Claim 1 of the ‘494 Patent
`
`A method of analyzing a database with indirect
`relationships, using links and nodes, comprising the
`steps of:
`selecting a node for analysis;
`generating candidate cluster links for the
`selected node, wherein the step of generating
`comprises an analysis of one or more indirect
`relationships in the database;
`deriving actual cluster links from the candidate
`cluster links;
`identifying one or more nodes for display; and
`displaying the identity of one or more nodes
`using the actual cluster links.
`
`‘494 patent at 51:37-49; see also IPR2013-00480 POR at 3-
`10.
`
`EXHIBIT 2118
`Facebook, Inc. et al. v. Software Rights Archive, LLC
`CASES IPR2013-00478
`IPR2013-00479
`IPR2013-00480
`IPR2013-00481
`
`1
`
`
`
`A method of analyzing a database with indirect
`relationships, using links and nodes, comprising the
`steps of:
`selecting a node for analysis;
`generating candidate cluster links for the
`selected node, wherein the step of generating
`comprises an analysis of one or more indirect
`relationships in the database;
`deriving actual cluster links from the candidate
`cluster links;
`identifying one or more nodes for display; and
`displaying the identity of one or more nodes
`using the actual cluster links.
`
`‘494 patent at 51:37-49; see also IPR2013-00480 POR at 3-
`10.
`
`EXHIBIT 2118
`Facebook, Inc. et al. v. Software Rights Archive, LLC
`CASES IPR2013-00478
`IPR2013-00479
`IPR2013-00480
`IPR2013-00481
`
`1
`
`
`
`Claim 1 requires there to be an analysis of one or more indirect
`relationships:
`
`generating candidate cluster links
`for the selected node, wherein the
`step of generating comprises an
`analysis of one or more indirect
`relationships in the database;
`
`‘494 patent at 51:37‐49; see also IPR2013‐00480 POR at 3‐10.
`
`2
`
`
`
`Petitioners rely upon the cluster
`splitting process of Fox SMART for the
`disclosure of generating and deriving
`cluster links.
`
`IPR2013‐00480 Pet. at 16‐20; see also IPR2013‐00480 POR at 16‐21.
`
`3
`
`
`
`Jacobs testifies “Clustering using
`bc and/or cc is not expressly or
`inherently disclosed.”
`
`IPR2013‐00480 POR at 16‐21; see also ‘494 Jacobs Decl., IPR2013‐
`00480 Ex 2113 at ¶ 57.
`
`4
`
`
`
`Petitioners Rely on the Following Statement:
`
`The first three values described specify how the
`overall similarity between documents can be
`determined based on available subvectors ‐
`relative weighting, similarity function, and
`whether real valued weights are allowed.
`
`Fox SMART at 46; IPR2013‐00480 Pet. at 17; POR at 18; see also ‘494
`Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 57.
`
`5
`
`
`
`The first three values described specify how the
`overall similarity between documents can be
`determined based on available subvectors ‐
`relative weighting, similarity function, and
`whether real valued weights are allowed.
`
`Fox SMART at 46; IPR2013‐00480 Pet. at 17; POR at 18; see also ‘494
`Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 57.
`
`6
`
`
`
`Dr. Fox Testified:
`
`Q: Is it fair to say that one could choose not
`to use bibliographic coupling or co‐citation
`under that same disclosure?
`
`A: Yeah, this was an experimental system
`that would let you try any one of these
`possible things, one by itself or them in
`different combinations.
`Fox Deposition Transcript Pt. 2 at 476:3‐11; POR at 31‐32;
`see also ‘494 Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶
`139.
`
`7
`
`
`
`Dr. Fox Testifies:
`
`“The sentence says the extended vector model was
`introduced whereby various types of bibliographic data
`were utilized to supplement the standard term vectors.
`So this was a general system to allow
`experimentation. That’s very clear through the whole
`document and through all the works.
`
`So clearly, one could do any one of these things or
`more of them or all combinations of them. That’s very
`clear from and inherent in the discussion.”
`
`Fox Deposition Transcript Pt. 2 at 476:22 – 477:3; POR at 31‐32; see also
`‘494 Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 139.
`
`9
`
`
`
`Dr. Fox testifies:
`Q: Just to finish up on this question, is it fair to say that
`you don’t specify any particular recipe of vectors for
`clustering here?
`
`Q: You leave that up to someone to decide for
`themselves?
`
`A: The sentence says the extended vector model was
`introduced whereby various types of bibliographic data
`were utilized to supplement the standard term vectors.
`So this was a general system to allow experimentation.
`That’s very clear through the whole document and
`through all the works
`Fox Deposition Transcript Pt. 2 at 476:15 – 477:3; POR at 31‐32; see also
`‘494 Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 139.
`
`10
`
`
`
`Fox states:
`“It can be inferred, however, that with the
`other subvectors present cc is not really
`needed and bc is probably not either.”
`Fox Thesis at 258; POR at 31‐32; see also ‘494 Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 139.
`
`11
`
`
`
`Jacobs Testifies :
`“Two Ph. D. students at the University of Massachusetts
`were among those who used the CACM collection for
`their experiments. One of them, Roger Thompson, who
`testified for the Petitioners, did not use the bc and cc
`data.”
`Thompson Part 3, IPR2013-00478 Exhibit 2012, at 96; see also POR at 31‐32; ‘494 Jacobs Decl.,
`IPR2013‐00480 Ex 2113 at ¶ 139.
`“A colleague of Dr. Thompson’s, Dr. Howard Turtle, also
`conducted experiments using the CACM collection and he
`does not use bc or cc either.”
`‘352 Jacobs Decl., IPR2013-00478 Exhibit 2113, at ¶¶ 235-236 (citing Turtle, Exhibit 2029); see also POR
`at 31‐32.
`
`12
`
`
`
`Jacobs testifies “there are no
`indirect relationship in a
`database.”
`
`POR at 21‐31; ‘494 Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶
`109, 51‐127.
`
`13
`
`
`
`Claim 1 recites “an analysis of one or more indirect relationships in the
`database.”
`
`The Board has construed ‘indirect relationships’ for the ‘494 patent as a
`“relationship where at least one intermediate object exists between two
`objects and where the intermediate object connect the two objects
`through a chain of citations.” IPR2013-00479 Inst. Dec. at 11.
`
`Jacobs testifies “one skilled in the art would under this claim language
`to require an object to actually refer (i.e., cite) to another object in a
`database.”
`
`IPR2013-479 Jacobs Decl. at ¶ 216; ‘494 PO Response, IPR2013-00480, at 21-22.
`
`14
`
`
`
`“The fourth and final format of data storage employed is that of
`relations stored in a database of the INGRES relational system.”
`Figures 2 through 4 thus describe the currently used INGRES
`relations.”
`
`Fox SMART at 17-19.
`
`15
`
`
`
`Fox SMART at 14; see also POR at 31‐32; ‘494 Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 139.
`
`16
`
`
`
`Fox SMART at 17; POR at 31‐32; see also
`‘494 Jacobs Decl., IPR2013‐00480 Ex 2113 at
`¶ 139.
`
`18
`
`
`
`Dr. Fox testifies:
`
`Q: What citation information or what do you contend
`constitutes objects with direct relationships with other
`objects that are being disclosed in figures 2, 3, and 4?
`
`A: So this is a high‐level description of how SMART could
`handle any kind of collection. It's not specific to the
`particular case that we're discussing here. So that's an
`instance of what could be done.
`
`Fox Deposition Transcript Pt. 2 at 401:19‐402:03 (emphasis added); POR at
`31‐32; see also ‘494 Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 139.
`
`19
`
`
`
`Fox SMART at 16; POR at 31‐32; see also ‘494
`Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 139.
`
`17
`
`
`
`Dr. Fox testifies:
`Q: Okay. Did any of the figures 2 through 4 describe ‐‐
`disclose ‐‐ specifically disclose the LN, BC, and CC
`subvectors as being among the relations that are stored
`in INGRES?
`
`A: No.
`
`Fox Deposition Transcript Pt. 2 at 407:1‐5 (emphasis added)
`
`Q: Does this mention anything about direct links, co‐
`citation, and bibliographic coupling being stored here?
`
`A: Not specifically.
`
`Fox Deposition Transcript Pt. 2 at 403:9‐13; POR at 31‐32;
`see also ‘494 Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 139.
`
`20
`
`
`
`Dr. Fox Testifies:
`
`Q: Isn't it true that the raw data triples are not described
`here as being stored in INGRES?
`
`A: The raw data triples you described were not at issue
`in my discussion, so they wouldn't have been described
`here.
`
`Fox Deposition Transcript Pt. 2 at 401:9‐18; POR at 31‐32; see also ‘494
`Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 139.
`
`21
`
`
`
`Dr. Fox testifies:
`
`Q: But does it disclose co‐citation information being
`described ‐‐ does this specifically disclose co‐citation
`information being stored here as a document detail?
`
`A: There is no specific mention of co‐citation on this
`page.
`
`Fox Deposition Transcript Pt. 2 at 402:15‐24; POR at 31‐32; see also
`‘494 Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 139.
`
`22
`
`
`
`Board’s Institution Decision Position
`
`IPR2013‐00480 Inst. Dec. at 17.
`
`23
`
`
`
`Claim 1 recites:
`A method of analyzing a database with indirect relationships, using
`links and nodes, comprising the steps of:
`selecting a node for analysis;
`generating candidate cluster links for the selected node,
`wherein the step of generating comprises an analysis of one
`or more indirect relationships in the database;
`deriving actual cluster links from the candidate cluster links;
`
`‘494 patent at 51:37-49; see also POR at 31‐32; ‘494 Jacobs Decl., IPR2013‐00480 Ex 2113 at ¶ 139.
`
`25
`
`
`
`Fox SMART at 51
`
`Fox SMART at 49
`
`Garbage Cluster
`
`Fox SMART at 52 (annotated)
`
`31
`
`
`
`Concentration test – “Candidate clusters which pass the concentration test are those formed by
`having enough highly correlated pairs in the proposed cluster.” Fox Smart at 50.
`
`Definition test – “Once such a core has been identified other slightly less tightly bound children
`… can be added.” Fox SMART at 50.
`
`Uncour – “‘Uncour’ compensates for … [overlap] by first deleting clusters that exhibit too much
`overlap with remaining clusters, and secondly by assigning the others to a ‘garbage’ or ‘orphan
`cluster.’” Fox SMART at 49.
`
`32
`
`
`
`Claim 5 of the ‘494 Patent
`
`The method of claim 1 wherein the step of
`generating the candidate cluster links comprises the
`step of:
`
`eliminating candidate cluster links, wherein the
`number of candidate cluster links are limited and the
`closest candidate cluster links are chosen over the
`remaining links. (Emphasis added).
`
`33
`
`
`
`Claim 1 of the ‘494 Patent
`
`A method of analyzing a database with indirect relationships,
`using links and nodes, comprising the steps of:
`selecting a node for analysis;
`generating candidate cluster links for the
`selected node, wherein the step of generating comprises an
`analysis of one or more indirect relationships in the
`database;
`deriving actual cluster links from the candidate
`cluster links;
`identifying one or more nodes for display; and
`displaying the identity of one or more nodes using
`the actual cluster links. (Emphasis added).
`
`34
`
`
`
`Claim 5 of the ‘494 Patent
`
`Claim 5, re‐written into independent form recites, inter alia:
`
`A method of analyzing a database with indirect relationships,
`using links and nodes, comprising the steps of:
`…
`generating candidate cluster links for the selected
`node, … wherein the step of generating the candidate cluster
`links comprises the step of: eliminating candidate cluster
`links, wherein the number of candidate cluster links are
`limited and the closest candidate cluster links are chosen
`over the remaining links,
`
`deriving actual cluster links from the candidate
`cluster links; ... (Emphasis added).
`
`35
`
`
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