Filed on Behalf of SIMPLEAIR, INC.
`
`By: Charles F. Wieland III, Esq.
`
`Robert G. Mukai, Esq.
`
`BUCHANAN, INGERSOLL, & ROONEY P.C.
`
`1737 King Street, Suite 500
`
`Alexandria, Virginia 22314
`
`Telephone (703) 836-6620
`
`Facsimile (703) 836-2021
`
`charles.wieland@bipc.com
`
`robert.mukai@bipc.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`GOOGLE INC.
`Petitioner
`
`v.
`
`SIMPLEAIR, INC.
`Patent Owner
`
`_______________
`
`Case IPR2015-00180
`Patent 8,601,154
`____________________
`
`
`DECLARATION OF DR. JAMES KNOX IN SUPPORT OF
`PATENT OWNER'S RESPONSE TO THE PETITION FOR
`INTER PARTES REVIEW
`
`
`
`
`
`
`
`

`
`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
`
`I.
`
`II.
`
`Table of Contents
`Expertise .......................................................................................................... 1
`A. Qualifications ........................................................................................ 1
`B.
`Relevant educational background ......................................................... 1
`C.
`Relevant work experience ..................................................................... 2
`Background to my opinions ............................................................................. 3
`A. Assignment ............................................................................................ 4
`B. Materials ................................................................................................ 4
`C.
`Understanding of the law ...................................................................... 4
`D.
`Claim interpretation and analysis .......................................................... 4
`III. Overview of the patent and asserted art .......................................................... 6
`A.
`Conventional wisdom ............................................................................ 6
`1.
`Unmediated access between online users and content
`providers. ..................................................................................... 6
`Provider control over transmission to users ................................ 9
`Users desire breadth of access, individualized control,
`and at-the-moment responses. ...................................................11
`Users resisted methods that required them to install
`additional software, or modify existing software, on the
`user’s computer. ........................................................................20
`The wireless paging environment was not suitable for
`online content and should be avoided. ......................................21
`Automated or manual data display. ..........................................27
`User alerts serve the function of alerting the user. ...................28
`Pre-set buttons and call back features should be simple
`dedicated buttons.......................................................................29
`The ‘154 Patent ...................................................................................29
`B.
`Overview of Usenet News (Netnews) .................................................36
`C.
`IV. Claim constructions .......................................................................................38
`A.
`a central broadcast server (claim 1, element C) ................................38
`
`6.
`7.
`8.
`
`2.
`3.
`
`4.
`
`5.
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`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
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`B.
`
`C.
`D.
`
`“a data channel associated with the remote computing devices”
`(claim 1, element C3.1) .......................................................................43
`“online or offline from a data channel” (claim 1, element C3.1) .......46
`C.
`“notifying of the receipt” (claim 9) .....................................................48
`D.
`V. Ground 1: Independent claim 1 .....................................................................52
`A.
`a central broadcast server (element C) ................................................53
`B.
`an information gateway (element C2) .................................................59
`1.
`“assign addresses to the data blocks” .......................................59
`2.
`“communicatively coupled to at least one information
`gateway” ....................................................................................64
`a transmission gateway (element C3) .................................................65
`data channel limitations (element C3.1) .............................................68
`1.
`A data channel “associated with the remote computing
`devices.” ....................................................................................68
`a.
`Yan’s user accessing the local news host. ......................69
`b.
`Yan’s user request to the SIFT server. ...........................71
`c.
`Kane’s modem and telephone line access to the
`central terminal. ..............................................................72
`Yan’s user profiles. .........................................................74
`d.
`a connection “via the Internet or another online service” .........76
`a.
`The meaning of “connected via the Internet.” ................77
`b.
`Connections that are not connections via the
`Internet ............................................................................80
`Diagrams illustrating Internet and non-Internet
`connections. ....................................................................90
`Dr. Madisetti’s definition of “connected via the
`Internet” is incorrect. ......................................................92
`The correct meaning of “another online service.” ........100
`Yan’s user access to the local news host. .....................101
`Kane’s user access to the central terminal. ...................103
`
`e.
`f.
`g.
`
`2.
`
`c.
`
`d.
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`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
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`3.
`
`4.
`
`“wherein the data channel is for accessing information
`from the information source that sent the data” ......................106
`a transmission made “whether…online or offline from a
`data channel” ...........................................................................109
`a.
`Applying the correct construction ................................109
`b.
`Applying the incorrect construction. ............................110
`VI. Ground 1: Dependent claims 2, 3, 6, 8, and 29 ..........................................114
`A.
`Claim 6 – “a network of servers” ......................................................114
`B.
`Claim 8 – “connection via the Internet between the remote
`computing device and the information source” ................................116
`1. The Yan user request to the SIFT server. ......................................117
`2. Yan’s user follow up to the local news host. ................................119
`(a) Yan does not expressly or inherently teach that a
`user connects to the local news host via an Internet
`connection. ....................................................................119
`(b) Yan does not expressly or inherently teach that the
`local news hosts provides data to the central
`broadcast server ............................................................120
`3. Yan’s mailing lists ........................................................................120
`VII. Ground 2: Dependent claim 4 ......................................................................121
`VIII. Ground 3: Dependent claims 9, 10, 14, 16, 20, and 21 ...............................121
`A.
`Claims 9, 10, 14, 16, 20, 21 – “a visual alert to notify users…of
`the receipt of the transmitted data” ...................................................121
`Claims 20 and 21 – “the launch of a viewer establishes an
`Internet connection…[to] the information source” ...........................123
`Claim 21 – “the connection…[to] the information sources
`comprises at least one wireless connection” .....................................125
`VIII. Ground 4: Dependent claim 11 ....................................................................126
`IX. Ground 5: Dependent claim 13 ....................................................................127
`X. Ground 6: Dependent claims 30 and 31 ......................................................130
`XI. Secondary objective factors of non-obviousness ........................................131
`A.
`Long felt, unmet need and failure of others ......................................131
`
`C.
`
`B.
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`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
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`B.
`Initial skepticism ...............................................................................132
`Teaching away ...................................................................................137
`C.
`Industry praise ...................................................................................138
`D.
`Industry licenses ................................................................................141
`E.
`Unexpected and unpredicted benefits ...............................................142
`F.
`G. Commercial success ................................................................................143
`XII. Signature ......................................................................................................147
`
`
`
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`
`iv
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`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
`
`I, James Knox, declare:
`
`1.
`
`I am making this declaration at the request of SimpleAir Inc. in the
`
`Inter Partes Review of U.S. Patent No. 8,601,154 B2 (the “‘154 patent”): IPR
`
`2015-00180, initiated by Petitioner Google, Inc. (“Petitioner”).
`
`I.
`
`Expertise
`
`A. Qualifications
`A copy of my resume is attached as Attachment A. I am qualified to
`
`2.
`
`
`
`render opinions regarding data communications, networks and networking, Internet
`
`and online services and technologies, wireless communication systems, electronics,
`
`and computer software. I have over 40 years of professional experience in industry
`
`and academics relating to these subjects, including computer networking and data
`
`communications. I am also familiar with and qualified to render opinions
`
`concerning the technology and inventions described in the patent at issue: U.S.
`
`Patent Nos. 8,601,154 (the ‘154 patent), titled “System and Method for
`
`Transmission of Data.”
`
`B. Relevant educational background
`
`3.
`
`I received a Bachelor’s degree in Electrical Engineering from The
`
`University of Texas in 1969, a Master’s degree in Computer Science from The
`
`University of Texas in 1971, and a Ph.D. in Electrical Engineering from The
`
`University of Texas in 1978. At The University of Texas, I studied and took
`
`courses in areas relating to computer networking and computer communications. I
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`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
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`also studied and took numerous courses dealing with data communications,
`
`wireless communications, electronics, electronic components, and computer
`
`software. In addition, I implemented a number of computer network systems,
`
`including broadband and baseband. My work included both the hardware and
`
`software designs and implementations. Following the academic work, I have
`
`developed, expanded, or implemented a number of military and civilian data
`
`networks. These include both proprietary and commercial systems, as well as
`
`classified military systems.
`
`C. Relevant work experience
`
`4.
`
`I have taught Electrical Engineering and Computer Science at The
`
`University of Texas, including courses involving the design, use, and programming
`
`of microprocessors and embedded microprocessor systems. These courses
`
`included the techniques for communicating over memory and I/O channels to
`
`remote devices, as well as the design and use of localized components such as A/D
`
`converters and digital switches, processors, memory, and high-speed data interface
`
`circuitry.
`
`5.
`
`After graduating from The University of Texas, my work experience
`
`in the computer hardware and software design field included the design and
`
`implementation of numerous electronic and data communication systems. I have
`
`designed microprocessors at the transistor circuit level (including designing
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`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
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`algorithmic structures within the microprocessor), and developed and implemented
`
`their use in land-based, sea-based, air-based, and deep space applications. I have
`
`designed many digital communication networks. I have opined in several other
`
`legal cases involving wired and wireless communication systems and devices,
`
`computer hardware and software, and the Internet, and I have been qualified as an
`
`expert and testified in court about such systems.
`
`6.
`
`I am currently the owner of a computer technology company called
`
`TriSoft, located in Austin, Texas. TriSoft is involved in the research and
`
`development of unique electronic systems and components. I consult in projects
`
`involving data and Internet communications, to name a very small subset. During
`
`my career, I have designed and implemented a variety of communications systems
`
`(both hardware and software), including systems for military, commercial, and
`
`security users, including remote telemetry, computer networking, data
`
`communications, operating systems, and application software.
`
`7.
`
`Through my education and experience in academia and industry, I
`
`have expertise in the field of the ‘154 patent. The ‘154 patent claims priority to a
`
`series of provisional applications, beginning with U.S. Provisional Application Ser.
`
`No. 60/010,651, filed Jan. 26, 1996. I am also familiar with the knowledge of a
`
`person of ordinary skill in the field of the patent at the time as well.
`
`II. Background to my opinions
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`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
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`A. Assignment
`
`8.
`
`I have been retained by SimpleAir as a technical consultant. I am
`
`being compensated for my time at my standard consulting rate of $300 per hour.
`
`My compensation is not in any way contingent on me stating any particular
`
`opinions nor is it contingent on the outcome of this proceeding; I was asked only to
`
`provide my best professional judgment. This declaration addresses the validity of
`
`certain claims of the ‘154 patent with regard to prior art asserted by Petitioner.
`
`B. Materials
`
`9.
`
`In preparing this declaration, I considered the materials identified
`
`in Attachment B and any materials I cite in the text of this declaration.
`
`C. Understanding of the law
`
`10. My understanding of the law regarding the validity of patents is based
`
`on my prior research and consulting work on patent matters and my discussions
`
`with counsel.
`
`D. Claim interpretation and analysis
`
`11.
`
`In my analysis, I applied the Court’s claim constructions from co-
`
`pending litigation involving the ‘154 patent (see Markman (Ex. 3001)). I
`
`understand that the Board has adopted these constructions in its Decision to
`
`Institute. I believe these constructions are correct and consistent with the broadest
`
`reasonable interpretation of the construed terms. For any terms not construed, I
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`applied their ordinary meaning, in the context of the ‘154 patent, to one of ordinary
`
`skill in the art.
`
`12. For the purposes of this declaration, it is my opinion that a person of
`
`ordinary skill in the art with respect to the patents would have a basic
`
`understanding of computers and computer software, wired and wireless data
`
`transmission systems and mechanisms, and the Internet and online services. See,
`
`e.g., ‘154, 1:31-33 (“The present invention relates generally to communication
`
`systems, and more particularly to both wired and non-wired data transmission
`
`communication system”). I am also of the opinion that such a person would be
`
`familiar with existing and then-developing technologies used to transmit Internet-
`
`based and other content to user computers, as described in the literature of that
`
`time period and used by those researching or working in the field. This would
`
`include methods of “Internet broadcasting,” “webcasting,” and “push
`
`technologies.” This person of ordinary skill in the art would typically be someone
`
`with a B.S. degree in Electrical Engineering or Computer Sciences (or the
`
`equivalent) and 3 years of experience in the field of networking and programming.
`
`Someone with a BSEE degree would require additional specialization in the
`
`computer block of EE (or equivalent).
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`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
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`13. My opinions are also based on my education and experience with
`
`various concepts and technologies that are implicated by the ‘154 patent (e.g.,
`
`networking and cellular technologies, standards, and protocols).
`
`III. Overview of the patent and asserted art
`
`A. Conventional wisdom
`
`14. The ‘154 Patent provided novel solutions to the problem of improving
`
`user access to online information, in particular in the field of Internet broadcasting.
`
`1:66-2:5; 2:17-28; claim 1. Those of ordinary skill who were working in the field
`
`of user access to online information at the time of the inventions (by January
`
`1996), as a result of their training and experience, would have been very familiar
`
`with certain basic paradigms and models, and would have had an ingrained
`
`understanding of the conventional wisdom (what one might call the traditional or
`
`“old” way of doing things) for a number of aspects relevant to the prior art and the
`
`problem they were addressing. Below I discuss some that are of particular
`
`relevance to analyzing the prior art as contrasted with the claimed inventions.
`
`1.
`
`Unmediated access between online users and content
`providers.
`
`15. One of ordinary skill in the art would have understood that it was
`
`advantageous for both online content providers and users of online content to have
`
`direct communications between the user and the source, without going through an
`
`intermediary that had the ability to control the content or presentation of the
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`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
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`information. In fact, the Internet and World Wide Web1 were based on and
`
`reinforce that paradigm. From the content provider’s viewpoint, any content
`
`provider can set up a web page or similar collection of on-line content and, by
`
`connecting it to the Internet, open its doors to an entire world. From the user’s
`
`viewpoint, any user can have direct access to a world wide web of content. As the
`
`‘154 patent noted:
`
`“Additionally, on-line services have revolutionized the distribution of
`
`information in our society by making available, to individuals
`
`throughout the world, endless amounts of information on every
`
`subject imaginable. The Internet and on-line services have brought
`
`together the world through a linkage of interconnected computer
`
`systems which can share information almost instantaneously.”
`
`‘154, 1:66-2:5.
`16. One of ordinary skill in the art at the time would have been
`
`dissuaded from a system that included an intermediary between users
`
`and Internet content providers. From the viewpoint of content
`
`providers, one of ordinary skill would have understood that content
`
`providers were wary of inserting an intermediary to further process or
`
`otherwise control their data. For one thing, the presence of such an
`
`1 I use this general term to include systems such as Gopher, as well as those
`adhering to the actual WWW protocols.
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`intermediary would raise concerns about additional costs, because the
`
`intermediary would not likely perform the service for free. In
`
`addition, content providers risked losing control over their
`
`communications—they might be filtered, altered, or negligently
`
`handled by the intermediary. In addition, an intermediary increased
`
`the risk of system interruption or failure, as well as additional loss of
`
`privacy for the user. An intermediary would add supplementary
`
`hardware and software systems that were at risk of failure, thereby
`
`disrupting communications (e.g. an update in the software could
`
`create unexpected problems), and at the very least would introduce
`
`additional delays in communication.
`
`17. From the viewpoint of Internet users, they generally desired to get
`
`information directly from the source, in part to avoid the potential that the
`
`information could be censored, edited, delayed or corrupted by an intermediary.
`
`Direct access also provided for the most current information, since copies of
`
`content located on a third party server might be dated or obsolete. Direct access by
`
`a user to a content provider also gives the user anonymity, which is one of the chief
`
`benefits of Internet access. Computer users viewed “exploring the World Wide
`
`Web [as] an entirely confidential and anonymous experience that leaves no record
`
`of itself.” Lee Gomes, Web “Cookies” May be Spying On You, Mercury News
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`(Feb. 13, 1996). A key benefit of the web to users is that it gave users privacy and
`
`anonymity as they examined various sources and types of information. One of
`
`ordinary skill at the time would have understood that any system that required
`
`disrupting a user’s anonymity was to be avoided.
`
`18. The desire for anonymity was demonstrated when the use of cookies
`
`was first given public attention. Cookies are bits of code that a web site operator
`
`may deposit on a user’s computer and that will allow the operator to track the visits
`
`and browsing of a particular user. An article examining the then-recent use of
`
`cookies noted that “many PC users may take a dim view” of cookies. Tim
`
`Jackson, Media Futures: This bug in your PC is a smart cookie, Financial Times
`
`(Feb.12, 1996). It stated: “As a group, those who inhabit the online world tend to
`
`be watchful of their privacy.” As an example, the article observed that when users
`
`became aware in 1995 that MSN “was able to download a list of programs on
`
`customers’ PCs as they logged in,” there “was such a fuss that the company was
`
`forced into a hasty damage-control exercise.” Id. The concern over cookies
`
`eventually led to investigations and hearings by federal agencies. See, e.g.,
`
`Internet Privacy Concerns, Hearing before the Senate Committee on Commerce,
`
`Science, and Transportation (Oct. 3, 2000).
`
`2.
`
`Provider control over transmission to users
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`19. A more specific aspect of the unmediated access model discussed
`
`above was that content and service providers desired to control transmission of
`
`their content and services to their users. One of the reasons for this conventional
`
`view was that, for a commercial online provider to monetize its content and
`
`services, the provider needed contact with its users, who were anonymous and
`
`remote from the providers. A provider could make money by measuring contacts
`
`between users and their content (to enable the sale of advertising), by collecting
`
`registration information (to create an email mailing list for upselling), or signing up
`
`subscribers for a fee. As a result, providers desired to control the transmission of
`
`their content and services to users so that they could determine who was receiving
`
`their information as well as what they were specifically receiving and when.
`
`20.
`
`In addition, providers of all types sought to avoid sharing their user
`
`base with others. Commercial providers naturally did not want to share access to
`
`their users with competing content or service providers. And non-profit or
`
`educational providers also desired to maintain a community and to avoid exploiting
`
`access to their user base. For these reasons, the conventional wisdom at the time
`
`was that each provider should control the server (or servers) that transmit
`
`information to its user base and should avoid comingling its user base with another
`
`provider’s user base. This model was present from the beginning of online
`
`services, such as CompuServe, Prodigy, and AOL. This conventional wisdom
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`taught the use of independent broadcast servers for each provider, rather than a
`
`shared central broadcast server. This conventional view can be diagrammed as
`
`follows:
`
`
`
`3.
`
`Users desire breadth of access, individualized control, and
`at-the-moment responses.
`
`21. One of ordinary skill in the art at the time would have been very
`
`familiar with the lessons learned from preceding efforts to improve user access to
`
`online information using web indexes and search engines. At the time of the
`
`inventions, the conventional wisdom was that successful methods for connecting
`
`users with content on the web should (a) seek to enlarge (or at the very least not
`
`diminish) the breadth of online information that the user could draw upon, (b)
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`enhance the user’s ability to actively request specific information, and (c) focus on
`
`meeting the desires that a particular user has at a particular moment in time.
`
`22. As discussed above, one of ordinary skill in the art would have
`
`understood that the basic paradigm of the Internet and Web was that it gave
`
`content and service providers direct, unmediated access to a world wide web of
`
`users, and users unmediated access to a world wide web of content and service
`
`providers. All a user needed was an address. Thus, from the users’ standpoint, the
`
`user simply needed an efficient method for the user to identify the address that was
`
`most likely to have the information that the user needed. More specifically, each
`
`user’s desire for particular information was time specific. At a particular moment
`
`in time, a user desired specific information.
`
`23. Early efforts to provide users access to online information included
`
`manually created indexes and lists. These included simple user-generated lists
`
`created by those with special interests in a particular field or group (known as SIGs
`
`or Special Interest Groups). There were also lists that represented more
`
`sophisticated peer-reviewed information, and became the online progeny of print
`
`indexes such as AKWAS (Applied Key Word in Alphabetical Sequence). Eugene
`
`Spafford began posting lists of Usenet groups in 1982. Eugene Spafford, “That’s
`
`All, Folks” (April 29, 1993) (retrieved from news.groups Google Groups).
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`24. Lists and indexes were also developed for the Web. The most popular
`
`of the early indexes was Yahoo!, which was developed in 1994 and publicly
`
`launched around September 1994. See “The History of Yahoo! – How it All
`
`Started,” Yahoo! Media Relations (2005); Gary Price, Google’s Usenet Timeline
`
`and Early Search Engine Announcements (January 20, 2005) (“Jerry Yang alerts a
`
`usenet group to the Yahoo database (9/21/94)”). “Yahoo! celebrated its first
`
`million-hit day in the fall of 1994, translating to almost 100 thousand unique
`
`visitors. Due to the torrent of traffic and enthusiastic reception Yahoo! was
`
`receiving, the founders knew they had a potential business on their hands.” “The
`
`History of Yahoo! – How it All Started,” Yahoo! Media Relations (2005).
`
`25. By September 1995, Yahoo! had been “spun-off as a commercial
`
`firm,” was receiving “millions of hits daily,” and was recognized as among the
`
`“Best of the Net.” See, e.g., Louis B. Rosenfeld, The Untimely Death of Yahoo:
`
`How the Double-Whammy of Web Architecture and Information Retrieval Will Do
`
`Yahoo In, CMC Magazine (Sept. 1, 1995). Yahoo! provided users with a very
`
`effective categorized, hierarchical listing of web sites. Id. But by the fall of 1995,
`
`there were predictions that this approach could not be sustained as the web
`
`continued to grow. Id. And, by the fall of 1995, Yahoo had moved to incorporate
`
`user-driven search capabilities. Id.
`
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`26.
`
`In addition, efforts were made to automate indexing by using spiders
`
`to crawl the web and retrieve and index document titles and headings. An early
`
`example was JumpStation, which commenced in December 1993. See, e.g.,
`
`http://en.wikipedia.org/wiki/JumpStation. A disadvantage of these approaches is
`
`that they relied upon document titles and headings that were entered by the creators
`
`of the websites. Such titles were inherently limited (they could not convey all of
`
`the details presented on a website) and depended on the ability of the website
`
`creator to provide an accurate description. See, e.g., Louis B. Rosenfeld, The
`
`Untimely Death of Yahoo: How the Double-Whammy of Web Architecture and
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`Information Retrieval Will Do Yahoo In, CMC Magazine (Sept. 1, 1995)
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`(“searching is only as good as the materials that are being searched. Yahoo's
`
`entries are self-labeled by those who submit them; in other words, the entries aren't
`
`being named by a single individual (or coordinated group) who follows a
`
`consistent labeling scheme”).
`
`27. By 1994 systems were developed to provide full text indexing of
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`websites (as contrasted with just indexing the titles or headings). An early example
`
`was WebCrawler. See, e.g.,
`
`http://www.thinkpink.com/bp/WebCrawler/History.html. Other online mechanisms
`
`were in parallel development. Gopher became one of the best known. Gopher came
`
`online in 1991, with a few sites still available today.
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`14
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`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
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`28. Then in December 1995, AltaVista was launched and quickly became
`
`a popular full text search engine. (I discuss AltaVista in detail below). Other
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`search engines that were launched between 1994 and 1996 included Lycos,
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`HotBot/Inktomi, and Excite. See, e.g., http://en.wikipedia.org/wiki/Lycos,
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`http://en.wikipedia.org/wiki/HotBot, http://en.wikipedia.org/wiki/Inktomi,
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`http://en.wikipedia.org/wiki/Excite. From these efforts to improve user access to
`
`online information, one of ordinary skill in the art as of January 1996 would have
`
`understood that successful methods should apply the following principles.
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`29. Maximize breadth of access to information. Users do not want access
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`to just one or two isolated ponds of information; they want access to the entire
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`ocean.
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`30. Give users individual control over their requests for information. Not
`
`all users want the exact same information, and each individual user is not just
`
`interested in one thing. Each user has multiple interests, and the combination of
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`interests of any one user will vary from the interests of any other user. It is
`
`important to give the user total freedom individually to select just the information
`
`he or she wants to access. See, e.g., James Gleick, “Pushy, Pushy,” The New York
`
`Times (March 23, 1997) (Ex. 2040) at 3 (“The Web browser and other Internet
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`tools are making their way into users’ hands with astonishing speed precisely
`
`because they allow the operator to move, find, control and wander at will.”).
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`15
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`Declaration of James Knox, IPR2015-00180, U.S. Patent No. 8,601,154
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`31. Dynamically satisfy the request that a user has at each particular
`
`moment in time. User interests vary over time. User interests vary from week to
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`week, day to day, even minute to minute. Users often desire to access information
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`sources that they have never previously accessed. Users desire to choose, at each
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`particular moment in time, exactly what they want to access. For example, in the
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`span of a half an hour, a user might desire, in order, the following information:
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`• the weather forecast for his neighborhood for tomorrow
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`• advice on what is the best consumer printer
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`• the origin of the word “nerd”
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`• some basic information on the hanging gardens of Babylon
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`• help solving a problem with his or her PC
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`• the location of where to buy a particular model of printer at the
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`cheapest prices
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`• etc.
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`See, e.g., James Gleick, “Pushy, Pushy,” The New York Times (March 23, 1997)
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`(Ex. 2040) at 2-3 (“Most of the valuable information you pull f