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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)
`
`IPR2013-00480 (Patent 5,832,494)
`
`IPR2013-00481 (Patent 6,233,571)
`
`Videotaped Deposition of EDWARD A. FOX, Ph.D.,
`
`Volume 1, at 15 Franklin Road, SW, Suite 7,
`
`Roanoke, Virginia, commencing at 9:00a.m.,
`
`Saturday, April 26, 2014, before Mary Ann
`
`Payonk, Nationally Certified Realtime Reporter
`
`and Notary Public.
`
`JOB No. 1852500
`
`PAGES 1 - 278
`
`Veritext National Deposition & Litigation Services
`866 299-5127
`
`Page 1
`
`EXHIBIT 2016
`Facebook, Inc. et al.
`v.
`Software Rights Archive, LLC
`CASE IPR2013-00480
`
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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)
`
`IPR2013-00480 (Patent 5,832,494)
`
`IPR2013-00481 (Patent 6,233,571)
`
`Videotaped Deposition of EDWARD A. FOX, Ph.D.,
`
`Volume 1, at 15 Franklin Road, SW, Suite 7,
`
`Roanoke, Virginia, commencing at 9:00a.m.,
`
`Saturday, April 26, 2014, before Mary Ann
`
`Payonk, Nationally Certified Realtime Reporter
`
`and Notary Public.
`
`JOB No. 1852500
`
`PAGES 1 - 278
`
`Veritext National Deposition & Litigation Services
`866 299-5127
`
`Page 1
`
`EXHIBIT 2016
`Facebook, Inc. et al.
`v.
`Software Rights Archive, LLC
`CASE IPR2013-00480
`
`
`
`A P P E A R A N C E S :
`
`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 :
`
` B Y : V I C T O R H A R D Y , E S Q .
`
` v h a r d y @ d p e h l a w . c o m
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` B Y : M I T C H Y A N G , E S Q .
`
` m y a n g @ d p e h l a w . c o m
`
` 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
`
` 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
`
` B Y : M A R T I N M . Z O L T I C K , E S Q .
`
` m z o l t i c k @ r f e m . c o m
`
` B Y M I C H A E L H . J O N E S , E S Q .
`
` 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
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` m z o l t i c k @ r f e m . c o m
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`
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`A P P E A R A N C E S ( C O N T I N U E D ) :
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`O N B E H A L F O F F A C E B O O K :
`
` B Y : H E I D I K E E F E , E S Q .
`
` h k e e f e @ c o o l e y . c o m
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` C O O L E Y L L P
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` 3 1 7 5 H a n o v e r S t r e e t
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` P a l o A l t o , C A 9 4 3 0 4
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`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 :
`
` B Y : D A V I D J . S I L B E R T , E S Q .
`
` 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 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 6
`
` EXHIBITS
`
`NUMBER MARKED
`
`Exhibit 2009 . . . . . . . . . . . 26
`
`Exhibit 2011 . . . . . . . . . . . 238
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` EXHIBITS REFERENCED
`
` (Previously marked)
`
`NUMBER REFERENCED
`
`Exhibit 1007 . . . . . . . . . . . 187
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`Exhibit 1009 . . . . . . . . . . . 33
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`Exhibit 1016 . . . . . . . . . . . 131
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` THE VIDEOGRAPHER: Good morning. 09:14
`
` We're on record at 8:14 a.m. [sic]. 09:14
`
` Today's date is April 26, 2014. This is 09:14
`
` the video recorded deposition of Edward 09:14
`
` A. Fox, Ph.D., volume 1. 09:14
`
` My name is Steve Oaks, here with 09:14
`
` our court reporter, Mary Payonk. We are 09:14
`
` here from Veritext Legal Solutions. 09:14
`
` This deposition is being held at Pierce 09:14
`
` Reporting Company in Roanoke, Virginia. 09:14
`
` The case caption is United States 09:14
`
` Patent and Trademark Office before the 09:14
`
` Patent Trial and Appeal Board, Facebook, 09:14
`
` Inc., LinkedIn Corp., and Twitter, Inc., 09:15
`
` Petitioners, versus Software Rights 09:15
`
` Archive LLC, Patent Owner, cases 09:15
`
` IPR2013-00478, Patent 5,544,352; 09:15
`
` IRP2013-00479, Patent 5,832,494; 09:15
`
` IPR2013-00480, Patent 5,832,494; 09:15
`
` IPR2013-00481, Patent 6,233,571. 09:15
`
` If the court reporter will swear 09:15
`
` the witness in and attorneys identify 09:15
`
` yourselves, we can do that. 09:15
`
` THE WITNESS: Do you want to change 09:16
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` it to 9:14 instead of 8:14? 09:16
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` THE VIDEOGRAPHER: Oh, I am so 09:16
`
` sorry. 9:14 is correct. 09:16
`
` (Whereupon, counsel placed their 09:16
`
` appearances on the video record.) 09:16
`
` EDWARD A. FOX, Ph.D., 09:16
`
` called as a witness, having been duly 09:16
`
` sworn, was examined and testified as 09:16
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` follows: 09:16
`
` EXAMINATION 09:16
`
`BY MR. HARDY: 09:16
`
` Q. Dr. Fox, does the term "link" have a 09:16
`
`meaning in the art? 09:17
`
` A. Are you referring to the prior art or 09:17
`
`are you referring to the current art? 09:17
`
` Q. Your field. 09:17
`
` A. Certainly, there's a number of 09:17
`
`different meanings for that word, just like any 09:17
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`other word. 09:17
`
` Q. Okay. What are those meanings? 09:17
`
` A. So a link can be a noun form or a 09:17
`
`verb form, for example. If you say I linked to 09:17
`
`something else, if we use the PTAB 09:17
`
`construction, that means cite, I think really 09:17
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`is what they're getting at. It may mean 09:17
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`referred to. It may be related to. There's 09:17
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`also the noun form of this, which is the object 09:17
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`or the thing or the entity that represents a 09:17
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`relationship. So you have a link between 09:17
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`things, various kinds of links. 09:18
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` Q. All right. Does the term "node" have 09:18
`
`a meaning in the art? 09:18
`
` A. You said "node"? 09:18
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` Q. "Node." 09:18
`
` A. Okay. Yes, again, "node" has a 09:18
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`number of different meanings. They're all, I 09:18
`
`think, noun forms. I don't think there are any 09:18
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`verb forms for "node." It tends to be used in 09:18
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`graph terminology as a point or a thing that's 09:18
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`connected to other things, so representing some 09:18
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`type of entity of some kind. Often, 09:18
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`graphically, it's shown as a circle. It may 09:18
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`represent an object or a name or a word or an 09:18
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`author or a document, a number of different 09:18
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`things. 09:18
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` Q. What is your understanding of what 09:18
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`"node" means with respect to the patents at 09:18
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`issue in this proceeding? 09:18
`
` A. So let me refer first to see if 09:18
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`there's anything construed about this, if you 09:19
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`give me a second to have -- I have a list here. 09:19
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`I think the exhibits have all been cleared so 09:19
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`this is -- they have this as an exhibit; right? 09:19
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` MR. SILBERT: No. This is a -- 09:19
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` Dr. Fox is referring to a sheet we 09:19
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` prepared that simply lists the claim 09:19
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` constructions that the PTAB made in 09:19
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` its -- in its various orders. 09:19
`
` MR. HARDY: Okay. 09:19
`
` A. So remind, the word -- 09:19
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` Q. What is your understanding of what a 09:19
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`node means in this proceeding? 09:19
`
` A. Okay. Well, "node" is used in a 09:19
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`number of places in the District Court's 09:19
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`construction, and I believe also in the PTAB's 09:19
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`constructions, so let me just look through 09:19
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`that. 09:19
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` MR. ZOLTICK: While the witness is 09:19
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` looking, counsel, if he's got a document 09:19
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` he prepared that isn't in the record, at 09:19
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` least I'd like to have a copy of it, 09:19
`
` what the witness is looking at. 09:19
`
` MR. SILBERT: We can make copies. 09:19
`
` It's simply a list of the claim 09:19
`
` constructions that are contained in the 09:20
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` PTAB's orders. So you have them 09:20
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` already, but we can make a copy of this 09:20
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` particular version of it. 09:20
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` A. So "node" occurs in a number of 09:20
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`different constructions. It's in the 09:20
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`construction for "candidate cluster links." 09:20
`
`From the District Court's construction, it's 09:20
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`the set of all possible cluster links between a 09:20
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`search node and a target node. So we have 09:20
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`"node" twice there. In the PTAB's construction 09:20
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`it's a set of possible cluster links between a 09:20
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`search node and a target node, so again, those 09:20
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`both occur. That was for the '494. It's also 09:20
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`used the same way in '571. 09:20
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` Q. Hold on a second. Let me interrupt 09:20
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`you. 09:20
`
` A. Okay. 09:20
`
` Q. Dr. Fox, do you know what the word 09:20
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`"node" means without looking at that piece of 09:20
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`paper? 09:20
`
` A. You just asked me a few minutes ago 09:20
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`to define it, and I did. And now you asked me 09:20
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`what it meant in this particular situation, so 09:20
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`I'm trying to be careful about that. 09:20
`
` Q. My question to you is: Do you know 09:20
`
`what the word "node" means when you're not 09:20
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`looking at that piece of paper? 09:20
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` MR. SILBERT: Objection. 09:20
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` A. I think they say "asked and 09:20
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`answered." 09:21
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` Q. You're not -- I'll repeat my 09:21
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`question -- 09:21
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` A. Okay. 09:21
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` Q. -- to you again. 09:21
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` A. Okay. The answer is yes, yes. 09:21
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` Q. Do you know what "node" -- 09:21
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` A. Yes. 09:21
`
` Q. -- means? 09:21
`
` A. Yes. 09:21
`
` Q. What is your understanding of what 09:21
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`"node" means -- 09:21
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` MR. SILBERT: Objection, asked and 09:21
`
` answered. 09:21
`
` Q. -- in the context of these patents? 09:21
`
` A. It means what I was just trying to 09:21
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`explain to you. I'm going through what it 09:21
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`means in this context of this patent, because 09:21
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`the construals are what's important here. 09:21
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` Q. Well, you have read to me the claim 09:21
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`construction for "candidate cluster link." I'm 09:21
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`not sure what that means, you know, to -- what 09:21
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`that has to do with what the word "node" means. 09:21
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`So my question to you is: What does the word 09:21
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`"node" mean? 09:21
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` MR. SILBERT: Objection, asked and 09:21
`
` answered. 09:21
`
` A. The word "node" occurs in a number of 09:21
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`constructions as the definition for particular 09:21
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`words. So the word "node" in this context 09:21
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`relates to the things that are defined by those 09:22
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`constructions. So in the context of this -- 09:22
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`these patents, that's what "node" means. 09:22
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` Q. Are you able to offer, to tell me a 09:22
`
`construction for the word "node" that you used 09:22
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`in preparing your opinion today? 09:22
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` A. I relied on the Court's -- on the 09:22
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`District Court's construction and also referred 09:22
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`to PTAB's construction for all of the 09:22
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`construals. "Node" is very important in these 09:22
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`different terms. We can invert these 09:22
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`definitions to go back to define what they are 09:22
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`in terms of the issues in the -- 09:22
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` Q. My -- 09:22
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` MR. SILBERT: Let him finish his 09:22
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` answer. 09:22
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` A. -- in the patent. 09:22
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` Q. My question to you is: Can you state 09:22
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`the definition of "node" used in these 09:22
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`proceedings? 09:22
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` A. Yes. 09:22
`
` MR. SILBERT: Objection, asked and 09:22
`
` answered. 09:22
`
` Q. Okay. Please state that construction 09:22
`
`of "node" that you used in preparing your 09:22
`
`opinion. 09:22
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` A. I think I've done it several times, 09:23
`
`but I'll do it again if you'd like me to. 09:23
`
`Would you like me to do it again? 09:23
`
` Q. I'd like you to do it the first time. 09:23
`
` MS. KEEFE: Objection, 09:23
`
` argumentative. 09:23
`
` MR. SILBERT: Objection. 09:23
`
` A. So in the context of these patents, 09:23
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`"node" is used in multiple situations. It's 09:23
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`used in the terms of nodes in a database. It's 09:23
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`used in the term of search node. It's used in 09:23
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`the sense of target node. So in all those 09:23
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`cases, those are putting context around what 09:23
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`"node" means. 09:23
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` So a node in a database is a thing in 09:23
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`a database, some kind of object of some kind. 09:23
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`it's a node that relates to searching or it's a 09:23
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`node that relates to the target of a search. 09:23
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` Q. So you would understand "node" to 09:23
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`mean an object in a database in the context of 09:23
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`these patents? 09:23
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` A. That's one of many different possible 09:23
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`meanings. 09:24
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` Q. Okay. Do you know what the phrase 09:24
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`"knowledge framework for extracting terms and 09:24
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`concepts" refers to? 09:24
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` A. I can guess at what it means. I'm 09:24
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`not sure if it occurred in any of these 09:24
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`documents. If it did occur in one of those 09:24
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`documents, I'd need to see the context of that 09:24
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`occurrence. 09:24
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` Q. Could you state what that means to 09:24
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`you? 09:24
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` A. Do you want me to state it by looking 09:24
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`for it in the documents, or do you want me to 09:24
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`do it based on just a guess at what might be in 09:24
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`the context? 09:24
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` Q. Yes. 09:24
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` A. Which one? 09:24
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` Q. I want your understanding of it. 09:24
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` A. I just told you, there's different 09:24
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`understandings depending on the context. Which 09:24
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`one would you like me to do? 09:24
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` Q. The one that you have presently 09:24
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`without looking at any documents. 09:25
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` A. Could you repeat it just so I get the 09:25
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`right phrase. 09:25
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` Q. Knowledge framework for extracting 09:25
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`terms and concepts. 09:25
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` A. So there's -- "terms and concepts" 09:25
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`was the last part? 09:25
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` Q. Uh-huh. 09:25
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` A. Okay. So there's multiple pieces to 09:25
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`this. One is knowledge. One is framework. 09:25
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`One is extracting. One is terms. And one is 09:25
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`concepts. So all of those have particular 09:25
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`meanings in this context. Do you want me to 09:25
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`try and go through each one of them? 09:25
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` Q. I'd like you to give me a meaning for 09:25
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`the phrase. Let me ask you this question: Do 09:25
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`you think that phrase could refer to your work 09:25
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`in Fox '83? 09:25
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` MR. SILBERT: Objection. 09:25
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` A. Could possibly, except I'm not sure 09:25
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`what you mean by Fox '83. Are you referring to 09:26
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`all of my works, or -- 09:26
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` Q. The experiments in your Fox Thesis, 09:26
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`in Fox SMART, and Fox Collections. 09:26
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` A. So my understanding is that we're 09:26
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`talking about today are sets of documents, not 09:26
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`systems or experiments. Do you mean I should 09:26
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`refer to the documents, or I should refer to 09:26
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`the systems, or the experiments? Which would 09:26
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`you like? Because you said "experiments." 09:26
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` Q. I'd say your work in the experiments, 09:26
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`the work, subject matter, and Fox '83 papers. 09:26
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` MS. KEEFE: Objection, compound. 09:26
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` A. I'm just trying to sort out because I 09:26
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`understand the grounds for these petitions and 09:26
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`declarations are documents per se as opposed to 09:26
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`other things. So you want me to go beyond the 09:27
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`bounds of what's in my declaration and talk 09:27
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`about other things that are not at issue? 09:27
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` Q. No, I'm asking -- the question is -- 09:27
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`is the subject matter of your -- of the work 09:27
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`described in the Fox '83 papers that I just 09:27
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`specified to you? 09:27
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` A. Okay. So I use the term "framework" 09:27
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`in a number of different cases. "Framework" is 09:27
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`kind of a broad outline or context or 09:27
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`theoretical foundation for something. So in my 09:27
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`more recent works, we refer to a 5S framework 09:27
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`and sometimes we talk about the theory or the 09:27
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`model and other aspects. So a knowledge 09:27
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`framework is certainly something that deals 09:27
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`with what one knows, knowledge kind of issues. 09:27
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` So knowledge framework is a very 09:28
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`broad kind of construct in a general sense. 09:28
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`Sometimes you talk about in physics 09:28
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`relativities of framework for a lot of physics, 09:28
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`for example. So I'm not exactly sure what 09:28
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`you're looking for there, but certainly there's 09:28
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`a broad bunch of work I did and some of that 09:28
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`has to do with extracting things. Some of it 09:28
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`has to do with terms and some of it has to do 09:28
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`with concepts. 09:28
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` Q. So let's bring it back to the 09:28
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`question that I originally asked. Is the term 09:28
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`"knowledge framework for extracting terms and 09:28
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`concepts," could that be used to describe 09:28
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`aspects of your work that describe the Fox '83 09:28
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`papers? 09:28
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` MR. SILBERT: Object to the form. 09:29
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` A. I guess so. People use different 09:29
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`kinds of explanations for different things. 09:29
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`It's a very general statement. It may describe 09:29
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`some of what I did. Certainly other things I 09:29
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`did were different from that. 09:29
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` Q. Well, let me ask you this question: 09:29
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`Did your work involve extracting terms and 09:29
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`concepts? 09:29
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` A. So it's unclear what you mean by 09:29
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`"extracting" in this case. There are lots of 09:29
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`different kinds of extraction. One of the -- 09:29
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`parts of the SMART system which I reported in 09:29
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`the -- on the tech reports and discussed in 09:29
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`thesis, and also in the collection, had to do 09:29
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`with sets of documents. Those documents were 09:29
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`strings of words as you might find in a title 09:29
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`or an abstract. They were English words with 09:30
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`other words in between, what sometimes might be 09:30
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`called stop words. 09:30
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` So in the parsing part of this, we 09:30
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`would go through those and we'd identify 09:30
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`typically non-stop words -- although sometimes 09:30
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`we would include those too -- and we would in 09:30
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`some cases apply some type of linguistic 09:30
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`processing, such as approximating constructing 09:30
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`the root form, a process called stemming. We 09:30
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`would often call those things terms as opposed 09:30
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`to words because they were indicative of one or 09:30
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`more words. So, for example, the word "fire" 09:30
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`might be the -- or -- "fire" would come out as 09:30
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`the term that would come out from "fires" or 09:30
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`"firing" or other kinds of things. So from the 09:30
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`original document, we would be extracting those 09:31
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`things in one sense. 09:31
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` Q. And you -- what would be extracting 09:31
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`concepts in your work? 09:31
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` A. So in my dissertation, I introduced 09:31
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`the idea of a concept type where there are 09:31
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`multiple types of concepts. So the term might 09:31
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`be in most people's vocabulary something 09:31
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`related to words, but there are other things 09:31
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`that are important in describing or 09:31
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`characterizing a document, in many cases. The 09:31
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`date is a type of concept related to it. The 09:31
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`category that it might be described in the 09:31
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`category system could also be a type of 09:31
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`concept. The names of authors could be a type 09:31
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`of concept. The linking between documents 09:32
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`could be a type of concept relating to a 09:32
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`document. The bibliographic coupling indicator 09:32
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`for a given document pair, typically, could be 09:32
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`another type of concept. 09:32
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` So I introduced this notion of 09:32
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`concept type, which of course means that there 09:32
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`are concepts that have types. 09:32
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` Q. Did you come up with the idea of 09:32
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`these concept types? 09:32
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` A. I think my dissertation and the other 09:32
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`publications have extensive related work 09:32
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`sections that talk about many different people 09:32
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`who came up with different kinds of things. I 09:32
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`was very fortunate for my bachelor's work to 09:32
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`have Michael Kessler as my thesis advisor. He 09:32
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`coined the term "bibliographic coupling," which 09:33
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`is one of the types of concepts I used, so he 09:33
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`gets credit for that one. There's a little bit 09:33
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`of debate of who came up with "co-citation." 09:33
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`There's a few different people, Small, 09:33
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`Garfield, and I can't remember the other one -- 09:33
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`starts with an M, potentially -- for the 09:33
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`co-citation. 09:33
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` But I think -- I think the concept of 09:33
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`date has been known for a long time. Does that 09:33
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`help? 09:33
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` Q. Yeah. And what is a knowledge 09:33
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`framework? How would that apply to what you're 09:33
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`doing? 09:33
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` MS. KEEFE: Objection. 09:33
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` A. So once again, I'm not sure what 09:33
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`you're referring to by knowledge framework. As 09:33
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`I said before also, there are lots of 09:33
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`interpretations. Sometimes, people are counted 09:33
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`as knowledge workers and so they -- some 09:33
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`framework in which they function. One of my 09:34
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`friends back in the early '90s was very 09:34
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`influential in the early hypertext work, and I 09:34
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`think the hypertext community felt that was a 09:34
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`framework for understanding things and 09:34
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`knowledge. Artificial intelligence has a 09:34
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`number of -- 09:34
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` Q. I'm sorry, my question was a little 09:34
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`imprecise. 09:34
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` A. Okay. I'm sorry. 09:34
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` Q. The -- what I meant was the knowledge 09:34
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`framework for extracting terms and concepts, 09:34
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`like what does that, when you put it all 09:34
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`together, what kind of knowledge -- what could 09:34
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`that be referring to -- 09:34
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` MS. KEEFE: Object to form. 09:34
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` Q. -- in your work? 09:34
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` A. Again, it could refer to a lot of 09:34
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`different things. I looked at a number of 09:34
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`different approaches to this broad field and 09:34
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`tried to provide some integration across those. 09:34
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`Some people would say -- would use "model" 09:34
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`instead of "framework," and the Boolean model 09:34
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`was used fairly commonly. Some people would 09:35
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`use the vector space model as another one. 09:35
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`Some people would use the probabilistic model 09:35
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`as a different one. Some people would use an 09:35
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`artificial intelligence model as a frame. 09:35
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` So there were many, many different 09:35
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`ones that were interesting to me and that I 09:35
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`looked at. 09:35
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` Q. What knowledge frameworks did you 09:35
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`use? 09:35
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` A. I used all of those that I just 09:35
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`mentioned, Boolean, vector space, one that was 09:35
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`a combination of those two, which is called 09:35
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`P-norm. I also did some linguistic processing, 09:35
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`some natural language processing or artificial 09:35
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`intelligence. So those are all models or 09:35
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`approaches that I think may fit into your 09:35
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`concept of knowledge framework. I'm not sure. 09:35
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` (Discussion held off the record.) 09:35
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`BY MR. HARDY: 09:37
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` Q. What does the term "feedback 09:37
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`precision" refer to in the context of your work 09:37
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`in the Fox '83 papers? 09:37
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` MR. SILBERT: I'm sorry, did you 09:37
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` say "feedback position"? 09:37
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` MR. HARDY: Precision. 09:37
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` MS. KEEFE: Object to form. 09:37
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` A. Again, I'd have to look specifically 09:37
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`to find where I said that. I can guess at what 09:38
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`I probably meant because I understand how all 09:38
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`that worked. Should I try and explain it from 09:38
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`that sense? 09:38
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` Q. Yeah.
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