Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`SERVICENOW, INC.,
`
`Petitioner,
`
`v.
`
`HEWLETT-PACKARD COMPANY,
`
`Patent Owner.
`____________________________________________
`
`Case No. IPR2015-00523
`
`U.S. Patent No. 6,321,229
`____________________________________________
`
`DECLARATION OF PAUL ONNEN REGARDING
`CLAIMS 8-10, 13, 15, AND 17-20 OF U.S. PATENT NO. 6,321,229
`
`Exhibit 2003
`ServiceNow v. HP
`IPR2015-00523
`
`

`
`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
`
`
`
`
`TABLE OF CONTENTS
`
`INTRODUCTION ......................................................................................... 3(cid:3)
`I.(cid:3)
`II.(cid:3) QUALIFICATIONS ...................................................................................... 3(cid:3)
`III.(cid:3) MATERIALS CONSIDERED ..................................................................... 5(cid:3)
`IV.(cid:3) UNDERSTANDING OF THE LAW ........................................................... 6(cid:3)
`A.(cid:3) Obviousness ........................................................................................... 6(cid:3)
`B.(cid:3)
`Claim Construction ............................................................................... 8(cid:3)
`PERSON OF ORDINARY SKILL IN THE ART ...................................... 9(cid:3)
`V.(cid:3)
`INSTITUTED GROUNDS .......................................................................... 11(cid:3)
`VI.(cid:3)
`VII.(cid:3) BRIEF DESCRIPTION OF THE TECHNOLOGY ................................ 11(cid:3)
`A.(cid:3) Databases ............................................................................................. 11(cid:3)
`B.(cid:3) Web Pages ........................................................................................... 13(cid:3)
`VIII.(cid:3) THE INVENTION OF THE ’229 PATENT ............................................. 15(cid:3)
`IX.(cid:3) OVERVIEW OF THE CITED PRIOR ART REFERENCES ............... 26(cid:3)
`A.(cid:3)
`Jones .................................................................................................... 26(cid:3)
`B.(cid:3)
`Fox ....................................................................................................... 30(cid:3)
`C.(cid:3)
`Forta ..................................................................................................... 32(cid:3)
`D.(cid:3) Williams .............................................................................................. 32(cid:3)
`X.(cid:3) UNDER THE BOARD’S CLAIM CONSTRUCTIONS, ALL THE
`CHALLENGED ’229 PATENT CLAIMS ARE NOT OBVIOUS
`BECAUSE CLAIM LIMITATIONS ARE NOT TAUGHT BY
`THE PRIOR ART........................................................................................ 33(cid:3)
`A.(cid:3)
`The cited prior art does not disclose the “category of
`information” limitation required by each challenged claim................ 33(cid:3)
`1.(cid:3)
`All challenged claims require that a given derived
`containers corresponds with “a category of information
`stored in said information repository.” ..................................... 34(cid:3)
`
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`2.(cid:3)
`
`2.(cid:3)
`
`B.(cid:3)
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`Jones and Fox do not disclose a derived container that
`corresponds with “a given category of information stored
`in said information repository.” ................................................ 36(cid:3)
`Jones and Fox do not disclose that contents of derived
`containers be “information extracted from said information
`repository” as required by claims 9-10 and 19-20 .............................. 41(cid:3)
`1.(cid:3)
`Claims 9-10 and 19-20 require that contents of derived
`containers be “information extracted from said
`information repository.” ............................................................ 42(cid:3)
`Jones and Fox do not disclose contents of derived
`containers to be “information extracted from said
`information repository.” ............................................................ 45(cid:3)
`XI.(cid:3) CHALLENGED CLAIMS 15 AND 17 ARE NOT OBVIOUS
`BECAUSE A PERSON OF ORDINARY SKILL IN THE ART
`WOULD NOT COMBINE JONES WITH FORTA ................................ 52(cid:3)
`XII.(cid:3) UNDER THE PROPER CLAIM CONSTRUCTIONS, ALL THE
`CHALLENGED ’229 PATENT CLAIMS ARE NOT OBVIOUS ......... 58(cid:3)
`A.(cid:3)
`The claim term “derived container” should be construed as “a
`data structure capable of executing a query based on an attribute
`from one or more corresponding container definition nodes” (all
`challenged claims). .............................................................................. 59(cid:3)
`None of the cited references alone or in combination discloses
`or suggests a “derived container” (all claims)..................................... 64(cid:3)
`XIII.(cid:3) CONCLUSION ............................................................................................ 67(cid:3)
`XIV.(cid:3) AVAILABILITY FOR CROSS-EXAMINATION .................................. 68(cid:3)
`XV.(cid:3) RIGHT TO SUPPLEMENT ....................................................................... 68(cid:3)
`
`
`B.(cid:3)
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
`
`
`I, Paul Onnen, declare as follows:
`
`I.
`
`INTRODUCTION
`
`1.
`
`I have been retained by Hewlett-Packard Company (“HP” or “Patent
`
`Owner”) to provide expert opinions in the matter referenced herein. This
`
`declaration sets forth my opinions regarding the validity of claims 8-10, 13, 15,
`
`and 17-20 of U.S. Patent No. 6,321,229 (“’229 patent”) (Ex. 1001).
`
`II. QUALIFICATIONS
`
`2.
`
`Education: In 1984, I received a Bachelor of Arts degree with honors
`
`in Mathematics and Physics, with a Concentration in Computer Science from St.
`
`Olaf College in Northfield, MN. In 1986, I received a Master of Science degree in
`
`Computer Science from the University of Wisconsin-Madison. My emphasis in
`
`my graduate work was in fault-tolerant distributed database systems.
`
`3.
`
`Career history: Since 1986, I have held positions of increasing
`
`responsibility in software development and system architecture, starting as a
`
`Member of Technical Staff at AT&T Information Systems Laboratories, and
`
`culminating almost 20 years later as Executive Vice President/Chief Technology
`
`Officer for Expedia, Inc., where I was responsible for all technology at all Expedia
`
`companies, including Expedia.com, HotWire, Hotels.com, TripAdvisor, and eLong
`
`(the second largest online travel agency in China). I have also held Chief
`
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`Technology Officer positions at Nordstrom.com, WebMD, and several smaller
`
`startups. More recently, I led the infrastructure engineering teams in EMEA
`
`(Europe, Middle East, and Asia) for Google as Director of Infrastructure
`
`Engineering. For the past six years since leaving Google I have been an
`
`independent technology consultant. In 2009 I co-founded, invested, and served as
`
`CTO and CISO at The Federal Tax Authority, a Certified Service Provider for
`
`sales tax calculation and remittance for e-commerce transaction. I have focused
`
`exclusively on Internet related technologies, including IT Operations, data centers,
`
`networking, and security for the past 15 years.
`
`4.
`
`As an independent technology consultant for the past six years, I have
`
`assisted both large and small companies with technology strategy, and I have
`
`served as an Interim CTO on several occasions.
`
`5.
`
`I have extensive experience with both unstructured and structured data
`
`stored both in file systems and databases, and with the creation of dynamic web
`
`pages to display that data.
`
`6.
`
`For example, as EVP Technology for Expedia, I was responsible for
`
`all technology at all Expedia companies, and implemented a new platform for the
`
`Expedia point-of-sale system. The Expedia platform consists of entirely custom-
`
`built software, with the exception of a standard Microsoft SQL Server database.
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`The custom-built software included a purpose-built web server, dynamic web page
`
`creation, and transactional business logic.
`
`7.
`
`Additionally, while serving as Director of Engineering at Google
`
`Switzerland, I managed Google’s infrastructure engineering team in EMEA. This
`
`team supported the rest of the engineering teams of Google, including teams for
`
`web search, crawling, Google Docs, Gmail, etc. One of my teams was responsible
`
`for all structured relational database work at the company (as compared to
`
`unstructured data that is used in Google’s Big Table and Map/Reduce platforms).
`
`8.
`
`9.
`
`A copy of my latest curriculum vitae (CV) is attached as Exhibit A.
`
`I am being compensated at my normal consulting rate of $300/hour
`
`for my time. My compensation is not dependent on and in no way affects the
`
`substance of my statements in this declaration.
`
`10.
`
`I have no financial interest in HP. I similarly have no financial
`
`interest in the ’229 patent, and have had no contact with the named inventors of the
`
`’229 patent.
`
`III. MATERIALS CONSIDERED
`
`11.
`
`I have reviewed the specification, claims, and file history of the ’229
`
`patent. I understand that this inter partes review is ongoing and other documents
`
`have been filed.
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`I have also reviewed the following documents:
`
`12.
`
`(cid:120) Petition for Inter Partes Review of U.S. Patent No. 6,321,229 (“Pet.”)
`
`(Paper 1), including all exhibits cited therein;
`
`(cid:120) Decision: Institution of Inter Partes Review (“Decision on Institution)
`
`(Paper 13), including all exhibits cited therein;
`
`(cid:120) Patents that issued from the co-pending applications that were filed
`
`with the ’229 patents application: U.S. Patent Nos. 6,314,291,
`
`6,343,291, and 6,345,277, and their respective file histories;
`
`(cid:120) All documents cited in this declaration.
`
`13.
`
`14.
`
`I have read and understood each of the above documents.
`
`I have considered certain issues from the perspective of a person of
`
`ordinary skill in the art at the time the application for the ’229 patent was filed.
`
`IV. UNDERSTANDING OF THE LAW
`
`15.
`
`I am not an attorney. For the purposes of this declaration, I have been
`
`informed about certain aspects of the law that are relevant to my opinions. My
`
`understanding of the law is as follows:
`
`A. Obviousness
`
`16.
`
`I have been informed that a patent claim is considered obvious if the
`
`subject matter as a whole would have been obvious to one of ordinary skill in the
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`art at the time the invention was made. The obviousness analysis involves several
`
`factual inquiries: (i) the scope and content of the prior art; (ii) the differences
`
`between the prior art and the claimed invention; (iii) the level of ordinary skill in
`
`the art at the time of the invention; and (iv) the existence of objective indicia of
`
`non-obviousness (“secondary considerations”), such as unexpected results, long
`
`felt but unresolved need, failure of others, and industry skepticism followed by
`
`acceptance.
`
`17.
`
`In connection with obviousness, I have been informed that there
`
`should be some reason that would have led one of ordinary skill in the art to
`
`combine or modify the relevant prior-art teachings to obtain the claimed invention.
`
`Furthermore, there must be a reasonable expectation of success that one of
`
`ordinary skill in the art would have obtained the claimed invention based on the
`
`teachings of the prior art. An invention is more likely to be deemed non-obvious
`
`to one of ordinary skill in the art if it yields unexpected results or if the prior art
`
`teaches away from the claimed invention.
`
`18.
`
`I understand that in considering obviousness, it is important not to
`
`determine obviousness using the benefit of hindsight derived from the patent being
`
`considered.
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`In connection with objective indicia of non-obviousness, I have been
`
`19.
`
`informed that there must be a nexus between the claimed invention and the
`
`evidence of objective indicia.
`
`B. Claim Construction
`
`20.
`
`I understand that before a patentability analysis can be conducted, the
`
`claims of a patent must be interpreted. I have been informed and understand that a
`
`claim in inter partes review is given the broadest reasonable construction in light
`
`of the specification.
`
`21.
`
`I understand that in the Decision on Institution the Patent and Trial
`
`and Appeal Board (the “Board”) initially construed the following claim terms:
`
`Claim Term
`
`Initial Construction
`
`“information repository”
`
`“[A] collection of information”
`
`“information model”
`
`“[I]nformation that defines a hierarchical
`organization for an information repository”
`
`“selection criteria
`attribute”
`
`“pointer”
`
`“container definition
`node”
`
`“derived container”
`
`“[A]n attribute that determines information that can
`be extracted as a derived container”
`
`“[A] piece of information that points to or references
`other information”
`
`“a container comprising attributes for created a
`derived container”
`
`“a container derived at least in part from a container
`definition node”
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`“an element in the directory tree that can contain
`other containers, leaf objects, or both”
`
`“container”
`
`
`
`Decision on Institution at 4-7 (Paper 13).
`
`22.
`
`I have applied the Board’s construction of these terms in this
`
`declaration.
`
`23. With respect to the construction of “derived container,” in my
`
`opinion, as explained below in section XII, the Board should reconsider its
`
`construction of this term. That said, I have adopted the above construction of
`
`“derived container” for sections of this declaration through section XI; my
`
`arguments in those sections would be the same under either the Board’s
`
`construction or my proposed construction. I have applied what I believe to be the
`
`proper definition of the term “derived container” in section XII of this declaration.
`
`V.
`
`PERSON OF ORDINARY SKILL IN THE ART
`
`24.
`
`I have been advised that “a person of ordinary skill in the relevant
`
`field” is a hypothetical person to whom one could assign a routine task with
`
`reasonable confidence that the task would be successfully carried out.
`
`25. The ’229 patent application was filed in the USPTO on February 26,
`
`1999, and does not claim priority to any earlier filing date, either in the U.S. or any
`
`foreign patent offices. Accordingly, I understand that the patent’s claims must be
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`construed from the perspective of a person of ordinary skill in the art as of
`
`February 26, 1999.
`
`26. Based on my understanding of the ’229 patent and my knowledge and
`
`experience, a person of ordinary skill in the art would have a Bachelor’s degree in
`
`Computer Science, Information Technology, Management Information Systems, or
`
`related discipline, or equivalent course work, and either (1) approximately two
`
`years of relevant industry experience or (2) an advanced degree, such as a Master’s
`
`degree or Ph.D., in Computer Science, Information Technology, Management
`
`Information Systems, or related discipline. The Bachelor’s degree or equivalent
`
`course work in the mentioned disciplines provides the breadth required from such a
`
`person; and the two alternative additional requirements provide depth in the
`
`technology areas of the patents.
`
`27. As reflected in my qualifications set forth above, as of 1999, I would
`
`have met or exceeded that level of experience. I have also considered the
`
`definition of a person of ordinary skill in the art as set forth in the declaration of
`
`Mr. Klausner. Klausner (Ex. 1002) at ¶ 10. Under that definition, my opinions are
`
`the same as set forth in this declaration.
`
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`

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`VI.
`
`INSTITUTED GROUNDS
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`28.
`
`I understand that inter partes review has been instituted by the Board
`
`on the following grounds presented in the petition filed by ServiceNow, Inc.
`
`(“ServiceNow” or “Petitioner”) (Paper 1):
`
`(cid:120) Ground 1: Claims 8-10 and 13 as obvious over the combination of U.S.
`
`Patent No. 6,199,098 to Jones (“Jones”) (Ex. 1003) and David Fox et al.,
`
`Web Publisher’s Construction Kit with HTML 3.2 (1996) (“Fox”) (Ex.
`
`1004)
`
`(cid:120) Ground 2: Claims 18-20 as obvious over the combination of Jones, Fox,
`
`and U.S. Patent No. 6,151,630 to Williams (“Williams”) (Ex. 1006)
`
`(cid:120) Ground 3: Claims 15 and 17 as obvious over the combination of Jones,
`
`Fox, and Forta, The Cold Fusion Web Database Construction Kit (1997)
`
`(“Forta”) (Ex. 1005)
`
`VII. BRIEF DESCRIPTION OF THE TECHNOLOGY
`
`A. Databases
`
`29. A database is a program that is able to store large amounts of data,
`
`and which also enables the ability to efficiently access that data. Databases store
`
`data in “tables,” which contain multiple columns (sometimes called “fields”),
`
`where each column is a set of values of a particular type, one for each row of data
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`in the table. An example of a typical database table is presented in Figure 7 of the
`
`’229 patent. As shown below, this table has six columns: JobNo, Job, Skills,
`
`Grade, Tech/Prof, and IsAvailable.
`
`
`
`’229 Patent, Fig. 7. Databases normally contain multiple tables, where the data in
`
`the tables in linked by one or more columns. For example, there might be an
`
`EMPLOYEE table that has certain fields, such as “Last Name,” “First Name,”
`
`“Address,” and “JobNo.” The JobNo field in the EMPLOYEE table relates to the
`
`JobNo field in Figure 7, which provides additional information about the
`
`employee’s job.
`
`30. Each table contains records/rows, which are the actual data of the
`
`database. As seen in Figure 7, there are 13 records: the first is the row beginning
`
`with JobNo 700, down to the last which begins with JobNo 712.
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`31. Databases are typically accessed using the Structured Query Language
`
`(“SQL”). SQL includes many instructions for creating tables, inserting, updating,
`
`and deleting data, etc. For querying the database, SQL includes the “SELECT”
`
`instruction. The “SELECT” instruction is used to retrieve/extract information from
`
`the database. Klausner (Ex. 1002) at ¶ 124. For example, if the name of the table
`
`in Figure 7 is “JOBS,” the SQL query statement:
`
`
`
`SELECT JobNo, Job, Skills FROM JOBS WHERE IsAvailable = TRUE
`
`
`
`will return a list of the JobNo, Job, and Skills data for all of the records/rows in the
`
`JOBS table in Figure 7 where the value of the “IsAvailable” field is “TRUE.”
`
`SQL statements typically require data to be joined across multiple tables using
`
`complex criteria – these queries are challenging to write such that 1) they produce
`
`the correct data being requested, and 2) they return results in a timely manner. In a
`
`large database, correctly tuning a query can be the difference between receiving
`
`results in seconds as opposed to hours.
`
`B. Web Pages
`
`32. Web pages are information that is sent from a Web Server to a Web
`
`Client, typically a Web Browser (such as Microsoft Internet Explorer). Klausner
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`U.S. Patent No. 6,321,229
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`(Ex. 1002) at ¶ 62. A Web Browser requests a particular web page by specifying a
`
`Uniform Resource Locator (URL). For a web page, the URL typically looks like
`
`“http://servername/pagename.html,” where “servername” is the name of a server
`
`(such as www.espn.com) and “pagename.html” is the name of the particular page
`
`being requested (e.g., BaseballScores.html). URLs can also include a suffix called
`
`the NAME attribute, which takes the form of the hashtag symbol (“#”) followed by
`
`a NAME field (e.g., “#page1”). This is used to navigate the Web Browser to a
`
`specific bookmark in the web page that has a tag for that particular name. If no
`
`such tag exists, then the Web Browser will display the web page from the top.
`
`33. Web pages are written in a language called HyperText Markup
`
`Language (HTML). Klausner (Ex. 1002) at ¶ 85; Jones (Ex. 1003) at 1:48-52.
`
`HTML includes multiple tags that are used to format the data in a web page for
`
`display in the Web Browser. For example, HTML tags can be used to control the
`
`font style, the text size, and the location of text on the page. Other tags are
`
`available, such as tags for including multimedia (such as images or videos) into the
`
`web page.
`
`34. There are two types of web pages that can be served by a web server:
`
`static and dynamic. A static web page is a file that already exists on the web
`
`server, and it is just sent as-is when requested by the Web Browser. The Web
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`Server does not need to do anything to create or modify the file before transmitting
`
`it to the Web Browser; it just finds the requested file and sends it over the network.
`
`While the file can be updated periodically by its creator, it is still static from the
`
`perspective of the web server (which just sends the file as it finds it).
`
`35. Dynamic files are created on-the-fly, when they are requested by users
`
`via Web Browsers. These files change based on information received with the
`
`request from the user, or based on information on the server. In the baseball scores
`
`example, the web page may change based on the current scores of the baseball
`
`games. The web servers need to be able to generate the dynamic pages quickly in
`
`order to handle large numbers of requests from different users and to ensure that
`
`there is not a delay in the client receiving the web page.
`
`
`VIII. THE INVENTION OF THE ’229 PATENT
`
`36. U.S. Patent No. 6,321,229 (the “’229 patent”) is directed to a system
`
`using custom data structures that provides to users flexible access to information
`
`repositories such as databases. The ’229 Patent teaches using specialized data
`
`structures that enable data in information repositories to be efficiently and easily
`
`accessed in different ways to support the needs of different users. ’229 patent (Ex.
`
`1001) at Abstract, 2:40-49. Information repositories (e.g., databases) contain
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`Declaration of Paul Onnen
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`information that can be useful for many different purposes and by different end-
`
`users. For example, a database containing an organization’s job information might
`
`be useful to human resources personnel, job-seekers, and employees, all of whom
`
`need to access different information in the database. But useful databases will
`
`typically become very large; accessing a large database to retrieve information in a
`
`timely manner is a difficult task. Id. at 1:39-44.
`
`37. As discussed in the specification, prior art solutions had two
`
`approaches. The first required writing a custom program for every application that
`
`needed to access the data from the information repository. The second approach
`
`required allowing end-users to search the database directly, which would require
`
`users to understand the query language used to access the database (typically
`
`SQL), understand how to construct proper queries using that language, and
`
`understand how the data is organized in the database. Id. at 1:57-2:49, 8:41-45.
`
`These prior art approaches have several drawbacks, such as requiring a great deal
`
`of expertise, time, and cost. They are also inefficient. Id.
`
`38. For example, the first approach would require a custom program to be
`
`developed for each potential use of the information in an information repository.
`
`Each custom program requires resources to design, develop, and maintain.
`
`Further, databases generally grow over time, expanding to include not only more
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`Declaration of Paul Onnen
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`of the type of data that the database was originally designed to handle, but
`
`additional types of information are often added to the database as well. For
`
`example, what may have been designed to be a human resources database
`
`intending to record basic employee information could grow not only as a result of
`
`new employees being added to the database, but the database may be expanded to
`
`include additional types of information (stored in new columns and/or tables), such
`
`medical insurance information and data on information technology resources (e.g.,
`
`computers, passwords) assigned to the employees. As the amount of information
`
`grows, the number of applications for the data grows, and correspondingly the
`
`number of programs that would be required to support those applications grows.
`
`Further, different databases, for example database containing financial information,
`
`would require new programs from the ones developed for the human resources
`
`database.
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`39. As to the second option, requiring the end-users to write their own
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`SQL database queries is problematic because such queries are complex to write
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`correctly, and users would duplicate efforts, thus wasting time, in creating their
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`own versions of the same queries. Also, allowing end-users to directly access the
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`database can cause both performance and security issues.
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`40. The ’229 patent solves these problems by providing a system for
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`efficiently accessing large information repositories using specialized data
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`structures called “container definition nodes” and “derived containers.” ’229
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`patent (Ex. 1001) at Abstract.
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`41. As described in the specification, a container definition node contains
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`attributes, including a label attribute and a selection criteria attribute, which
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`contains part of the query used to specify the data records to be selected from the
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`database. See, e.g., id. at 8:59-65, 10:24-38, 11:18-19, Figs. 9, 11, 12. In other
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`words, by specifying selection criteria, each container definition node represents a
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`way of organizing the data in the information repository.
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`42. An information model is created by creating different container
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`definition nodes with different selection criteria and arranging them in a hierarchy.
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`Id. at 5:12-16, 7:60-63, 10:19-38, 11:18-19, Figs. 9-12. To take a simple example,
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`if an information repository contained information about the states and capitals in
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`the United States, one user might wish to explore the information by region first
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`and then by state. For that user, the first level of the information model hierarchy
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`would contain container definition nodes for each region, and the second level
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`would contain container definition nodes for each state. By doing this, the user
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`could first drill into a region of the United States, then pick a particular state to
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`explore information about. Another user might instead want to explore the
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`database starting from a particular capitol, then explore information about its state
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`and region. That user would create a different information model where the first
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`level contains container definition nodes for each capitol, and the next level
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`contained information about the state, and so on.
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`43. A derived container connects the container definition nodes to the data
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`in the information repository. A derived container corresponds to a container
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`definition node and extracts and displays the relevant data from the database by
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`executing a query based on the selection criteria from the container definition
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`nodes. Id. at 2:63-67, 4:7-10, 6:61-67, 12:52-59.
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`44. A user exploring the data in the information repository represented by
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`the hierarchy can select a derived container; the system will display the contents of
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`the derived container upon selection. Id. at 4:18-22. If the selected derived
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`container is not at a leaf node of the information hierarchy, the selected derived
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`container’s contents can include child derived containers, which are displayed. Id.
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`at 12:59-65. This is described in the specification in steps 1410, 1412, and 1414 of
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`Figure 14. Id. at 12:44-65, Fig. 14.
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`45. When the user selects a derived container at a leaf node, the system
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`will build a query based on the selection criteria of the derived container’s
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`container definition node (and which may include the criteria for that container
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`definition node’s parents up to the root of the hierarchy). Once the query is
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`created, it is executed to extract information to be displayed. Id. at 3:8-11, 4:18-
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`22, 12:52-59, 12:65-13:14, Fig. 14 (steps 1410, 1418, and 1420). This process
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`ultimately allows an end user to drill-down or navigate through the information
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`repository to view a specific subset of the database data that the user requests.
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`Different hierarchies allow the user to see the data in different ways. Id. at Figs.
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`11, 12.
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`46. Figure 7 of the ’229 patent describes an example using sample records
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`of a database of jobs. ’229 patent (Ex. 1001) at 3:39-40.
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`Id. at Fig. 7. Figure 12 depicts container definition nodes 1200, 1202, 1204, 1206,
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`1208 of an information model for the Technical / Professional jobs based on the
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`database shown in Figure 7.
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`
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`Id. at Fig. 12. Figure 17 depicts the same information model of Figure 12 after the
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`generation of three derived containers 1604, 1700, 1704. ’229 patent (Ex. 1001) at
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`3:60-62, 10:57-62, 11:1-7, Figs. 7, 12, 17.
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`U.S. Patent No. 6,321,229
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`Id. at Fig. 17.
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`47. As described in the specification, container definition node 1200 of
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`Figures 12 and 17 contains the selection criteria “Tech/Prof=TRUE.” Derived
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`container 1604 of Figure 17 corresponds to container definition node 1200 and
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`displays the label “Technical/Professional.” Upon selection by a user, derived
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`container 1604 and derived containers 1700 (Computers) and 1704 (Electronics) of
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`Figure 12 are generated and displayed. Id. at 13:60-14:7. Derived container 1704
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`corresponds to container definition node 1204, which is a child container definition
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`node of container definition node 1200. Container definition node 1204 of Figures
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`12 and 17 contains the selection criteria “skills=ELEC.” Id. at Fig. 17.
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`Declaration of Paul Onnen
`Case No. IPR2015-00523
`U.S. Patent No. 6,321,229
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`If the user then selects derived container 1704 (a leaf node), the
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`48.
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`system dynamically builds a query that includes the selection criteria from
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`container definition nodes 1204 and 1200. In other words, a query is dynamically
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`built using the selection criteria “{{Tech/Prof=TRUE} AND {skills=ELEC}}” and
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`is executed to extract and display records matching this criteria from the database.
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`Id. at 14:43-63. In SQL, this criteria would form part of the “WHERE” clause.
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`Based on the data in Figure 7, only the job with JobNo 711 meets this criteria, so it
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`is the only record that will be displayed when the user selects derived container
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`1704. Id. at Fig. 7.
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`49.
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` If the user selects derived container 1700, a query using the selection
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`criteria from container definition nodes 1200 and 1202 is dynamically built. This
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`query would include the constructed criteria “{{Tech/Prof=TRUE} and
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`{skills=COMP}}”; that query will be executed to extract and display records
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`matching this criteria from the database. Id. at 14:43-63. Based on the data in
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`Figure 7, such a query will return jobs 700, 704, 705, and 706, which match the
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`constructed selection criteria. Id. at Fig. 7.
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`50. Each derived container in the hierarchy of deriv