IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Control No.
`Patent No.
`Filed
`
`: 90/011,014
`: 5,832,494
`: May 26, 2010
`
`Art Unit
`Examiner
`Con£ No.
`
`:3992
`: Joshua D. Campbell
`:6009
`
`Title: METHOD AND APPARATUS FOR INDEXING, SEARCHING, AND DISPLAYING
`DATA
`
`37 C.F.R. § 1.132 DECLARATION OF PAULS. JACOBS
`
`I, PaulS. Jacobs, declare as follows:
`
`1.
`
`My name is PaulS. Jacobs. I am the Founder and President of Jake Technologies,
`
`Inc. My business address is 27 Logan Circle NW #14, Washington, DC 20005. I understand
`
`that my declaration is being submitted in connection with the above-referenced reexamination
`
`proceeding pending in the United States Patent and Trademark Office.
`
`I.
`
`Qualifications, Background, and Experience
`
`2.
`
`I received a Bachelor of Science in Applied Mathematics from Harvard
`
`University in 1981, a Master of Science in Applied Mathematics from Harvard University in
`
`1981, and a Ph.D. in Computer Science from the University of California at Berkeley in 1985.
`
`3.
`
`I have authored or co-authored over 50 scientific and technical publications, I am
`
`listed as an inventor on two U.S. patents directed to computational lexicons, and I have over 25
`
`years of experience in the computer and information retrieval industry.
`
`4.
`
`I have served in numerous professional and scientific capacities, including one
`
`year as a visiting professor of computer science at the University of Pennsylvania and several
`
`years as a member ofthe executive committee of the Association for Computational Linguistics.
`
`Currently, I serve on the Public Policy Council of the Association for Computing Machinery
`
`(USACM). I am currently a technology consultant and an adjunct lecturer at the University of
`EXHIBIT 2018
`Facebook, Inc. et al.
`v.
`Software Rights Archive, LLC
`CASE IPR2013-00479
`
`1
`
`
`
`Control No.
`Patent No.
`Filed
`
`: 90/011,014
`: 5,832,494
`: May 26, 2010
`
`Art Unit
`Examiner
`Con£ No.
`
`:3992
`: Joshua D. Campbell
`:6009
`
`Title: METHOD AND APPARATUS FOR INDEXING, SEARCHING, AND DISPLAYING
`DATA
`
`37 C.F.R. § 1.132 DECLARATION OF PAULS. JACOBS
`
`I, PaulS. Jacobs, declare as follows:
`
`1.
`
`My name is PaulS. Jacobs. I am the Founder and President of Jake Technologies,
`
`Inc. My business address is 27 Logan Circle NW #14, Washington, DC 20005. I understand
`
`that my declaration is being submitted in connection with the above-referenced reexamination
`
`proceeding pending in the United States Patent and Trademark Office.
`
`I.
`
`Qualifications, Background, and Experience
`
`2.
`
`I received a Bachelor of Science in Applied Mathematics from Harvard
`
`University in 1981, a Master of Science in Applied Mathematics from Harvard University in
`
`1981, and a Ph.D. in Computer Science from the University of California at Berkeley in 1985.
`
`3.
`
`I have authored or co-authored over 50 scientific and technical publications, I am
`
`listed as an inventor on two U.S. patents directed to computational lexicons, and I have over 25
`
`years of experience in the computer and information retrieval industry.
`
`4.
`
`I have served in numerous professional and scientific capacities, including one
`
`year as a visiting professor of computer science at the University of Pennsylvania and several
`
`years as a member ofthe executive committee of the Association for Computational Linguistics.
`
`Currently, I serve on the Public Policy Council of the Association for Computing Machinery
`
`(USACM). I am currently a technology consultant and an adjunct lecturer at the University of
`EXHIBIT 2018
`Facebook, Inc. et al.
`v.
`Software Rights Archive, LLC
`CASE IPR2013-00479
`
`1
`
`
`
`12.
`
`It is also my understanding that, on January 25, 2011, the USPTO issued an
`
`Office Action in this Ex Parte Reexamination Proceeding (''the Office Action"). In the Office
`
`Action, claims 1-3, 5, 7-16, 18-21, 23-25 and 31-33 ofthe '494 patent stand rejected under
`
`35 U.S.C. § 102(b) as anticipated, and/or under 35 U.S.C. § 103(a) as obvious over the
`
`references identified in the Office Action.
`
`13.
`
`I have read and understand the '494 patent, its prosecution history and the
`
`references cited in the '494 patent. I have read and understand the Request, the Order granting
`
`the Request, the Office Action, and the references cited in these documents. The documents and
`
`other materials that I have reviewed and relied upon in preparing this Declaration are listed in
`
`Exhibit 2J.
`
`14.
`
`I was asked to consider and address the rejections raised by the USPTO in the
`
`Office Action in my declaration.· I understand that the Office Action has grouped the rejections
`
`into six issues:
`
`Issue 1 - Claims 1-3 and 5 in view ofLucarella
`
`Issue 2- Claim 12-16 in view ofBaase
`
`Issue 3- Claims 18-21 in view ofFox
`
`Issue 4- Claims 23-25 and 31-33 in view ofFrei & Stieger
`
`Issue 5- Claims 7-11 in view ofLucarella and Doyle
`
`Issue 6- Claims 18, 20, and 21 in view ofEgger (US Patent Number 5,544,352)
`
`4
`
`
`
`EXHIBIT 2J
`
`
`
`List of References Consulted
`
`U.S. Patent No. 5,832,494, to Daniel Egger, et al.
`
`File History of U.S. Patent No. 5,832,494 and
`cited references
`
`Request for Ex Parte Reexamination, filed May
`25, 2010, Control No. 90/011,014
`
`Non-Final Office Action, mailed Jan. 25, 2011
`
`R.A. Botafogo and B. Shneiderman, "Identifying
`Aggregates in Hypertext Structures," Hypertext
`'91 Proceedings, December 1991, pp.63-74
`
`R.A. Botafogo, "Cluster Analysis for Hypertext
`Systems," ACMSIGIR'93, Vol. 6, pp. 116-125,
`199
`
`H.P. Frei and D. Stieger, "Making Use of
`Hypertext Links when Retrieving Information,"
`ACM, 1992
`
`S. Baase, Computer Algorithms: Introduction to
`Design and Analysis, 2nd Edition, Addison-Wesley
`Publishing Co., 1988
`
`D. Lucarella, "A Model for Hypertext-Based
`Information Retrieval," Proceedings of the
`ECHT'90, Cambridge University Press, N. Streitz,
`A. Rizk and J. Andre, eds., pp. 81-94, November
`1990
`
`E. Fox, "Extending the Boolean and Vector Space
`Models oflnformation Retrieval with P-Norm
`Queries and Multiple Concept Types," Cornell
`University, 1983 ("Fox 1983")
`
`B.R. Schatz and J.B. Hardin, "NCSA Mosaic and
`the World Wide Web: Global Hypermedia
`Protocols for the Internet," Science, Vol. 265,
`Aug.
`12, 1994 ("Schatz & Hardin 1994")
`
`APPENDIX C to Request
`
`APPENDIX D to Request
`
`APPENDIX E to Request
`
`APPENDIX F to Request
`
`APPENDIX G to Request
`
`APPENDIX H to Request
`
`APPENDIX I to Request
`
`1
`
`
`
`U.S. Patent No. 5,838,906 to Michael D. Doyle, et
`al., Issued November 17, 1998 ("Doyle")
`
`APPENDIX J to Request
`
`V-SEARCHPUBLISHER'S TOOLKIT USER'S
`MANUAL 4, Fig.3 (1995)
`
`Exhibit A to Parties' Local Patent Rule 4-3 Joint
`Claim Constructions and Supporting Evidence,
`Software Rights Archive, LLC, v. Google
`
`Application No. 08/649,304: Information
`Disclosure Statement, January 27, 1998
`
`Belew, R. "A Connectionist Approach to
`Conceptual Information Retrieval", ICAIL '87
`(1987)
`
`Rose & Belew, "Legal Information Retrieval: A
`Hybrid Approach", ICAIL '89 (1989)
`
`lSI collection and documents obtained from
`ftp://ftp.cs.cornell.edu/pub/smart/
`
`CACM collection and documents obtained from
`ftp://ftp.cs.cornell.edu/pub/smart/
`
`E. Fox, Characterization of Two New
`Experimental Collections in Computer and
`Information Science Containing Textual and
`Bibliographic Concepts, Cornell Report 83-561,
`1983 ("Fox Collections")
`
`Gerard Salton, "Associative Document Retrieval
`Techniques Using Bibliographic Information,"
`Journal ofthe ACM 10 (4) pp. 440-57, 1963
`
`G. Salton and Y. Zhang, Enhancement of text
`representations using related document titles.
`Information Processing & Management, Volume
`22, Issue 5, 1986, pp. 385-394.
`
`Exhibit 3J
`
`Exhibit 4J
`
`Exhibit 5J
`
`Exhibit 6J
`
`Exhibit 7J
`
`Exhibit 8J
`
`Exhibit 9J
`
`Exhibit 10J
`
`Exhibit 11J
`
`Exhibit 12J
`
`G. Salton, J. Allan, C. Buckley, and A. Singhal.
`Automatic analysis, theme generation, and
`
`Exhibit 13J
`
`2
`
`
`
`summarization of machine-readable texts. Science
`264.n5164 (June 3, 1994): pp. 1421-6 ("Salton
`1994")
`
`Transcript oftalk delivered by Sergey Brin at the
`School of Information, University of California,
`Berkeley, 2007, video available from
`http://www. youtube.com/watch?v=Ka9IwHNvkfU
`
`S. Brin and L. Page. The Anatomy of a Large-
`Scale Hypertextual Web Search Engine.
`Computer Networks and ISDN Systems 30 (1-7),
`pp. 107-117, 1998.
`
`M. F. Bruandet, Outline of a knowledge base
`model for· an intelligent information retrieval
`system, Information Processing & Management,
`Volume 25, Issue 1, 1989, Pages 89-115
`
`E. Garfield, "Citation Indexes for Science," from
`Science magazine, Vol. 123, No. 3159, July, 1955,
`pp. 110-111.
`
`E. Garfield. The Role of the Medical Librarian in
`SDI Systems, Bulletin of the Medical Library
`Association 57 (4): pp. 348-351, October 1969
`
`Amendment and Response, filed March 23, 1995,
`in parent '352 prosecution (App. No. 08/076,658)
`
`Exhibit 14J
`
`Exhibit 15J
`
`Exhibit 16J
`
`Exhibit 17J
`
`Exhibit 18J
`
`Exhibit 19J
`
`3
`
`
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