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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`FACEBOOK, INC., LINKEDIN CORP., and TWITTER, INC.,
`
`Petitioner
`
`vs.
`
`SOFTWARE RIGHTS ARCHIVE, LLC,
`
`Patent Owner
`
`Cases:
`
`IPR2013-00478 (Patent 5,544,352)
`
`IPR2013-00479 (Patent 5,832,494)
`
`IPR2013-00481 (Patent 6,233,571)
`
`DEPOSITION OF EDWARD A. FOX, Ph.D.
`
`Volume 2
`
`Roanoke, Virginia
`
`April 27, 2014
`
`Reported by:
`
`22 Mary Ann Payonk
`
`23
`
`24
`
`25
`
`PAGES 279 - 561
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`Page 279
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`EXHIBIT 2017
`Facebook, Inc. et al.
`v.
`Software Rights Archive, LLC
`CASE IPR2013-00479
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`FACEBOOK, INC., LINKEDIN CORP., and TWITTER, INC.,
`
`Petitioner
`
`vs.
`
`SOFTWARE RIGHTS ARCHIVE, LLC,
`
`Patent Owner
`
`Cases:
`
`IPR2013-00478 (Patent 5,544,352)
`
`IPR2013-00479 (Patent 5,832,494)
`
`IPR2013-00481 (Patent 6,233,571)
`
`DEPOSITION OF EDWARD A. FOX, Ph.D.
`
`Volume 2
`
`Roanoke, Virginia
`
`April 27, 2014
`
`Reported by:
`
`22 Mary Ann Payonk
`
`23
`
`24
`
`25
`
`PAGES 279 - 561
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`EXHIBIT 2017
`Facebook, Inc. et al.
`v.
`Software Rights Archive, LLC
`CASE IPR2013-00479
`
`
`
` April 27, 2014
`
` 9:00 a.m.
`
` Deposition of EDWARD A. FOX, Ph.D.,
`
` Volume 2, held at the offices of Pierce
`
` Reporting Company, 15 Franklin Road, SW, Suite
`
` 7, Roanoke, Virginia, pursuant to Notice before
`
` Mary Ann Payonk, Nationally Certified Realtime
`
` Reporter and Notary Public of the Commonwealth
`
` of Virginia, States of New York and Maryland,
`
` and District of Columbia.
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` A P P E A R A N C E S :
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` O N B E H A L F O F S O F T W A R E R I G H T S A R C H I V E , L L C :
`
` V I C T O R H A R D Y , E S Q U I R E
`
` v h a r d y @ d p e h l a w . c o m
`
` M I T C H Y A N G , E S Q U I R E
`
` m y a n g @ d p e h l a w . c o m
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` D i N O V O P R I C E E L L W A N G E R & H A R D Y L L P
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` 7 0 0 0 N . M o p a c E x p y , S u i t e 3 5 0
`
` A u s t i n , T X 7 8 7 3 1
`
` M A R T I N M . Z O L T I C K , E S Q U I R E
`
` m z o l t i c k @ r f e m . c o m
`
` M I C H A E L H . J O N E S , E S Q U I R E
`
` m j o n e s @ r f e m . c o m
`
` R O T H W E L L , F I G G , E R N S T & M A N B E C K P C
`
` 6 0 7 1 4 t h S t r e e t , N . W . , S u i t e 8 0 0
`
` W a s h i n g t o n , D . C . 2 0 0 0 5
`
` m z o l t i c k @ r f e m . c o m
`
` O N B E H A L F O F F A C E B O O K :
`
` H E I D I K E E F E , E S Q U I R E
`
` h k e e f e @ c o o l e y . c o m
`
` C O O L E Y L L P
`
` 3 1 7 5 H a n o v e r S t r e e t
`
` P a l o A l t o , C A 9 4 3 0 4
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` A p p e a r a n c e s ( C o n t ' d . ) :
`
` O N B E H A L F O F L I N K E D I N a n d T W I T T E R :
`
` D A V I D J . S I L B E R T , E S Q U I R E
`
` d s i l b e r t @ k v n . c o m
`
` K E K E R & V A N N E S T L L P
`
` 6 3 3 B a t t e r y S t r e e t
`
` S a n F r a n c i s c o , C A 9 4 1 1 1
`
` A L S O P R E S E N T :
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` S t e v e O a k e s , v i d e o g r a p h e r
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` P a u l J a c o b s
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`
`
` - INDEX TO WITNESSES -
`
` WITNESS PAGE
`
` Edward A. Fox, Ph.D.
`
` Examination by Mr. Hardy 284
`
` - INDEX TO EXHIBITS -
`
` NO. MARKED
`
` Exhibit 2010 . . . . . . . . 368
`
` Exhibit 2012 . . . . . . . . 396
`
` Exhibit 2013 . . . . . . . . 474
`
` - EXHIBITS REFERENCED -
`
` (Previously marked)
`
` NO. REFERENCED
`
` Exhibit 1007 . . . . . . . . 375
`
` Exhibit 1210 . . . . . . . . 534
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` THE VIDEOGRAPHER: On the record at 09:05
`
` 9:05 a.m. This continues the deposition 09:05
`
` of Edward A. Fox, Ph.D., in Facebook, 09:05
`
` LinkedIn, Twitter versus Software Rights 09:05
`
` Archive LLC. 09:05
`
` MR. SILBERT: So we were just 09:05
`
` discussing off the record that 09:05
`
` yesterday, Dr. Fox had agreed to produce 09:05
`
` a list of the cases, patent cases in 09:05
`
` which he's testified, I believe in the 09:05
`
` last few years. Is that correct? 09:05
`
` THE WITNESS: I think actually it's 09:05
`
` a full list. 09:05
`
` MR. SILBERT: He prepared that list 09:05
`
` and I'm handing it to counsel. And in 09:05
`
` addition, Dr. Fox had consulted a 09:05
`
` summary of the PTAB's claim 09:05
`
` constructions, and we're handing a copy 09:06
`
` of that to counsel as well. 09:06
`
` THE WITNESS: I may have been 09:06
`
` deposed in the 1970s as a fact witness, 09:06
`
` but that's the -- otherwise, that's a 09:06
`
` complete list. 09:06
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` EDWARD A. FOX, Ph.D.,
`
` recalled as a witness, was examined and
`
` testified further as follows:
`
` EXAMINATION (Cont'd.)
`
` BY MR. HARDY: 09:06
`
` Q. Okay. Are there any other new notes 09:06
`
` that you might have that you might be 09:06
`
` testifying from or that are contained up there 09:06
`
` with you during this examination that we 09:06
`
` haven't received previously? 09:06
`
` A. Nothing in front of me other than 09:06
`
` what we've discussed. 09:06
`
` MR. SILBERT: I should mention 09:06
`
` also -- I'm sorry, Victor -- that 09:06
`
` Dr. Fox had prepared some errata to his 09:06
`
` declaration, and we handed a copy of 09:06
`
` those to counsel yesterday. 09:06
`
` Q. Since our break yesterday, have you 09:06
`
` had any conversations with counsel on that side 09:06
`
` of the table with respect to any substance in 09:06
`
` this case? 09:06
`
` A. No. 09:07
`
` Q. Okay. Are you aware of anyone 09:07
`
` performing the methods described in your papers 09:07
`
` using extended vectors concerning -- containing 09:07
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` co-citation and bibliographic coupling on 09:07
`
` collections other than the CACM and ISI? 09:07
`
` MR. SILBERT: Objection, scope. 09:07
`
` A. Say it one more time. Am I aware of 09:07
`
` anyone -- 09:07
`
` Q. Are you aware of anyone performing 09:07
`
` the methods described in your paper concerning 09:07
`
` using the extended vector space model 09:07
`
` containing co-citation and bibliographic 09:07
`
` coupling on collections other than the CACM and 09:07
`
` ISI -- 09:08
`
` MR. SILBERT: Same objection. 09:08
`
` Q. -- collections. 09:08
`
` MR. SILBERT: Same objections. 09:08
`
` A. So, by performing, do you mean 09:08
`
` present tense? People today? Or do you mean 09:08
`
` someone since the time I wrote my works? 09:08
`
` Q. Both. 09:08
`
` A. Both? Okay. And you're asking me if 09:08
`
` the methods of having longer representations 09:08
`
` for similarity are being used? Is that -- I'm 09:08
`
` just trying to understand. Companies like 09:08
`
` Google and others do very similar kinds of 09:08
`
` things. Is that what you're getting at? 09:08
`
` Q. No, I'm talking about using the 09:08
`
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` vector space model described in the -- your 09:08
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` 1983 papers, and particularly the methods that 09:08
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` you guys point to for purposes of invalidating 09:08
`
` the claims, containing co-citation and 09:08
`
` bibliographic couplings extended vectors, and 09:08
`
` that being presented on a collection other than 09:08
`
` the CACM or ISI. 09:08
`
` MR. SILBERT: Object to the form, 09:09
`
` and also scope. 09:09
`
` A. This is a kind of memory test of 30 09:09
`
` years or so. Actually, more than 30 years. 30 09:09
`
` years of research in the field. 09:09
`
` I remember that Bruce Croft did some 09:09
`
` studies with that kind of approach, if I 09:09
`
` remember correctly, in the I cubed R system. I 09:09
`
` think he used the CACM collection per se as an 09:09
`
` example. 09:09
`
` I certainly did work in the -- with 09:09
`
` the LEND, MARIAN, CODER and Envision systems. 09:09
`
` I published a paper which has as part of the 09:09
`
` title REVTOLC that did some of that kind of 09:09
`
` thing. I'm not sure if I had the bibliographic 09:09
`
` coupling and co-citation in that, but I had 09:09
`
` extended vectors. And there were lots of other 09:09
`
` papers published and my works were cited by 09:10
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` many people. So it would take a long time to 09:10
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` find -- give you an accurate answer to that. 09:10
`
` Q. Sure. I think you didn't understand 09:10
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` the question because -- by the way you answered 09:10
`
` that. The key component -- not the key 09:10
`
` component, but this particular question was 09:10
`
` inquiring about collections other than the CACM 09:10
`
` and ISI collection. 09:10
`
` A. Okay. 09:10
`
` MR. SILBERT: Same objections. 09:10
`
` A. It's hard to know for sure, as I 09:10
`
` said, without going through an extensive 09:10
`
` search. The software that was able do this 09:10
`
` kind of processing was widely distributed to 09:10
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` hundreds or probably thousands of people. So 09:10
`
` to know what they did with it, since I had 09:10
`
` written about how to do this and the benefits 09:10
`
` of it and so forth, it's hard to say. It would 09:10
`
` be very difficult to answer your question. I 09:10
`
` could try, but I'd have to get online and do a 09:10
`
` lot of searching. 09:10
`
` Q. Are you aware of anyone performing 09:11
`
` your methods using the extended vectors 09:11
`
` containing BC and CC information on the World 09:11
`
` Wide Web? 09:11
`
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` MR. SILBERT: Same objections. 09:11
`
` A. So first, the question says on the 09:11
`
` World Wide Web. I'm not sure what you mean by 09:11
`
` that. Most people today doing almost any kind 09:11
`
` of research are doing it on the World Wide Web. 09:11
`
` So I don't think that's a constraint, and I 09:11
`
` think my previous answer is germane to that -- 09:11
`
` to this question too. 09:11
`
` Q. And the previous answer was you 09:11
`
` weren't presently aware of such things? 09:11
`
` MS. KEEFE: Object to form. 09:11
`
` MR. SILBERT: And scope. 09:11
`
` A. So what I think I've said, just to 09:11
`
` make it clear, is that I don't think your 09:11
`
` comment about the World Wide Web is a 09:12
`
` limitation on your previous question. And my 09:12
`
` previous answer was that it would take me a 09:12
`
` long time to find a precise answer to that 09:12
`
` because my system enabled that kind of 09:12
`
` capability. 09:12
`
` Q. Well, I guess what I'm asking you, 09:12
`
` are you aware here at this deposition today of 09:12
`
` such things? 09:12
`
` MR. SILBERT: Same objections. 09:12
`
` A. If I stopped and thought for half an 09:12
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` hour, I might be able to come up with 09:12
`
` something, but I can't offhand quickly. 09:12
`
` Q. Let me ask you the same version of 09:12
`
` that question. Are you aware of anyone using 09:12
`
` your methods using extended vectors, including 09:12
`
` co-citation and bibliographic couplings, for 09:13
`
` commercial applications as opposed to research 09:13
`
` applications? 09:13
`
` MR. SILBERT: Same objections. 09:13
`
` A. I think the same answer pertains. 09:13
`
` It's very hard -- it's even harder to find out 09:13
`
` what people are doing for commercial 09:13
`
` applications because most people don't publish 09:13
`
` about that. There are some publications by 09:13
`
` people, and I -- I can conjecture that some 09:13
`
` people would -- the company that I got some of 09:13
`
` the data from, ISI, did lots and lots of 09:13
`
` studies with citation, co-citation information. 09:13
`
` So I would expect that that is a commercial 09:13
`
` organization that probably did some of the same 09:13
`
` kind of studies. But I'm just guessing. 09:13
`
` Q. Okay. Did you ever publish more on 09:13
`
` the use of bibliographic coupling and 09:13
`
` co-citation after your 1983 experiments? 09:14
`
` MR. SILBERT: Same objections. 09:14
`
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` A. I think so. I think in some of the 09:14
`
` work with the MARIAN system and LEND and the 09:14
`
` Envision system, we did probably publish 09:14
`
` something about that. The MARIAN system did 09:14
`
` have the capability to do that kind of 09:14
`
` analysis, and I published a lot about that, a 09:14
`
` number of different papers, published about all 09:14
`
` of those different systems. 09:14
`
` Q. Okay. 09:14
`
` A. I'd have to go look for it if -- if I 09:14
`
` were to be sure. 09:14
`
` Q. Okay. Now, what is the MARIAN 09:14
`
` system? 09:15
`
` MR. SILBERT: Same objections. 09:15
`
` A. So -- 09:15
`
` Q. Let me withdraw that question. 09:15
`
` A. Okay. 09:15
`
` Q. And ask a slightly different 09:15
`
` question. Are there any publications on the 09:15
`
` MARIAN system -- 09:15
`
` A. Yes. 09:15
`
` Q. -- describing the use of 09:15
`
` bibliographic coupling and co-citation extended 09:15
`
` vector space model? 09:15
`
` MR. SILBERT: Same objections, 09:15
`
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` which are objections to the form and to 09:15
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` scope. 09:15
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` A. I think I answered that. I said I 09:15
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` think there are. I have published a number of 09:15
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` things about the MARIAN system and I think some 09:15
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` of them talk about this. 09:15
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` Q. Can you identify the publication? 09:15
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` MR. SILBERT: Same objections. 09:15
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` A. Probably the France dissertation. 09:15
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` Probably the Betrabet master's thesis, 09:15
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` B-E-T-R-A-B-E-T, Betrabet. First name is 09:15
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` S-A-N-G-I-T-A, Sangita. Her master's thesis 09:16
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` talked about graph languages and representing 09:16
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` things, and I expect she talked about that. 09:16
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` And I think there were some publications she 09:16
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` coauthored, and certainly lots of publications 09:16
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` that Robert France coauthored. But I'd have to 09:16
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` go look to look specifically for your question. 09:16
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` Q. Okay. Was the MARIAN -- what is the 09:16
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` MARIAN system? Can you describe it? 09:16
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` MR. SILBERT: Same objection as to 09:16
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` scope. 09:16
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` A. So there are multiple answers to that 09:16
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` question. Again, I can go on for a long period 09:16
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` of time. One answer is that in the more than 09:17
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` 12 hours you asked me to try and find records 09:17
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` about some of this, I found some information 09:17
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` about the MARIAN, some of the source code 09:17
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` relating to it, and I -- and that was provided 09:17
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` to you through discovery. So that's one 09:17
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` partial answer. 09:17
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` It stood for multiple access 09:17
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` retrieval of information with annotations. 09:17
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` That was the expansion of the word. It was a 09:17
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` system that was developed probably from the 09:17
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` late '80s up and to maybe 2002 or so, somewhere 09:17
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` in that range. So various versions or parts of 09:17
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` it were developed over that period. So there's 09:17
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` quite a lot of different things about it. 09:17
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` The idea of it -- tell me to stop if 09:17
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` you want me to. 09:17
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` Q. Sure. Let me ask you this question. 09:17
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` Is this a research system or is this a -- was 09:18
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` this a research system or commercial system? 09:18
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` MR. SILBERT: Same objection. 09:18
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` A. Both. 09:18
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` Q. Okay. Explain the context of it 09:18
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` being a research system. 09:18
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` A. Okay. 09:18
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` MS. KEEFE: Object to form and 09:18
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` scope. 09:18
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` A. Research in the sense that it was 09:18
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` tied in with master's and doctoral theses and 09:18
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` dissertations, student project reports and 09:18
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` graduate courses. Probably some independent 09:18
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` studies, or I should say undergraduate research 09:18
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` kinds of studies. Also, that it was supported 09:18
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` in part by a number of different grants from 09:18
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` different groups, including the National 09:18
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` Library of Medicine, the National Science 09:18
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` Foundation. They typically fund research and 09:18
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` there were proposals that related to this that 09:18
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` it led to a number of publications, research 09:18
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` publications. So those are all -- some 09:19
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` examples of research. 09:19
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` Q. Sure. Can you explain the context of 09:19
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` why it was a commercial system? 09:19
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` MR. SILBERT: Same objection. 09:19
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` A. Yes, I can. 09:19
`
` Q. Please do. 09:19
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` MR. SILBERT: Same objection. 09:19
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` A. Qi Fan Chen -- that's Q-I, F-A-N, 09:19
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` C-H-E-N -- was the first student to finish his 09:19
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` Ph.D. with me as advisor. His dissertation 09:19
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` related to LEND, which was sort of the database 09:19
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` piece of MARIAN. Virginia Tech -- we did a 09:19
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` disclosure to Virginia Tech Intellectual 09:19
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` Properties of that invention. VTIP is the 09:19
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` short form of Virginia Tech Intellectual 09:19
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` Properties. Had a license agreement with -- if 09:20
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` I remember, it's HaL Computer in Texas, with 09:20
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` regard to the LEND system, which was part of 09:20
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` MARIAN. So that's an example of a commercial 09:20
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` activity. 09:20
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` Q. In what way was it -- can you explain 09:20
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` more about -- what was the HaL -- did HaL 09:20
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` Computer sell this to the public? 09:20
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` A. I have no idea what they did with it. 09:20
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` MR. SILBERT: I'm sorry. Same 09:20
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` objection as to scope. 09:20
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` A. They had a -- we had a commercial 09:20
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` license with them, so that's a commercial 09:20
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` situation. 09:20
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` Q. Commercial license with them. And 09:20
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` did they use the bibliographic co-citation 09:20
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` and -- excuse me, bibliographic coupling and 09:20
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` co-citation subvectors for purposes of 09:20
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` conducting search? 09:20
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` A. I have no idea what they did with it. 09:20
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` MR. SILBERT: Object to the form 09:21
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` and to scope. 09:21
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` A. They could have. It was certainly 09:21
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` possible to do that. 09:21
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` Q. Okay. Now, are you aware of any 09:21
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` commercial licenses of your SMART system? 09:21
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` MR. SILBERT: Same objections. 09:21
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` Q. Or the SMART system. 09:21
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` A. So the SMART system was something 09:21
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` that continued to evolve for a number of years. 09:21
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` I expect there were some companies that made 09:21
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` use of it. As I said, it was widely 09:21
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` distributed and some companies probably made 09:21
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` use of it and adapted it to their own purposes. 09:21
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` But I don't have particular records about that. 09:21
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` I don't keep records of such things. 09:21
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` Q. Are you aware of any companies that 09:21
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` specifically used bibliographic coupling or 09:21
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` co-citation subvectors in connection with the 09:22
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` SMART system? 09:22
`
` MR. SILBERT: Object to scope. 09:22
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` A. I think I answered that. I don't 09:22
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` know what they did with it. It's hard to say. 09:22
`
` Q. Okay. 09:22
`
` A. They could have. 09:22
`
` Q. Do you have any other publications 09:22
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` other than the one about MARIAN concerning the 09:22
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` use of bibliographic coupling or co-citation 09:22
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` extended vectors in the vector space model? 09:22
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` MR. SILBERT: Same objection. 09:22
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` A. The first part of your question had 09:22
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` an error in it which I got stuck on. It was 09:22
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` something wrong with it, the question. Could 09:22
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` you say it one more time? 09:22
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` Q. Are you able to identify any other 09:22
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` publications other than the one about MARIAN 09:22
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` that we previously talked about -- 09:23
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` A. Okay. So -- sorry. 09:23
`
` Q. -- that used the bibliographic 09:23
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` coupling and co-citation extended vectors? 09:23
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` MR. SILBERT: I object as to scope. 09:23
`
` Q. Strike that question. Okay? 09:23
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` Let me try to phrase something. Are 09:23
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` you aware of any other publications that use -- 09:23
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` that -- concerning the use of bibliographic 09:23
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` coupling and co-citation extended vectors in 09:23
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` the vector space model? 09:23
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` MR. SILBERT: Object as to scope 09:23
`
` and to form. 09:23
`
` A. I'm not -- 09:23
`
` Q. By you. 09:23
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` A. By me? Okay. 09:23
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` MR. SILBERT: Same objections. 09:23
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` A. Okay. So the problem with your 09:23
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` question before was you said "the one" about 09:23
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` MARIAN, and I told you that I had many 09:23
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` publications about MARIAN, so I'm not sure of 09:23
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` the scope of what you're asking, whether it's 09:23
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` beyond the many ones about MARIAN -- 09:24
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` Q. "The other" means other than the ones 09:24
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` you previously identified about MARIAN. 09:24
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` MR. SILBERT: Same objections. 09:24
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` MS. KEEFE: Also to form. 09:24
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` A. Okay. Your question's very 09:24
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` complicated, and I think I answered it. So 09:24
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` there were -- I published hundreds of papers 09:24
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` and presentations, maybe a thousand all 09:24
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` together. I can't remember which ones talked 09:24
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` about the specific topic and which ones didn't, 09:24
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` so I can't really answer you quick on that. I 09:24
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` can go through them if you want me to, try to 09:24
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` see, but it would be -- take a while. 09:24
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` Q. Well, are you aware of any -- 09:24
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` standing here, are you aware of conducting any 09:24
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` further experiments on bibliographic and 09:24
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` coupling using the vector space model in your 09:24
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` publications? 09:24
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` MR. SILBERT: Object to form and to 09:24
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` being beyond the scope. 09:24
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` A. I'm not standing here, I'm sitting 09:25
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` here. 09:25
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` If -- do you want me to answer it 09:25
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` from the sense of sitting here? 09:25
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` Q. You may. 09:25
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` A. So there were a number of 09:25
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` publications in the sort of ten years after my 09:25
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` dissertation work that probably talked about 09:25
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` some of this, but again, I can't remember 09:25
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` specifically which ones. 09:25
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` As I said before, the Envision system 09:25
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` used the CACM collection and bibliographic 09:25
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` coupling and co-citation as part of the data 09:25
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` that was in that and that's part of the record 09:25
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` in this case. So that's beyond the objections 09:25
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` we have been hearing. 09:25
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` Q. Do you have access to the source code 09:26
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` of the Envision system? 09:26
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` MR. SILBERT: Object to scope. 09:26
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` A. What was disclosed to you is a 09:26
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` substantive part of the Envision system. I'm 09:26
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` not sure if it's everything. It might be. It 09:26
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` listing the files was 327 pages. So it's not 09:26
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` easy for me to be sure whether I had everything 09:26
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` or not. I have boxes and boxes of things 09:26
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` relating to the system. 09:26
`
` Q. Okay. Now, yesterday, we discussed
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