PETITION FOR POST-GRANT REVIEW OF
`U.S. PATENT NO. 8,326,924
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`U.S. Class:
`
`Group Art Unit:
`
`Conf. No.:
`
`Petition filed: ___________
`
`FILED ELECTRONICALLY PER
`37 C.F.R. § 42.6(B)(1)
`
`In re Covered Business Method Post-
`Grant Review of:
`
`U.S. Patent No: 8,326,924
`
`Issued: December 4, 2012
`
`Applicant: Harvey Lunenfeld
`
`Filed: August 1, 2012
`
`Title: METASEARCH ENGINE FOR
`ORDERING AT LEAST ONE
`ITEM RETURNED IN
`SEARCH RESULTS USING
`AT LEAST ONE QUERY ON
`MULTIPLE UNIQUE HOSTS
`AND FOR DISPLAYING AS-
`SOCIATED ADVERTISING
`
`
`
`
`DECLARATION OF GARY LIAO
`IN SUPPORT OF PETITION FOR POST-GRANT REVIEW OF A
`COVERED BUSINESS METHOD UNDER 35 U.S.C. § 321 AND AIA, § 18
`
`
`
`MAIL STOP PATENT BOARD
`PATENT TRIAL AND APPEAL BOARD
`U.S. Patent and Trademark Office
`P.O. BOX 1450
`ALEXANDRIA, VA 22313-1450
`
`

`

`
`
`1. My name is Gary Liao. I am currently President and owner of Where
`
`Exactly, Inc., an Oregon Corporation founded in 2005, providing software consult-
`
`ing, computer and software forensics, and location specific advertising services. I
`
`have a Bachelor of Science degree in Electrical Engineering from University of
`
`California, San Diego (1988), and a Master of Business Administration degree
`
`from Portland State University (1999).
`
`2.
`
`I have spent the last 25 years working either as a software engineer, or
`
`as a consultant focused on analyzing software. From 1988 to 2005, I worked for a
`
`range of companies as a software engineer including Advanced Micro Devices,
`
`The Scripps Research Institute, Biosym Technologies, Charles Schwab & Co.,
`
`Inc., Integrated Surgical Systems, Inc., DAT Services, Inc., Intel Corp., Step Tech-
`
`nology, Webridge, Inc., and SoftSource Consulting. In 2005, I started my own In-
`
`ternet Advertising and Consulting company, WhereExactly, Inc.
`
`3.
`
`In 1996, I designed and implemented a message oriented middleware
`
`protocol for a distributed database client-server Internet based application.
`
`Through 1999, I was the technical lead providing architectural guidance and/or
`
`software developer for e-commerce stores including model.com, clique.com,
`
`forbes.clique.com, animalfairboutique.com, skinet.clique.com, gear.com, dan-
`
`ner.com, and 800.com. These various websites provided e-commerce functionality
`
`using various technologies including Microsoft Site Server Commerce Edition,
`
`
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`Microsoft SQL Server, and Cybercash for credit card transactions. I was also the
`
`technical lead and architect for the Oregon Department of Fish and Wildlife
`
`(ODFW) Point of Sale (POS) system. This project enabled the sale of all Oregon
`
`Department of Fish and Wildlife fishing and hunting licenses, tags, parking per-
`
`mits, and raffle tickets throughout the state of Oregon. This system utilized a 3-tier
`
`client-server architecture over the Internet with each client computer utilizing an
`
`Internet Browser at all Point-of-sale locations to conduct the transactions to a cen-
`
`tral server. Through 2004, I joined an Internet startup, Webridge. As the name
`
`suggests, Webridge provided technology using the Web (Internet) to create a
`
`Bridge between businesses and consumers, and between businesses and businesses.
`
`Among other tasks, I was tasked to incorporate various technologies into the prod-
`
`uct solutions including Microsoft Commerce Server 2000 and Biztalk Server.
`
`Webridge, as well as many other technology companies of the early 2000’s, strug-
`
`gled to address the challenges of scale; how to increase the number of client com-
`
`puters and still provide adequate performance. So, I am well aware of the tech-
`
`nical challenges for accomplishing scale at that time. Currently, I provide Internet
`
`advertising and consulting services. I provide Search Engine Optimization (SEO)
`
`and other consulting services to various websites and currently provide software
`
`development consulting services to Johns Hopkins University School of Medicine,
`
`Johns Hopkins University School of Public Health, Huron Consulting Group, and
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`
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`Ochsner Health Systems, and I provide litigation consulting services for a number
`
`of clients as well.
`
`4.
`
`Based on the above experience and qualifications, I have a solid un-
`
`derstanding of the knowledge and perspective of a person of ordinary skill in this
`
`technical field in 1999-2001.
`
`5.
`
`I have no financial interest in the outcome of the related litigations or
`
`this proceeding.
`
`6.
`
`Counsel for petitioners have asked me to provide my opinions regard-
`
`ing the technology, field and state of the art, and the level of ordinary skill in the
`
`art concerning U.S. Patent Application No. 09/791,264 (“the 2001 application”),
`
`and U.S. Patent No. 8,326,924.
`
`7.
`
`I have reviewed the following materials:
`
`a)
`
`1001: U.S. Patent No. 8,326,924 (filed Aug. 1, 2012, issued
`
`Dec. 4, 2012),
`
`b)
`
`1004: U.S. Patent Application No. 09/791,264 (filed Feb. 22,
`
`2001),
`
`c)
`
`1005: May 5, 1998, Mamma.com Web site captured by Internet
`
`Archives,
`
`d)
`
`1006: 1996 Xerox Knowledge Broker (Borghoff, et al., Con-
`
`straint-based Information Gathering for a Network Publication System, Proc.
`
`
`
`Page 3
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`
`
`PAAM ’96, Apr. 22-24, 1996, London, U.K.),
`
`e)
`
`1007: 1997 Xerox Knowledge Broker (Borghoff, et al., Proc.
`
`PAAM ‘97, Apr. 21-23, 1997, London, U. K.)
`
`The 2001 Application
`
`8.
`
`The only type of search described in the 2001 application was an un-
`
`structured keyword search in which matches are sought for one or more attribute-
`
`less keywords regardless of the semantic meaning of those word(s) in the matching
`
`documents. The 2001 application did not describe (or enable) any other type of
`
`search beyond attribute-less keyword searches.
`
`a)
`
`b)
`
`c)
`
`It did not disclose any Boolean “OR” or other Boolean search.
`
`It did not disclose any natural language search.
`
`It did not describe an ordered keyword phrase search or exact
`
`keyword phrase search. Although it did give examples of multiple keywords
`
`in the same search, there is no indication that those multiple keywords were
`
`treated as a phrase. In other words, there was no indication that they were
`
`sent to a search engine as a phrase search rather than just as multiple key-
`
`words. For instance in Fig 14a, the example includes a search for “Catcher
`
`in the Rye.” This is an example of a multiple keyword search. An ordered
`
`keyword phrase search would require that the words appear in the order re-
`
`quested in the search form with possibly some intervening words between
`
`
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`the terms. An exact keyword phrase search would require the words appear
`
`in the requested order and with no intervening words. Additional infor-
`
`mation would be required to inform the search engine how to perform the
`
`search and interpret request terms. I find no example of providing additional
`
`information about how to interpret multiple keyword search terms.
`
`d)
`
`It did not disclose any structured (parametric) searching in
`
`which a user provides values for particular fields or attributes or parameters
`
`having semantic meaning. It did not, for example, disclose a user entering a
`
`value for a desired item’s title, or price, or author, or date of publication, or
`
`publisher, etc., as would be the case in a structured search.
`
`9.
`
`The 2001 application declares many capabilities. But, the application
`
`does not teach specific technical solutions to provide the promised capabilities. It
`
`did not describe the structure, configuration or programming of any specific hard-
`
`ware or software elements that supposedly provide the promised capabilities. For
`
`example,
`
`a)
`
`The 2001 application identifies element “PS(18)” as supposedly
`
`providing many of the promised capabilities. But, it did not describe any-
`
`thing specific inside PS(18) that supposedly has the promised capabilities.
`
`The closest the 2001 application comes to explaining what is inside PS(18)
`
`is a blank box labeled optional database (Fig. 53A), but this does not further
`
`
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`
`
`
`describe how PS(18) parses, processes, formats, sorts, and/or groups the re-
`
`quest inputs nor the resulting responses. The 2001 application does not de-
`
`scribe any modules, components, APIs, objects, or functionally inside this
`
`PS(18) for doing any of the supposed functions of PS(18).
`
`b)
`
`The 2001 application did not describe any particular type of da-
`
`ta communications protocols, such as Web Services, XML, SOAP, HTTP,
`
`SMTP, FTP, or remote procedure calls.
`
`c)
`
`The 2001 application did not describe any particular middle-
`
`ware technology. For example, a distributed transaction server, or transac-
`
`tion server, or object request broker, etc.
`
`d)
`
`The 2001 application did not describe any particular program-
`
`ming or script language, such as C, C++, Java, or Perl, etc.
`
`e)
`
`The 2001 application did not describe any particular type of
`
`computing/programming
`
`technology, such as Enterprise Java Beans,
`
`servlets, objects, etc.
`
`f)
`
`g)
`
`The 2001 application did not describe any particular APIs.
`
`The 2001 application did not describe any particular storage
`
`technology, such as relational database, SQL database, object-oriented data-
`
`base, etc., or caching, flash memory, etc.
`
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`
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`h)
`
`The 2001 application did not describe any presentation layer
`
`technologies used to deliver video and audio and/or combinations to the user
`
`interfaces.
`
`10. The 2001 application did not describe how the supposed functions
`
`promised in the 924 patent, are actually performed, or enable those of skill in the
`
`art in 2001 to achieve these functions following the teachings of the application.
`
`For example, the 2001 application did not describe how to:
`
`a)
`
`process an “infinite number” of substantially simultaneous
`
`searches, such as multiple-language searches. (Ex. 1001, 126:17-21).
`
`b)
`
`perform a “substantially infinite variety of the queries” (id.,
`
`108:53, 110:11-12), to a “substantially infinite variety of the server address-
`
`es” (id., 109:61-67) of a user’s choosing, or how a “substantially infinite va-
`
`riety of URL’s, links, locations, sites, servers, and/or clients, other items
`
`and/or objects may be used with the client-server multitasking system 10 of
`
`the present invention” (id., 111:9-12).
`
`c)
`
`discover a search target’s query interface or language model,
`
`especially for a “substantially infinite variety” (id., 109:61-67, 111:9-13) of
`
`search targets chosen by a user, or search a search target without first dis-
`
`covering that interface and model.
`
`
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`d)
`
` translate a specific user query into different native queries for
`
`multiple search targets chosen by a user.
`
`e)
`
`search a group of people with similar values, thoughts or vi-
`
`sions, etc. (Id., 142:51-59).
`
`f)
`
`sort the results from disparate search targets “by order of . . .
`
`relevance” or “order of importance,” and also “removes duplicates,” and al-
`
`so “is capable of, for example, determining best query results, with respect
`
`to a plurality of search engine results.” (Id., 2:49-67; 7:10-29; 8:32-35;
`
`55:15-26; 59:53-65; 103:35-53; 104:57-60; 110:53-111:4; 126:60-63).
`
`g)
`
`achieve “unlimited multitasking and search capabilities.” (Id.,
`
`126:60-63).
`
`h)
`
`place orders for purchasing multiple products of multiple ven-
`
`dors with grouping, sorting, rank, and item/price comparisons, in dynamic
`
`rapidly changing environments. (Id., 4:9-12).
`
`i)
`
`Place orders and/or purchases automatically without user inter-
`
`vention. (Id., 112:39-43).
`
`11. The 924 patent promises many capabilities, but the 2001 application
`
`did not teach one of skill in the art how to achieve those promised capabilities.
`
`One example is the supposed ability to search “servers” comprising people tied to-
`
`gether by values, visions, thoughts, etc. (Ex. 1001, 142:53-59). Another is the pa-
`
`
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`tent’s promise that its invention “is capable of expanding the universe to an infinite
`
`number of simultaneous searches in multiple languages.” (Id., 126:18-19). Anoth-
`
`er is its declaration of “unlimited multitasking and search capabilities.” (Id.,
`
`126:60-61). Others are its promises to handle a “substantially infinite variety of
`
`the queries,” (id., 108:52-53) to a “substantially infinite variety of the server ad-
`
`dresses,” (id., 109:63-64) and that a “substantially infinite variety of URL’s, links,
`
`locations, sites, servers, and/or clients, other items and/or objects may be used with
`
`the client-server multitasking system 10 of the present invention.” (Id., 111:9-12).
`
`The patent proclaims that the user need only provide the queries and the names of
`
`any servers the user chooses to be searched, anywhere in the world (or “space
`
`based” (Id., 107:45–107:46)), and the “invention” does the rest. (Id., 75:3-22).
`
`The patent says that the client, the server, and the PS(18) each may be an URL
`
`(Uniform Resource Locator): “The clients C.sub.1 . . . C.sub.n (16), the server PS
`
`(18), the servers S.sub.1 . . . S.sub.z (20), and/or the optional servers SO.sub.1 . . .
`
`SO.sub.p (22) may be search engines, and/or sites, and/or servers, and/or clients,
`
`and/or URL's, and/or databases, and/or locations on the network, and/or other suit-
`
`able components and/or systems, and/or other suitable means, and/or combinations
`
`thereof, which may be capable of communicating on the network 24.” (Id.,
`
`106:54-106:61). An URL is simply an address, so this assertion is non-sensical.
`
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`The 2001 application did not describe or enable persons of skill in the art to create
`
`any such structure or programming capable of the above feats.
`
`12. The 924 patent purports to encompass “all suitable means” that might
`
`exist. It also seeks to encompass all other means “on the horizon”: “The scope of
`
`the client-server multitasking system 10 of the present invention . . . , however, is
`
`not limited to . . . other suitable means, . . . , as it is recognized that other compo-
`
`nents, systems, technologies, and/or operating systems exist and/or emerge that
`
`may make use of the benefits of the present invention, and are either on the horizon
`
`and/or are recognized to be forthcoming.” (Ex 1001, 106:61-107:6).
`
`Descriptions Added to Patent After 2001 Application
`
`13. Compared to the 2001 application, the 924 patent expands the scope
`
`and meaning of the term “server.” For example, the patent expands “server” to in-
`
`clude:
`
`a)
`
`a wireless sensor node the size of “a grain of dust.” For exam-
`
`ple, the patent added: “The size of a single sensor node can vary from shoe-
`
`box-sized nodes down to devices the size of a cubic millimeter or even down
`
`to the size of a grain of dust. Sensor nodes may be considered to be small
`
`computers or servers, or server devices.” (Ex. 1001, 139:60-65).
`
`b)
`
`c)
`
`“nanoscale” computers. (Id., 114:7-8).
`
`a “wireless robot.” (Id., 114:4-5).
`
`
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`d)
`
`e)
`
`f)
`
`a “cellular phone.” (Id., 114:6).
`
`a “Really Simple Syndication feed,” etc. (Id., 114:19-114:20).
`
`“social networks”: “any one or more of the servers . . . of the
`
`client-server multitasking system 10/metasearch system may comprise one
`
`or more social networks and/or one or more small world networks.” (Id.,
`
`142:24-142:28). This added disclosure in the patent, relative to the 2001 ap-
`
`plication, defined “social networks” expansively, in part as follows: “Social
`
`networks that are social in context typically comprise social structures that
`
`may be viewed in terms of social relationships, in which the nodes generally
`
`comprise individuals and/or organizations that are tied together by interde-
`
`pendencies, such as values, friends, relationships, ideas, philosophies,
`
`thoughts, trade, financial exchange, visions, likes, dislikes, conflicts, links,
`
`kinship, disease transmission, travel routes, technologies, interests, and/or
`
`other suitable interdependencies.” (Id., 142:51-59). The 2001 application
`
`did not describe or enable simultaneously posing queries to a collection of
`
`people united by values, thoughts, visions, conflicts, disease transmission,
`
`etc.
`
`14. Some of these technologies the patent describes as examples of a
`
`“server” did not even exist in 2001. For example, the patent describes, “In more
`
`detail, the client-server multitasking system 10/metasearch system of the present
`
`
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`invention may be used to send user requests to and group, sort, and return results
`
`from each of the servers S1 ... S2 (20) and/or the optional servers SO1 … SOp(22),
`
`which may comprise and/or be from the group consisting of: …at least one na-
`
`noscale server, at least one nanoscale computer, at least one nanocomputer.” (Ex
`
`1001,
`
`113:42-114:8)
`
`But
`
`from
`
`encyclopedia.com
`
`(
`
`http://www.encyclopedia.com/doc/1G2-3401200582.html ) regarding nanocompu-
`
`ting:
`
`“Nanocomputing describes computing that uses extremely small, or
`
`nanoscale, devices (one nanometer[nm] is one billionth of a meter).
`
`In 2001, state-of-the-art electronic devices could be as small as about
`
`100nm, which is about the same size as a virus. … since the beginning
`
`of the 2000s, the term “nanocomputing” has been reserved for device
`
`features well below 50 nm to even the size of individual molecules,
`
`which are only a few nm.”
`
`15. Compared to the 2001 application, the 924 patent expanded the scope
`
`and meaning of “client device.” For example, the 924 patent lists many different
`
`types of clients the invention may include, including “a nanoscale server, a
`
`nonscale computer, a nanocomputer, …” (id., 134:34-49) even though nanocompu-
`
`ting was not mentioned in the 2001 application, similar to how “server” was ex-
`
`panded.
`
`
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`16. Compared to the 2001 application, the 924 patent expanded the scope
`
`and meaning of “metasearch engine.” For example, the term “metasearch” was not
`
`used in the 2001 application, but the following was requested to be amended to the
`
`Specification: “The client-server multitasking system and process should be capa-
`
`ble of performing as a multiple query search engine, which performs multiple que-
`
`ries of multiple sites, and of performing as a single point of sale for purchasing
`
`multiple products from multiple sources.” But the 924 patent expands the scope
`
`with many additional features and applications, including, “Homeland Securi-
`
`ty/quick response intelligence gathering/anti-terrorist applications/military applica-
`
`tions, including multiple simultaneous data acquisition and analysis capabilities,
`
`such as database queries of facial signatures, recognition, fingerprinting, signature
`
`analysis, and identification systems, and a multiple battlefield tactical and strategic
`
`observation and analyses in real time.” (Ex. 1001, 118:21-28). But there is no
`
`teaching in the 2001 application regarding how to search for facial signatures,
`
`recognition, fingerprinting, etc.
`
`The 2001 Application Did Not Describe The Claimed Combinations
`
`17. Each 924 Patent claim recites the combination of steps of receiving a
`
`request for an item that can be ordered, causing an advertisement associated with
`
`that request or item to be displayed in the response, and receiving and processing
`
`an order for that same item, among other things.
`
`
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`18. Unlike the 924 Patent, the 2001 application does not refer to “key-
`
`word advertisements.” It does give two examples of advertisements related to a
`
`search term, in Figs. 36A and 46A. In Fig. 46A, the search terms were “sports”
`
`and “television,” and ads were returned for sportsonline.com and USA Today TV.
`
`In Fig. 36A, one search term was “sports” and the same sportsonline.com ad was
`
`returned. But, neither of these Figures refers to ordering anything, and certainly
`
`not ordering “sports” or “television.” The 2001 application gave no example of the
`
`same item being (1) requested, (2) advertised in response to a keyword used in that
`
`request, and (3) ordered and the order processed, as recited in these claims.
`
`19.
`
`924 patent claim 1 recites “(e) causing at least one advertisement as-
`
`sociated with the at least one item that may be ordered to be displayed in the re-
`
`sponse; (f) communicating the response from the metasearch engine to the client
`
`device; (g) receiving another Hypertext Transfer Protocol request from the client
`
`device for placing an order for the at least one item; (h) processing the order.” The
`
`2001 application describes no example of any structure capable of consolidating
`
`results from a substantially infinite variety of “servers” into a response, and then
`
`performing these item-advertisement and item-order processing steps.
`
`20.
`
`I have reviewed and analyzed the below chart provided to me by Peti-
`
`tioners and edited by me. It fairly describes the disclosures of the cited references
`
`(Exs. 1005-07) and how they correspond to the method recited in claim 1 of the
`
`
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`924 patent, from the perspective of a person of ordinary skill in the art in 1999-
`
`2001.
`
`
`
`CLAIM
`ELEMENT
`
`MAMMA.COM &
`KNOWLEDGE BROKER CLAIM MAPPINGS
`
`1. A process for
`metasearching on the
`Internet, wherein the
`steps of the process
`are performed by a
`metasearch engine
`executing on a hard-
`ware device, the pro-
`cess comprising the
`steps of:
`
`Mamma.com: A Web-server-based “meta search engine”
`that sends a user’s unstructured keyword query(ies) to oth-
`er Web search engines, and groups, sorts and returns the
`results to the user. (Ex. 1005, pp. 4-7).
`
`
`Knowledge Broker: “[A] uniform meta-search interface”
`sends a user’s unstructured keyword query(ies) to “differ-
`ent search engines” (Ex. 1007, pp. 4-5, 13) including
`“Webcrawlers” (id., Fig. 4), and groups, sorts and returns
`the results to the user (id., Sec. 3). (See also Ex. 1006,
`Sec. 4).
`
`(a) receiving a Hyper-
`text Transfer Protocol
`request from a client
`device for the
`metasearch engine to
`send at least one
`search query to a plu-
`rality of unique hosts
`that provide access to
`information to be
`searched, wherein the
`Hypertext Transfer
`Protocol request from
`the client device is
`associated with at
`least one item that
`may be ordered from
`a plurality of items
`
`Mamma.com: Client Web browsers send a keyword or
`keyword-phrase query to the mamma.com Web server, for
`it to be processed and sent to the six listed Web search en-
`gines. (Ex. 1005, pp. 1, 4). Companies may purchase tar-
`geted keyword ads (in which advertisements appear only
`in response to a search using one of the advertiser-selected
`keywords or keyword phrases). Also, companies may
`provide a download icon for their items, which the user
`clicks to download the item. (Id., p. 8).
`
`
`
`Knowledge Broker: Users simultaneously search “dif-
`ferent search engines” (Ex. 1007, Sec. 1.4, pp. 4-5) by re-
`questing, over the Web, the meta search engine to launch
`one or more simultaneous queries to the plural search en-
`gines, including “several queries concurrently” (Id., pp. 8-
`12, Figs. 3, 4). Users order items described in the search
`results. (Id., pp. 4-5, 8-12; Sec. 4, pp. 12-13). (See also
`Ex. 1006, pp. 4-5).
`
`
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`
`
`CLAIM
`ELEMENT
`
`MAMMA.COM &
`KNOWLEDGE BROKER CLAIM MAPPINGS
`
`that may be ordered;
`
`(b) sending the at
`least one search query
`to the plurality of
`unique hosts in re-
`sponse to the Hyper-
`text Transfer Protocol
`request received from
`the client device;
`
`(c) receiving search
`results from the plu-
`rality of unique hosts
`in response to the at
`least one search query
`sent to the plurality of
`unique hosts;
`
`(d) incorporating the
`received search re-
`sults into a results list
`and incorporating the
`results list into a re-
`sponse;
`
`Mamma.com: “[P]roperly formats queries and sends
`them to the best search engines on the Web.” (Ex. 1005,
`p. 12).
`
`
`
`Knowledge Broker: For each of multiple servers, a
`“wrapper receives the description of the constraints corre-
`sponding to the query, translates them into the query-string
`required by the search script, . . . . It then queries the serv-
`er . . . .” (Ex. 1007, p. 12). (See also Ex. 1006, Sec. 4).
`
`Mamma.com: “Mamma will then organize the results in-
`to a uniform format, and presents them by relevance and
`source.” (Ex. 1005, pp. 3, 4).
`
`
`
`Knowledge Broker: “It then queries the server and re-
`ceives the results in html format. Finally it parses the re-
`sults and translates them into the constraint format accept-
`ed by the CBKB system.” (Ex. 1007, p. 12). (See also Ex.
`1006, Sec. 4).
`
`Mamma.com: “Mamma will then organize the results in-
`to a uniform format, and presents them by relevance and
`source.” (Ex. 1005, pp. 3, 4).
`
`
`
`Knowledge Broker: “Present the results obtained from
`the different servers.” (Ex. 1007, p. 9). “Homogeniz[es]
`the presentation of results from different backends, e.g.
`presenting information always in the same order . . . .”
`(Id., p. 12). Users choose to view results in various for-
`mats and rankings. (Id., pp. 8-12). (See also Ex. 1006,
`Sec. 4).
`
`(e) causing at least
`one advertisement as-
`sociated with the at
`
`Mamma.com: Companies place advertisements about
`items, triggered by keywords or keyword phrases in que-
`ries. (Ex. 1005, pp. 7-9). They also may provide down-
`
`
`
`Page 16
`
`

`

`
`
`CLAIM
`ELEMENT
`
`MAMMA.COM &
`KNOWLEDGE BROKER CLAIM MAPPINGS
`
`least one item that
`may be ordered to be
`displayed in the re-
`sponse;
`
`(f) communicating
`the response from the
`metasearch engine to
`the client device;
`
`(g) receiving another
`Hypertext Transfer
`Protocol request from
`the client device for
`placing an order for
`the at least one item;
`
`load icons which a user clicks to download the item. (Id.,
`pp. 8-9).
`
`
`
`Knowledge Broker: Response describes the item to be
`ordered (Ex. 1006, Secs. 4.2 – 4.4; Ex. 1007, p. 10), and
`system offers to sell copy of item (Ex. 1006, pp. 4-5; Ex.
`1007, pp. 12-13). But, does not refer to “advertisements”
`being returned in addition to the search results themselves.
`
`Mamma.com: “Mamma will then organize the results in-
`to a uniform format, and presents them by relevance and
`source.” (Ex. 1005, pp. 3, 4).
`
`
`
`Knowledge Broker: User chooses format and specificity
`of the displayed results. (Ex. 1007, Sec. 3). (See also Ex.
`1006, Sec. 4).
`
`Mamma.com: Companies may provide a download icon
`for their items, which the user clicks to download the item.
`(Ex. 1005, pp. 8-9).
`
`Knowledge Broker: Users may select and order desired
`items using a Web browser. (Ex. 1007, pp. 4-5, 10, 12-
`13). (See also Ex. 1006, Sec. 4).
`
`
`
`
`
`(h) processing the or-
`der.
`
`Mamma.com: The item is downloaded from an ftp site.
`(Id., pp. 8-9).
`
`Knowledge Broker: The system services the client’s re-
`quest to place the order so that ordered items are delivered
`to the user in book form (Ex. 1007, pp. 4-5, 10, 12-13) or
`by printing at a local copy center (Ex. 1006, pp. 4-5).
`
`
`
`
`
`Page 17
`
`

`

`
`
`I declare under penalty of perjury under the laws of the United States that
`
`the foregoing is true and correct.
`
`Executed on the 26th day of September, 2013, in Scappoose, Oregon.
`
`
`
`
`
`
`
`Gary Liao
`
`
`
`
`
`Page 18
`
`