Trials@uspto.gov
`571-272-7822
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`Paper No. 49
`Entered: September 24, 2015
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`SAMSUNG ELECTRONICS CO., LTD., SAMSUNG
`ELECTRONICS AMERICA, INC., and SAMSUNG
`TELECOMMUNICATIONS AMERICA, LLC,
`Petitioner,
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`v.
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`BLACK HILLS MEDIA, LLC,
`Patent Owner.
`____________
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`Cases IPR2014-00717 and IPR2015-00335
`Patent 6,108,686
`____________
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`Held: July 28, 2015
`____________
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`
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`
`
`BEFORE: BRIAN J. McNAMARA, DAVID C. McKONE, and
`FRANCES L. IPPOLITO, Administrative Patent Judges.
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`The above-entitled matter came on for hearing on Tuesday, July 28,
`2015, commencing at 1:31 p.m., at the U.S. Patent and Trademark
`Office, 600 Dulany Street, Alexandria, Virginia.
`
`
`571-272-7822
`
`Paper No. 49
`Entered: September 24, 2015
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SAMSUNG ELECTRONICS CO., LTD., SAMSUNG
`ELECTRONICS AMERICA, INC., and SAMSUNG
`TELECOMMUNICATIONS AMERICA, LLC,
`Petitioner,
`
`v.
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`BLACK HILLS MEDIA, LLC,
`Patent Owner.
`____________
`
`Cases IPR2014-00717 and IPR2015-00335
`Patent 6,108,686
`____________
`
`Held: July 28, 2015
`____________
`
`
`
`
`
`BEFORE: BRIAN J. McNAMARA, DAVID C. McKONE, and
`FRANCES L. IPPOLITO, Administrative Patent Judges.
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`The above-entitled matter came on for hearing on Tuesday, July 28,
`2015, commencing at 1:31 p.m., at the U.S. Patent and Trademark
`Office, 600 Dulany Street, Alexandria, Virginia.
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`Cases IPR2014-00717 and IPR2015-00335
`Patent 6,108,686
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`APPEARANCES:
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`ON BEHALF OF THE PETITIONER:
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`ON BEHALF OF PATENT OWNER:
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`ANDREA G. REISTER, ESQUIRE
`GREGORY S. DISCHER, ESQUIRE
`Covington & Burling, LLP
`One City Center
`850 Tenth Street, N.W.
`Washington, D.C. 20001-4956
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`THOMAS J. ENGELLENNER, ESQUIRE
`GEORGE S. HAIGHT, IV, ESQUIRE
`ANDREW W. SCHULTZ, ESQUIRE
`Pepper Hamilton, LLP
`19th Floor, High Street Tower
`125 High Street
`Boston, Massachusetts 02110-27361
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`JUDGE McNAMARA: Good afternoon. This is the oral
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`hearing in case IPR2014-00717, which has been joined with case
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`IPR2015-00335. As you can tell today, we have two remote judges,
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`Judge McKone is joining us from Detroit. Judge Ippolito is joining us
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`from California. So I would remind everybody when they are making
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`their presentations today to speak into the microphones so that the
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`remote judges will be sure to be able to hear you. And if there are any
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`references to demonstratives, exhibits, parts of the record, please state
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`that orally so that we can be sure that everyone can access the
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`information on the same page.
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`I would like to have the parties introduce themselves. So let
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`me begin first with the patent owner, ask you to approach the podium
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`and introduce your team.
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`MR. ENGELLENNER: Good afternoon, Your Honors.
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`Tom Engellenner from Pepper Hamilton representing patent owner,
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`Black Hills Media. Also with me is my co-counsel, George Haight
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`and co-counsel, Andrew Schultz, and also a representative of the
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`patent owner, Hugh Svendsen.
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`JUDGE McNAMARA: Thanks very much. And for the
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`petitioner?
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`MS. REISTER: Good afternoon, Your Honors. This is
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`Andrea Reister on behalf of the Samsung petitioners representing all
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`of the petitioners in the joined proceeding. With me today and who
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`will be giving the presentation on behalf of the petitioners is my
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`co-counsel, Mr. Greg Discher. We also have with us today another
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`lawyer from Covington, Mr. Sawyer as well as representative of
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`Samsung, Mr. Rett Snotherly.
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`JUDGE McNAMARA: Thank you. Each party will have
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`40 minutes of total argument time. Petitioner will go first, present its
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`case with regard to the challenged claims. The patent owner then will
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`argue its opposition to petitioner's case, and petitioner then may use
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`any time it reserved to rebut the patent owner's opposition. There are
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`no other issues or motions to be heard today. So is everybody ready
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`to proceed?
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`MS. REISTER: Yes, we are, Your Honor.
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`JUDGE McNAMARA: Let's start with the petitioner, is
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`there some amount of time you would like for me to reserve for you?
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`MR. DISCHER: Fifteen minutes, Your Honor.
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`JUDGE McNAMARA: Okay.
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`MR. DISCHER: Good afternoon, Your Honors. I am
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`Gregory Discher representing Samsung Electronics, petitioner, here to
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`talk about the '686 patent. The challenged claims in the '686 patent
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`are broadly stated and we believe, as a result are unpatentable.
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`The '686 patent and Reilly both disclose information
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`retrieval systems that enable a user to view information of interest that
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`is obtained from a remote database and stored locally.
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`The '686 patent and Reilly solved the same problem, that is
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`enabling users to obtain specific information on a predefined subject
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`such as news or sports, and the '686 patent and Reilly solved the
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`problem in the same way. In the '686 patent, it provides for the
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`creation of search rules to obtain specific information for a predefined
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`subject. That specific information is retrieved from a network
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`database and stored in a local database.
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`Reilly also provides for the creation of search rules to obtain
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`specific information such as stories about the 49ers or Rams for a
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`predefined subject such as a sport like football.
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`The stories about the 49ers or Rams are retrieved from a
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`network database and stored in a local database. There's two
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`fundamental disputes in this case with regard to the independent
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`claims. The first dispute is whether information retrieval carried out
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`in Reilly is a search. The second dispute is whether the information
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`retrieved in Reilly is only on a predefined subject. And I'll address
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`these two issues in turn.
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`With regard to the term "search," BHM argues that Reilly
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`does not disclose a search agent because the word "search" does not
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`appear in Reilly. As we point out in our reply, it's black letter law that
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`a prior art reference need not disclose the exact terminology used in
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`the claim. What matters is what Reilly discloses when considered
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`together with the knowledge of one of ordinary skill in the pertinent
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`art.
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`BHM's own definition of search which appears, one
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`definition on slide 11 of its own demonstratives reads as follows: To
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`seek specific data within a file or structure. The functionality of
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`Reilly satisfies this definition. Reilly presents a user with a menu for
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`subjects such as sports, as explained in column 9 of Reilly. Reilly
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`allows the user to select one or more particular sports and type in
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`words such as 49ers or Rams which corresponds to the specific data in
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`BHM's definition.
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`This request for specific data generates search rules and
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`these search rules are used to retrieve news items that include the
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`word 49ers or Rams from a database information server 104 which
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`corresponds to the file or structure in BHM's definition. Those news
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`items retrieved from Reilly's information server are stored in the
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`information database of Reilly's local area network server 108.
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`Our declarant, Dr. Almeroth, has also testified that Reilly's
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`LAN server 108 can retrieve specific information such as only news
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`items that include either the words 49ers or Rams from information
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`server 104. BHM has not explained why typing in the words 49ers or
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`Rams would not be seeking specific data within the database of
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`Reilly's information server. Dr. Almeroth has also testified that with a
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`word-specific capability Reilly discloses a more granular search
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`capability than the '686 patent which does not disclose the ability to
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`search for particular words. So seeking specific data within a file or
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`structure as the criteria for a search, Reilly discloses the ability to seek
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`data with more specificity than what is disclosed in the '686 patent.
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`BHM also contends that filtering and searching are mutually
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`exclusive. BHM alleges that filtering, as disclosed in Reilly, is
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`distinct from the '686 patent's notion of searching utilizing a search
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`agent, search rules or search criteria. But again, BHM does not
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`explain why the retrieval of news items with words such as 49ers or
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`Rams is not a search under BHM's own definition.
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`BHM also argues that filtering, as disclosed by Reilly, is
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`distinct from the '686 patent's notion of searching because Reilly
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`merely screens out unwanted content. Well, Reilly does not merely
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`screen out unwanted content. Reilly instead allows users to specify
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`desired content such as news stories about football, just like the '686
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`patent. And further, screening out unwanted content is a form of
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`searching. Dr. Almeroth has testified that search engines allow a user
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`to request, for example, articles about burgers but not cheeseburgers.
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`JUDGE McNAMARA: Counsel, how does Reilly decide
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`what subjects it's keeping information on?
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`MR. DISCHER: There is a category manager in Reilly,
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`Your Honor, and that would be shown in Reilly Figure 3. And in our
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`petition, we contend that the category profiler within category 3
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`generates the search rules and the category profile data structure
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`corresponds to the search rules or the search criteria. That category
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`manager, Your Honor, would correspond to elements, for example, as
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`disclosed in Reilly to news, weather and sports. Some of those
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`exemplary categories are, for example, as shown, for example, in
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`Figure 8.
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`JUDGE McNAMARA: Is that applicable to -- is that for a
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`specific user? In other words, I'm looking at the first limitation of
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`claim 1 which talks about the rule generation unit which defines for
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`each of the plurality of local users a set of search rules applicable to a
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`defined subject. So is Reilly a more general search device that just
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`puts things in, and this is where the question between searching and
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`filtering comes in, then it just filters out for individuals or does Reilly
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`have rules that go for the each -- for each of the plurality of local
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`users?
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`MR. DISCHER: Yes, Your Honor. Reilly does have search
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`capability for each of the local users. And Figure 5 of Reilly, for
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`example, would allow a user to interact with Reilly's system and select
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`within a category such as sports and more detailed information as
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`shown in the left-hand column. And then on the right-hand column
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`where I mentioned the word 49ers and Rams, that was referred to as
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`an include-only.
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`So when you type in the words 49ers or Rams, Reilly is very
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`clear. For example, if you look at column 9 at, for example, lines 54
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`through 59, it says, for instance, if the subscriber types in the words
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`49ers, Rams, in the box for the include-only filter for the football
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`news subcategory, only news items using either of those words will be
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`shown to the subscriber.
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`JUDGE McNAMARA: Will be shown to the subscriber and
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`I think that's mainly the question here, the difference between filtering
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`and searching. In other words, is Reilly going to go out and search
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`information on the NFL and all the different teams and then decide
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`what to display to a user by filtering out the stuff that the user is not
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`interested in? And is that different from a search or is that the same as
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`a search? That's what I'm trying to find out.
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`MR. DISCHER: Yes, Your Honor. Thank you. I think
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`there may be two facets to that question. And with regard to the term
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`"search agent" which is what we are talking about in the claim
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`language, Reilly's search agent does allow the user, as shown in
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`Figure 5, to include. The operative language in Figure 5 is include
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`only. Not exclude there. So it's including stories with the words
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`49ers and Rams.
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`My second point was that once that information is returned
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`to the LAN server, BHM also makes an argument that there's filtering
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`done at that point, but I believe that is a separate issue than what is
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`required by the claim language with respect to the search agent. And
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`that's the part I addressed in the first portion of my question. Typing
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`in the words 49ers and Rams, as shown in Figure 5 of Reilly, clearly
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`says include those terms. So that would be looking for stories that
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`include those terms as shown in Figure 5 of Reilly.
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`way?
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`JUDGE McNAMARA: Okay.
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`JUDGE McKONE: I'm sorry, can you hear me okay, by the
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`MR. DISCHER: Yes, Your Honor.
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`JUDGE McKONE: Which module is actually performing
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`this filtering, then, that you have shown in Figure 5? If we go back to,
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`I guess, Figures 1 through 3, which of the modules in Figures 1
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`through 3 is actually performing this filter?
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`MR. DISCHER: We've identified the -- in Reilly's Figure 3,
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`the category profile data structure corresponds to the search rules and
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`the search criteria as set forth in the claim language. Claim 1 recites
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`search rules. Independent claim 20 recites search criteria and
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`independent claim 29 recites the term search rules also.
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`So in the petition, we've identified again category profile
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`data structure 202B in Figure 3 as what results in the search criteria or
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`search rules. And Figure 5 of Reilly would, for example, correspond
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`those rules or criteria.
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`JUDGE McKONE: So it's your view that what's being
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`shown in Reilly is that the category profiler sitting on, I guess we'll
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`say on the server side, is filtering out information that it sends to the
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`LAN server, I guess. So the LAN server only receives information
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`that corresponds to this filtering? Is that your theory?
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`MR. DISCHER: The LAN server, yes, Your Honor, will
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`only receive information that is requested by the users as it results in
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`the data structure as shown in Figure 3, element 202. And I would
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`point Your Honor to column 15 of Reilly where there is a first
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`embodiment of the LAN, and if you look at approximately line 22, it
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`says in that embodiment the client or in this case, the LAN server is
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`the client, downloads all news items into the local database. So that's
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`like one embodiment within the LAN server. It can't download
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`everything in total, but that's not the embodiment we are focusing on
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`We are focusing in the second preferred embodiment of the
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`LAN client server which begins at approximately line 23 in the
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`second preferred embodiment. And that generates the group profile
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`based upon the news category and subcategory preferences that I
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`mentioned with respect to Figure 5. So that is the particular
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`information that I mentioned in column 9 that will be returned for
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`each particular user as they have requested.
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`JUDGE McKONE: Okay. Thank you.
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`MR. DISCHER: So Dr. Almeroth has testified that search
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`engines allow a user to request articles about burgers, not
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`cheeseburgers. Though searches are accomplished using a Boolean,
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`“not” operator, which is indisputably a part of the Lycos search engine
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`which appears in a definition cited by Black Hills' own declarant,
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`Mr. Putnam, for the very same term, search engine. That is why
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`Dr. Almeroth testified that a person of ordinary skill in the art would
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`understand that filtering is simply a form of searching.
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`JUDGE McNAMARA: Excuse me. Will Reilly -- does
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`Reilly disclose being able to search something that it wouldn't search
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`by default? So for example, I'm a Ravens fan and maybe I want to
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`know about Joe Flacco's college career and why he left Pittsburgh to
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`go to Delaware. They have all this database on the NFL. Maybe they
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`keep it down to some level of granularity, but maybe not that level of
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`granularity, but that's what I want to put in my search profile. So I'm
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`a user. Will Reilly -- how will Reilly get that? Because it won't have
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`that stuff in a database to filter out. Will it actually go out and find it?
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`MR. DISCHER: Yes, Your Honor. That is what Figure 5
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`indicates. And I would also point you to why this capability occurs.
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`For a user to search for specific terms is because in the LAN
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`embodiment, this is shown in Figure 2 of Reilly. So Figure 2, this
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`would normally correspond to, for example, a client computer shown
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`in Figure 1102, but Reilly states that in a LAN embodiment all this
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`functionality in secondary memory 174 about, I mentioned before the
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`category manager 202, that's stored on the LAN server. So that
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`Category 202, again, corresponds to Figure 3 and the category profiler
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`202A corresponds to Figure 5.
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`So what the user enters in to Figure 5 is stored on the LAN
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`server in the LAN embodiment we are talking about. And again, if
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`you have the capability to type in particular words such as 49ers or
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`Rams, Reilly very clearly indicates, as I mentioned, at column 9 that
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`or “Rams” back. And that's include-only. I think that's an important
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`thing to know, that there's two types, include-only in Figure 5 and
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`exclude-only in Figure 5.
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`So in Figure 5 it's particularly looking for stories that
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`include these words. It has to be looking for these words.
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`JUDGE McNAMARA: Okay. Thank you.
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`MR. DISCHER: BHM also offers an ordinary and
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`12 of its response. We think Reilly's search agent satisfies that
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`definition also for substantially the same reasons I just discussed with
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`respect to BHM's definition of the term search.
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`I would like to turn now to the second topic on whether
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`information is retrieved and Reilly is only on a predefined subject.
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`We have two grounds of unpatentability in this trial and in the
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`petition. Ground 1 is based on the combination of Reilly and the
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`technology and learning article. And in that ground of
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`unpatentability, the petition relies on news as corresponding to the
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`predefined subject.
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`So in the Reilly LAN server embodiment that I just pointed
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`out in column 15 of Reilly, every news story in the information server
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`104 is in the predefined subject of news. BHM has not contested that.
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`BHM did not address that in its preliminary response and BHM did
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`not dispute this in its response after institution of trial. So this issue is
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`undisputed with respect to ground 1 of unpatentability. In fact, Mr. --
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`JUDGE McKONE: I'm sorry, what issue is undisputed?
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`Are you saying the construction of a predefined subject is undisputed?
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`MR. DISCHER: Yes, Your Honor. We have stated that
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`news is the predefined subject for ground 1 in the petition.
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`JUDGE McKONE: Okay. Why not -- why wouldn't sports
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`news, for example, be a predefined subject or weather news be a
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`predefined subject? Why should we pick news as the predefined
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`subject? Or how do we know?
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`MR. DISCHER: Sure, Your Honor. Thank you for that
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`question. So in Figure 1 of Reilly, Figure 1 shows on the right-hand
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`side the AP news feed, the Dow news feed, the sports ticker feed, and
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`in the petition, what we rely on for that is in column 4 at
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`approximately lines -- in the paragraph that begins “information
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`server,” in that paragraph. And that paragraph indicates that all those
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`feeds that I just mentioned in Figure 1 are newswire interfaces. This
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`newswire interface is receiving news feeds for information
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`transmission through AP news feed, Dow news feed, various sports
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`news feeds, et cetera. So that's all news going in there.
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`And if you look at Figure 1 of Reilly, there's no other input
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`into the system for historical stories or any other subjects. So what
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`Reilly is receiving is within the predefined subject of news. You may
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`think of it, for example, as a newspaper. Newspaper is all news, but it
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`could have news on sports, it could have news on weather, it could
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`have news on a multiplicity of different things, but it's all news.
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`JUDGE McKONE: What if Figure 5, looks like there's
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`several different items of news, sports scorecard, baseball news,
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`football news, hockey news. Why isn't Figure 5 showing a selection
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`of three separate predefined subjects?
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`MR. DISCHER: So for ground 1, Your Honor, we did rely
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`on the predefined subject as news. So even though Reilly has
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`different categories, as I stated, they have categories of sports,
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`categories of news, categories of weather. It's all at the predefined
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`subject in ground 1. So --
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`JUDGE McKONE: You may have relied on it, but why
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`should we rely on that as the correct definition of predefined subject?
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`JUDGE IPPOLITO: Counsel, a follow-up to that, it would
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`be very helpful if you could point to something either in the '686
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`patent or what else you are relying on other than necessarily Reilly for
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`your claim construction of predefined subject.
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`MR. DISCHER: We set that forth in the petition, Your
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`Honor, and Mr. Putnam, in paragraph 41 of his declaration --
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`JUDGE McKONE: I'm sorry, where in the petition?
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`MR. DISCHER: In the petition we can go to the claim
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`chart. For example, at page 29, we clearly indicate there that news
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`corresponds to the claim predefined subject. And the passage we cite
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`on the following page 30 corresponds to the passage I just identified
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`to you, column 4 at approximately lines 23 through 38. So that's
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`clearly the passage we relied upon for the predefined subject being
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`news. All those news feeds pertain to news and thus would be within
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`the predefined subject of news.
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`JUDGE McKONE: Okay. Is there any support -- if your
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`construction that predefined subject is news, have you supported that
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`with any of the traditional things that we would look to for
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`construction such as ordinary meaning or citations to the specification,
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`expert testimony construing the term "predefined subject"?
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`MR. DISCHER: Mr. -- we relied on Mr. Putnam himself,
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`BHM's only declarant, in paragraph 41 has stated and admitted this.
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`So we look at Exhibit 2013 --
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`JUDGE McNAMARA: That's paragraph 41 of the Putnam
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`declaration, right?
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`MR. DISCHER: Yes, Your Honor.
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`JUDGE McKONE: That wasn't cited to, though, in your
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`petition, correct?
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`MR. DISCHER: Yes, Your Honor. That would be going
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`more to my point that the patent owner didn't dispute that. So we are
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`relying fundamentally on the disclosure of Reilly itself in the context
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`of what I just mentioned, that the only input into that system is
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`directed to different aspects of news, AP, sports news, but that's all
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`that's indicated that is provided as input into the Reilly system.
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`There's no other inputs that would indicate any other subject.
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`And in the '686 patent, if you look, for example, column 3,
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`lines 40 through 45 approximately, starting at 43, various topics such
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`as news, cooking, weather and sports.
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`JUDGE McKONE: That's topics. Is topics the same as
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`predefined subjects or is topics the same as rules? How do we know?
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`MR. DISCHER: Again, I would refer to paragraph 41 of
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`Exhibit 1013 -- 2013, I'm sorry, Your Honor. The search agents
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`described in the '686 patent are designed to be specific to a predefined
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`subject area such as news, cooking, weather or sports. So there could
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`only be one search agent that is directed to the predefined subject of
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`news.
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`JUDGE McKONE: What about sports news? You don't
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`have to answer that. That was a half joke. Don't worry about it.
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`Patent 6,108,686
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`JUDGE McNAMARA: That's just an alert that you have
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`got 15 minutes left.
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`MR. DISCHER: I'll reserve the balance of my time for
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`rebuttal. Thank you, Your Honors.
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`MR. ENGELLENNER: With the Board's permission, my
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`co-counsel, George Haight, will present the patent owner's oral
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`arguments.
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`JUDGE McNAMARA: All right. Just a reminder, as you
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`are using demonstratives, point out which one it is.
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`MR. HAIGHT: Yes, thank you, Your Honor. Thank you,
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`and good afternoon, Your Honors. My name is George Haight and on
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`behalf of patent owner, Black Hills Media, I would like to present a
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`few topics this afternoon to help assist the Board in its analysis of the
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`petition and the cited prior art.
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`It is patent owner's position that the cited prior art not only
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`operates in fundamentally different ways but also fails to disclose
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`each and every element of the challenged claims. The prior art of
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`record discloses a system with fundamental differences in the way that
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`information is accessed on and over a network.
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`On the one hand, we have Williams and the '686 patent. The
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`Williams patent uses a search-based technology in which information
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`sought by a user or a client is actively retrieved from remote servers.
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`The Reilly patent, on the other hand, does not disclose search-based
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`methods. Rather, information is gathered, organized and transmitted
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`Patent 6,108,686
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`to the user's machine without a specific request or action by the user
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`or a client.
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`JUDGE McNAMARA: Doesn't the user have some sort of a
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`profile that he puts in?
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`MR. HAIGHT: They do, Your Honor. That profile is set up
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`well in advance and is stored on either the client or the LAN server of
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`the embodiment that is alleged to anticipate the claims.
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`The information that is gathered, however, is gathered by the
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`administrator at the server end, in the information server. When we
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`get to the explanation of Reilly, I will show you where that exists.
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`JUDGE McNAMARA: Is it your position that when the
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`user puts in his profile, that's not a request for specific types of data?
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`MR. HAIGHT: That's correct. As I will explain, it is patent
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`owner's position that that is a filtering mechanism that sets up a
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`filtering criteria as to what is actually presented to the user when that
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`screen saver of the Reilly system comes into display.
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`As I mentioned, Reilly further restricts the information seen
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`by the user by implementing the filtering mechanism of unwanted
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`information according to that previously set up user profile.
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`As I will explain, Reilly discloses what is known in the art
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`as a push-based technology and gained some notoriety around the
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`time the Reilly patent was filed. It is patent owner's position that the
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`petition should fail because petitioner, through its petition and reply to
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`patent owner's opposition, has mischaracterized and conflated the
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`Patent 6,108,686
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`teachings of both the Reilly patent and the Williams patent as well as
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`the petitions of patent owner and its expert.
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`A clear and unambiguous reading of the references makes it
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`readily apparent that the claims of the Williams patent recite
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`fundamentally different ways of accessing information over a network
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`from those disclosed in Reilly.
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`If we could turn to slide 2, please, here we see the cover of
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`the Williams, the '686 patent. Petitioner has already given a slight
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`overview of the '686 patent, but there are a few additional points that
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`are relevant to how this invention came to be that I would like to
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`discuss.
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`If we could jump to slide 5, in the background of the
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`invention, Williams has described his goal of trying to find an
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`improved way of accessing information over remote servers. He
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`acknowledges that there are traditional systems that were slow,
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`required expensive high-speed connections and the information that
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`was received from those remote servers was poorly organized.
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`What Williams found was that those traditional tools
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`favored presentation over organization. Williams explicitly points out
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`that one of those types of systems that favored presentation over
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`organization was a push-based technology which, according to
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`Williams, addressed some of the speed issues but did not address the
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`issue of organization.
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`According to Williams, with push technology, a remote
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`server generally gathers information on various topics from remote
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`Patent 6,108,686
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`databases, packages the information into subject groupings called
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`channels and automatically downloads selected channels to the user's
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`computer. The user does not need to search for or request the
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`information. And as we will see, this is exactly the type of system
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`that is disclosed in the Reilly patent.
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`On the other hand, Williams invented a system using a
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`search-based technology. A search agent is used to retrieve a single
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`predefined subject according to a set of search rules or search criteria.
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`That information retrieved from the database is then stored in a local
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`database in a particular structure that is the same or similar to the
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`structure as it was stored on the remote server. One of the salient
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`differences between the Williams claims and that of push-based
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`systems, as described in the background of Williams, is the use of an
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`affirmative retrieval of information via a search agent. The search
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`agent searches either by manual user input or by executing a search
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`automatically by a client. In all cases a search is executed.
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`If we could go to slide 4, please, here we see Figure 4 of the
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`Williams patent which depicts the SIRViS systems as Williams has
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`chosen to call it. SIRViS stands for a subject-specific information
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`retrieval and viewing system. According to that system, a search
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`agent is used to locate and retrieve information from a remote content
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`database. It's a little blurry, but that would be the bottom box labeled
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`number 34.
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`Cases IPR2014-00717 and IPR2015-00335
`Patent 6,108,686
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`That information searched for is defined by a set of rules or
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`criteria shown on the left-hand side under search rules and pertains to
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`a single predefined subject. The search and retrieval --
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`JUDGE McKONE: Are ther
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