Petitioner’s Arguments
`
`EXHIBIT 2121
`Facebook, Inc. et al. v. Software Rights Archive, LLC
`CASES IPR2013-00478
`IPR2013-00479
`IPR2013-00480
`IPR2013-00481
`
`F
`
`1
`
`
`
`EXHIBIT 2121
`Facebook, Inc. et al. v. Software Rights Archive, LLC
`CASES IPR2013-00478
`IPR2013-00479
`IPR2013-00480
`IPR2013-00481
`
`F
`
`1
`
`
`
`ISI
`
`
`
`ISIISI
`
`
`
`
`
`2
`
`
`
`Petitioners rely upon these statements concerning the
`experiment of Table 8.7 (“ISI”):
`Apparently, the best combination is to use tm and cc.
`Regression methods lead to a combined similarity computation
`which is a 5% improvement over terms alone.
`Fox Dec. at ¶ 64; Fox Thesis at 246.
`Of all the subvectors, terms are best, though co-citations are
`not much worse. Author subvectors are not worthwhile, alone
`or in combination. Using regression or guessed at coefficients,
`the tm and cc combination yields a 5-6% improvement over
`the performance when terms alone are used.
`Fox Dec. at ¶ 65 Fox Thesis at 247; ‘352 Jacobs Decl., IPR2013-00478 Ex. 2113, at ¶ 287; IPR2013-00478 POR
`at 32-34.
`
`3
`
`
`
`‘352 Jacobs Decl., IPR2013-00478 Ex. 2113, at ¶ 289.
`
`Fox Thesis, IPR2013-00478 Exhibit 1009 at 241-256; ‘352 Jacobs Decl., IPR2013-00478 Ex. 2113, at ¶ 287; IPR2013-00478 POR at 32-34.
`
`4
`
`
`
`Fox thesis states:
`“Mild improvements for ISI suggested further testing and so
`the CACM collection was considered.”
`
`‘352 Jacobs Decl., IPR2013-00478 Ex. 2113, at ¶ 289 (citing Fox Thesis at 283); ‘352 Jacobs Decl., IPR2013-
`00478 Ex. 2113, at ¶ 287; IPR2013-00478 POR at 32-34.
`
`G
`
`5
`
`
`
`Fox Thesis states:
`“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.”
`
`Fox Thesis at 253; ‘352 Jacobs Decl., IPR2013-00478 Ex. 2113, at ¶ 291; IPR2013-00478 POR at 52.
`
`6
`
`
`
`Fox Thesis 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 253; ‘352 Jacobs Decl., IPR2013-00478 Ex. 2113, at ¶ 203; IPR2013-00478 POR at 52.
`
`7
`
`
`
`The Prior Art as a Whole Must be Considered:
`“[T]he prior art as a whole must be considered. The teachings are
`to be viewed as they would have been viewed by one of ordinary
`skill. “It is impermissible within the framework of section 103 to
`pick and choose from any one reference only so much of it as will
`support a given position, to the exclusion of other parts necessary to
`the full appreciation of what such references fairly suggests to one of
`ordinary skill in the art.”
`In re Hedges, 783 F.2d 1038, 1041 (Fed. Cir. 1986) (quoting In re Wesslau, 353 F.2d at 241, 147
`USPQ at 393).
`
`H,I
`
`8
`
`
`
`Jacobs Testifies:
`“The ISI collection itself is a specialty collection where the documents in
`the collection were chosen specifically to be rich in co-citation data so that
`the effects of co-citation may be more easily detected:
`A…[W]e constructed a collection of works that were highly co-cited… I
`was trying to show the benefit of using co-citation….
`Q. …are you saying that you selected documents that would be rich
`in co-citation relationships?
`A. Yes.
`Fox Depo. Tr. Pt. 1 at 159:20-160:17.
`To be in the ISI collection an article must be cited 5 times, which is a
`condition that would not normally be present absent this engineering.
`‘352 Jacobs Dec., IPR2013-00478, Exhibit 2113 at ¶ 295; see also IPR2013-00478 POR at 52.
`
`9
`
`
`
`Jacobs Testifies:
`“[T]he improvements were mild and below the threshold of
`significance set forth by Dr. Fox’s thesis advisor:”
`“An average effectiveness improvement above 10 percent
`is normally considered important enough to warrant
`serious attention…”
`
`Salton 1986 at 9; see also ‘352 Jacobs Decl., IPR2013-00478 Ex. 2113, at ¶ 294; IPR2013-00478 POR at 52.
`
`10
`
`
`
`Jacobs testified:
`
`• “direct links were not
`available for the ISI
`collection” ‘352 Jacobs Dec. at ¶ 296
`• “there was no testing to determine
`whether … cc and bc would
`degrade precision results in the
`presence of the other subvectors—as
`was the case for nearly all of the
`other feedback experiments
`disclosed in Chapter 8” (id.)
`
`“[N]o teaching [or experiment] in the Fox Papers that … suggested that either bc or
`cc would improve results when direct links (ln) were available.” Jacobs ¶ 297.
`
`‘352 Jacobs Dec., IPR2013-00478 Exhibit 2113 at ¶ 287 (citing Fox Thesis, IPR2013-00478 Exhibit 1009 at 241-256), 288; IPR2013-00478 POR at 50-53.
`
`11
`
`
`
`Jacobs Testifies: No experiment “suggested that either bc or cc
`would improve results when direct links (ln) were available.”
`Jacobs ¶ 297.
`
`Experiment
`8.8-CACM (bc)
`8.8-CACM (cc)
`8.11-CACM (bc)
`8.11-CACM (cc)
`
`Result
`-43.5% (vs ln)
`-26.7% (vs ln)
`-7.4% (vs ln)
`-6% (vs ln)
`
`Experiment
`8.11-CACM (bc+cc)
`8.12-CACM (bc)
`8.12-CACM (cc)
`
`Result
`-4.1% (vs ln)
`-30% (vs ln)
`-32.4% (vs ln)
`
`‘352 Jacobs Dec., IPR2013-00478 Exhibit 2113 at ¶ 227, 287; see also IPR2013-00478 POR at 1, 50-54.
`
`12
`
`
`
`Claim 26 of the ‘352 Patent Requires a First Numerical
`Representation Based Upon an Object’s Direct Relationship
`with Other Objects
`Claim 26 of the ‘352 patent reads:
`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:
`
`…c
`
`reating a first numerical representation for each identified
`object in the database based upon the object's direct
`relationship with other objects in the database;
`storing the first numerical representations for use in
`computerized searching;
`
`… ‘
`
`352 patent at 35:28-53 (emphasis added); see also IPR2013-00478 POR at 44.
`
`13
`
`
`
`Jacobs Testifies on Nunn’s ISI Results:
`
`13.2-13.5% degradation
`
`Jacobs Depo. Tr. Pt. 2 at 397-402; Nunn, Exhibit 2027, at 37; ‘352 Jacobs Decl., IPR 2013-00478 at ¶ 213; IPR2013-
`00478 POR at 50-55.
`
`14
`
`
`
`Jacobs Testifies as to the ISI Results
`
`Experiment
`8.2-ISI (cc)
`8.2-ISI (cd)
`8.3-ISI (cc+terms)
`8.3-ISI (cc+other subvectors)
`8.3-ISI (cc+terms)
`8.7-ISI (cc+terms regression)
`
`Result
`-37% (vs terms)
`-54% (vs terms)
`-6.2% (vs terms)
`-7.8% (vs terms)
`+4.5 to 6.1% (vs terms)
`+5 to 6% (vs terms)
`
`-13.2%
`-13.5 %
`degradation
`over terms
`Nunn, Exhibit 2027 at 37; see also Jacobs Depo. Tr. Pt. 2 at 397-402; IPR2013-00478 POR at 1, 53-54; ‘352 Jacobs
`Dec., IPR2013-00478 Exhibit 2113 at ¶ 287, 397-402.
`15
`
`15
`
`
`
`“[S]ince no obvious way exists for
`distinguishing the positive from the negative
`effects, the citation methodology cannot be
`recommended for inclusion in practical
`retrieval environments.”
`Salton 1986, Ex. 2009, at 11, abstract (emphasis added).
`“Overall, the procedure is not sufficiently
`reliable to warrant incorporation into
`operational automatic retrieval systems.”
`Salton 1986, Ex. 2009, at 11, abstract (emphasis added); see, e.g., ‘352 Jacobs Decl.,
`IPR2013-00478 Ex. 2113 at ¶ 211; IPR2013-00478 POR at 51.
`
`16
`
`
`
`“Merely Inferior Results”
`
`Petitioners’ Reply to Patent Owner’s Response, IPR 2013-00481, Paper 38 at 11.
`
`17
`
`
`
`Even if certain isolated experiments showed that a particular
`subvector was less useful than others under certain conditions,
`Dr. Fox’s work still did not “teach away.” See Fox Reply Decl. ¶¶
`375-89; In re Moutter [sic], 686 F.3d 1322, 133-34 (Fed. Cir.
`2012) (holding that prior art did not teach away even though it
`considered the claimed invention to be inferior); Syntex (U.S.A.)
`LLC v. Apotex, Inc., 407 F.3d 1371, 1380 (Fed. Cir. 2005) (same).
`
`Petitioners’ Reply to Patent Owner’s Response, IPR 2013-00481, Paper 38 at 11.
`
`18
`
`
`
`Although predictability is a touchstone of obviousness, the “predictable result”
`discussed in KSR refers not only to the expectation that prior art elements are
`capable of being physically combined, but also that the combination would
`have worked for its intended purpose.
`…
`The opposite conclusion would follow, however, if the prior art indicated
`that the invention would not have worked for its intended purpose or
`otherwise taught away from the invention. See United States v. Adams, 383 U.S.
`39, 52, 86 S.Ct. 708, 15 L.Ed.2d 572 (1966); In re ICON Health & Fitness, Inc.,
`496 F.3d 1374, 1382 (Fed.Cir. 2007) (“[A] reference teaches away from a
`combination when using it in that combination would produce an inoperative
`result.”
`DePuy Spine, Inc. v. Medtronic Sofamor Danek, Inc., 567 F.3d 1314, 1326 (Fed. Cir. 2009).
`
`19
`
`
`
`Jacobs’s Opinions:
`I. “The experimental record showed that the use of
`indirect relationships generally resulted in worse search
`results”. Jacobs Dec. at ¶¶ 217-254; 287-296. ‘352 POR
`at 25-26.
`
`II. “The experimental record showed that the use of
`indirect relationships … was not sufficiently reliable to
`be used in an automated retrieval system.” Jacobs Dec.
`at ¶¶ 205-216. ‘352 POR at 25-26.
`
`20
`
`
`
`Jacobs Testifies as to Degradation:
`
`Fox Thesis, IPR2013-00478 Exhibit 1009 at 241-256; ‘352 Jacobs Dec., IPR2013-00478 Ex. 2113 at ¶ 287; IPR2013-00478 POR at 1, 50.
`
`21
`
`
`
`Jacobs Testifies as to Degradation:
`Experiment
`Result
`Experiment
`-37% (vs terms)
`8.2-ISI (cc)
`8.11-CACM (bc)
`-54% (vs terms)
`8.2-ISI (cd)
`8.11-CACM (cc)
`-6.2% (vs terms)
`8.3-ISI (cc+terms)
`8.11-CACM (bc+cc)
`-7.8% (vs terms)
`8.3-ISI (cc+other
`8.11-CACM (bc)
`subvectors)
`8.3-ISI (cc+terms
`emphasized)
`8.7-ISI
`(cc+terms regression)
`-62% (vs terms)
`8.12-CACM (bc)
`8.8-CACM (bc)
`-51% (vs terms)
`8.8-CACM (cc)
`8.12-CACM (cc)
`‘352 Jacobs Dec., IPR2013-00478 Exhibit 2113 at ¶ 287; see, .e.g, IPR2013-00478 POR at 1.
`
`+4.5 to 6.1% (vs
`terms)
`+5 to 6% (vs terms)
`
`8.11-CACM (cc)
`
`8.11-CACM (bc+cc)
`
`Result
`-6.3% (vs terms)
`-1.4% (vs terms)
`-2.9% (vs terms)
`-7.4% (vs ln)
`
`-6% (vs ln)
`
`-4.1% (vs ln)
`
`-26.5% (vs terms)
`-29% (vs terms)
`
`22
`
`
`
`Salton States “Citation Methodology Cannot be
`Recommended”:
`“The evaluation results of Tables 3 to 8 lead to the
`conclusion that the term association process based on the
`bibliographically related title words is not reliable…
`since no obvious way exists for distinguishing the
`positive from the negative effects, the citation
`methodology cannot be recommended for inclusion in
`practical retrieval environments.
`
`Salton 1986 at 11, abstract (emphasis added); see, e.g., ‘352 Jacobs Dec., IPR2013-00478 Ex. 2113 at ¶ 211;
`IPR2013-00478 POR at 51.
`
`23
`
`
`
`Salton Explicitly States:
`“Overall, the procedure is not sufficiently
`reliable to warrant incorporation into
`operational automatic retrieval systems.”
`
`Salton 1986 at 11, abstract (emphasis added); see, e.g., ‘352 Jacobs Dec., IPR2013-00478 Ex. 2113 at ¶ 211;
`IPR2013-00478 POR at 51.
`
`24
`
`
`
`Croft Paper
`
`Fox Reply Decl. at ¶ 401.
`
`25
`
`
`
`Within the information retrieval community, a number of techniques have
`been developed that can represent the content of documents and
`information needs. These representations have a much different flavor
`than NLP representations. They are generally based on simple, very
`general, features between documents (e.g., words, citations) and represent
`simple relationships between features (e.g., phrases) and between
`documents (e.g., two documents cite the same document). …
`Given the availability of a number of representation techniques that
`capture some of the meaning of the document or information need, our
`basic premise is that decisions about which documents match an
`information need should make use of as many of the representation forms
`as practical.
`Croft Paper at 130 (Ex. 1031); Jacobs Tr., IPR2013-00478, Ex. 1033 at 393-396; see Fox Reply Decl. at ¶
`401; see also Jacobs Tr., IPR2013-00478, Ex. 1033 at 273-396.
`
`26
`
`
`
`Our interest, however, is in retrieval techniques that can be applied under
`program control to select items from machine-readable collections. For
`these machine-readable collections, we have descriptions of the objects in
`the collection rather than the objects themselves (for objects that exist
`only in machine readable form, e.g., electronic mail messages, we may
`have the actual objects. These descriptions usually consist of text
`describing various attributes of the objects, but may also include
`descriptors assigned by the creator of the object or some indexing agent
`(e.g., controlled vocabulary terms assigned by a human indexer or some
`automatically assigned classification), or used to describe relationships
`between objects in the collection (e.g., citations or hypertext links).
`Croft Paper at 130 (Ex. 1031); see Fox Reply Decl. at ¶ 401; see also Jacobs Tr., IPR2013-00478, Ex. 1033 at
`273-396.
`
`27
`
`
`
`The Croft and Turtle Paper (Exhibit 1031) presents work first
`reported in Turtle’s Ph.D. Thesis (Exhibit 2029). “On pages 154-
`157, Turtle describes the methodology of his experiments and he
`does not use bc or cc.”
`‘352 Jacobs Decl., IPR2013-00478 Exhibit 2113, at ¶¶ 235-236 (citing Turtle, Exhibit 2029); see also
`Jacobs Tr., IPR2013-00478, Ex. 1033 at 273-396.
`
`“A colleague of Dr. Turtle’s, Roger Thompson, who testified for the
`Petitioners, also conducted experiments using the CACM collection.
`He also did not use the bc and cc subvectors.”
`‘352 Jacobs Decl. at ¶ 234 (citing Thompson Part 3 at 96 (Exhibit 1012)); see also Jacobs Tr., IPR2013-
`00478, Ex. 1033 at 273-396.
`
`28
`
`
`
`Jacobs Testifies:
`Q. Okay. So you – in your opinion, this passage doesn’t say
`anything about which is the best type of representation to use
`for search. Is that fair?
`A. Or even which ones would be effective or useful at all….
`Q. Okay. And does it say – does this passage also teach that the
`descriptions of the relationships between documents that can be
`used for search include citations between the documents or
`hypertext links between the documents?
`A. That’s what it says.
`Jacobs Tr., Ex. 1033 at 273:2-291:13.
`
`not quoted
`
`relied on by
`petitioners
`
`29
`
`
`
`Jacobs Testifies:
`Q. Do you -- is it your testimony that a person of ordinary skill in the art,
`reading the passage that we’ve read, would not understand that a document
`representation, such as is -- is described here, could be used for search?
`A. … Now, the – fact that something can be used as a document
`representation, in theory, means that that might be used for search. But
`one of ordinary skill would understand that the results of using such a
`representation would depend on the quality of the representation and on
`empirical results in terms of whether it worked or not. … So I don’t think
`this particular paragraph sheds any light on where a – a particular
`representation should be used for search, and, at – at most, in the abstract, says
`that – that – that these areas of different representations of documents have
`been explored.
`Jacobs Tr., Ex. 1033 at 270:23-273:1.
`
`30
`
`
`
`Jacobs Testifies:
`Q. Do you -- is it your testimony that a person of ordinary skill in the art,
`reading the passage that we’ve read, would not understand that a document
`representation, such as is -- is described here, could be used for search?
`A. … Now, the – fact that something can be used as a document
`representation, in theory, means that that might be used for search. But
`one of ordinary skill would understand that the results of using such a
`representation would depend on the quality of the representation and on
`empirical results in terms of whether it worked or not. … So I don’t think
`this particular paragraph sheds any light on where a – a particular
`representation should be used for search, and, at – at most, in the abstract, says
`that – that – that these areas of different representations of documents have
`been explored.
`Jacobs Tr., Ex. 1033 at 270:23-273:1.
`
`31
`
`
`
`Jacobs Testifies:
`Q. Does any of these passages describe using citations for the
`purposes of search?
`A. No.
`Q. Does [the passage on page 128 of Croft beginning with “our
`interest, however…”] describe analyzing citations for purposes
`of conducting a search?
`A. No. It just says citations can be part of a description of an
`object.
`
`Jacobs Tr., IPR2013-00478, Ex. 1033 at 393:20-396:19.
`
`32
`
`
`
`Jacobs Testifies:
`Q. Does anything in this passage describe treating hypertext
`links as citations for the purposes of search?
`A. No – no. And there would be many ways to use hypertext
`links as descriptions that didn’t involve using them for search
`that would be pertinent in information retrieval.
`
`Jacobs Tr., IPR2013-00478, Ex. 1033 at 393:20-396:19.
`
`33
`
`
`
`Jacobs Testifies:
`Q. So in that case, would they be analyzing the citations in a
`methodology similar to Fox or the other prior art at issue in this
`case?
`A. No. This paragraph really doesn’t say anything about
`what one might or might not do using the methodology of
`Fox.
`Q. Would one skilled in the art read that and conclude that one
`would use indirect relationships for search?
`A. No.
`Jacobs Tr., IPR2013-00478, Ex. 1033 at 393:20-396:19.
`
`34
`
`
`
`Nunn
`
`Fox Reply Decl. at ¶ 393; IPR2013-00478 POR at 52-55.
`
`W
`
`35
`
`
`
`“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.”
`Fox Thesis at 253; see IPR2013-00478 POR at 53-55; ‘352 Jacobs Decl., IPR 2013-00478 at ¶ 223.
`
`36
`
`
`
`“[I]t 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 (emphasis added); IPR2013-00478 POR at 53-55; ‘352 Jacobs Decl., IPR 2013-00478
`at ¶ 203.
`
`37
`
`
`
`Jacobs Testifies as to Degradation:
`
`approx. -13.5% degrade
`
`Nunn Ex. 2027 at 37; see also Jacobs Depo. Tr. Pt. 2, Ex. 1033 at 397-402; IPR2013-00478 POR at 53-55.
`
`38
`
`
`
`“The base runs in CACM2 and ISI2 of each collection are not as high as those
`of CACM1 and ISI1. … Though disappointing, these results are not
`surprising – term relevance weights and coefficients for concept types were
`derived through a feedback sampling process on a different half of the
`collection.”
`Nunn Ex. 2027 at 32; ‘352 Jacobs Dec., IPR2013-00478 Ex. 2113 at ¶ 214.
`
`“The coefficients that were used in the feedback runs with SMART proved to
`be of limited usefulness here as improvements in precision were limited to the
`1% to 5% range. … The author of this study would like to suggest that
`further research might be pursued … to try to develop coefficients that
`could be generalized to other collections.”
`Nunn Ex. 2027 at 42; see also see also Jacobs Depo. Tr. Pt. 2, Ex. 1033 at 397-402; IPR2013-00478 POR at
`53-55; ‘352 Jacobs Dec., IPR2013-00478 Ex. 2113 at ¶ 205-215.
`
`39
`
`
`
`Tapper
`
`IPR2013-00478 POR at 40-49.
`
`Tapper
`
`IPR2013—OO478 POR at 40-49.
`
`40
`
`
`
`Tapper States :
`“Table 2 shows the upper part of the correlation table for the cases in
`the British database. The first column gives the numbers allocated to
`the cases. The second gives the correlation value indicated by the
`conventional VEXT technique without weighting, and the third the
`rank order according to those values. The fourth and fifth correspond
`to the second and third except that the values there are derived from
`the Oxford technique with Oxford weighting. Great care must be
`taken in interpreting this table. It is necessary to bear in mind that the
`absolute values are very low, and that only the first two or three
`pairs have a value of any real significance at all.”
`‘494 Jacobs Decl., IPR2013-00479 Ex. 2113 at ¶ 350 (citing Tapper 1982 at 148 (emphasis added));
`IPR2013-00478 POR at 40-49; ‘352 Jacobs Dec., IPR2013-00478 Ex 2113 at ¶ 222.
`
`41
`
`
`
`Tapper Recognizes:
`
`“What [the citation experiment’s results] do not, and cannot, demonstrate is
`whether or not the technique can be improved to yield still better results, and
`whether or not it can be developed into a component part of an operational
`commercial system. It is sadly little appreciated just how wide a gap separates a
`system which operates perfectly satisfactorily in an experimental or limited
`environment, and one which can take the strains imposed by the massive
`databases, constant use, and variety of misuse, much of it quite possibly
`unimaginable, to which a commercial system is inevitably exposed.”
`Tapper 1982 at 157; IPR2013-00478 POR at 40-49; ‘352 Jacobs Dec., IPR2013-00478 Ex 2113 at ¶ 222.
`
`42
`
`
`
`“The former question can be answered by the conduct of a series
`of careful and systematic experiments. … It is now necessary to
`consider the question of testing the system. Some of the further
`research described above could and should be tested by the same
`methods as those employed hitherto. Some testing should however
`be organized on a more scientific and practical basis.”
`Tapper 1982 at 157; IPR2013-00478 POR at 40-49; ‘352 Jacobs Dec., IPR2013-00478 Ex 2113 at ¶ 222.
`
`J,K,L
`
`43
`
`
`
`In Conclusion…
`
`In Conclusion...
`
`
`
`M,N,O
`
`44
`
`
`
`Pre-1998, “no one at the web search companies mentioned using
`links. The links were the reason that a research project running on a
`computer in a Stanford dorm room had become the top performer.”
`Michael Specter, “Search and Deploy,” The New Yorker, May 29, 2000 (IPR2013-00479 Exhibit 2041) (emphasis added); see also
`Langville Dec., IPR2013-00478 Exhibit 2114 at ¶¶ 43-65.
`
`“Before [1998], people were only looking at the content. They
`were completely ignoring the fact that people were going to the
`effort of putting a link from one page to another and that there
`must be a meaning to that.”
`Professor Rajeev Motwani, IPR2013-00479 Exhibit 2041 (emphasis added); IPR2013-00478 POR at 56-60; see also
`Langville Dec., IPR2013-00478 Exhibit 2114 at ¶¶ 43-65. .
`
`45
`
`
`
`“We originally developed PageRank kind of playing around with all
`the links on the web and that too was a pretty revolutionary idea,
`though it seems very simple, the fact you can even just collect [the
`links of the web] and do anything meaningful with them …
`I really credit Larry for pursuing that idea that it is even worth
`collecting the graph and then that you could run any kind of
`processing on it.”
`
`Brin transcript, IPR2013-00478 Ex. 2032, at 6:15-6:20, 15:17 – 15:33 (emphasis added); IPR2013-00478
`POR at 56-60; Langville Dec., IPR2013-00478 Exhibit 2114 at ¶¶ 43-65.
`
`46
`
`
`
`“In 1998, Google didn’t exist; Yahoo and Alta Vista were leading
`the young search industry, and there was no place for a late
`comer. By bringing to the market a major innovation (the
`“page rank” technology), Google put the previous order of
`competitors upside down.”
`
`Ex. 2074: “The right candidates to wound a group with $64 billion pile of case? A start-up and a living-dead
`. . .,” Innovation Tribune eng (January 2005) (available at http://portail-
`innovation.typepad.com/eng/2004/12/index.html) (emphasis added); IPR2013-00478 POR at 56-60;
`Langville Dec., IPR2013-00478 Exhibit 2114 at ¶¶ 43-65.
`
`.
`
`47
`
`
`
`“AUDIENCE: My question is, at the time that you developed and released
`Google there were other search engines that had been accepted as the standard
`and were considered to work fine and so on. What is it that inspired you to go
`back to the drawing board, create a new search engine, and release it?
`SERGEY BRIN: Great question. So at the time there were probably five major
`search engines or so. And you might not even remember some of them. I don't
`know. People here are pretty young. But what we found was we-- kind of by
`accident almost-- we found that this processing of the link structure of the
`web, we could create a search that was better in important ways. In ways
`that these search engines had ignored.”
`
`Brin transcript, IPR2013-00478 Ex. 2032, at 6:15-6:20, 15:17 – 15:33 (emphasis added); IPR2013-00478
`POR at 56-60; Langville Dec., IPR2013-00478 Exhibit 2114 at ¶¶ 43-65.
`
`P
`
`48
`
`
`
`Remaining Claim Elements
`Some of these remaining claim elements include:
`‘352 claim 28 – “wherein the step of searching comprises the steps of matrix searching of the
`second matrices and examining the chronological data.” ‘352 patent at 36:1-3.
`‘352 claim 32 – “wherein the step of analyzing further comprises the step of weighing, wherein
`some indirect relationships are weighed more heavily than other indirect relationships” ‘352 patent
`at 36:44-47
`‘352 claim 34 – “wherein objects in the database may be divided into subsets and wherein the
`marking step includes the step of marking subsets of objects in the database and wherein
`relationships exist between or among subsets of objects in the database” ‘352 patent at 36:65-37:2.
`‘352 claim 39 – “pool-similarity searching to identify a similar pool of textual objects, similar in
`relation to the objects in the marked pool; and pool-importance searching to identify an important
`pool of textual objects, important in relation to the objects in the selected pool.” ‘352 patent at
`37:32-37. See also IPR2013-00478 POR at 24, 37-39, 47-50; ‘352 Jacobs Decl. at ¶¶ 302-313.
`
`49
`
`
`
`Remaining Claim Elements
`Some of these remaining claim elements include:
`‘494 claim 20 – “searching for objects in a database using the stored numerical representation,
`wherein direct and/or indirect relationships are searched” ‘494 patent at 53:50-53.
`‘494 claim 45 – “wherein the direct relationships are hyperlink relationships between objects on
`the world wide web and the second numerical representation of direct and indirect relationships is
`a value that is generated by analyzing direct link weights in a set of paths between two indirectly
`related objects” ‘494 patent C1 at 2:16-22.
`‘494 claim 51 – “wherein the identified objects include web sites and the step of identifying
`includes proving a Universal Resource Locator that identifies a web page within one of said web
`sites” ‘494 patent C1 at 2:44-47.
`‘494 claim 54 – “wherein an independent application determines a cost associated with accessing
`the identified objects” ‘494 patent C1 at 2:62-64; see also IPR2013-00478 POR at 24, 37-39, 47-
`50; ‘494 Jacobs Decl., IPR2013-00480, at ¶¶ 237-245.
`
`50
`
`
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