voice-recognition system first released in 1996.12 One of the technical challenges
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`at the time was that algorithms for Natural Language Processing were not optimized to handle the
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`variety of voice inputs from different human voices.13
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`22.
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`Apple first introduced speech recognition in its MacOS operating systems in 1993,
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`but the commands were limited to terminology preprogrammed in the computer, had problems with
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`background noise, different pronunciations of the same word, and the inability to block applications
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`by Parental Controls without an administrator's permission.14 Apple's iPhone did not include voice
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`recognition technologies until 2008, and researchers behind this application claimed that users could
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`get gibberish results at times.15 Siri, Apple's personal digital assistant, was first released in 2011 on
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`the iPhone 4s.16 Thanks to advancements in computer processing power, faster internet connection
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`speeds, and improved natural language processing, Siri applied statistical analysis to decipher the
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`meaning behind questioners' sentences.
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`23.
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`Google began the development of voice recognition technologies around 2004, and
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`in 2007 launched a free 411 service called GOOG-411.17 The system would accept verbal commands
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`to look up business listings and "worked at about 70% efficiency."18 Google's development team
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`admitted "…the 411 service didn't exist solely because Google wanted to help people out — it also
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`gave Google a vast amount of voice data, allowing it to improve its speech recognition technology
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`
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`12 https://www.pcworld.com/article/126613/article.html
`13 Lapata, M., & Keller, F. (2005). Web-based models for natural language processing. ACM Transactions on Speech
`and Language Processing (TSLP), 2(1), 3-es. https://doi.org/10.1145/1075389.1075392
`14 https://en.m.wikipedia.org/wiki/Speakable_items
`15 https://www.pcworld.com/article/153871/search.html
`16 https://www.pcworld.com/article/242479/what_makes_siri_special_.html
`17 https://techcrunch.com/2011/02/13/the-power-of-voice-a-conversation-with-the-head-of-googles-speech-technology/
`18 https://techcrunch.com/2010/10/08/google-411/
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`for the voice services that are now present throughout Android and on many other phones, including
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`the iPhone, BlackBerry, Nokia S60, and Windows."19
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`24.
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`The field of intelligent automation was still in development in the mid-2000s, with
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`researchers citing, among others, challenges in the areas of monitoring and diagnosis.20 The
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`complexity of such automation systems resulted in the development of industry standard IEC
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`6149921 to address challenges in validating architectures for industrial automation systems.22
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`Despite the progress in defining generic architectures and guidelines for intelligent automation
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`systems, implementation problems remained.23 For example, the combination of intelligent
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`interfaces using human speech and systems that used intelligence did not exist and intelligent system
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`applications, including intelligent automation, at or from remote wireless handheld computing
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`devices was virtually nonexistent due to the very limited computing power and the lack of high-
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`speed wireless connectivity that existed at the time.
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`25.
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`In the hospitality industry, in particular, significant work was still needed in or around
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`2005 to advance the digital delivery and data management of remote, location-based tourism
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`systems.24
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`26.
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`Thus, as discussed above, no prior art discloses or renders the specific inventive
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`features of the claims conventional, and none of the prior art understood, handled, or converted fixed
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`
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`19 https://googleblog.blogspot.com/2010/10/goodbye-to-old-friend-1-800-goog-411.html
`20 Gilabert, E., & Arnaiz, A. (2006). Intelligent automation systems for predictive maintenance: A case study. Robotics
`and Computer-Integrated Manufacturing, 22(5-6), 543-549. https://doi.org/10.1016/j.rcim.2005.12.010
`21 IEC 61499-1:2012, Function blocks - Part 1: Architecture
`22 Vyatkin, V., Hanisch, H. M., Karras, S., Pfeiffer, T., & Dubinin, V. (2006). Rapid engineering and re-configuration
`of automation objects aided by formal modelling and verification. International Journal of Manufacturing Research, 1(4),
`382-404. https://www.inderscienceonline.com/doi/abs/10.1504/IJMR.2006.012252
`23 Vyatkin, V. V. (2006). The potential impact of the IEC61499 standard on the progress of distributed intelligent
`automation.
`International
`journal of manufacturing
`technology
`and management, 8(1-3), 107-125.
`https://www.inderscienceonline.com/doi/abs/10.1504/IJMTM.2006.008801
`24 P. Hawking, et al., "Emerging issues in location based tourism systems," International Conference on Mobile Business
`(ICMB'05), Sydney, NSW, 2005, pp. 75-81. https://ieeexplore.ieee.org/abstract/document/1493591
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`and free format messaging to make and execute intelligent decisions by accessing and applying
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`intelligent automated assistant technology as described in the '651 specification or explained in the
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`claims (e.g., Claim 1: a, f, and g; Claim 2: a, f, and g; and Claim 3: a, f, g, and h).
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`VIII. U.S. PATENT NO. 9,747,651
`
`27.
`
`Claim 1 of the '651 patent states:
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`1. A rule capable intelligent automated assistants (IAA) system for use with
`remote wireless handheld computing devices and the internet, comprising:
`a) at least one hospitality software back-office application with at least one
`IAA-based interface and enabled to execute one or more rules while communicating
`via free format messaging and at least one interface with fixed format messaging
`communications with web browsers for communicating bi-directionally with two or
`more different remote wireless handheld computing devices;
`b) a master database containing data and parameters of the at least one
`hospitality software application pursuant to a master database file structure with
`predefined formats and specific fields and which is accessible through a database
`application programming interface (API);
`c) at least one computer server, with associated data storage capabilities for
`the at least one hospitality software application, and the master database;
`d) at least one application software based communications control module
`(CCM) integrated with the hospitality application software and enabled to interface
`with at least one communications protocol;
`e) at least one web server enabled by the CCM to concurrently communicate
`via the internet with two or more different remote wireless handheld computing
`devices;
`f) at least one wireless handheld remote computing device with at least one
`IAA mobile application and user interface with free format messaging that enables
`access to and communications with the back office hospitality software application
`and its IAA-based interface;
`g) at least one other wireless handheld remote computing device which uses
`a web browser based user interface with fixed format messaging to access and
`communicate with the back office hospitality application software;
`h) at least one external application programming interface for fully integrating
`via the internet the hospitality back office software application with one or more non
`hospitality software applications;
`wherein the system elements are enabled to communicate bi-directionally in
`real time via the back office hospitality application software and the database API
`and the communications control module while utilizing the parameters and data of
`the master database file structure in interfacing the back office hospitality software
`application between and with the two or more remote wireless handheld computing
`devices with their different user interfaces while maintaining consistency with the
`master database.
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`28.
`
`Claim 2 of the '651 patent states:
`
`2. A rule capable intelligent automated assistants (IAA) system for use with
`remote wireless handheld computing devices and the internet, comprising:
`a) at least one hospitality software back-office application with at least one
`IAA-based interface and enabled to execute one or more rules while communicating
`via free format messaging and at least one mobile software application based
`interface with combined free and fixed format messaging communications for
`communicating bi-directionally with two or more different remote wireless handheld
`computing devices;
`b) a master database containing data and parameters of the at least one
`hospitality software application pursuant to a master database file structure with
`predefined formats and specific fields and which is accessible through a database
`application programming interface (API);
`c) at least one computer server, with associated data storage capabilities for
`the at least one hospitality software application, and the master database;
`d) at least one application software based communications control module
`(CCM) integrated with the hospitality application software and enabled to interface
`with at least one communications protocol;
`e) at least one web server enabled by the CCM to concurrently communicate
`via the internet with two or more different remote wireless handheld computing
`devices;
`f) at least one wireless handheld remote computing device with at least one
`IAA mobile application and user interface with free format messaging that enables
`access to and communications with the back office hospitality software application
`and its IAA-based Interface:
`g) at least one other wireless handheld remote computing device which uses
`a mobile hospitality software application based user interface with combined free and
`fixed format messaging to access and communicate with the back office hospitality
`application software;
`h) at least one external API for fully integrating via the internet the hospitality
`back office software application with one or more non hospitality software
`applications;
`wherein the system elements are enabled to communicate bi-directionally in
`real time via the back office hospitality application software and the database API
`and the communications control module while utilizing the parameters and data of
`the master database file structure in interfacing the back office hospitality software
`application between and with the two or more remote wireless handheld computing
`devices with their different user interfaces while maintaining consistency with the
`master database.
`
`29.
`
`Claim 3 of the '651 patent states:
`
`3. A rule capable intelligent automated assistants (IAA) system for use with
`remote wireless handheld computing devices and the internet, comprising:
`a) at least one hospitality software back-office application with at least one
`IAA-based interface and enabled to execute one or more rules while communicating
`
`
`
`10
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`via free format messaging and at least one interface with web browsers with fixed
`format messaging communications and with at least one mobile software application
`interface with
`fixed
`format messaging communications for bi-directional
`communications with three or more different remote wireless handheld computing
`devices;
`b) a master database containing data and parameters of the at least one
`hospitality software application pursuant to a master database file structure with
`predefined formats and specific fields and which is accessible through a database
`application programming interface (API);
`c) at least one computer server, with associated data storage capabilities for
`the at least one hospitality software application, and the master database;
`d) at least one application software based communications control module
`(CCM) integrated with the hospitality application software and enabled to interface
`with at least one communications protocol;
`e) at least one web server enabled by the CCM to concurrently communicate
`via the internet with three or more different remote wireless handheld computing
`devices;
`f) at least one wireless handheld remote computing device with at least one
`IAA mobile application and user interface via free format messaging that enables
`access to and communications with the back office hospitality software application
`and its IAA-based interface;
`g) at least one other wireless handheld remote computing device which uses
`a web browser based user interface with fixed format messaging to access and
`communicate with the back office hospitality application software;
`h) at least one other wireless handheld remote computing device which uses
`a mobile hospitality software application based user interface with fixed format
`messaging to access and communicate with the back office hospitality application
`software;
`i) at least one external API for fully integrating via the internet the hospitality
`back office software application with one or more non hospitality software
`applications;
`wherein the system elements are enabled to communicate bi-directionally in
`real time via the back office hospitality application software and the database API
`and the communications control module while utilizing the parameters and data of
`the master database file structure in interfacing the back office hospitality software
`application between and with the three or more remote wireless handheld computing
`devices with their different user interfaces while maintaining consistency with the
`master database.
`
`30.
`
`The inventions claimed in the '651 patent enhance the functionality of a computer
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`system by: (1) being able to automatically understand, convert, and execute both structured and
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`unstructured data, (2) being able to concurrently execute both free and fixed format messaging
`
`through a variety of communication conversions, and (3) being able to make intelligent decisions by
`
`
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`11
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`Case 1:20-cv-00518-GBW Document 1-2 Filed 04/16/20 Page 14 of 64 PageID #: 74
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`accessing and applying intelligent automated assistants technology.
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`31.
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`Further, as detailed in the above Background section, prior to 2005, the combination
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`of enabling technologies disclosed in the '651 patent to accomplish this type of integrated
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`functionality did not exist and was non-conventional.
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`32.
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`A POSITA would not have been able to develop such an intelligent system prior to
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`July 2005 without the disclosures of the '651 patent specification because, at the time, mobile
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`handheld devices had limited processing power needed to handle intelligent decision making, data
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`conversion technologies were inadequate, wireless networks were too slow and nobody had
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`conceived of nor demonstrated how a computer system would be able to automatically understand,
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`convert, and execute both structured and unstructured data, be able to concurrently execute both free
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`and fixed format messaging through a variety of communication conversions, and be able to make
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`intelligent decisions by accessing and applying intelligent automated assistants technology.
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`33.
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`Thus, the inventions claimed in the '651 patent were not available prior to July 2005,
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`and were neither routine nor conventional. The claimed inventions were innovative and enhanced
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`the operation of computer systems using remote wireless handheld devices.
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`34.
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`The claims as understood by a POSITA, after reading the specification and reviewing
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`the figures, provide a roadmap for how to develop a computer system optimized for hospitality
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`applications (e.g., online reservations using a handheld device that utilizes both fixed and free format
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`messaging and intelligent automated assistant technologies). The claims themselves also guide a
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`POSITA and provide a roadmap of how to build and integrate the disclosed computer system.
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`Namely, the '651 patent includes: an architecture, measures of effectiveness and performance, and
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`technical guidance and requirements.
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`Case 1:20-cv-00518-GBW Document 1-2 Filed 04/16/20 Page 15 of 64 PageID #: 75
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`35.
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`The architecture25 of the system is described in the claims and includes a clear
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`example of how the components of the system integrate and intercommunicate is specified and
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`shown in Figure 10 "Ameranth 21st Century Communications Integration With Conversion
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`Technologies." Accordingly, the architecture contains the framework and components necessary to
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`implement the system and prescribes the arrangement and integration of the components needed to
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`take advantage of the innovative technical functionality described in the '651 patent.
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`36.
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`As an example, with reference to claim 1, of particular importance are the
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`"Communication Conversions" components (indicated with the red arrows added for emphasis),
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`which generally correspond to the claimed "at least one hospitality software back-office application
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`with at least one IAA-based interface and enabled to execute one or more rules while communicating
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`via free format messaging and at least one interface with fixed format messaging communications
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`with web browsers for communicating bi-directionally with two or more different remote wireless
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`handheld computing devices" (Claim 1: a; See also e.g., Claim 2: a; Claim 3: a), "at least one wireless
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`handheld remote computing device with at least one IAA mobile application and user interface with
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`free format messaging that enables access to and communications with the back office hospitality
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`software application and its IAA-based interface" (Claim 1: f; See also e.g., Claim 2: f; Claim 3: f),
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`and "at least one other wireless handheld remote computing device which uses a web browser based
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`user interface with fixed format messaging to access and communicate with the back office
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`hospitality application software." (Claim 1: g; See also e.g., Claim 2: g; Claim 3: g, h) (emphasis
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`added).
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`37.
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`The "Ameranth Middleware/Framework" in the center of Figure 10 include