IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`Plaintiff,
`
`
`
`
`
`
`
`v.
`
`
`IMPROVED SEARCH LLC,
`
`
`
`
`
`AOL INC.,
`
`
`
`
`
`
`
`C.A. No. 15-262 (SLR) (SRF)
`
`)))))))))
`
`
`
`
`
`Defendant.
`
`
`AMENDED JOINT CLAIM CONSTRUCTION STATEMENT
`
`Plaintiff Improved Search LLC (“Improved Search”) and Defendant AOL Inc. (“AOL”)
`
`
`
`submit the following Amended Joint Claim Construction Statement, updating the Joint Claim
`
`Construction Statement submitted on October 4, 2016 [D.I. 51] to reflect the terms on which the
`
`parties have reached agreement, and the terms over which there remains a dispute.
`
`a.
`
`The Construction of Terms on Which the Parties Agree
`
`
`
`The parties have agreed upon the constructions of the following terms of the asserted
`
`claims:
`
`Claim Term/Phrase
`
`Agreed Construction
`
`1. receiving through an input device,
`a query /receiving from the user
`through an input device a query
`(’101 Patent, Claim 1; ’154 Patent
`Claim 1)
`
`2. first language
`(’101 Patent Claims 1, 2, 4, 25, 27,
`28; ’154 Patent, Claims 1, 7)
`
`3. content word
`(’101 Patent, Claim 1; ’154 Patent,
`Claims 1, 7)
`
`receiving on a user’s computer a query
`from an input device connected to that
`computer
`
`
`language in which the query is entered
`by a user
`
`a word other than a preposition, article,
`or pronoun
`
`AOL Ex. 1018
`Page 1 of 4
`
`
`FOR THE DISTRICT OF DELAWARE
`
`Plaintiff,
`
`
`
`
`
`
`
`v.
`
`
`IMPROVED SEARCH LLC,
`
`
`
`
`
`AOL INC.,
`
`
`
`
`
`
`
`C.A. No. 15-262 (SLR) (SRF)
`
`)))))))))
`
`
`
`
`
`Defendant.
`
`
`AMENDED JOINT CLAIM CONSTRUCTION STATEMENT
`
`Plaintiff Improved Search LLC (“Improved Search”) and Defendant AOL Inc. (“AOL”)
`
`
`
`submit the following Amended Joint Claim Construction Statement, updating the Joint Claim
`
`Construction Statement submitted on October 4, 2016 [D.I. 51] to reflect the terms on which the
`
`parties have reached agreement, and the terms over which there remains a dispute.
`
`a.
`
`The Construction of Terms on Which the Parties Agree
`
`
`
`The parties have agreed upon the constructions of the following terms of the asserted
`
`claims:
`
`Claim Term/Phrase
`
`Agreed Construction
`
`1. receiving through an input device,
`a query /receiving from the user
`through an input device a query
`(’101 Patent, Claim 1; ’154 Patent
`Claim 1)
`
`2. first language
`(’101 Patent Claims 1, 2, 4, 25, 27,
`28; ’154 Patent, Claims 1, 7)
`
`3. content word
`(’101 Patent, Claim 1; ’154 Patent,
`Claims 1, 7)
`
`receiving on a user’s computer a query
`from an input device connected to that
`computer
`
`
`language in which the query is entered
`by a user
`
`a word other than a preposition, article,
`or pronoun
`
`AOL Ex. 1018
`Page 1 of 4
`
`
`
`Claim Term/Phrase
`
`Agreed Construction
`
`4. search in the second
`language/searching in the second
`language
`(’101 Patent, Claim 1; ’154 Patent,
`Claims 1, 7)
`
`5. advertising cues
`(’154 Patent, Claims 1, 7)
`
`6. “means to send the search results
`and the matching advertising cues
`to the user’s computer screen”
`(’154 Patent, Claim 7)
`
`searching using only words in the
`second language including words from
`other languages that are used in the
`second language
`
`advertisements, as well as signals or
`references that direct a user to an
`advertisement
`
`Means Plus Function
`Function: to send the search results and
`the matching advertising cues to the
`user’s computer screen
`Structure: server and/or browser or
`equivalents
`
`
`
`
`
`b.
`
`Proposed Constructions of Disputed Terms
`
`The Parties’ proposed constructions of disputed terms are provided in the chart below.
`
`Claim Term, Phrase or
`Clause
`
`Improved Search’s Proposed
`Construction
`
`AOL’s Proposed
`Construction
`
`1. Translating
`(’101 Patent, Claims 1,
`25; ’154 Patent, Claims
`1, 7)
`
`2. second language
`(’101 Patent, Claims 1,
`5, 24, 27, 28; ’154
`Patent, Claims 1, 7)
`
`3. contextual search /
`contextually searching
`(‘101 Patent, Claims 1,
`24, 25; ’154 Patent
`Claims 1, 7)
`
`changing text from one
`language into an equivalent
`text in a different language
`
`language different from the
`first language, including
`different dialects of the first
`language
`
`identification of/identifying
`relevant documents from the
`domain-unlimited set of
`documents available on the
`World Wide Web, based on
`words contained in the
`documents.
`
`2
`
`changing text from one
`language into an equivalent
`text in a different language
`pre-selected by the user
`
`language different from the
`first language
`
`identification of relevant
`documents based on words
`contained in those documents
`
`AOL Ex. 1018
`Page 2 of 4
`
`
`
`Claim Term, Phrase or
`Clause
`
`Improved Search’s Proposed
`Construction
`
`AOL’s Proposed
`Construction
`
`4. dialectal
`standardization /
`dialectally
`standardizing /
`dialectally standardized
`(’101 Patent, Claim 1;
`’154 Patent, Claims 1,
`7)
`
`5. means for receiving
`from the user through
`an input device a query
`in the first language
`(’154 Patent, Claim 7)
`
`6. dialectal controller for
`dialectally
`standardizing a content
`word extracted from the
`query
`(’154 Patent, Claim 7)
`
`7. means to search the
`database of the
`advertising cues based
`on the relevancy to the
`translated content word
`(’154 Patent, Claim 7)
`
`
`
`to map keywords from
`different styles and dialects
`into standard and less
`ambiguous keywords
`
`changing a word to a more
`standard and less ambiguous
`word in a different dialect of
`the same language, if such a
`word is identified
`
`Means Plus Function:
`Indefinite (no disclosed
`structure)
`
`Means Plus Function:
`Indefinite (no disclosed
`structure)
`
`Means Plus Function:
`Indefinite (no disclosed
`structure)
`
`Means Plus Function:
`Function: receiving from the
`user through an input device a
`query in a first language
`Structure: Keyboard or
`equivalents
`
`This term is not governed by
`35 U.S.C. § 112(6). If it is
`ruled to be so governed,
`Improved Search submits that
`the following structures
`provide the function of
`“dialectally standardizing a
`content word extracted from
`the query”:
`Server or equivalents
`
`Means Plus Function:
`Function: to search the
`database of the advertising
`cues based on the relevancy to
`the translated content word
`Structure: Server or
`equivalents
`
`3
`
`AOL Ex. 1018
`Page 3 of 4
`
`
`
`
`
`
`
`
`
`
`FARNAN LLP
`
`/s/Michael J. Farnan
`
`
`
`
`Brian E. Farnan (#4089)
`Michael J. Farnan (#5165)
`919 North Market Street
`12th Floor
`Wilmington, DE 19801
`(302) 777-0300
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw.com
`
`Attorneys for Plaintiff
`
`OF COUNSEL:
`
`Robert Yorio
`CARR & FERRELL LLP
`120 Constitution Drive
`Menlo Park, CA 94025
`(650) 812-3400
`
`
`January 26, 2017
`
`
`
`
`
`
`
`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`
`/s/ Jack B. Blumenfeld
`
`
`
`
`Jack B. Blumenfeld (#1014)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19801
`(302) 658-9200
`jblumenfeld@mnat.com
`
`Attorneys for Defendant
`
`OF COUNSEL:
`
`Kevin Hardy
`Samuel Bryant Davidoff
`Melissa B. Collins
`Sanjiv P. Laud
`WILLIAMS & CONNOLLY LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
`(202) 434-5000
`
`
`4
`
`AOL Ex. 1018
`Page 4 of 4
`
`
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