`
`IPR2013-00478 POR at 11.
`
`EXHIBIT 2116
`Facebook, Inc. et al. v. Software Rights Archive, LLC
`CASES IPR2013-00478
`IPR2013-00479
`IPR2013-00480
`IPR2013-00481
`
`1
`
`
`
`The Patents at Issue Claim a Method of
`Non-Semantical Searching
`Claim 26 of the ‘352 patent recites:
`A non-semantical method for numerically representing objects in a
`computer database and for computerized searching of the numerically
`represented objects in the database, wherein direct and indirect
`relationships exist between objects in the database, comprising:
`…
`searching the objects in the database using a computer and the stored
`second numerical representations, wherein the search identifies one or
`more of the objects in the database.
`‘352 patent at 35:28-53 (emphasis added); see also IPR2013-00478 POR at 11.
`
`2
`
`
`
`The District Court Construed “Non-Semantical” as
`One That “Does Not Account for Phrases and Words”
`In previous litigation, the District Court construed the
`term “non-semantical method" as "a method of analysis
`that is based on direct relationships between textual
`objects and that otherwise does not account for phrases
`and words in a textual object.”
`Claim Construction Order, IPR2013-00478 Exhibit 2022; see also IPR2013-00478 POR at 11.
`
`Q
`
`3
`
`
`
`‘352 Jacobs Dec., IPR2013-00478 Exhibit 2113 at ¶ 244-250 ;Fox Thesis, IPR2013-00478 Exhibit 1009 at 241-256; IPR2013-00478 POR at 50-
`54.
`
`4
`
`
`
`‘352 Jacobs Dec., IPR2013-00478 Exhibit 2113 at ¶ 244-250 ; Fox Thesis at 242-260; IPR2013-00478 POR at 50-54.
`
`5
`
`
`
`Jacobs Testifies The Fox Papers Explicitly
`Teach to Use Terms
`“The recipe proposed is to at least employ terms (tm), some manually
`assigned categorization scheme (cr), and direct links between
`documents (ln). When bibliographic information is only available
`among articles in a collection the simplest form of that information,
`references (ln) [i.e., the direct links vector], seems to be the most reliable
`and most useful of all the types considered (bc, ln, cc) [(bc) and (cc) are
`the indirect bibliographic vectors]. The ln subvectors are typically
`longer than the other two and are easier to obtain so use of them is
`encouraged by practicality considerations as well as effectiveness tests.”
`‘352 Jacobs Dec., IPR2013-00478 Exhibit 2113 at ¶ 223, 244-250; Fox Thesis at 253; see also
`IPR2013-00478 POR at 50-54.
`
`6
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