UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`EMC CORPORATION, EMC INTERNATIONAL US. HOLDINGS, INC. and
`VMWARE, INC.
`Petitioners
`
`v.
`
`CLOUDING CORP.
`Patent Owner
`
`____________
`
`Case IPR2014-01218
`
`Patent 7,254,621 B1
`
`REPLY DECLARATION OF DR. BENJAMIN GOLDBERG
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`1
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`EMC 1022
`EMC Corp. v. Clouding Corp.
`IPR2014-01218
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`
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`
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`

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`Table of Contents
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`I.   Qualifications .....................................................................................................3  
`II.   Subject Matter of this Declaration ..................................................................4  
`III.   Materials Considered ......................................................................................5  
`IV.   I Agree with the PTAB’s Claim Construction ..............................................6  
`V.   Schilit Anticipates the Challenged Claims of the ’621 Patent Under
`Patent Owners’s Claim Construction ....................................................................8  
`VI.   The Dependent Claims ..................................................................................14  
`VII.   Schilit Addresses the Same Problems as the ’621 Patent .........................17  
`VIII.   Conclusion ...................................................................................................21  
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`I.
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`Qualifications
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`1.
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`I am a tenured Associate Professor in the Department of Computer
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`Science of the Courant Institute of Mathematical Sciences, New York University
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`(“NYU”), in New York, NY. I have held this position since September 1994.
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`From 1987 to 1994, I was an Assistant Professor in the Department of Computer
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`Science at NYU. Since September 1, 2014, I have served as the Director of
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`Graduate Studies for the MS program for the Department of Computer Science,
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`having previously served in the capacity from September 2009 throught August
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`2012. I served as the Director of Undergraduate Studies for the Department of
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`Computer Science from September 1995 through August 1998 and from
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`September 2003 through August 2006. In addition, I have held a one-year visiting
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`professorship at the Institut National de Recherche en informatique et en
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`Automatique (INRIA), a national laboratory in France, and was twice appointed to
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`a month-long position as an invited professor at the Ecole Normale Supérieur, a
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`university in Paris.
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`2.
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`I received my Doctoral degree in Computer Science from Yale
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`University, New Haven, Connecticut in 1988, having previously received Master
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`of Science and Master of Philosophy degrees in Computer Science from Yale in
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`1984. My undergraduate degree from Williams College in 1982 was a Bachelor of
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`Arts degree with highest honors in Mathematical Sciences.
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`3.
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`I have taught courses at the undergraduate and graduate level in
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`programming languages, embedded systems (including mobile devices), operating
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`systems, hardware design, and other areas related to the technology of the ’621
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`patent. Additional information concerning the computer science courses that I
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`have taught, my professional publications and presentations in the field of
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`computer science, and cases in which I have testified as an expert at trial or
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`deposition in the past four years are set forth in my current Curriculum Vitae, a
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`copy of which is attached as Exhibit A.
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`4.
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`I am being compensated at a rate of $450 per hour for my work in this
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`matter. My compensation is in no way conditioned on the outcome of this matter.
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`II.
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`Subject Matter of this Declaration
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`5.
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`I have been asked to consider and formulate responses to the
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`arguments set forth in the March 23, 2015 Patent Owner Response to Petition for
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`Inter Partes Review Of U.S. Patent No. 7,254,621 (“the PO response”) and to the
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`opinions expressed in the March 23, 2015 Declaration Of Scott M. Nettles, Ph.D.
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`(“the Nettles declaration”) regarding the validity of US Patent 7,254,621 (“the ’621
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`patent”).
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`6.
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`In the July 29, 2014 Declaration of Dr. Benjamin Goldberg (“my
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`opening declaration”), I expressed opinions regarding the meaning of certain terms
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`of the challenged claims of the ’621 patent as well as opinions regarding the
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`anticipation of the challenged claims of the ’621 patent by US Patent 6,670,968
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`(“Schilit”).
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`7.
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`After considering the PO response and the Nettles declaration, as well
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`as the PTAB’s Institution of Inter Partes Review decision (“PTAB decision”), my
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`opinions regarding the anticipation of the ’621 patent have not changed. That is,
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`under the claim construction set forth in the PTAB decision, which is consistent
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`with the opinions I expressed in my opening declaration, it is still my opinion that
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`Schilit anticipates the challenged claims of the ’621 patent.
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`8.
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`Finally, as discussed in detail below, even if the PTAB were to
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`ultimately adopt the claim construction proposed by the patent owner in the PO
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`response and supported by Dr. Nettles in the Nettles declaration, it would still be
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`my opinion that Schilit anticipates the challenged claims of the ’621 patent.
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`III. Materials Considered
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`9.
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`In formulating the opinions expressed in this declaration, I have
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`considered the PTAB decision, the PO response, the Nettles Declaration, the ’621
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`patent, the Schilit patent, and the transcript of the May 11, 2015 deposition of Scott
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`Nettles. I had previously also considered those materials listed in my opening
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`declaration.
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`IV.
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`I Agree with the PTAB’s Claim Construction
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`10. The PTAB decision states, “although independent claims 1, 9, and 17
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`do require that the steps and elements recited therein, other than the receiving step
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`and the receive step, be responsive to the same data access request, they do not
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`preclude either receiving additional data access requests or having steps performed
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`in response to another request.” (PTAB Decision, p. 8). I agree with this
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`construction, since one of skill would understand that the claims can be satisfied
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`even if the references to the data manipulation operations for the data that was
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`obtained (e.g. by a proxy) in response to the original data request are returned to
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`the pervasive device after a subsequent request.
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`11. The patent owner writes (PO response, p. 8),
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`From the standpoint of the person of ordinary skill in the art, the claims of the
`’621 patent recite methods, systems, and computer-readable media
`embodying computer program instructions that provide for the return of
`references to the determined data manipulation operations in response to the
`same data access request from a pervasive device. Ex. 2001 at ¶ 30, 38-40.
`The “requested data” is synonymous with the “obtained data;” indeed, it is the
`only “data” found in the claims. Id. at ¶ 40. The Board acknowledges this by
`stating its agreement that “all recitations of ‘data’ referenced in independent
`claim 1 are to the same data access request.” Paper 10 at 7.
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`The cited paragraphs of the Nettles declaration, at ¶ 30, 38-40, echo the patent
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`owner’s argument. I disagree with the patent owner and Dr. Nettles. There is no
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`dispute that the obtained data refers to the data requested in the original data access
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`request, and that the data manipulation operations are determined for that same
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`obtained data. However, contrary to the position of the patent owner and Dr.
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`Nettles, in my opinion one of skill would understand that claims 1, 9 and 17 do not
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`dictate when the “obtaining”, “determining” and “providing” steps occur. That is,
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`although all three steps could occur in response to the original data access request
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`and without any intervening requests, the claims do not mandate it. One of skill
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`would understand that a method or system in which the “obtaining”, “determining”
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`and/or “providing” steps occur in response to additional access requests – as long
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`as the obtained data is the requested data of the original request and the data
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`manipulation operations are determined for the same obtained data – would fall
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`within the scope of claims 1, 9, and 17 of the ’621 patent.
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`12. Furthermore, the ’621 patent specification states, “changes may be
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`made to the logic that is illustrated therein (for example, by altering the order of
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`operations shown in some cases, by combining operations, etc.) without deviating
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`from the inventive concepts disclosed herein” (’621 patent, 4:57-60), supporting
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`the position that the embodiment in the specification is not the only possible
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`embodiment satisfying the claim limitations.
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`V.
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`Schilit Anticipates the Challenged Claims of the ’621
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`Patent Under Patent Owner’s Claim Construction
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`13. As explained in my opening declaration, it is my opinion that Schilit
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`anticipates the challenged claims of the ’621 patent under the claim constructions
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`that were adopted by the PTAB in this proceeding and in prior proceedings. I see
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`nothing in the patent owner’s response or the Nettles declaration that disputes that
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`Schilit anticipates independent claims 1, 9, and 17 (and various dependent claims)
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`of the ’621 patent under the PTAB’s constructions, thus I do not discuss it further
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`here.
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`14. Even if the PTAB were to adopt the patent owner’s proposed
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`constructions, it is still my opinion that Schilit anticipates the challenged claims of
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`the ’621 patent. The PO response and the Nettles declaration consider one of the
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`scenarios disclosed in Schilit, starting at the user’s request for the FXPAL web
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`page and ending with services for a publication entitled “Interaction Revisited”
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`being provided to the pervasive device after the user has clicked on the
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`“publications” link and the “Hypertext Interact...” link. However, as I discuss
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`below, what the patent owner and Dr. Nettles don’t consider is that part of this
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`scenario discloses the claim limitations of the independent claims without any
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`additional data access requests after a first data access request.
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`15. Dr. Nettles writes (Nettles declaration, ¶ 56),
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`As explained above, Schilit describes a process in which a user of a mobile
`device must engage in a series of request-response operations with an m-link
`browser in order to obtain access to data manipulation operations available for
`the obtained data. See for example Ex. 1006 at 8:60-65 and Figs. 6A-6C
`(showing access to “the services made available by m-link for the document”
`only after the user clicks through two menus). Each click/selection of a menu
`constitutes a data access request across the network because the m-link
`browser is not local to the device. Thus the method disclosed in Schilit
`requires multiple data access requests (even after obtaiing [sic] the requested
`data) from the pervasive device before allowing the pervasive device to
`receive access to any data manipulation operations.
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`That is, the scenario that the patent owner and Dr. Nettles consider is the
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`following, illustrated by figures 6A-C from Schilit along with my annotations.
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`16. However, within the above scenario in Schilit is a disclosure of a first
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`data access request that results in the obtaining of the requested data, the
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`determining what data manipulation operations are available for the obtained data,
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`and the providing of references to the determined data manipulation operations to
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`the pervasive device – without any additional data access requests. This disclosure
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`in Schilit is illustrated below by figures 6B-C of Schilit along with my annotations.
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`That is, when the data access request of the “receiving” step of claims 1, 9, and 17
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`
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`of the ’621 patent is considered to be the request sent to the m-link browser as a
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`result of the user clicking on the “Hypertext interact...” link shown in Schilit Fig.
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`6B, above, the services (references to data manipulation operations) for the
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`“Hypertext interaction revisited” publication – such as “read”, “print”, “fax”, etc. –
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`are provided to the pervasive device without any further data access requests.
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`17. A corresponding disclosure within the Schilit specification is the
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`following (Schilit, 8:51-65).
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`10
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`The above passage discloses that when a link (such as the “hypertext interact...”
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`link of Fig. 6B) is selected, the m-link browser uses the URL to access (obtain) the
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`requested content from a Web server, fetches the services for that content from a
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`database, and returns the services to the pervasive device to be displayed as shown
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`in Fig. 6C.
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`18. There are several additional disclosures in Schilit in which, in
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`response to a single data request from the pervasive device and with no subsequent
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`data requests, the m-link browser performs all the steps of claims 1, 9 and 17 and
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`provides references to the data manipulation operators to the pervasive device. For
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`example, a disclosure in Schilit is the following (Schilit, 8:4-21).
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`The above passage discloses that, in response to a single request from the
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`pervasive device for the FXPAL web page, the m-link browser returns to the
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`pervasive device the telephone number (requested data) from the FXPAL web
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`page, together with a link (reference to a data manipulation operation) such that, if
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`the user clicks on the phone number, the mobile phone will dial the number. This
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`scenario can be illustrated as follows.
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`12
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`19. Yet another disclosure in Schilit which anticipates claims 1, 9 and 17
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`of the ’621 patent – even under patent owner’s proposed claim constructions – is
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`the following (id., 8:22-36).
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`The above passage discloses that, in response to the user clicking “FX Palo Alto
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`
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`Labor...” (data access request), the m-link browser returns to the mobile phone the
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`address (requested data) from the FXPAL web page, together with links to services
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`(references to data manipulation operations) for that address, such as a providing a
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`map locating the address. This scenario can be illustrated as follows.
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`13
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`VI.
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`The Dependent Claims
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`
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`20. Regarding claims 8, 16, and 24 of the ’621 patent, the patent owner
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`writes (PO response, pp. 14-15),
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`Claims 8, 16, and 24 each depend on independent claims 1, 9, and 17,
`respectively, and recite the additional steps of:
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`perform[ing] one or more data manipulation operations on the obtained data,
`thereby creating transformed data;
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`determin[e/ing] what data manipulation operations are available for the
`transformed data; and
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`provid[e/ing] references to the determined data manipulation operations for
`the transformed data to the pervasive device.
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`Ex. 1001 at 19:22-29, 20:14-26, and 20:53-61.
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`The “transformed data” recited in these claims is data that has been created by
`performing one of the recited data manipulation operations on the “obtained
`data” (i.e., the data obtained in response to the original data access request).
`Schilit does not describe any corresponding process. For example, while
`Schilit does disclose providing a list of links extracted from a web page in
`response to a request from a pervasive device, see Ex. 1006 at Figs. 6A-C, a
`person of ordinary skill in the art would not consider merely extracting links
`from a document to constitute performing one of the data manipulation
`operations. Ex. 2001 at ¶ 58. Indeed, the links are extracted before the data
`manipulation operations even become available for selection. Ex. 1006 at
`5:34-37; 8:50-51. Thus, claims 8, 16 and 24 cannot be anticipated by Schilit.
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`In support, Dr. Nettles states, “a person of ordinary skill in the art would not
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`consider merely extracting links from a document to constitute performing one of
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`the data manipulation operations. For example, the links are extracted and
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`provided to the pervasive device before the data manipulation operations available
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`for the subject web page are even determined.” (Nettles declaration, ¶ 58).
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`21.
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`I disagree with the patent owner and Dr. Nettles because they appear
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`to have misread the claim language. The “performing” step of the dependent
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`claims applies data manipulation operations to the obtained data to create the
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`transformed data and the “determining” and “providing” steps recite data
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`manipulation operations for the transformed data – but there is no relationship
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`between (1) the “data manipulation” operations performed on the “obtained” data
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`to create the “transformed data” and (2) the data manipulation operations for the
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`transformed data. The “data manipulations” in the steps of the dependent claims
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`requiring “performing one or more data manipulations on the obtained data” to
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`create “transformed data” have no antecedent basis in the independent claims, and
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`hence are not “recited.” (’621 patent, claims 8, 16 and 24). They are not the
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`“determined data manipulation operations” of the independent claims. (’621
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`patent, claims 1, 9 and 17). Instead, these are independent “data manipulation
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`operations” which create “transformed data” from the obtained data. It is this
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`“transformed data” of the dependent claims which is then further made subject to
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`15
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`the step “determining what data manipulations are available.” If the determined
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`data manipulation operations in the independent claims and the “one or more data
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`manipulations” of the dependent claims were intended to be the same, then the
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`“performing” step would recite “the data manipulation operations” or “said data
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`manipulation operations”. With no definite article before “data manipulation
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`operations” in the “performing” step of the dependent claims, the data
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`manipulation operations have no antecedent in the independent claims.
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`22. Given this correct reading of the claims, one of skill would certainly
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`understand that extracting links from a document and creating new links from
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`certain data in the document (e.g. phone numbers and addresses), as Schilit
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`discloses, are data manipulation operations that create transformed data as recited
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`in the “performing” step. Furthermore, the argument set forth by Dr. Nettles that
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`“the links are extracted and provided to the pervasive device before the data
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`manipulation operations available for the subject web page are even determined”
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`(Nettles declaration, ¶ 58) doesn’t hold because the data manipulation operations to
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`extract the links have nothing to do with the data manipulation operations available
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`for the subject web page. Thus, it is still my opinion that Schilit anticipates
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`dependent claims 8, 16, and 24 for the reasons stated in my opening declaration
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`and the claim chart cited therein.
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`VII.
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`Schilit Addresses the Same Problems as the ’621 Patent
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`23. As part of his argument that Schilit does not anticipate the challenged
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`claims of the ’621 patent, Dr. Nettles asserts that Schilit and the ’621 patent sought
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`to solve different problems – and thus the inventions of Schilit and ’621 patent are
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`different. I disagree with this position, since Schilit and the ’621 patent are
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`directed at precisely the same problems – namely allowing users of pervasive
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`devices with limited capabilities to access data, such as web pages or documents,
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`and to utilize services, such as printing, on that data1. Furthermore, as described in
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`my opening declaration, Schilit and the ’621 patent disclose the same solution to
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`these problems – namely providing a proxy (which Schilit refers to as the m-link
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`browser) that performs much of the necessary computation that the pervasive
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`devices are not capable of.
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`1 I understand that “big picture” arguments, such as those presented by the patent
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`owner and Dr. Nettles, are not necessarily germane to a claim anticipation analysis
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`and, rather, it is the recited limitations of the claims themselves that are the focus
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`of such an analysis. However, I have been asked to respond to these “big picture”
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`arguments to the extent that they mischaracterize the disclosure of the Schilit
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`patent.
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`24. For example, Dr. Nettles states (Nettles declaration, ¶¶ 60-61),
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`“Looking at the ’481/’621 patents we see that the goal was to allow potentially
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`very limited capacity pervasive nodes [to] access and manipulate complex data that
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`they could not otherwise handle. [...] In contrast, Schilit focuses on browsing
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`using some of the same kinds of devices. However, the key resource that is limited
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`is screen space and the activity not general data access and manipulation, but rather
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`browsing by a human.” I disagree with Dr. Nettles for several reasons. First,
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`Schilit discloses many of the same constraints on pervasive devices that the ’621
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`patent does, not just limited screen space. For example, in describing the WML
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`protocol used to allow mobile devices to access web pages, Schilit states that
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`WML is “intended for use in specifying content and user interface for narrowband
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`devices, including cellular telephones and pagers, to allow users mobile access to
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`the resources of the Internet.” (Schilit, 2:31-34). One of skill would understand a
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`“narrowband device” to be a device with limited (low data-rate) communication
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`capabilities. Furthermore, Schilit recites additional constraints on mobile devices,
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`including “limits of transmission bandwidth, storage requirements, screen size and
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`resolution on mobile handheld devices.” (id., 2:53-55).
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`25. Second, the operations disclosed by Schilit are not limited to
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`browsing. For example, just as in the ’621 patent, Schilit discloses printing of the
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`obtained data – as well as reading, faxing, and emailing (Schilit, Fig. 6C).
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`For these reasons, I disagree with Dr. Nettles’ characterization of Schilit, that “the
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`key resource that is limited is screen space and the activity not general data access
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`and manipulation, but rather browsing by a human.” (Nettles declaration, ¶61.) In
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`my opinion, the resource limitations and the supported activities disclosed in the
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`’621 patent and in Schilit are essentially the same.
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`26. Dr. Nettles also attempts to distinguish the ’621 patent from Schilit in
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`terms of the number of messages exchanged between the pervasive device and the
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`proxy in their respective preferred embodiments – particularly that by always
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`sending the data manipulation operations to the pervasive device after the initial
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`request, the ’621 proxy is able to minimize the communication overhead. I
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`disagree with Dr. Nettles, since the Schilit patent discloses the scenario discussed
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`above where the m-link browser sends the data manipulation operations (services)
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`to the pervasive device after a single data access request.
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`27. To differentiate the ’621 patent from Schilit, Dr. Nettles writes, “it is
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`evident that how these two systems handle requests and responses is very different.
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`The ’481/’621 patents use a minimal message exchange optimizing the limited
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`resources of the pervasive device, while Schilit uses a more costly iterative
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`approach that is deemed to best facilitate the browsing process.” (Nettles
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`declaration, ¶ 62). I disagree, since in the Schilit system – once a user issues a
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`request for data (e.g. the “Hypertext interaction revisited” document) – the services
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`for the data (e.g. “read”, “print”, “fax”, etc.) are provided to the pervasive device
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`without any additional requests. Further, although Dr. Nettles is correct that
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`distributed algorithms are often evaluated in terms of the number of message sent,
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`this is an oversimplification which is often useful for analytical purposes. In
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`practice, one of skill would understand that given a substantial amount of data (e.g.
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`a large web page), it may be more efficient to send a short message representing
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`some information extracted from the data, in order to preserve the possibility that
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`the rest of the data won’t have to be sent. In fact, Schilit discloses that the very
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`purpose for extracting links from a web page for sending to the pervasive device is
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`to reduce communication overhead, saying (Schilit, 11:11-13), “To minimize
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`transmissions over relatively low-bandwidth wireless connections, the m-link
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`browser typically separates and transmits links to mobile-devices, as indicated
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`above.” (emphasis added). Similarly, there may be scenarios in which it is more
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`efficient for the proxy to receive multiple data access requests before returning the
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`references to the data manipulation operations to the pervasive device, such as (1)
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`allowing the user to specify a subset of the possible data manipulation operations
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`that he or she is interested in using (e.g., if there are too many possible data
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`manipulation operations to be displayed on the screen), and (2) allowing the user to
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`specify which part of the requested data he or she is interested in, which may
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`determine what data manipulation operations to return.
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`28. For the reasons given above, I disagree with Dr. Nettles about the
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`differences in the “big picture” between the ’621 patent and Schilit. They both
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`sought to solve the same problems and disclosed essentially the same mechanisms
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`for doing so.
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`VIII. Conclusion
`
`I hereby declare that all statements made herein of my own knowledge are true and
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`that all statements made on information and belief are believed to be true, and
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`further that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`Dated: June 22, 2015
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`
`
`
`Dr. Benjamin Goldberg
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`21
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`
`EXHIBIT A
`Curriculum Vitae
`BENJAMIN F. GOLDBERG
`Courant Institute of Mathematical Sciences
`Department of Computer Science
`New York University
`251 Mercer Street
`New York, New York 10012
`Phone: (212) 998-3495
`Fax: (212) 995-4121
`Email: goldberg@cs.nyu.edu
`http://cs.nyu.edu/goldberg
`
`
`Personal
`Born January 31, 1961, Las Cruces, New Mexico.
`U.S. Citizen.
`
`Education
`Ph.D. in Computer Science, Yale University, 1988. Dissertation: "Multiprocessor Execution of
`Functional Programs."
`M.S. and M.Phil in Computer Science, Yale University, 1984.
`B.A. with Highest Honors in Mathematical Sciences, Williams College, Cum Laude, Phi Beta
`Kappa, Sigma Xi, June 1982. Honors Thesis: "Theory and Implementation of an Automatic
`Program Verifier."
`
`Employment
`Associate Professor (Tenured), Courant Institute of Mathematical Sciences, Department of
`Computer Science, New York University. September 1994 – Present.
`Invited Professor, Ecole Normale Supérieur, Paris, France. June 2007 – July 2007 and
`June 2003 – July 2003.
`Director of Graduate Studies (for the MS programs), Department of Computer Science, New York
`University. September 2009 – August 2012 and September 2014 – present.
`Director of Undergraduate Studies, Department of Computer Science, New York University.
`September 1995 – August 1998 and September 2003 – August 2006.
`Visiting Professor, Institute National de Recherche en Informatique et en Automatique (INRIA),
`Rocquencourt, France. September 1994 – August 1995.
`Assistant Professor, Courant Institute of Mathematical Sciences, Department of Computer
`Science, New York University. September 1987 - August 1994.
`
`

`
`Expert Testimony at Trial or Deposition in the Past Four Years
`Retained by Orrick on behalf of EMC and VMware in the matter of Clouding v. EMC et al. (Inter
`Partes Review before the PTO), June 2014 – present.
`Retained by Quinn Emanuel and Perkins Coie on behalf of Samsung, Google, and HTC in the
`matter of Smartflash v. Samsung et al. April 2014 – present.
`Retained by Kenyon & Kenyon on behalf of Advanced Ground Information Systems (AGIS) in the
`matter of AGIS v. Life360 (Patent Litigation). August 2014 – present.
`Retained by Milbank Tweed on behalf of Apple in the matter of Wi-LAN v. Apple, February 2014 –
`September 2014.
`Retained by Boies Schiller on behalf of InfoSpan in the matter of InfoSpan v. Emirates NBD Bank,
`September 2013 – present.
`Retained by Boies Schiller on behalf of Apple in the matter of Apple v. Personal Web
`Communications (Inter Partes Review before the PTO), August 2013 – present.
`Retained by Cooley on behalf of Apple in the matter of GBT v. Apple, October 2013 – June 2014.
`Retained by Quinn Emanuel on behalf of Toshiba in the matter of Certain Digital Media Devices,
`Including Televisions, Blu-Ray Disc Players, Home Theater Systems, Tablets and Mobile Phones,
`Components Thereof and Associated Software (Black Hills Media v. Toshiba et al). International
`Trade Commission. September 2013 – February 2014.
`Retained by Wilson Sonsini on behalf of Sasken in the matter of Sasken v. Spreadtrum. American
`Arbitration Association. July 2013 – January 2014.
`Retained by Sheppard Mullin on behalf of HTC and Apple in the matter of Wi-LAN v. HTC et al.
`June 2013 – October 2013.
`Retained by Bingham McCutchen on behalf of Oracle America in the matter of Oracle America v.
`Service Key et al. March 2013 – September 2013.
`Retained by Latham & Watkins on behalf of InterDigital Communications, Inc. in the matter of
`Certain Wireless Devices with 3G Capabilities and Components Thereof (InterDigital v. Huawei et
`al). International Trade Commission, December 2011 – February 2013.
`Retained by Ballard Spahr on behalf of Go Daddy in the matter of WhitServe v. Go Daddy. August
`2011 – June 2013.
`Retained by Kenyon & Kenyon on behalf of Barnes & Noble in the matter of Deep9 v. Barnes &
`Noble. February 2012 – August 2012.
`Retained by Gibson Dunn & Crutcher on behalf of Lawson Software in the matter of ePlus v
`Lawson Software. October 2011 – April 2013.
`Retained by Kenyon & Kenyon on behalf of Barnes & Noble in the matter of Certain Handheld
`Electronic Computing Devices, Related Software, and Components Thereof (Microsoft v. Barnes &
`Noble), International Trade Commission. August 2011 – February 2012.
`Retained by Morrison & Foerster on behalf of Oracle America in the matter of Oracle America v.
`Google. August 2011 – May 2012.
`
`
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`

`
`Retained by Jones Day on behalf of Nielsen in the matter of comScore v. Nielsen et al. May 2011
`– November 2011.
`Retained by Kellogg Huber on behalf of Verizon in the matter of ActiveVideo Networks v. Verizon
`Communications. February 2011 – July 2011.
`Retained by Hughes Hubbard & Reed on behalf of SyncSort in the matter of SyncSort v. IRI.
`September 2005 – March 2011.
`
`Teaching Awards
`New York University "Golden Dozen" Award, 1992. Awarded to twelve faculty members in the
`entire College of Arts and Sciences for excellence in teaching.
`
`Professional Activities
`Editorial Board, The Computer Journal. Published by Oxford University Press on behalf of the
`British Computer Society. 2007 – 2009.
`Program Committee member: 2007 Symposium on Principles of Programming Languages (POPL)
`External Review Committee member: 2013 Symposium on Principles of Programming Languages
`(POPL)
`Program Committee member: 2001 Workshop on Practical Applications of Declarative Languages
`(PADL'01), ACM SIGPLAN'95 Conference on Programming Language Design and
`Implementation, 1995 ACM SIGPLAN Symposium on Partial Evaluation and Semantics-Based
`Program Manipulation (PEPM '95), 1995 International Workshop on Memory Management
`(IWMM'95), ACM SIGPLAN'93 Conference on Programming Language Design and
`Implementation.
`Review Panel Member, National Science Foundation, January 1998 and January 2000.
`Official Collaborator, Los Alamos National Laboratory, Computing and Communications Division.
`Member, Association for Computing Machinery and ACM Special Interest Group on Programming
`Languages (SIGPLAN).
`Referee for: ACM TOPLAS, IEEE Computer, International Journal of Parallel Programming,
`Software Practice and Experience, Computational Intelligence, ACM TOCS, ACM Computing
`Surveys, etc.
`Referee for a variety of ACM and IEEE conferences.
`
`Journal Papers
`"Translation and Run Time Validation of Optimized Code'', with L. Zuck, A. Pnueli, C. Barrett, Y.
`Fang, and Y. Hu, Formal Methods in System Design. 27(3): 335-360, November 2005
`"VOC: A Methodology for Translation Validaton of Optimizing Compilers'', with L. Zuck, A. Pnueli,
`and Y. Fang. Journal of Universal Computer Science, March 2003.
`"A Syntactic Method for Finding Least Fixed Points o