UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`ACTIVISION BLIZZARD, INC.,
`ELECTRONIC ARTS INC.,
`TAKE-TWO INTERACTIVE SOFTWARE, INC.,
`2K SPORTS, INC.,
`ROCKSTAR GAMES, INC.,
`Petitioners
`
`v.
`
`ACCELERATION BAY, LLC,
`Patent Owner
`________________
`
`Case No. IPR2016-00726
`Patent 6,910,069
`________________
`
`DECLARATION OF MICHAEL GOODRICH, Ph.D.
`
`
`
`Acceleration Bay Exhibit 2001, p. 1
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`

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`TABLE OF CONTENTS
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`Page
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`QUALIFICATIONS ........................................................................................ 3
`I.
`SCOPE OF ASSIGNMENT AND APPROACH ............................................ 5
`II.
`III. APPLICABLE STANDARDS AND CONTROLLING
`PRINCIPLES ................................................................................................... 6
`A. Anticipation ............................................................................................ 6
`B.
`Obviousness ............................................................................................ 6
`C.
`Person Of Ordinary Skill In The Art ...................................................... 9
`IV. There is No Motivation to Combine Obraczka and Denes ........................... 11
`DECLARATION ..................................................................................................... 14
`
`
`Acceleration Bay Exhibit 2001, p. 2
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`

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`I, Michael Goodrich, Ph.D., declare and state as follows:
`
`I.
`
`QUALIFICATIONS
`
`1.
`
`I make this Declaration based upon my own personal knowledge,
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`information, and belief, and I would and could competently testify to the matters
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`set forth herein if called upon to do so.
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`2.
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`I received a Bachelor of Arts (“BA”) degree in Mathematics and
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`Computer Science from Calvin College in 1983 and a PhD in Computer Sciences
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`from Purdue University in 1987.
`
`3.
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`I am a Chancellor's Professor in the Department of Computer Science
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`at the University of California, Irvine, where I have been a faculty member since
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`2001. The Chancellor's Professor title at University of California, Irvine is
`
`designed for persons who have earned the title of Professor and who have
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`demonstrated unusual academic merit and whose continued promise for scholarly
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`achievement is unusually high. In addition, I am technical director for the Center
`
`for Algorithms and Theory of Computation in the Donald Bren School of
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`Information and Computer Sciences at University of California, Irvine. I was a
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`professor in the Department of Computer Science at Johns Hopkins University
`
`from 1987-2001.
`
`4.
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`I have authored or coauthored over 300 publications, including several
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`widely adopted books, such as Introduction to Computer Security and Algorithm
`
`Acceleration Bay Exhibit 2001, p. 3
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`

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`Design and Applications. My research includes contributions to data structures and
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`algorithms, information security and privacy, networking, graph algorithms,
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`computational geometry, distributed and parallel algorithms, and cloud security.
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`My research is supported by grants from the Defense Advanced Research Projects
`
`Agency (DARPA) and the National Science Foundation (NSF).
`
`5.
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`In addition, I have consulting experience in matters involving
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`algorithms, cryptography, machine learning, digital rights management, computer
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`security, networking, software, and storage technologies.
`
`6.
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`I am an ACM Distinguished Scientist, a Fellow of the American
`
`Association for the Advancement of Science (AAAS), a Fulbright Scholar, a
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`Fellow of the Institute of Electrical and Electronics Engineers (IEEE), and a
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`Fellow of the Association for Computing Machinery (ACM). I am also a recipient
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`of the IEEE Computer Society Technical Achievement Award and the Pond Award
`
`for Excellence in Undergraduate Teaching.
`
`7.
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`Attached hereto as Appendix A is a true and correct copy of my
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`Curriculum Vitae (CV).
`
`8.
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`In developing my opinions below, I have considered the materials
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`cited herein, including the subject Petition and all the exhibits cited therein and
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`identified on Petitioner’s Exhibit List. In addition, I have reviewed the documents
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`Acceleration Bay Exhibit 2001, p. 4
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`

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`cited by Dr. David R. Karger in his declaration to the Petition (Dr. Karger’s
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`declaration hereinafter referred to as “Karger Decl”).
`
`9.
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`To the extent that I am presented with new information concerning the
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`subject matter of this declaration or affecting any assumptions made herein, I
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`reserve the right to supplement this declaration accordingly.
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`II.
`
`SCOPE OF ASSIGNMENT AND APPROACH
`
`10.
`
`I have been retained as an expert on behalf of Patent Owner,
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`Acceleration Bay LLC, (“Acceleration Bay”), to provide information and opinions
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`to the Patent Trial and Appeal Board (hereinafter “the Board”) to assist in the
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`determination of whether or not the Board should institute inter partes review of
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`one or more claims of Acceleration Bay’s U.S. Patent No. 6,910,069 (the “‘069
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`Patent”). Specifically, counsel for Acceleration Bay asked me to provide opinions
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`regarding the validity of claims 1–17 of the ‘069 Patent in view of certain prior art
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`references cited by Activision Blizzard, Inc., Electronic Arts Inc., Take-Two
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`Interactive Software, Inc., 2K Sports, Inc., and Rockstar Games, Inc. (collectively,
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`“Petitioner”). In my opinion, claims 1-17 of the ‘069 Patent are valid in light of the
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`prior art and arguments presented in the Petition and the Karger Decl.
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`11.
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`I have been informed by counsel and I understand that the analysis of
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`whether a patent is anticipated or obvious is performed from the perspective of a
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`person of ordinary skill in the art at the time of the patented inventions. The
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`Acceleration Bay Exhibit 2001, p. 5
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`

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`relevant timeframe for the challenged claims of the ‘069 Patent is at least July
`
`2000.
`
`III. APPLICABLE STANDARDS AND CONTROLLING PRINCIPLES
`A. Anticipation
`12. Counsel has informed me, and I understand, that an issued patent
`
`claim is invalid as anticipated if each and every element of that claim is disclosed
`
`in a single prior art reference that enables a person of ordinary skill in the art to
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`make the allegedly anticipating subject matter. I understand that to be anticipatory,
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`a reference must enable one of skill in the art to practice an embodiment of the
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`claimed invention without undue experimentation.
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`13. Counsel has informed me, and I understand, that if a prior art
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`reference does not disclose a given element expressly, it may do so inherently. I
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`have been informed by counsel and I further understand that a prior art reference
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`will inherently anticipate a claimed invention if any claim elements or other
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`information missing from the reference would nonetheless be known by the person
`
`of ordinary skill in the art to be necessarily present in the subject matter of the
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`reference.
`
`B. Obviousness
`14. Counsel has informed me, and I understand, that an issued patent
`
`claim is invalid as obvious if it can be shown that the differences between the
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`patented subject matter and the prior art are such that the subject matter as a whole
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`Acceleration Bay Exhibit 2001, p. 6
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`

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`would have been obvious, at the time the invention was made, to a person having
`
`ordinary skill in the art. Relevant considerations include the level of ordinary skill
`
`in the art; the scope and content of the prior art; differences between the prior art
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`and the claims at issue; and the so-called objective secondary factors of
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`nonobviousness.
`
`15. Counsel has informed me, and I understand, that in order to evaluate
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`the obviousness of any claim of the ‘069 Patent over a given prior art combination,
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`I should analyze whether the prior art references, included collectively in the
`
`combination, disclose each and every element of the allegedly invalid claim as
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`those references are read by the person of ordinary skill in the art at the time of the
`
`invention. Then I am to determine whether that combination makes the claims of
`
`the ‘069 Patent obvious to the person of ordinary skill in the art by a
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`preponderance of the evidence, at the time of the inventions. I understand that
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`such preponderance of the evidence is satisfied if the proposition is more likely to
`
`be true than not true.
`
`16. Counsel has informed me, and I understand, that the obviousness
`
`inquiry requires that the prior art be considered in its entirety. I am further
`
`informed and I understand that an invention cannot be obvious to try where “the
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`breadth of the[] choices and the numerous combinations indicate that the[]
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`disclosures would not have rendered the claimed invention obvious to try.”
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`Acceleration Bay Exhibit 2001, p. 7
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`

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`17. Counsel has informed me, and I understand, that even where all of the
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`claim limitations are expressly disclosed in the prior art references, there must be
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`some showing that a person of ordinary skill in the art would have been motivated
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`to combine such prior art references and that there would have been a reasonable
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`expectation of successfully achieving the claimed invention from such
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`combination.
`
`18. Counsel has informed me, and I understand, in considering the
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`obviousness of a claimed invention, one should not view the invention and the
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`prior art with the benefit of hindsight. It is for that reason, I am informed and I
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`understand, that obviousness is assessed by the person of ordinary skill in the art at
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`the time the invention was made. In this regard, I am informed and I understand
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`that the invention cannot be used as a guide to selecting and understanding the
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`prior art. I understand that the appropriate standard is to determine whether a
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`person of skill in the art would be motivated to combine references, not whether
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`they could.
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`19. Counsel has informed me, and I understand, that obviousness cannot
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`be predicated on what was unknown at the time of the invention, even if the
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`inherency of a certain feature is later established. Counsel has also informed me,
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`and I understand, that unknown properties of the prior art may not be relied upon
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`Acceleration Bay Exhibit 2001, p. 8
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`

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`to provide the rationale for modifying or combining the prior art to reach the
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`claimed subject matter.
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`20. Counsel has informed me, and I understand, that a reference may be
`
`said to teach away when a person of ordinary skill, upon reading the reference,
`
`would be discouraged from following the path set out in the reference, or would be
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`led in a direction divergent from the path that was taken by the applicant.
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`21. Counsel has informed me, and I understand, that the “time of
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`invention” applicable to the inventions of claims 1–17 the‘069 Patent is no later
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`than July 31, 2000, which I understand to be the priority date on the face of the
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`‘069 Patent.
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`Person Of Ordinary Skill In The Art
`
`C.
`22. Counsel has informed me, and I understand, that the “person of
`
`ordinary skill in the art” (“POSITA”) is a hypothetical person who is presumed to
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`be familiar with the relevant scientific field and its literature at the time of the
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`invention. This hypothetical person is also a person of ordinary creativity capable
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`of understanding the scientific principles applicable to the pertinent field.
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`23.
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`I am informed by counsel and I understand that the level of ordinary
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`skill in the art may be determined by reference to certain factors, including (1) the
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`type of problems encountered in the art, (2) prior art solutions to those problems,
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`(3) the rapidity with which innovations are made, (4) the sophistication of the
`
`Acceleration Bay Exhibit 2001, p. 9
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`

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`technology, and (5) the educational level of active workers in the field. I further
`
`understand that the face of the ‘069 Patent claims a priority date of July 31, 2000.
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`24.
`
`It is my opinion that the person of ordinary skill in the art in the field
`
`of the ‘069 Patent would have be someone with a bachelor’s degree in computer
`
`science or related field, and either (1) two or more years of industry experience
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`and/or (2) an advanced degree in computer science or related field.
`
`25. Based on my training and experience, I believe that I am (and was as
`
`of July 2000) a person of greater than ordinary skill in the relevant art, which
`
`permits me to give an opinion about the qualifications of one of ordinary skill at
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`the time of the invention.
`
`26.
`
`I note that Dr. Karger’s opinion on a person of ordinary skill in the art
`
`in his declaration is:
`
`In my opinion, a POSITA at the time of the alleged inventions
`claimed by the ’147 and ’069 patents would have a minimum of: (i) a
`bachelor’s degree in computer science, computer engineering, applied
`mathematics, or a related field of study; and (ii) four or more years of
`industry experience relating to networking protocols and network
`topologies. Additional graduate education could substitute for
`professional experience, or significant experience in the field could
`substitute for formal education.
`
`Karger Decl. at ¶ 19.
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`Acceleration Bay Exhibit 2001, p. 10
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`

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`27. My opinions stated in this declaration would be the same if rendered
`
`from the perspective of a person of ordinary skill in the art set out by Dr. Karger.
`
`IV. THERE IS NO MOTIVATION TO COMBINE OBRACZKA AND
`DENES
`
`28. A POSITA would not be motivated to combine Katia Obraczka Katia
`
`Obraczka, Massively Replicating Services in Wide-Area Internetworks, Ph.D.
`
`Thesis, University of Southern California (Ex. 1010, “Obraczka”) and (2) Tamás
`
`Denes, The “Evolution” of Regular Graphs of Even Order by their Vertices,
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`Matematikai Lapok, 27, 3–4 (Ex. 1016, “Denes”).
`
`29.
`
`In my opinion, a POSITA would not be motivated to combine
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`Obraczka with Denes simply because “were in the same technical field, and
`
`addressed the same technical problems.” Petition at 19; Karger Decl. at ¶257.
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`30. Obraczka and Denes do not address the same technical problems.
`
`Obraczka is concerned with how to scale “replication mechanisms for wide-area,
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`autonomously managed services” and, in particular, how to organize replicas into
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`groups that use the underlying physical network efficiently. Obraczka at xiv, ¶¶ 1–
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`3. On the other hand, Denes is a graph theory paper that defines an “evolutionary
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`transformation” for adding or removing a node from a graph. More importantly,
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`the mere fact that two references are in similar technical fields—especially a field
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`Acceleration Bay Exhibit 2001, p. 11
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`

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`as active for academic and corporate researchers as that of computer networks—
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`would not commend a POSITA to combine any two given references.
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`31.
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`It is also my opinion that a POSITA would not have “appl[ied] the
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`simple formula disclosed in Denes to Obraczka’s system.” Petition at 20; Karger
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`Decl., ¶ 260. Obraczka’s entire operating premise is based upon complete
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`recalculation of a group topology whenever a new member joins the group:
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`Replicas may join or leave a replication group at any time. To join a
`group, a new replica copies a neighbor’s database, and floods its
`existence to the rest of the group. When a new member joins the
`group, a topology calculation is spawned. The resulting topology
`includes the new replica and is distributed to the group.
`
`Obrackza, pg. at 20, ¶ 7 (emphasis added). The reason that Obraczka generates an
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`entirely new topology is so that its system can incorporate “estimates of the
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`underlying physical topology” into its calculation:
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`We claim that, analogously to the fact that database applications need
`to have access to raw disks for efficiency while the underlying
`operating system exports file system abstractions, existing and future
`network applications will benefit from exposed physical network
`topology information. In particular, our replication architecture
`builds logical update topologies that try to make efficient use of the
`underlying network, while limiting update propagation delays. It
`builds these logical topologies based on information about the current
`state of the network.
`
`Acceleration Bay Exhibit 2001, p. 12
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`Id. at 16, ¶ 2 (emphasis added). These new topologies, which incorporate the new
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`replica, are generated randomly until one is found that is feasible. Id. at 40, ¶ 2. In
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`contrast, Denes discloses an algorithm for adding a node to an existing graph that
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`otherwise remains undisturbed.
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`32. Whether or not “it is generally appealing in systems to make
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`incremental changes,” as proposed in the Petition, a POSITA would not understand
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`that it would be beneficial to modify Obraczka’s system to use such incremental
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`changes, let alone the type of incremental change disclosed in Denes. See Petition
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`at 20; Karger Decl. at ¶ 260. For example, replacing Obraczka’s wholesale
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`topology generation with Denes process for adding nodes would prevent
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`Obraczka’s topology calculator from factoring in “cost… estimates of the
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`underlying physical topology.” Obraczka, pg. 40, ¶ 1. Because incorporating
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`estimates of the underlying physical network into new topologies is central to the
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`concept espoused in Obrackza, a POSITA would not implement a modification
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`that prevents consideration of the underlying physical network, such as the
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`algorithm disclosed in Denes.
`
`
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`Acceleration Bay Exhibit 2001, p. 13
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`

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`DECLARATION
`
`I declare that all statements made herein on my own knowledge are true and
`that all statements made on information and belief are believed to be true, and
`further, that these statements were made with the knowledge that willful false
`statements and the like so made are punishable by fine or imprisonment, or both,
`under Section 1001 of Title 18 of the United States Code.
`
`Executed in Cambridge, Massachusetts on this 17th day of June, 2016.
`
`
`
`Michael Goodrich, Ph.D.
`
`Acceleration Bay Exhibit 2001, p. 14
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`

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`
`
`APPENDIX A
`
`
`
`
`
`Acceleration Bay Exhibit 2001, p. 15
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`

`
`CURRICULUM VITAE
`Michael T. Goodrich
`
`Dept. of Computer Science
`Bren School of Info. & Computer Sciences
`University of California, Irvine
`Irvine, CA 92697-3435
`
`E-mail: goodrich (at) ieee.org
`http://www.ics.uci.edu/˜goodrich/
`Phone: (949)824-9366
`Fax: (949)824-4056
`
`CITIZENSHIP: U.S.A.
`
`EDUCATION
`Ph.D.
`
`1987
`
`M.S.
`B.A.
`
`1985
`1983
`
`Efficient Parallel Techniques for Computational Geometry
`Computer Sciences, Purdue Univ. (M.J. Atallah, advisor)
`Computer Sciences, Purdue Univ.
`Mathematics and Computer Science, Calvin College
`
`July ’12 to June ’13
`
`October ’06 to June ’12
`
`July ’01 to March ’07
`
`Fall ’00
`
`PROFESSIONAL EXPERIENCE
`April ’07 to present
`Chancellor’s Professor, Dept. of Computer Science
`Univ. of California, Irvine
`Chair, Dept. of Computer Science
`Univ. of California, Irvine
`Assoc. Dean for Faculty Dev., Bren School of Info. and Comp. Sci.
`Univ. of California, Irvine
`Professor, Dept. of Computer Science
`Univ. of California, Irvine
`Visiting Professor of Computer Science
`Brown Univ.
`Professor of Computer Science (on leave, from July ’01)
`Johns Hopkins Univ.
`Associate Professor of Computer Science
`Johns Hopkins Univ.
`Visiting Associate Professor of Computer Science
`Univ. of Illinois, Urbana-Champaign
`Assistant Professor of Computer Science
`Johns Hopkins Univ.
`
`July ’96 to June ’02
`
`July ’92 to June ’96
`
`Spring ’94
`
`July ’87 to June ’92
`
`RESEARCH INTERESTS
`
`Algorithm and Data Structure Design
`Information Assurance and Security
`Parallel and Distributed Computing
`Graph and Geometric Algorithms
`
`HONORS AND AWARDS
`• Compere Loveless Fellowship in Computer Sciences, Purdue Univ., 1985
`• Research Initiation Award, National Science Foundation, 1988
`• Oraculum Award for Excellence in Teaching, Johns Hopkins, 1993, 1994, 1995
`• ACM Recognition of Service Award, 1996
`• Robert B. Pond, Sr. Award for Excellence in Undergraduate Teaching, Johns Hopkins, 1998
`• Elected Senior Member, the Institute of Electrical and Electronics Engineers (IEEE), 1999
`• Spirit of Technology Transition Award, DARPA Dynamic Coalitions Program, 2002
`
`1
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`Acceleration Bay Exhibit 2001, p. 16
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`

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`• Brown Univ. Award for Technological Innovation (with R. Tamassia, N. Triandopoulos,
`D. Yao, and D. Ellis), 2006
`• ACM Distinguished Scientist, 2006
`• 2006 IEEE Computer Society Technical Achievement Award, “for outstanding contributions
`to the design of parallel and distributed algorithms for fundamental combinatorial and geo-
`metric problems”
`• Fulbright Scholar, 2007, for senior specialist service to University of Aarhus, Denmark
`• Fellow of the San Diego Supercomputer Center, 2007
`• Fellow of the American Association for the Advancement of Science (AAAS), “for distin-
`guished contributions to parallel and distributed algorithms for combinatorial and geometric
`problems, and excellence in teaching, academic and professional service, and textbook writ-
`ing,” 2007
`• Fellow of the Institute of Electrical and Electronics Engineers (IEEE), “for contributions to
`parallel and distributed algorithms for combinatorial and geometric problems,” 2009
`• Fellow of the ACM, “for contributions to data structures and algorithms for combinatorial
`and geometric problems,” 2009
`• ICS Dean’s Award for Research, “for his contributions in the area of parallel and distributed
`algorithms,” 2014
`• Chancellor’s Award for Excellence in Fostering Undergraduate Research, Univ. of California,
`Irvine, 2016
`
`PUBLICATIONS
`
`Patents and Patent Applications:
`
`P-1. G. Ateniese, B. de Medeiros, and M.T. Goodrich, “Intermediated Delivery Scheme for Asym-
`metric Fair Exchange of Electronic Items,” U.S. Patent Application US 2004/0073790 A1,
`April 15, 2004.
`P-2. M.T. Goodrich and R. Tamassia, “Efficient Authenticated Dictionaries with Skip Lists and
`Commutative Hashing,” U.S. Patent 7,257,711, August 14, 2007.
`P-3. J.W. Green, J.L. Schultz, Y. Amir, and M.T. Goodrich, “High Refresh-Rate Retrieval of
`Freshly Published Content using Distributed Crawling,” U.S. Patent 7,299,219, November
`20, 2007.
`P-4. R. Tamstorf, M.T. Goodrich, D. Eppstein, “Attribute Transfer Between Computer Mod-
`els Including Identifying Isomorphic Regions in Polygonal Meshes,” U.S. Patent 8,681,145,
`March 25, 2014. (also Application US 2010/0238166 A1, September 23, 2010).
`P-5. N. Triandopoulos, M.T. Goodrich, D. Nguyen, O. Ohrimenko, C. Papamanthou, R. Tamas-
`sia, C.V. Lopes, “Techniques for Verifying Search Results Over a Distributed Collection,”
`U.S. Patent, 9,152,716, October 6, 2015.
`
`Books and Monographs:
`
`B-1. M.T. Goodrich and R. Tamassia, Data Structures and Algorithms in Java, John Wiley and
`Sons, Inc., 1998.
`B-2. M.T. Goodrich and C.C. McGeoch, eds., Algorithm Engineering and Experimentation, Lec-
`ture Notes in Computer Science (LNCS), Vol. 1619, Springer-Verlag, 1999.
`B-3. M.T. Goodrich and R. Tamassia, Data Structures and Algorithms in Java, Second Edition,
`John Wiley and Sons, Inc., 2001.
`
`2
`
`Acceleration Bay Exhibit 2001, p. 17
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`

`
`B-4. M.T. Goodrich and R. Tamassia, Algorithm Design: Foundations, Analysis, and Internet
`Examples, John Wiley and Sons, Inc., 2002.
`B-5. M.T. Goodrich and S.G. Kobourov, eds., 10th International Symposium on Graph Drawing
`(GD), Lecture Notes in Computer Science, Vol. 2528, Springer-Verlag, 2002.
`B-6. M.T. Goodrich, R. Tamassia, and D. Mount, Data Structures and Algorithms in C++, John
`Wiley and Sons, Inc., 2004.
`B-7. M.T. Goodrich and R. Tamassia, Data Structures and Algorithms in Java, Third Edition,
`John Wiley and Sons, Inc., 2004.
`B-8. M.T. Goodrich and R. Tamassia, Data Structures and Algorithms in Java, Fourth Edition,
`John Wiley and Sons, Inc., 2006.
`B-9. M.T. Goodrich and R. Tamassia, Data Structures and Algorithms in Java, Fifth Edition,
`John Wiley and Sons, Inc., 2011.
`B-10. M.T. Goodrich and R. Tamassia, Introduction to Computer Security, Addison-Wesley, Inc.,
`2011.
`B-11. M.T. Goodrich, R. Tamassia, and D. Mount, Data Structures and Algorithms in C++,
`Second Edition, John Wiley and Sons, Inc., 2011.
`B-12. M.T. Goodrich, R. Tamassia, and M. Goldwasser, Data Structures and Algorithms in Python,
`John Wiley and Sons, Inc., 2013.
`B-13. M.T. Goodrich, R. Tamassia, and M. Goldwasser, Data Structures and Algorithms in Java,
`Sixth Edition, John Wiley and Sons, Inc., 2014.
`B-14. M.T. Goodrich and R. Tamassia, Algorithm Design and Applications, Wiley, 2015.
`
`Book Chapters:
`
`Ch-1. M.J. Atallah and M.T. Goodrich, “Deterministic Parallel Computational Geometry,” in
`Synthesis of Parallel Algorithms, J.H. Reif, ed., Morgan Kaufmann, 497–536, 1993.
`Ch-2. M.T. Goodrich, “The Grand Challenges of Geometric Computing,” in Developing a Com-
`puter Science Agenda for High-Performance Computing, U. Vishkin, ed., ACM Press, 64–68,
`1994.
`Ch-3. M.T. Goodrich, “Parallel Algorithms in Geometry,” CRC Handbook of Discrete and Com-
`putational Geometry, J.E. Goodman and J. O’Rourke, eds., CRC Press, Inc., 669–682, 1997.
`Ch-4. M.T. Goodrich and K. Ramaiyer, “Geometric Data Structures,” Handbook of Computational
`Geometry, J.-R. Sack and J. Urrutia, eds., Elsevier Science Publishing, 463–489, 2000.
`Ch-5. M.T. Goodrich and R. Tamassia, “Simplified Analyses of Randomized Algorithms for
`Searching, Sorting, and Selection,” Handbook of Randomized Computing, S. Rajasekaran,
`P.M. Pardalos, J.H. Reif, and J.D.P. Rolim, eds., Kluwer Academic Publishers, Vol. 1, 23–
`34, 2001.
`Ch-6. M.T. Goodrich, “Parallel Algorithms in Geometry,” Handbook of Discrete and Computational
`Geometry, Second Edition, J.E. Goodman and J. O’Rourke, eds., Chapman & Hall/CRC
`Press, Inc., 953–967, 2004. (Revised version of Ch-3.)
`Ch-7. C. Duncan and M.T. Goodrich, “Approximate Geometric Query Structures,” Handbook of
`Data Structures and Applications, Chapman & Hall/CRC Press, Inc., 26-1–26-17, 2005.
`Ch-8. M.T. Goodrich, R. Tamassia, and L. Vismara, “Data Structures in JDSL,” Handbook of
`Data Structures and Applications, Chapman & Hall/CRC Press, Inc., 43-1–43-22, 2005.
`Ch-9. Y. Cho, L. Bao and M.T. Goodrich, “Secure Location-Based Access Control in WLAN
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`Systems,” From Problem Toward Solution: Wireless and Sensor Networks Security, Zhen
`Jiang and Yi Pan, eds., Nova Science Publishers, Inc., Chapter 17, 2007.
`Ch-10. M.T. Goodrich and M.J. Nelson, “Distributed Peer-to-Peer Data Structures,” Handbook of
`Parallel Computing: Models, Algorithms and Applications, R. Rajasekaran and J. Reif, eds.,
`CRC Press, 17-1–17-17, 2008.
`Ch-11. C.A. Duncan and M.T. Goodrich, “Planar Orthogonal and Polyline Drawing Algorithms,”
`Handbook of Graph Drawing and Visualization, CRC Press, Inc., 223–246, 2013.
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`Journal Papers:
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`J-1. M.J. Atallah and M.T. Goodrich, “Efficient Parallel Solutions to Some Geometric Problems,”
`Journal of Parallel and Distributed Computing, 3(4), 1986, 492–507.
`J-2. M.T. Goodrich, “Finding the Convex Hull of a Sorted Point Set in Parallel,” Information
`Processing Letters, 26, 1987, 173–179.
`J-3. H. ElGindy and M.T. Goodrich, “Parallel Algorithms for Shortest Path Problems in Poly-
`gons,” The Visual Computer, 3(6), 1988, 371–378.
`J-4. M.J. Atallah and M.T. Goodrich, “Parallel Algorithms For Some Functions of Two Convex
`Polygons,” Algorithmica, 3, 1988, 535–548.
`J-5. M.J. Atallah, R. Cole, and M.T. Goodrich, “Cascading Divide-and-Conquer: A Technique
`for Designing Parallel Algorithms,” SIAM Journal on Computing, 18(3), 1989, 499–532.
`J-6. M.T. Goodrich, “Triangulating a Polygon in Parallel,” Journal of Algorithms, 10, 1989,
`327–351.
`J-7. M.T. Goodrich and M.J. Atallah, “On Performing Robust Order Statistics in Tree-Structured
`Dictionary Machines,” Journal of Parallel and Distributed Computing, 9(1), 1990, 69–76.
`J-8. M.T. Goodrich and J.S. Snoeyink, “Stabbing Parallel Segments with a Convex Polygon,”
`Computer Vision, Graphics and Image Processing, 49, 1990, 152–170.
`J-9. J. Johnstone and M.T. Goodrich, “A Localized Method for Intersecting Plane Algebraic
`Curve Segments,” The Visual Computer, 7(2–3), 1991, 60–71.
`J-10. M.T. Goodrich, “Intersecting Line Segments in Parallel with an Output-Sensitive Number
`of Processors,” SIAM Journal on Computing, 20(4), 1991, 737–755.
`J-11. R. Cole and M.T. Goodrich, “Optimal Parallel Algorithms for Point-Set and Polygon Prob-
`lems,” Algorithmica, 7, 1992, 3–23.
`J-12. M.T. Goodrich, “A Polygonal Approach to Hidden-Line and Hidden-Surface Elimination,”
`Computer Vision, Graphics, and Image Processing: Graphical Models and Image Processing,
`54(1), 1992, 1–12.
`J-13. M.T. Goodrich, S. Shauck, and S. Guha, “Parallel Methods for Visibility and Shortest Path
`Problems in Simple Polygons,” Algorithmica, 8, 1992, 461–486, with addendum in Algorith-
`mica, 9, 1993, 515–516.
`J-14. M.T. Goodrich, C. ´O’D´unlaing, and C. Yap “Constructing the Voronoi Diagram of a Set of
`Line Segments in Parallel,” Algorithmica, 9, 1993, 128–141.
`J-15. M.T. Goodrich, “Constructing the Convex Hull of a Partially Sorted Set of Points,” Com-
`putational Geometry: Theory and Applications, 2, 1993, 267–278.
`J-16. M.T. Goodrich, “Constructing Arrangements Optimally in Parallel,” Discrete and Compu-
`tational Geometry, 9, 1993, 371–385.
`J-17. M.T. Goodrich, M.J. Atallah, and M. Overmars, “Output-Sensitive Methods for Rectilinear
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`Hidden Surface Removal,” Information and Computation, 107(1), 1993, 1–24.
`J-18. M.J. Atallah, P. Callahan, and M.T. Goodrich, “P-Complete Geometric Problems,” Int.
`Journal of Computational Geometry & Applications, 3(4), 1993, 443–462.
`J-19. M.J. Atallah, M.T. Goodrich, and S.R. Kosaraju, “Parallel Algorithms for Evaluating Se-
`quences of Set-Manipulation Operations,” Journal of the ACM, 41(6), 1994, 1049–1088.
`J-20. M.T. Goodrich, “Efficient Piecewise-Linear Function Approximation Using the Uniform Met-
`ric,” Discrete and Computational Geometry, 14, 1995, 445–462.
`J-21. H. Br¨onnimann and M.T. Goodrich, “Almost Optimal Set Covers in Finite VC-Dimension,”
`Discrete and Computational Geometry, 14, 1995, 463–479.
`J-22. M.T. Goodrich, “Planar Separators and Parallel Polygon Triangulation,” J. Computer and
`System Sciences, 51(3), 1995, 374–389.
`J-23. M.T. Goodrich, M. Ghouse, and J. Bright, “Sweep Methods for Parallel Computational
`Geometry,” Algorithmica, 15(2), 1996, 126–153.
`J-24. M.T. Goodrich and S.R. Kosaraju, “Sorting on a Parallel Pointer Machine with Applications
`to Set Expression Evaluation,” Journal of the ACM, 43(2), 1996, 331–361.
`J-25. A. Garg, M.T. Goodrich, and R. Tamassia, “Planar Upward Tree Drawings with Optimal
`Area,” International Journal of Computational Geometry & Applications, 6(3), 1996, 333–
`356.
`J-26. M.H. Nodine, M.T. Goodrich, and J.S. Vitter, “Blocking for External Graph Searching,”
`Algorithmica, 16(2), 1996, 181–214.
`J-27. R. Cole, M.T. Goodrich, C. ´O D´unlaing, “A Nearly Optimal Deterministic Parallel Voronoi
`Diagram Algorithm,” Algorithmica, 16, 1996, 569–617.
`J-28. G. Das and M.T. Goodrich, “On the Complexity of Optimization Problems for 3-Dimensional
`Convex Polyhedra and Decision Trees,” Computational Geometry: Theory and Applications,
`8, 1997, 123–137.
`J-29. M.T. Goodrich and R. Tamassia, “Dynamic Ray Shooting and Shortest Paths in Planar
`Subdivisions via Balanced Geodesic Triangulations,” J. Algorithms, 23, 1997, 51–73.
`J-30. M. Ghouse and M.T. Goodrich, “Fast Randomized Parallel Methods for Planar Convex Hull
`Construction,” Computational Geometry: Theory and Applications, 7, 1997, 219–235.
`J-31. L.P. Chew, M.T. Goodrich, D.P. Huttenlocher, K. Kedem, J.M. Kleinberg, and D. Kravets,
`“Geometric Pattern Matching under Euclidean Motion,” Computational Geometry: Theory
`and Applications, 7, 1997, 113-124.
`J-32. M.T. Goodrich and E.A. Ramos, “Bounded-Independence Derandomization of Geometric
`Partitioning with Applications to Parallel Fixed-Dimensional Linear Programming,” Discrete
`& Computational Geometry, 18(4), 1997, 397–420.
`J-33. M.T. Goodrich, “An Improved Ray Shooting Method for Constructive Solid Geometry Mod-
`els via Tree Contraction,” International Journal of Computational Geometry & Applications,
`8(1), 1998, 1–23.
`J-34. G. Barequet, A.J. Briggs, M.T. Dickerson, and M.T. Goodrich, “Offset-Polygon Annulus
`Placement Problems,” Computational Geometry: Theory and Applications, 11(3–4), 1998–
`99, 125–141.
`J-35. M.T. Goodrich and R. Tamassia, “Dynamic Trees and Dynamic Point Location,” SIAM J.
`Comput., 28(2), 1999, 612–636.
`J-36. G. Barequet, S.S. Bridgeman, C.A. Duncan, M.T. Goodrich, and R. Tamassia, “GeomNet:
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`Geometric Computing Over the Internet,” IEEE Internet Computing, 3(2), 1999, 21–29.
`J-37. M.T. Goodrich, J.S.B. Mitchell, and M.W. Orletsky, “Approximate Geometric Pattern
`Matching Under Rigid Motion,” IEEE Trans. on Pattern Analysis and Machine Intelligence,
`21(4), 1999, 371–