`
`In the Inter Partes Review of U.S. Patent No. 7,797,717
`Trial No.: Not Yet Assigned
`Issued: September 14, 2010
`Filed: May 23, 1995
`Inventors: John Christopher Harvey, et al.
`Assignee: Personalized Media Communications, LLC
`Title: SIGNAL PROCESSING APPARATUS AND METHODS
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`DECLARATION OF CHARLES J. NEUHAUSER, Ph.D.
`UNDER 37 C.F.R.§ 1.68
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`I, Dr. Charles J. Neuhauser, do hereby declare:
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`1.
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`I am making this declaration at the request of Zynga, Inc. in the matter
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`of the Inter Partes Review of U.S. Patent No. 7,797,717 (“the ‘717 Patent.”)
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`2.
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`I am being compensated for my work in this matter at my standard
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`hourly rate of $375 for consulting services. My compensation in no way depends
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`on the outcome of this proceeding.
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`3.
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`In preparing this Declaration, I considered the following materials:
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`(a) U.S. Patent No. 7,797,717 to Harvey (“Harvey ‘717) (Exhibit
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`1001);
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`
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`(b) U.S. Patent No. 4,567,359 to Lockwood (“Lockwood”) (Exhibit
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`1008);
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`(c) U.S. Patent No. 4,825,045 to Humble (“Humble”) (Exhibit
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`1009);
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`
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`(d) U.S. Patent No. 4,204,206 to Bakula (“Bakula”) (Exhibit 1010);
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`and
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`(e) U.S. Patent No. 4,674,041 to Lemon (“Lemon”) (Exhibit 1011).
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`I.
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`Professional Background
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`4.
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`I am an engineer by training and profession. My current CV is
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`attached. I was awarded the degree of BSEE from the University of Notre Dame
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`in 1968. Directly after graduating I was employed by Bell Telephone Laboratories
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`(now Alcatel-Lucent) as a Member of the Technical Staff. In this capacity I
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`worked on the specification, testing and development of computer controlled data
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`and telephone switching systems for deployment in telephone central offices.
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`While I was at Bell Telephone Laboratories I received my MSEE from
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`Northwestern University under a company sponsored program.
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`5.
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`In 1971 I left Bell Telephone Laboratories to pursue a PhD in a newly
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`formed CS/EE program at the Johns Hopkins University. My degree was awarded
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`in 1980 based on my research into the use of emulation techniques in the
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`evaluation of computer architectures.
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`6.
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`In 1974 while working on my Ph.D. research I joined the Digital
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`Systems team at Stanford University as a research associate where I worked on the
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`2
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`development of an emulation system used for architectural research. From about
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`1972 I also worked part-time with Palyn Associates, Inc. (later Palyn-Gould
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`Group) (“Palyn) as a Member of the Technical Staff. At Palyn I worked initially
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`on the development of a range of commercial products based on emulation
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`concepts.
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`7.
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`In 1980 I joined Palyn full time as a member of their technical staff
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`and later as Director of Engineering and by 1985 as Vice President of Engineering.
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`Palyn was a consulting company with a range of international clients in the general
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`field of computer technology. My responsibilities at Palyn related to two broad
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`areas. First, I was responsible for directing product development on behalf of our
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`clients, and second, I consulted directly with clients on issues related to processor
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`and peripheral design. My work here related to main-frame processors, mini-
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`computers, micro-computers and systems that used such components.
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`8.
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`In my role directing product development I was responsible for the
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`specification, design, testing and debugging of a wide range of devices including
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`mini-computers, microprocessors and peripheral controllers, such as printers,
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`communications and printer interfaces. Work on these systems involved both
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`hardware and software development.
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`9.
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`In 1994 I began working as an independent consultant first doing
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`business as CTCS and later as Neuhauser Associates, Inc. Since that time my
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`3
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`professional work has focused on technical analysis of system primarily in the
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`support of litigation or potential litigation. I have worked extensively in the
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`analysis of patent claims both with respect to determining infringement and
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`invalidity. I also have experience in software copyright and technical trade secret
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`matters. From time to time I lead teams of engineers in testing and technical
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`evaluations.
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`10. At this time I have nearly 45 years of continuous professional
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`experience in the field of processors and systems controlled by such processors.
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`The Harvey ‘717 patent relates to system level interconnection of communication
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`and computer devices. It also relates to their control by computers in response to
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`signals. Over my engineering career I have designed many such computer
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`controlled systems.
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`11. Since 1972 I have had extensive experience with microprocessors and
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`systems controlled by such devices. In addition to the specification, design,
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`implementation, testing, debugging and deployment of such hardware systems, I
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`have also developed the support software for many such systems. Commonly, I or
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`the engineers I directed made use of microprocessor based systems to implement
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`communications functions or to control larger processors systems. This included
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`responding to certain protocols or developing our own protocols.
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`4
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`12.
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`In my current capacity as an independent consultant I have reviewed
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`and verified the operation of a wide variety of technical systems, including
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`processors, personal computers, television devices, peripherals and bus systems.
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`13.
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`In forming the opinions expressed in this report I have relied upon my
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`education and my 45 years of professional experience.
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`II. Relevant Legal Standards
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`14.
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`I have been asked to provide my opinion as to whether claims 1-7 and
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`9 of the ‘717 Patent are anticipated or would have been obvious to a person of
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`ordinary skill in the art at the time of the alleged invention, in view of the prior art.
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`15.
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`I am an engineer by training and profession. The opinions I am
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`expressing in this report involve the application of my engineering knowledge and
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`experience to the evaluation of certain prior art with respect to the Harvey ‘717
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`patent. My knowledge of patent law is no different than that of any lay person.
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`Therefore, I have requested the attorneys from Jones Day, who represent Zynga, to
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`provide me with guidance as to the applicable patent law in this matter. The
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`paragraphs below express my understanding of how I must apply current principles
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`related to patent validity to my analysis.
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`16.
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`It is my understanding that in determining whether a patent claim is
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`anticipated or obvious in view of the prior art, the Patent Office must construe the
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`claim by giving the claim its broadest reasonable interpretation consistent with the
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`5
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`specification. For the purposes of this review, I have construed each claim term in
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`accordance with its plain and ordinary meaning under the required broadest
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`reasonable interpretation.
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`17.
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`It is my understanding that a claim is anticipated under 35 U.S.C.
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`§ 102 if each and every element and limitation of the claim is found either
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`expressly or inherently in a single prior art reference.
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`18.
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`It is my understanding that a claim is unpatentable under 35 U.S.C. §
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`103 if the claimed subject matter as a whole would have been obvious to a person
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`of ordinary skill in the art at the time of the alleged invention. I also understand
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`that an obviousness analysis takes into account the scope and content of the prior
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`art, the differences between the claimed subject matter and the prior art, and the
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`level of ordinary skill in the art at the time of the invention.
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`19.
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`In determining the scope and content of the prior art, it is my
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`understanding that a reference is considered appropriate prior art if it falls within
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`the field of the inventor’s endeavor. In addition, a reference is prior art if it is
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`reasonably pertinent to the particular problem with which the inventor was
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`involved. A reference is reasonably pertinent if it logically would have
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`commended itself to an inventor’s attention in considering his problem. If a
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`reference relates to the same problem as the claimed invention, that supports use of
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`the reference as prior art in an obviousness analysis.
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`6
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`20. To assess the differences between prior art and the claimed subject
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`matter, it is my understanding that 35 U.S.C. § 103 requires the claimed invention
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`to be considered as a whole. This “as a whole” assessment requires showing that
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`one of ordinary skill in the art at the time of invention, confronted by the same
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`problems as the inventor and with no knowledge of the claimed invention, would
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`have selected the elements from the prior art and combined them in the claimed
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`manner.
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`21.
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`It is my further understanding that the Supreme Court has recognized
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`several rationales for combining references or modifying a reference to show
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`obviousness of claimed subject matter. Some of these rationales include:
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`combining prior art elements according to known methods to yield predictable
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`results; simple substitution of one known element for another to obtain predictable
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`results; a predictable use of prior art elements according to their established
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`functions; applying a known technique to a known device (method or product)
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`ready for improvement to yield predictable results; choosing from a finite number
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`of identified, predictable solutions, with a reasonable expectation of success; and
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`some teaching, suggestion, or motivation in the prior art that would have led one of
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`ordinary skill to modify the prior art reference or to combine prior art reference
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`teachings to arrive at the claimed invention.
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`7
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`III.
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`Person of Ordinary Skill in the Art
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`22.
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`It is my understanding that when interpreting the claims of the Harvey
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`‘717 patent I must do so based on the perspective of one of ordinary skill in the art
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`at the relevant priority date. My understanding is that the priority date of the
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`Harvey ‘717 patent is September 1987.
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`23. The Harvey ‘717 patent describes the interconnection and operation of
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`very well-known components. These components include television receivers,
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`radio receivers, amplifiers, micro-computers (“personal computers”), audio
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`recorders and video recorders, among other things. In addition, the Harvey ‘717
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`patent discusses at a general level various types of “signal decoders”, such as
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`television line decoders, used to decode radio and television signals, and switches
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`to direct these types of signals between various components. The Harvey ‘717
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`patent also describes simple signal and message formats.
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`24. The technology scope of the Harvey ‘717 patent may be discerned
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`easily by a simple review of the figures. These figures show components that were
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`very well known in 1987. What they do not show is any unusual circuitry or
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`interconnection of components. This is also true of the text of the Harvey ‘717
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`patent. Although the text of patent is extensive it does not describe the use of any
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`unusual technology beyond what is shown in the figures. For example, there are
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`no formulae, computer programs, descriptions of circuitry or the like. Basically,
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`8
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`the Harvey ‘717 patent relates to the interconnection of well-known components
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`and their control using widely known and understood techniques.
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`25. Based on my review of the specification of the Harvey ‘717 patent, it
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`is my opinion that one of ordinary skill in the art would be an engineer with a
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`Bachelor’s of Science in Electrical Engineering or a closely related field1. This
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`person would have between three and five years of experience beyond graduation
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`in the implementation of communications systems and controlling these systems
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`(or similar types of systems) through the use of computer technology. Someone
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`would be equally qualified if they had a Master’s of Science degree and somewhat
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`less practical experience.
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`26.
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`I am able to make this assessment because by 1987 I worked with,
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`supervised and hired engineers with these types of qualifications. These engineers
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`had the requisite knowledge to make and use systems as described in the claims of
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`the Harvey ‘717. Because I have worked with and supervised engineers with this
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`background I know very well what their capabilities were in September 1987 and
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`1 By the 1980’s most Electrical Engineer students took courses in communications
`and computer programming. Even in college these students would likely have had
`practical experience building systems based techniques similar to those described
`in the Harvey ‘717 patent.
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`9
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`how they would interpret the claims of the Harvey ‘717 patent and the disclosures
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`of the applicable prior art.
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`IV. Summary of the ‘717 Patent
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`27. The Harvey ‘717 patent contains nearly 300 columns of text and 22
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`drawing sheets. For brevity, I have limited my summary of the Harvey ‘717 patent
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`to one example embodiment described in the patent’s specification. I will do this
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`not from today’s perspective over 25 years after the priority date, but rather from
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`the perspective of what one of ordinary skill in the art would have understood in
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`1987.
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`28. One of ordinary skill in the art would recognize various commonly
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`used terms in the Harvey ‘717 patent, such as “control signal”, “device”, “storage”,
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`“computer program” and so forth. Other terminology, such as “complete
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`programming” can be interpreted based on the plain meaning of the words.
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`29. Basically, the Harvey ‘717 patent is related to the reception,
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`distribution, storage, and presentation of information carried on various types of
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`electrical signals. Much of the discussion and many of the examples shown in the
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`Harvey ‘717 relate to performing these activities on standard radio and television
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`signals. The Harvey ‘717 patent also assumes at places that such signals can
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`include embedded control signals using what were well-known techniques in 1987.
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`10
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`30. Most of the discussion in the Harvey ‘717 patent and the examples
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`given as preferred embodiments would be understood by one of ordinary skill in
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`the art to be system descriptions at a very high “block diagram” level. Block
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`diagrams are well-known representations used by engineers when they want to
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`convey general relationships between known components without having to give
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`details of their internal operation. This person would understand that the basic
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`technology of the Harvey ‘717 patent is the interconnection and control of various
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`building blocks, such as television receivers, computers, matrix switches, and so
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`forth.
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`31. The exemplary figure of the Harvey ‘717 patent is the rather
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`formidable Figure 7, which shows a very complex embodiment. However, the
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`some of the basics of the Harvey system can be understood more easily from the
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`much simpler Figure 1 shown below. With respect to the claims of the Harvey
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`‘717 I will present an example below called “Farm Plans of Europe” that might be
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`more relevant.
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`11
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`32. What is shown in this figure is a basic system that might make use of
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`the concepts expressed in the Harvey ‘717 patent. In this case the basic notion is to
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`generate a presentation on the TV monitor 202M that is a composite of broadcast
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`information (i.e. information that is available at every receiver) and information
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`that is specific to a particular receiver. The components of Figure 1 are all
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`conventional and include a television tuner 215, microcomputer 205, TV signal
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`decoder 203 and TV monitor 202M. The Harvey ‘717 patent characterizes this
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`arrangement as an example of a “subscriber station” [10:41-42]2. A basic
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`description of this system and some examples of its operation are provided,
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`generally, at 10:41-15:12.
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`2 In this section all references are to the Harvey ‘717 patent.
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`12
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`33. Briefly, it is assumed that the signal received by the TV tuner 215
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`includes embedded control signals. Although not described explicitly in the
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`Harvey ‘717 patent, one such transmission protocol for embedding control signals
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`and other information in a television signal might have been the Teletext protocol
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`or one of its variants. These techniques have been widely used since the early
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`1970s. Basically, Teletext3 and similar protocols allow the television station to
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`transmit digital data in an “unused” portion of the television signal. A television
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`tuner receives the TV signal, which includes the embedded data, and provides a
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`video and audio signal. Divider 4 serves to split the received video signal into two
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`copies. One copy of the video signal is sent to TV signal decoder 203 where the
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`embedded data, which is not visible in the signal, is extracted. The line labeled
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`“signals only” represents the extracted data [10:53-63].
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`34. Both the extracted data and the second copy of the video signal from
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`divider 4 are sent to the microcomputer 205. This microcomputer is an IBM
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`Personal Computer, a device that was widely known in 1987 because it or a
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`compatible variant was used in many homes and businesses. Although not shown
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`in Figure 1, the microcomputer 205 contains a specialized graphic overlay card
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`[11:6-10]. This card serves two purposes. First, under control of program code in
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`3 Closed captioning is another such technique, which is more widely used in the
`United States.
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`13
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`microcomputer 205 it can generate graphic letters and symbols. Second, these
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`generated graphics can be combined or overlaid on the video signal to produce an
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`output signal that is sent to the TV monitor 202M [11:15-18]. This combined
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`video signal presents the viewer with the general TV picture received from the
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`television tuner 215, but overlaid with whatever graphics were generated by the
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`graphics overlay card in the microcomputer 205.
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`35. Because microcomputer 205 is a general purpose computer it offers
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`the opportunity for the overlay information presented on TV monitor 202M to
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`reflect
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`information
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`that
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`is particular
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`to each viewer.
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` This
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`is because
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`microcomputer 205 may hold data that is specific to that viewer and an embedded
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`signal received on the general television transmission that is sent to all viewers
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`may trigger the presentation of this user-specific information in a way that is
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`different or unique to each viewer.
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`Example Preferred Embodiment of Harvey ‘717
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`36. The following is a thumbnail sketch of claims 1-7 and 9 of the Harvey
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`‘717 and is presented to provide a point of reference for understanding the claims
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`and how the prior art anticipates the claims. It is not my intention here to define
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`the claim terms, but rather simply to highlight some aspects of the claims that seem
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`important and to give an intuitive feel for how these aspects relate to each other. In
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`14
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`this discussion the italicized terms in quotations are terms taken from the language
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`of claims 1-7 and 9.
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`37. Claims 1-7 and 9 of the Harvey ‘717 Patent relate to computing a
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`“benefit datum” at a “receiver station”. This benefit datum is generated in
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`response to a “first control signal” received by the receiver station and is based on
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`“subscriber specific data” held at the receiver station. The receiver station also
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`receives “information content”. The “information content” and the “benefit
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`datum” are delivered to the subscriber on an “output device”. In response to
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`viewing (or perhaps hearing) the “information content” and the “benefit datum”
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`the subscriber may provide “input” to the receiver station. Input from the
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`subscriber “controls” the receiver station in some manner.
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`38. To aid in understanding the claims I will present here an example
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`from the Harvey ‘717 that appears to be related to claims 1-7 and 9 of the Harvey
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`‘717. There may be other and perhaps better examples among the dozen or so
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`preferred embodiments presented in the Harvey ‘717 specification. However, I
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`believe this example is useful for making claims 1-7 and 9 somewhat more
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`concrete. I will discuss certain aspects of the example and how these aspects might
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`be seen to correspond to various claim terms. Figure 7 represents the “receiver
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`station” in this example.
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`15
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`39. The particular example that I will be discussing here is referred to in
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`the Harvey ‘717 as “Summary Example #11” [Harvey 274:45-286:46] and relates
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`to a television program called “Farm Plans of Europe”. The 12 columns of the
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`Harvey ‘717 devoted to the description of “Farm Plans of Europe” actually cover
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`many other aspects of the preferred embodiment that are not addressed in claims 1-
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`7 and 9. Rather than going over the entire example in detail I will emphasize here
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`those aspects that are important to the claims.
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`40. The example is based on a scheme where European farmers view a
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`television program related to planting crops for the next growing season.
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`Government planners at the national and local levels develop farm and economic
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`16
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`models based on markets, weather projections, employment figures, taxes and so
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`forth. These models represent general information that will be sent to farmers in
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`each nation and each locality. In addition each farmer using the system has
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`developed data specific to his or her own situation, such as the acreage available
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`for planting, equipment on hand, sun and shade conditions for each parcel and so
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`forth [274:65-275:6]. This information is stored in his or her “receiver station” as
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`a file labeled “MY_FARM.DAT” and is specific to each individual farmer. Later,
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`national and local information received at the “receiver station” plus information
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`in the MY_FARM.DAT file are used to compute a unique crop planting plan
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`which is stored in the PLANTING.DAT file. Because each farm has different
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`characteristics in the MY_FARM.DAT file the crop plan in the PLANTING.DAT
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`file will differ from farm to farm [282:31-283:57]. The PLANTING.DAT file in
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`this example might be seen as “subscriber specific data”.
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`41. The “Farm Plans of Europe” example deals with several levels of
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`transmission stations. There are national level stations and local level stations.
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`Much of the discussion at 274:45-281:39 is related to passing information on
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`national and local economic conditions between various national and local
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`transmission stations. This protocol is unimportant to understanding claims 1-7
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`and 9. However, one aspect is somewhat relevant. Namely that, in addition to the
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`television video and audio of the program, television stations, particularly the local
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`17
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`station broadcasting to a group of farmers, embed certain “control signals” in the
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`transmissions. These signals may trigger certain actions at the “receiver station”.
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`For example, they may cause a record/playback unit 217 (Figure 7) at the
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`“receiver station” to begin recording information content for later presentation
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`[284:56-67].
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`42. There are many aspects to the proposed Example #11, “Farm Plans of
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`Europe”. For example, the system will develop a planting proposal (the file
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`PLANTING.DAT) for each farmer based on the national plan, the local plan and
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`their particular farm conditions. In addition, the system will play a selection of
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`commercials that is specific to each farmer based on the planting proposal and the
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`economic conditions of the farm. For example, a framer might see a commercial
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`for a new truck because his particular truck is older than his other equipment
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`[283:58-284:17].
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`43. A small excerpt from example #11 may serve to illustrate certain
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`aspects of claims 1-7 and 9 of the Harvey ‘717. This excerpt relates to the playing
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`of a commercial spot to each farmer. At the time the commercial is played the
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`farmer is also presented with profit projection data showing how the purchase of
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`this particular product or service would benefit his farm. This benefit is calculated
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`at the farmer’s particular station based on his or her current conditions and farm
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`plan [285:49-60]. The selected commercial might be considered to be the
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`18
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`“information content” and the projected profits described might be considered to
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`be the “benefit datum”.
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`44. With respect to the commercials to be played, Example #11 proposes
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`that 26 individual commercials be stored at the local transmission station. During
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`the program “Farm Plans of Europe” the national station sends an embedded signal
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`to each local station. The local station in turn cues up the 26 commercials on its
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`recorder/player 78 to be played over a second television channel in parallel with
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`the continuing transmission of the “Farm Plans of Europe” program [284:46-55].
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`When each farmer’s individual “receiver station” receives the embedded signal
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`from its local station it tunes to the second television channel and prepares to
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`record one or more of the 26 commercial spots on its recorder/player 217, 217A
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`[284:56-67].
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`45. After some preparation interval, the local station transmits the 26
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`commercial spots to all the “receiver stations” where they are recorded on the
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`recorder/player 217, 217A. This aspect might be considered as relating to claim 5.
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`Each commercial spot is includes an embedded program unit identification which
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`are used to organize the commercials at the “receiver station” into a station specific
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`playback schedule. This might be considered “modifying” the commercial spot
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`according to claim 13. The commercial spots are stored at the farmer’s receiver
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`station for use near the end of the “Farm Plans of Europe” program [285:1-9].
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`19
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`46. At the same time a program file TELEPHONE.EXE is also received
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`at all “receiver stations” and recorded on the disk drive of each receiver station.
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`This program will be used later by individual farmers to modify the farm plans that
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`have been developed for them [285:24-33].
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`47. As the program “Farm Plans of Europe” comes to a close each
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`“receiver station” receives a control signal that cause one or more of the
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`previously stored commercial spots to be played. The particular spots played are
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`those that were previously selected based on the PLANTING.DAT file at each
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`receiver station. This control signal might be considered the “first control signal”
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`of claim 1. When one of the previously selected commercials is played the
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`processor at the receiver station accesses the PLANTING.DAT file and computes
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`the benefit of purchasing the product or service shown in the commercial based on
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`the individual farm plan. For example, the benefit shown might be the financial
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`benefit of purchasing a new tractor. This information is presented (in an
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`unspecified way) together with the commercial [285:34-60]. With respect to claim
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`1 the following correspondences might apply: the selected commercial is
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`“information content”, calculating the benefit is “generating”, and the calculated
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`benefit shown is the “benefit datum”.
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`48. Example #11 goes on to suggest that once the planting plan for a
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`particular farm is developed the farmer may use the TELEPHON.EXE program
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`20
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`(previously downloaded) to make modifications to the farm crop plan. For
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`example, the farmer may for his or her own reasons decide to plant a different set
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`of crops. Once these modifications are complete the TELEPHON.EXE program
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`sends the file by telephone from the receiver station to a remote data collection
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`station [285:61-286:9]. Within the context of claim 1 the modification the farmer
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`makes to the PLANTING.DAT file might be considered to be “receiving input”
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`and the transmission of the PLANTING.DAT file might be considered to be
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`“controlling the receiver station”.
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`49. With respect to certain dependent claims, the modification of the
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`PLANTING.DAT file by a farmer might be considered to be the related to claim 3,
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`where the PLANTING.DAT file is the “subscriber specific data”. With respect to
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`claim 15, the particular telephone number dialed to send the PLANTING.DAT file
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`to the remote data collection station might be considered to be the “identifier”.
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`50. The Harvey ‘717 patent shows a number of other preferred
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`embodiments and describes other similar examples of personalized program
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`presentation. In general, they are just elaborations of this simple example.
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`V. Anticipation in View of Lockwood
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`The Lockwood ‘359
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`51. Claims 1, 2, 3, 4, 5, 6 and 9 of the Harvey ‘717 are anticipated by
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`Lockwood (4,567,359) and therefore are unpatentable.
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`21
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`
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`Background of Lockwood
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`52. U.S. patent 4,567,359 (“Lockwood”)
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`issued
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`to Lawrence B.
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`Lockwood and titled “Automatic Information, Goods and Services Dispensing
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`System” was filed on May 24, 1984. It is my understanding that Lockwood has a
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`priority date of May 24, 1984, and thus is prior art to the Harvey ‘717 patent.
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`Technical Summary of Lockwood
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`53. Lockwood discloses a multi-terminal system connected to a central
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`processor that is intended to allow users to purchase products or services. The
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`preferred embodiment of Lockwood is a system that supports the sales of insurance
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`policies, however, Lockwood suggests other types of goods and services that might
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`be offered, such as travel, catalog sales, financial services and the like [3:64-68].
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`Figure 1 below shows the basic structure of the Lockwood system.
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`22
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`
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`54. There are three major components to the system of Lockwood.
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`Terminals 2 are specifically designed to be used by customers of the product,
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`which in this case are insurance policies [4:24-29]. Terminals 4 are located at
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`insurance companies. These terminals are used by insurance company personnel
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`to update policy prices and terms and to download various reports from the system
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`[4:1-13; 5:37-44].
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`55. Terminals 2 and 4 are connected to a central data processing center 1,
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`which stores information about policies and coordinates the operation of the
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`system in memory 23 (Figure 1) [5:37-44].
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`
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`23
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`
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`56. Terminal 2 is a special purpose terminal, shown in greater detail in
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`Figure 2 below.
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`
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`57. The purpose of terminal 2 is to be a “user friendly” interface to the
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`insurance policy system. Terminal 2 is envisioned as a booth or kiosk that would
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`be located in public places like banks, supermarkets and grocery stores [2:30-33].
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`The primary user interface on terminal 2 is a monitor and keyboard 8 and a touch
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`
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`24
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`
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`pad 13. Terminal 2 also includes a video disc player 9 that can generate an
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`audiovisual presentation [4:33-51]. The notion is that user will interact with the
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`audiovisual presentation, which is liked to a “factitious insurance agent” who will
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`present information and ask questions. The user will answer via the touch pad 13
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`or keyboard (part of monitor 8) [5:7-13].
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`58. Processing center 1 coordinates terminals 2 and stores information
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`about insurance policies and pricing for various insurance companies [2:44-47].
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`At terminal 2 customers will select a type of insurance policy that they wish to
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`review, such as an automobile policy [6:51-53]. Next they will answer a series of
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`questions providing the system with personal information such as age, gender and
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`marital status [6:51-61]. Once this information has been gathered at terminal 2 it
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`will be sent to the processing center 1 [7:5-10]. Upon receipt of this information
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`the processing center 1 will develop a personalized insurance quotation based on
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`the specific customer data provided. In addition, the processing center may
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`develop personalized policy quotation for several competing insurance companies
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`[7:5-10]. This information is then presented to the customer on monitor 8 of
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`terminal 1 and may be printed out for further review [7:10-15].
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`59. Once a customer has reviewed the policy information and the price
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`quotations they may elect to purchase a particular policy. At this point they will be
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`asked for their credit card information and their name and address, which is sent to
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`
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`25
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`
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`processing center 1 for verification [7:25-55]. If a policy is purchased, it can be
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`printed out on the printer 13.
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`60. A good summary of the steps involved in the system operation is
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`given at 1:58-2:7 and at 5:68-6:32. Figures 4 and 5 outline the basic sequencing in
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`flowchart form.
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`Lockwood