`
`IPR2013-00481 POR at 1-59.
`
`EXHIBIT 2115
`Facebook, Inc. et al. v. Software Rights Archive, LLC
`CASES IPR2013-00478
`IPR2013-00479
`IPR2013-00480
`IPR2013-00481
`
`1
`
`
`
`Claim 12 of the ‘571 Patent Recites a Method of Displaying
`Data Related to a Web Having Identifiable Web Pages
`Claim 12 of the ‘571 patent reads:
`A method for visually displaying data related to a web having identifiable web pages and
`Universal Resource Locators with pointers, comprising:
`choosing an identifiable web page;
`identifying Universal Resource Locators for the web pages, wherein the identified Universal
`Resource Locators either point to or point away from the chosen web page;
`analyzing Universal Resource Locators, including the identified Universal Resource Locators,
`wherein Universal Resource Locators which have an indirect relationship to the chosen web
`page are located, wherein the step of analyzing further comprises cluster analyzing the
`Universal Resource Locators for indirect relationships; and
`displaying identities of web pages, wherein the located Universal Resource Locators are used
`to identify web pages.
`‘571 patent at 52:38-56 (emphasis added); see IPR2013-00481 POR at 6-8.
`
`2
`
`
`
`Petitioners Rely on Fox Envision:
`Principle 3: Links should be recorded, preserved, organized, and generalized. As we integrate documents into
`very large collections covering an entire scientific domain or professional area, links among those documents
`become increasingly important to help with search and browsing. Groupings of those links into paths, threads,
`tours, and webs are essential for organizing, personalizing, sharing, and preserving the structural,
`interpretational, and evolutionary connections that develop. We are beginning to see the emergence of wide
`area hypertext systems (Yankelovich, 1990) like the World Wide Web (WWW), that carry this concept
`forward into a distributed environment. Clearly, we must coordinate hypertext and hypermedia linking with
`the various approaches to search and retrieval (Fox et al., 1991b). One approach is the idea of information
`graphs (including hypergraphs), where objects of all types are interrelated by links or arcs that capture
`not only citation (reference) but also inheritance, inclusion, association, synchronization, sequencing, and
`other relationship. By specializing object-oriented databases to this task, we are building a foundation for next-
`generation integrated retrieval systems (Chen, 1992). Our work with the Large object-oriented External Network
`Database (LEND) system and methods for querying information graphs (Betrabet et al., 1993) is along these
`lines, as are other efforts to build systems for managing information graphs (Giyssens et al., 1990; Paredaens et
`al., 1992). Clearly, adaptations of hypertext (link) and semantic network (A1) concepts are essential for digital
`libraries.
`Envision at 482; see also Pet. at 4; IPR2013-00481 POR at 16-17; ‘571 Jacobs Dec., IPR2013-00481 (Exhibit 2113) at ¶ 97-100.
`
`1,2,3
`
`3
`
`
`
`“Using hypertext links with anchors for
`navigating between objects in a hypergraph
`is entirely different from analyzing hypertext
`links or URLs for indirect relationships.”
`‘571 Jacobs Dec., IPR2013-00481 (Exhibit 2113) at ¶ 97; see also IPR2013-
`00481 POR at 16-20.
`
`4‐11
`
`4
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