throbber
Claims Construction Expert Report of William Huxhold
`Boundary Solutions Inc. v. CoreLogic, Inc.
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`CoreLogic Exhibit 1035
`CoreLogic, Inc. v. Boundary Solutions, Inc.
`Trial IPR2015-00228
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`Page 1 of 38
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`I.
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`INTRODUCTION
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`1.
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`I have been asked by counsel for Boundary Solutions Inc. (“BSI”) to analyze
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`and opine on issues related to claim construction of U.S. Patent No. 7,092,957, 7,499,946, and
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`8,065,352, (collectively “Patents-in-Suit”) in this case.
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`II.
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`QUALIFICATIONS
`2.
`My name is William Huxhold, and I am a Professor at the University of
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`Wisconsin – Milwaukee in the Department of Urban Planning. Details of my professional
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`qualifications and background are set out in my curriculum vitae, a copy of which is attached as
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`Exhibit A.
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`3.
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`I hold B.S. and M.S. degrees in Industrial Engineering and Engineering
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`Management (Public Administration emphasis).
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`5.
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`I have been involved in the study, construction, implementation and operation
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`of Geographic Information Systems (GIS) for over 40 years.
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`6.
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`For the time I expend on this case, I am currently being compensated at a rate
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`of $275/hour. My compensation is not in any way dependent on the outcome of the dispute.
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`7.
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`I have considered the Patents-in-Suit and their file histories for the purposes of
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`providing my technical expert opinion regarding the meaning of certain claim terms. The
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`patents generally relate to design, construction, updating and operation of a national parcel
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`boundary map database designed to serve maps over computer networks in an efficient and
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`effective manner. Because of my background, training, and experience, I am qualified as a
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`technical expert in the technical areas relevant to these patents.
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`III. MATERIALS REVIEWED FOR INFRINGEMENT OPINION
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`8.
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`To prepare this report, I reviewed the Patents-in-Suit; the prosecution history of
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`the patents and including certain references cited therein; and extrinsic evidence as detailed
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`below. Through my work in the field, I have also examined various textbooks, patents, and
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`publications in existence before the Patents-in-Suit that inform my opinions. While I have
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`reviewed a number of materials, the materials I have relied upon in rendering my opinions
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`disclosed in this report are set forth in Exhibit B.
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`9.
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`I reviewed the definitions for the identified terms proposed by Boundary
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`Solutions and I agree with them.
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`IV.
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`FIELD OF THE INVENTIONS
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`10.
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`The Patents-in-Suit describe the solution to a particular set of problems that
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`GIS organizations faced in the assembly and presentation of the voluminous data from many
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`sources that was needed to provide systems that could exactly identify property locations by
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`their actual parcel boundaries. In particular, in the United States, many counties (usually in
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`their tax assessor’s office) had developed databases which could display parcel maps for their
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`own counties. While there was much discussion of standards and data formats to be used for
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`this work, the counties had not designed their database to work in concert with each other, and
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`they had, in fact, used a wide variety of GIS data and database formats.
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`11.
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`As described in the patents, digital maps generally combine both spatial
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`(geographic) data and non-geographic information. The geographic data describes points, lines
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`and areas. The non-geographic data, often referred to as “attributes” are information associated
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`with a geographic feature. In this case, parcels, can have many attributes, such as owner name,
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`address, type of building structure, assessed value, year built, land use restrictions and the like.
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`Two basic means of storage had developed for GIS data. The data could be stored directly in
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`files that the GIS system software would load for each project. Alternatively, the data could be
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`stored in a relational database, where a series of tables contained the information in “records”
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`and the tables could be flexibly joined for particular queries (searches). In any case, many
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`aspects of the collection of the data (its sources, forms, and currency), the types of analysis that
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`were expected, and the storage and operation of the system impacted the design of the system.
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`V.
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`CLAIM CONSTRUCTION
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`12.
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`I am informed that terms in patent claims must be construed as a first step in
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`analyzing whether a claim is infringed and/or whether the claim is invalid. I am further
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`informed that patent claims must be construed the same way for infringement and invalidity
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`analyses. I understand that claim construction starts with the plain language of the claims, and
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`that the meaning of claim terms may be informed by referring to the specification and file
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`histories.
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`13.
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`It is my understanding that disputed claim terms should be interpreted using
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`their plain and ordinary meaning to one of skill in the art at the time of the invention (i.e., the
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`date the earliest supporting priority application was filed, namely January 18, 2002 for these
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`patents), unless the inventor acted as his or her own lexicographer, redefined a well-known
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`term of art, or disclaimed certain subject matter. I also understand that the specification plays a
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`significant role in claim construction, and that the claims must be read in view of the
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`specification of which they are a part. I also understand that the specification may reveal a
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`special definition given to a claim term by the patentee that differs from the meaning it would
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`otherwise possess, and that in such cases the special definition (“lexicography”) governs. I
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`further understand that subject matter can be disclaimed from the scope of a claim term if there
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`is a clear and unambiguous disavowal of that subject matter. I further understand that the
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`prosecution history of the patent should also be considered, and that it provides evidence of
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`how the U.S. Patent and Trademark Office and the inventor understood the patent.
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`14.
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`I further understand that the claim language (in the context of non-means plus
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`function claiming) is to be viewed from the perspective of a person of ordinary skill in the art at
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`the time of invention. A person of ordinary skill in the relevant art of the Patents-in-Suit at that
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`time would have had a Bachelor’s degree or higher in, GIS engineering with at least 5 years of
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`academic or industry experience in GIS database design. When analyzing the disputed claim
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`language, I apply this standard to reach my conclusions.
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`V.
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`PATENTS-IN-SUIT OVERVIEW
`15.
` On August 15, 2006, United States Patent No.7,092,957, (“the ‘957 patent”)
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`entitled “Computerized national online parcel-level map data portal” was duly and legally
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`issued.
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`16.
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` On March 3, 2009, United States Patent No. 7,499,946, (“the ‘946 patent”)
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`entitled “Computerized national online parcel-level map data portal” was duly and legally
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`issued.
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`17.
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` On November 22, 2011, United States Patent No. 8,065,352 (“the ‘352
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`patent”) entitled “Computerized national online parcel-level map data portal” was duly and
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`legally issued.
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`18.
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`The ’957, ‘946, and ‘352 patents (“Patents-in-Suit”) are directed to methods for
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`the online delivery of parcel-level maps and linked attribute data. The ‘957 and ‘946 patents
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`covers methods for retrieving geographic parcel boundary polygon maps and associated parcel
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`attribute data linked to a non-graphic database. The ‘352 patent covers methods for retrieving
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`and displaying geographic parcel boundary polygon maps.
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`19.
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`The patents are all in the same family sharing a common specification. For this
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`discussion I use line and column cites to the ‘957 patent. The patents relates to a computerized
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`National Online Parcel-Level Map Data Portal (NPDP). The patents states that while “hundreds
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`of local governments have finished digitizing their parcel maps, a single national parcel map
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`source (portal) does not exist. The National Online Parcel-Level Map Data Portal (NPDP)
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`remedies this problem by providing the first national repository of parcel data.” Id., 1:26-31.
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`As described throughout the specification the construction, maintenance, operation of the
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`database present a series of technical challenges, including the large number of data sources
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`each having prepared their data in varying formats and according to their own styles and
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`inconsistent forms. Id., 7:31-54; 12:9-15. The national repository is assembled by collecting the
`spatial data from local municipal sources primarily county property assessor’s offices. Id.,
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`Abstract, 1:49-59, 3:42-53, 4:8-17. “Typically this is a countywide parcel map (parcel polygons
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`geocoded with APNs) provided by a single taxing authority.” Id., 7:56-58. The patents describe
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`specifics of the NPDP that “optimizes online delivery of parcel-level maps and linked attribute
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`data” by inter alia “managing a database of assembled and current vector based parcel data in a
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`spatial format (GIS) that enables geocoded parcel boundaries to be linked to property tax
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`records, and maintains relationships with “individual property assessor’s offices” to obtain
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`updates assuring “a sustained and expanding flow of increasingly competent content.” Abstract.
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`20.
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`This process is further described in reference to Figure 5 of the patents:
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`The specification explains:
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`
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`FIG. 5 is an illustration of the process for establishing ongoing data
`acquisition and maintenance operations needed to build, maintain and
`improve the public domain content of the NPDP, along with commercially
`supplied data sets and the national street centerline map as described
`above.
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`Data must first be obtained from the public sector, step 301. Through a
`sustained program, all property tax assessment agencies are contacted, and
`metadata profiles of parcel map GIS databases recorded along with terms
`and conditions for data acquisition. Each county is requested to submit in
`digital format a copy of their jurisdiction wide parcel boundary map,
`complete with tax number geocodes for each parcel.
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`11:55-12:1.
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` 21.
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`Further, the NPDP “is developed in a manner that “accommodates easy
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`updating of both the graphic and the non-graphic database since a central value of the NPDP is
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`its currency” (8:11-13) and “expedites the ultimate self-updating of the spatial data by the
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`sponsoring agency” (12:19-21).
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`22.
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`The patents next describe in detail a process of “normalizing” data received
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`from the counties using a common data protocol, called the “NPDP protocol.” The common
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`spatial data protocol is described in the specification as a series of operations applied to the raw
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`parcel-level map data from “multiple sources” to prepare the data for loading into the national
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`database. Id. at 12:15-19. (“As the data is found or made compliant with NPDP specifications,
`it is loaded in step 304 onto the server in a directory that has the same FIPS number as the
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`jurisdiction in which the NPDP data sponsor is located.”); id. at 3:14-19 (“The first, NPDP
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`warehousing, is the gathering and storing of parcel-level map data from multiple sources
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`formatted to a single protocol suitable for online access and use. “); id. at 4:8-11 (“The digital
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`assemblage of parcel-level databases from all the sponsoring agencies is stored in a server
`system according to a standard protocol. The process begins with the acquiring of the raw
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`parcel-level data from various data sponsors.”)
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`23.
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`In addition, the database is optimized to deliver online maps with parcel level
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`information and associated non-geographic attribute data. The patent describes retrieving a
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`parcel level map based on a requested address of a parcel. Id., 1:65-2:1, 2:63-65, 4:52-56. In
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`some claims, a lookup table (e.g., a jurisdictional lookup table “JLT”) is searched to identify,
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`the state and county (“the pertinent county”) in which the parcel is located. Id., 8:26-30, 9:12-
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`28. In other claims, a directory is accessed, and the non-graphic database stored in the county
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`directory is searched for a record having a matching address value. Id., 2:1-2, 8:30-33, 9:23-30,
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`9:57-61. Finally, in all cases, the server searches “a multi-jurisdictional parcel map database” or
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`“a portion of a multi-jurisdictional database” using a “jurisdictional identifier.” If the record is
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`identified, the APN is used to access a graphic database containing the selected parcel and
`adjacent parcels within a prescribed search radius of the selected parcel. Id., 2:1-7, 3:56-63.
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`These parcels may be displayed to form the parcel level map, with the selected parcel in the
`center of the screen displayed as a highlighted polygon. Id., 2:1-7, 4:61-63. The parcel’s linked
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`tax record can also be displayed. Id., 4:63-64.
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`VI.

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`DISPUTED CLAIM TERMS TO BE CONSTRUED
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`Claim Term
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` “associated parcel attribute data linked
`to a non-geographic database” (claim 1
`of ’957 patent; claims 1 and 20 of ’946
`patent)
`
` “applications program” (claim 1 of
`’957 patent; claims 1 and 20 of ’946
`patent)
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` “multiple jurisdictional [digital parcel
`map] databases”
`
`(claim 1 of ’957 patent; claims 1 and 20
`of ’946 patent)
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` “jurisdictional database” (claim 1 of
`’957 patent; claims 1 and 20 of ’946
`patent;
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`claim 7 of ’352 patent)
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` “normalized to a common [spatial]
`data protocol” (claim 1 of ’957 patent;
`claims 1
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`and 20 of ’946 patent; claims 1, 9 and
`12 of ’352 patent)
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`
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`BSI Proposed Construction and Supporting
`Evidence
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`BSI’S PROPOSED CONSTRUCTION
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`Plain and Ordinary Meaning; No construction is
`necessary.
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`BSI’S PROPOSED CONSTRUCTION
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`Plain and Ordinary Meaning; No construction is
`necessary.
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`BSI’S PROPOSED CONSTRUCTION
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`Parcel map databases supplied by two or more
`sponsoring jurisdictions
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`BSI’S PROPOSED CONSTRUCTION
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`a parcel map database supplied by sponsoring
`jurisdictions
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`BSI’S PROPOSED CONSTRUCTION
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`a set of one or more automated and/or semi-
`automated processes applied to data and data updates
`supplied by sponsoring jurisdictions using a set of
`rules or procedures in order to transform the data for
`use in the multi-jurisdictional database.
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`EXTRINSIC EVIDENCE
`
`Encyclopedia of Geographic Information Science,
`Sage Publications, 2008, at pages 320-321.
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`“jurisdiction look up table” (claim 1 of
`’957 patent, claims 1 and 21 of ’946
`patent)
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`BSI’S PROPOSED CONSTRUCTION
`
`Plain and Ordinary Meaning; No construction is
`necessary.
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`
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` “jurisdiction” (claims 1 of ’957 patent; BSI’S PROPOSED CONSTRUCTION
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`Claim Term
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`claims 1, 20 and 21 of ’946 patent)
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`
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` “[numerical] jurisdictional identifier”
`(claim 1 of ’957 patent; claims 1 and 21
`of ’946 patent; claims 1, 9, 12, and 20
`of ’352 patent)
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`“fill” (claim 1 of ’957 patent; claims 1
`and 20 of ’946 patent)
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`BSI Proposed Construction and Supporting
`Evidence
`
`In claim 1 of the ‘957 patent and claims 1 and 21 of
`the ‘946, the term used in the claim is “selected
`jurisdiction.” The term does not appear in claim 20
`of the ‘946 patent.
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`Plain and Ordinary Meaning; No construction is
`necessary.
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`BSI’S PROPOSED CONSTRUCTION
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`a [numerical] code for identifying a jurisdictional
`database.
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`BSI’S PROPOSED CONSTRUCTION
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`Completely or almost completely occupy a space
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` “highlighted” (claim 1 of ’957 patent;
`claims 1 and 20 of ’946 patent; claims 4
`and 5 of ’352 patent)
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`BSI’S PROPOSED CONSTRUCTION
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`Plain and Ordinary Meaning; No construction is
`necessary.
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`“the parcel is displayed to the center of
`the screen” (claim 5 of ’957 patent;
`claim 5 of ’946 patent)
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`“scale selection mode” (claim 8 of ’957
`patent; claim 8 of ’946 patent)
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`
`
` “specialized fields” (claim 13 of ’957
`patent; claim 13 of ’946 patent)
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`
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`BSI’S PROPOSED CONSTRUCTION
`
`Plain and Ordinary Meaning; No construction is
`necessary.
`
`BSI’S PROPOSED CONSTRUCTION
`
`Plain and Ordinary Meaning; No construction is
`necessary.
`
`BSI’S PROPOSED CONSTRUCTION
`
`Plain and Ordinary Meaning; No construction is
`necessary.
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` “ornate” (claim 12 of ’957 patent)
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`BSI’S PROPOSED CONSTRUCTION
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`Plain and Ordinary Meaning; No construction is
`necessary.
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`Claim Term
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` “multi-jurisdictional [digital parcel
`map] database” (claims 1, 3, 7, 8, 9, 10,
`11, 12, 14,
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`19, 20, 21, 22, 23 of ’352 patent)
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`“service area directories corresponding
`to multi-jurisdictional service areas”
`(claims 1, 11, 23 of ’352 patent)
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` “portion” (claim 20 of ’946 patent;
`claims 7, 8, 9, 19, 20, 21 of ’352 patent)
`
`
`
` “index of jurisdictional databases”
`(claim 7 of ’352 patent) / “index of a
`multijurisdictional digital parcel map
`database” (claims 9, 19, and 20 of ’352
`patent)
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`“spatial query” (claim 20 of the ’946
`patent)
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`“involving, as needed, city, state, zip
`code and Assessor's Parcel Number”
`(claim 20 of the ’946 patent)
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`“surrounding parcels”
`
`(claims 1, 9 and 12 of the ’352 patent)
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`“client computer”
`
`(claim 1 of the ‘352 patent)
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`BSI Proposed Construction and Supporting
`Evidence
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`BSI’S PROPOSED CONSTRUCTION
`
`A database consisting of multiple jurisdictional
`databases supplied by sponsoring jurisdictions.
`
`BSI’S PROPOSED CONSTRUCTION
`
`subsets of information in a database describing
`individual land parcels within geographic areas,
`corresponding to one or more jurisdictional areas,
`arranged with reference to a catalogue or listing of
`resources
`
`BSI’S PROPOSED CONSTRUCTION
`
`Plain and Ordinary Meaning; No construction is
`necessary.
`
`BSI’S PROPOSED CONSTRUCTION
`
`Plain and Ordinary Meaning; No construction is
`necessary beyond that provided in other
`constructions.
`
`A request for information that includes the selection
`of geographic features based on a location or spatial
`relationship. Other non-spatial attributes may be
`included in the query.
`
`Plain and Ordinary Meaning. No construction
`necessary.
`
`Plain and Ordinary Meaning. No construction
`necessary.
`
`Plain and Ordinary Meaning. No construction
`necessary.
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`24.
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`Having reviewed the Patents and file histories, it is my opinion that the
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`constructions proposed by Boundary Solutions reflect how one skilled in the art would have
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`understood the disputed patent claim terms as of January 2002.
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`25.
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`For those terms that Boundary Solutions argues are “plain and ordinary”
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`meaning, it is my opinion that one skilled in the art after reading the specification and file
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`history would not interpret those terms any differently from the lay understanding of the words.
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`I understand that CoreLogic contends that five of those terms are ones that the Court should
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`construe. In the following paragraphs, I provide the reasons why I think the terms do not have
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`the meanings claimed by CoreLogic.
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`26.
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`CoreLogic interprets “associated parcel attribute data linked to a non-geographic
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`database” to mean “parcel information (e.g. tax and building data) that is stored in a database that
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`does not contain information describing the shape of the parcel.” My understanding of this is that
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`CoreLogic argues that non-geographic attribute information must be stored in a separate database
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`from the parcel boundary data. This term appears in the preamble of claim 1 of the ‘957 patent as
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`follows: “An interactive computer implemented method for retrieving geographic parcel
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`boundary polygon maps and associated parcel attribute data linked to a non-graphic database,
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`wherein the data is acquired electronically.” First, I presume that “describing the shape of the
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`parcel” is meant to mean having the vectors and coordinates that define the location of the
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`parcel. Even with that clarification, CoreLogic’s construction adds a requirement that I do not
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`think is needed. Specifically, nothing in the claim language requires physical “linking” To me,
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`reading the patents as a whole, the language of the claim covers the situation where non-
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`geographic information may appear in a table in a relational database linked to another table in
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`the same database that has the vectors and coordinates information that defines the shape of the
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`parcel boundary polygon. In other words, “linking” can be logical, rather than physical and thus
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`requires no specific storage arrangements. While a relational database may be stored together, it
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`still involves the “linking” of a non-geographic database (the attribute information) to geographic
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`information. In fact, the graphic database described in the patents always includes at least one
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`piece of non-geographic information, the parcel’s APN, which in turns links to the other non-
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`geographic data.
`
`27.
`
` Throughout the patent, the process of bringing the geographic and non-
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`geographic information into the single location “server” or “portal” is described. Indeed, in a
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`non-limiting definition, the specification defines the NPDP as “National Online Parcel-Level
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`Map Data Portal, as “an internet warehouse that optimizes online delivery of parcel-level maps
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`and linked attribute data.” 2:32-34. The specification further describes a specific embodiment
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`where the graphic and non-graphic database are maintained in a single database. 3:44-48. (“This
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`non graphic database is associated, parcel by parcel, with the graphic database, stored in the form
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`of a single DBMS file, the records either generated by public providers or by commercial sector
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`sources.”). The specification further explains that having both geographic and non-graphic data
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`stored in a single database allows for standardized APN geocodes to work. 3:49-55 (“This
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`configuration of graphic boundary segments and textural attribute assignments makes automated
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`search of a digital spatial database possible. When a tax record with matching address values is
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`found, the APN in the attribute table's index field is used to access the graphic database (all the
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`parcel boundary segments) to find all boundary segments with this matching geocode.”) A
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`DBMS was well known in the art. One typical definition is: “A database management system
`
`(DBMS) is system software for creating and managing databases. The DBMS provides users and
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`programmers with a systematic way to create, retrieve, update and manage data.”
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`http://searchsqlserver.techtarget.com/definition/database-management-system. The conception of
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`the NPDP as including linked tables, as opposed to hyperlinks which might take one to an
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`entirely different database, is clearly seen in the specification’s description of the response to a
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`user’s entry of an address:
`
`In an embodiment of the invention, as part of the basic function, an end
`user seeking only a subset of parcel-level data, enters a street address
`including the city, state, street name and/or the number of the desired
`parcel into a window displayed on a computer screen. According to the
`state entered, a folder is electronically accessed containing all spatial data
`files for that state including supporting tax record databases for each
`agency for which there is stored spatial data.
`
`If there is an address match, the pertinent parcel displays as a highlighted
`polygon in the center of the screen along with surrounding parcels. In
`addition, the parcel's linked tax record is displayed.
`
`4:47-59. If a separate database, or a separate server, was to be accessed to obtain the linked tax
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`record, such a process would have been described. It is also clearly shown in an excerpt
`
`describing the location of both the graphic data and the Parcel Record Attribute Database
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`(PRAD). The patent describes that the “(PRAD) 104 serves as the above non-graphic database.”
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`8:13-14.
`
`7:55-61.
`
`Each jurisdictional directory at a minimum contains a graphic database
`derived from public sector sources. Typically this is a countywide parcel
`map (parcel polygons geocoded with APN s) provided by a single taxing
`authority, and provided in SHP-ESRI Arc View native spatial data file
`format. Most often, this file will contain a polygon for every parcel in the
`county.
`
`When the user selects a desired jurisdiction (city, township, town,
`administrative area or other place name), the FIPS number of the county in
`which the jurisdiction is located is retrieved from JLT 102. This FIPS
`number is used to access the NPDP county directory named by a matching
`FIPS number. The non-graphic database (Parcel Record Attribute
`Database-PRAD) located in this directory is searched in step 104 in the
`selected jurisdiction.
`
`9:23-30. If the PRAD resides in the same directory as the parcel boundary data, they perforce are
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`in the same database. These embodiments suggest that parts of the database, such as tables of tax
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`and building attributes within a relational database are “non-graphic databases,” that are linked to
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`“geographic parcel boundary polygon maps and associated parcel attribute data.” Nonetheless,
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`they may not be “stored in a database that does not contain information describing the shape of
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`the parcel” as required by CoreLogic’s construction.
`
`27.
`
`CoreLogic interprets “applications programs” as “a program that displays maps
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`and accesses a parcel database.” While I agree that these are applications programs, it may be
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`that different applications access the database and display the map. It also may be that the
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`application may have many other functions, such as a web browser that might not be considered
`
`as a program “that displays maps and accesses a parcel database.”
`
`28.
`
`CoreLogic interprets “jurisdiction look up table” to mean “a single tabular file
`
`containing the following fields: state, jurisdiction, county name, county FIPS number, accuracy,
`
`publication date, percent complete, ortho scale, ortho resolution, and update frequency.” The
`
`term “look up table” is one well know in the art. It need not be a single tabular file and it
`
`certainly does not need to contain specific specified fields. My reading of the specification is
`
`that the patentee was describing a particular embodiment of the invention in the portion relied
`
`upon by CoreLogic. This is made clear by the use of capitalization, the reference to the
`
`patentee’s own particular implementation, the NPDP, and the reference to an element of an
`
`illustrative figure, Fig. 2, of the NPDP Standard Feature Operation. 8:25 (“Jurisdiction Lookup
`
`Table (JLT) 102”); 9:14 (“NPDP Jurisdiction Lookup Table (JLT) 102)”.
`
`29.
`
`CoreLogic interprets “jurisdiction” to mean “a named territory, e.g. city,
`
`township, town, administrative area or other place name.” To me, the plain and ordinary
`
`meaning of the term “jurisdiction” refers to a governmental entity that is responsible for a
`
`- 13 -
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`Page 14 of 38
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`geographic area. “A named territory” could refer to jurisdictions that the patentee does not
`
`appear to intend. For example, in my opinion, one skilled in the art would not refer to a zip code
`
`as a jurisdiction, there is no governmental entity responsible for a zip code – the U.S. Postal
`
`Service maintain zip code maps to speed delivery of mail. The reference to administrative area or
`
`other place name seems incongruous as well. While the patent specification uses those
`
`examples, my opinion is that reading the patent as a whole shows that the term “jurisdiction”
`
`should bear its ordinary meaning. It appears to me that the reference to other place names is a
`
`reference to the fact that a user might want to search on place names that either do not have a
`
`specific address, or can be identified without reference to the address. For example, one might
`
`search a San Jose map by inputting San Jose State University. In general street mapping
`
`applications such as Bing or Google maps these place names, often called “Points of Interest.”
`
`Such a search is equivalent to an address search using a city and state name in that the software
`
`would likely locate the university address; then input San Jose, California into the “jurisdiction
`
`look up table.”
`
`30.
`
`The primary reference to “jurisdiction” appears in connection with the jurisdiction
`
`look up table. That table is described as having as an input an address, which includes a city (or
`
`town or township) name and a state name (these items described as “values”), and having as an
`
`output a “[numerical] jurisdictional identifier” used to find the portion of the database in which
`
`to search for the appropriate parcels to display. (“The JLT makes it possible for the state and
`
`jurisdiction values stated in an address entry transaction to be used to determine the pertinent
`
`county in which it is located. Hence, by the table also containing the county's FIPS number, the
`
`appropriate county directory is automatically accessed for data retrieval purposes.”). Indeed, the
`
`patentee wasfocused on local jurisdictions, contrasting states and jurisdictions: “The end user
`
`- 14 -
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`Page 15 of 38
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`

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`first enters the street address number, street name, city name and state name into a provided data
`
`entry window, step 101. This same process can also be done using pick lists in which the user
`
`first selects a state and a jurisdiction from displayed pick lists. Given the user selected
`
`jurisdiction, a street pick-list display appears. The user then selects street name and street
`
`numbers from additional pick-list displays.” 9:3-10. In my opinion, the “selected jurisdiction”
`
`referenced in the second phrase, must include both a city and state name. Similarly, in another
`
`expcert:
`
`When the user selects a desired jurisdiction (city, township, town,
`administrative area or other place name), the FIPS number of the county in
`which the jurisdiction is located is retrieved from JLT 102. This FIPS
`number is used to access the NPDP county directory named by a matching
`FIPS number. The non-graphic database (Parcel Record Attribute
`Database-PRAD) located in this directory is searched in step 104 in the
`selected jurisdiction. … Upon selection of desired street name, PRAD is
`queried to identify all street address numbers assigned to the selected
`street name (within the selected jurisdiction).
`
`
`9:23-36. Since the selected jurisdiction is singular, it cannot be interpreted as both the
`
`state and the city within it.
`
`31.
`
`CoreLogic argues that “highlighted” means “changing the color of the
`
`parcel polygon to a brighter or different color from surrounding parcels also displayed.”
`
`While the specification gives these examples, I read them to not define the term; they just
`
`provide examples of how to highlight a parcel. In my opinion, one skilled in the art
`
`would read the claims should be read with the term’s ordinary meaning. First, the
`
`specification explains the purpose of highlighting is simply to allow the user to identify
`
`the property of interest. Abstract (“A user enters a street address into an appropriate
`
`screen window to call up and view road right-of-ways, all parcel boundaries and the
`
`"exact" address location as a highlighted parcel area.”) The portion of the specification
`
`- 15 -
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`Page 16 of 38
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`

`

`
`on which CoreLogic relies relates to an embodiment of the invention, specifically the
`
`patentee’s own system, the NPDP. 2:58-63 (“If there is a match, the NPDP displays the
`
`road right-of-ways, all parcel boundaries within a select distance, the "exact" address
`
`location highlighted, the pertinent parcel polygon changing the color to a brighter or
`
`different color from surrounding parcels also displayed.”)
`
`32.
`
`CoreLogic proposes that “index of jurisdictional databases” / “index of a
`
`multijurisdictional digital parcel map database” be construed as “a single tabular file containing
`
`identifiers of jurisdictional databases.” CoreLogic cites the following in support of this
`
`construction: ’957 patent at 7:23-30; 8:25-32 and 02/03/2006 Remarks (’957 file history) at 12.
`
`None of the excerpts refer to an index or indices, except to the extent of describing the
`
`jurisdiction look up table as indexed for identification of the pertinent jurisdictional database.
`
`The only reference to a single tabular file is in connection with the jurisdiction look up table,
`
`which as I mentioned above, was simply an illustrative example. One definition of a database
`
`index is a “data structure that improves the speed of data retrieval operations on a

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