UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`UNIFIED PATENTS INC.
`Petitioner
`
`v.
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`VILOX TECHNOLOGIES LLC.
`Patent Owner
`
`____________________
`
`Case IPR2018-00044
`Patent No. 7,302,423
`____________________
`
`DECLARATION OF WESLEY W. CHU, PH.D.
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`Table of Contents
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`INTRODUCTION ................................................................................................................................ 3
`I.
`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE........................................................ 3
`III.
`Level of Ordinary Skill in the Art and Relevant Legal Standards .................................. 10
`IV.
`U.S. PATENT 7,302,423 (THE ‘423 PATENT) ....................................................................... 13
`A. Specification and Prosecution History............................................................................. 13
`1. Specification ............................................................................................................................ 13
`2. Prosecution History ............................................................................................................... 17
`V. REFERENCES RELIED ON BY THE PETITION ....................................................................... 23
`A. U.S. Patent 5,701,453 to Maloney (Maloney, Ex. 1006) ................................................. 23
`1. Maloney Does Not Disclose or Suggest a Processor Determines a Database
`Schema .......................................................................................................................................... 23
`2. Maloney Does Not Disclose or Suggest Other ‘423 Patent Claim Limitations ...... 25
`3. Some Features of Maloney Would Be Rendered Inoperable If Combined with
`Bertram .......................................................................................................................................... 26
`B. U.S. Patent 7,168,039 to Bertram (Bertram, Ex. 1007) .................................................. 30
`C. Excel 2000 Bible (Excel, Ex. 1009 and Excel II, Ex. 2004) ............................................ 34
`D. U.S. Patent 6,300,947 to Kanevsky .................................................................................... 35
`E. Excel 2000 Bible (Excel II) (Ex. 2004) ................................................................................ 35
`F. Maloney in View of Bertram ................................................................................................ 38
`G. Excel 2000 Bible (Both Excel and Excel II) in View of Bertram .................................. 39
`PETITION ...................................................................................................................................... 40
`A. Overview and Summary ....................................................................................................... 40
`B. Challenge 1: Claims 1 – 4, 7 – 9, and 13 ........................................................................... 40
`C. Challenge 2: Claims 1 – 4, 7 – 9, and 13 ........................................................................... 45
`D. Challenge 3: Claims 5 and 6 ................................................................................................ 51
`E. Challenge 4: Claims 5 and 6 ................................................................................................ 51
`VII. CONCLUSION .............................................................................................................................. 52
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`VI.
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` Exhibit 2001 / Page 2 of 52
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
`
`
`
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`I.
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`INTRODUCTION
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`1.
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`I make this Declaration at the request of Vilox Technologies, LLC regarding my
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`opinions as an independent expert regarding issues raised in the matter of Petition
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`IPR2018-00044 (“Petition”).
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`2.
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`I am being compensated for this work, and my compensation is not dependent on
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`the outcome of this matter.
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`3.
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`In preparation for this Declaration, I studied Exhibits 1001 – 1010 provided by
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`Petitioner as well as the Petition. Also, I studied these additional materials:
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`Exhibit 2003, Declaration of Dr. Joseph L. De Bellis;
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`Exhibit 2004, Excel 2000 Bible;
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`Exhibit 2005, U.S. Patent 6,593,949 to Chew;
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`Exhibit 2006, Webster’s New Collegiate Dictionary
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`4.
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`In preparing this Declaration, I relied, in addition to the above Exhibits, on my
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`knowledge and experience gained through 56 years as an engineer, professor, and
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`consultant.
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`II.
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`QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
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`5.
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`My Curriculum Vitae is provided as Exhibit 2002. Following is a summary of my
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`education and relevant experience.
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`6.
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`I am Emeritus Distinguished Professor at the University of California, Los Angeles.
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`I received a Bachelor of Science degree in electrical engineering from the University of
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`Michigan in 1960 and a Master of Science degree in electrical engineering from the
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` Exhibit 2001 / Page 3 of 52
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`University of Michigan in 1961. I received a Ph.D. in electrical engineering from Stanford
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`University in 1966.
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`7.
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`From 1961 to 1962, I worked at General Electric (now Honeywell) in Phoenix,
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`Arizona with a focus on electrical switching circuits for computers. From 1964 to 1966, I
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`worked on the design of large-scale computers at IBM in San Jose, California. From 1966
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`to 1969, I worked at Bell Laboratories in Holmdel, New Jersey with a focus on computer
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`communications and distributed databases.
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`8.
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`I joined the faculty of the of California, Los Angles in 1969 in the Computer Science
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`Department. I served as Department Chair from 1988 to 1991, as Distinguished
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`Professor since 1998, and as Emeritus Distinguished Professor since 2009.
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`9.
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`From 1982 to 2005, I worked as a consultant for several large computer
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`companies:
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`• 1982 - 1984, Western Union Corporation, Upper Saddle River, New Jersey,
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`Executive Consultant to VP Engineering and Member of the Technical Review
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`Board with duties that included:
`o Evaluating and planning for the Western Union Packet Switched Network,
`Easylink, and other value-added services.
`o Developing transition plans for network modernization, integration with
`existing networks and for future network growth.
`o Critiquing on going and proposed enhancement plans and compare with
`other viable alternatives for effectiveness.
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`
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` Exhibit 2001 / Page 4 of 52
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`• 1983 – 1986, Titan Systems Inc., Inglewood California, Consultant, with duties that
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`included developing, evaluating and validating the SENTRY Distributed Data Base
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`System.
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`• 1985 – 1988, Unisys SDC Corp., Huntsville, Alabama, Consultant, with duties that
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`included designing and developing a real time distributed database system for
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`missile defense applications.
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`• 1995 – 2005, Xerox Corporation, El Segundo, California, Consultant, fault tolerant
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`computing, with duties that included designing and developing word processing
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`systems.
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`10.
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`Early in my career, my research focus was on computer communication and
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`networks, distributed databases, memory management, real-time distributed processing
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`systems, and statistical multiplexing - the latter contributing to the development of ATM
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`networks. My pioneering work in file allocation and directory design for distributed
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`databases aided the design and development of domain name servers for the web and
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`current cloud computing systems. I was named an IEEE Fellow for my contributions in
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`these areas.
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`11. Over the past two decades, my research interests evolved to include intelligent
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`(knowledge-based) information systems and knowledge acquisition for large information
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`systems. Using my methodology for relaxing query constraints, I led the development of
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`CoBase, a cooperative database system for structured data, and KMed, a knowledge-
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`based multimedia medical image system.
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`12. Under the KMed project, I developed a Medical Digital Library that provides
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`approximate content-matching and navigation; the library will serve as a cornerstone for
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` Exhibit 2001 / Page 5 of 52
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`future paperless hospitals. More recently, I worked on inference techniques for data
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`security and privacy protection (ISP) and social network-based recommender system
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`(SNRS).
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`13.
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`Together with my students, I received numerous best paper awards at conferences
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`and workshops, and also a certificate of merit for work on the Medical Digital Library
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`system. I am the recipient of the IEEE Computer Society's Technical Achievement Award
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`for contributions to intelligent information systems.
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`14.
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`I am the author or coauthor of more than 150 articles, an editor of three textbooks
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`on information technology, and the co-editor of a reference book on data mining.
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`15.
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`I have received the following U.S. Patents:
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`•
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`“System and Methods for Evaluating Inferences for Unknown Attributes in a Social
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`Network,” U.S. Patent Number 8,160,993 April 17, 2012, Lead inventor, Wesley
`
`W. Chu.
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`•
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`“System and Method for Retrieving Scenario Specific Documents,” U.S. Patent
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`Number 7, 548,910, June 2009, Lead inventor, Wesley W. Chu.
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`•
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`“Database Event Detection and Notification System Using Type Abstraction
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`Hierarchy (TAH),” U.S. Patent Number 6,247,146, July 2002.
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`•
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`“Database System with Query Relaxation Using Type Abstraction Hierarchy (TAH)
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`as Query Condition Relaxation Structure,” U.S. Patent Number 6,427,146,
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`September 1999.
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`•
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`“Multiplexed MOS Multi-Accessed Memory System” (co-invented with D. Hibbits),
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`U.S Patent Number 4,415,991, November 1983.
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`
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` Exhibit 2001 / Page 6 of 52
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`•
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`“Multi-access Memory Module for Data Processing System” (co-invented with P.
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`Korff), U.S. Patent Number 4,109,719, August 1978.
`
`•
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`“Statistical Multiplexing Systems for Computer Communications,” U.S. Patent
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`Number 4,093,823, June 1978.
`
`•
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`“Statistical Multiplexing Systems for Computer Communications,” U.S. Patent
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`Number 4,082,922, April 1978.
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`16.
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`I have received the following special recognitions:
`
`•
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`Invited by United Nations (1984) and World Bank (1987) as a member of scientific
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`delegates to consult and lecture on Computer Communications and Networks, and
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`Distributed Data Bases in People's Republic of China.
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`•
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`IEEE Computer Society Distinguished Visitors Program to give invited lectures to
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`selected universities, 1990-1994.
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`• Selected by National Science Council as a delegate scientist to visit Taiwan and
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`give invited lecture series (1992).
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`• External program review committee for the Department of Information and
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`Computer Science for UC Irvine, June 1996.
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`• KMeD as a feature article on Cutting Edge Technology related to content-based
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`medical image retrieval in the Los Angeles Times, Business Section, August 4,
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`1997.
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`• National Science Foundation research proposal review panel member, 1998-2008.
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`17.
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`I have provided the following professional services:
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`• ACM SIGCOMM chairman from 1973 to 1976.
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`
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` Exhibit 2001 / Page 7 of 52
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`• Associate editor for IEEE Transactions on Computers for Computer Networking
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`and Distributed Processing System (1978 to 1982) and received a meritorious
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`award for his service to IEEE.
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`• Workshop co-chair of the IEEE First International Workshop on Systems
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`Management (1993) and received a Certificate of Appreciation award for his
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`service.
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`• Technical program chairs for SIGCOMM (1975), VLDB (1986), Information
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`Knowledge Sharing (2003), and ER (2004), general conference chair of ER (1997).
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`Technical program chair (knowledge management track) of the 2009 International
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`conference on information and knowledge management (CIKM09).
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`• Guest editor and associate editor for several journals related to intelligent
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`information systems.
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`18.
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`I served as an expert witness in the following matters:
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`• 2009 – 2012
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`U.S. Department of Justice, Case name: FedEx Corporation v. United States, case
`
`number: 2:08-cv-02423, filed in the U.S. District Court for the Western District of
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`Tennessee.
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`I was retained by the U.S. Government to evaluate the software projects by U.S.
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`corporations to determine if they qualified for research credits under the legal
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`standards of Internal Revenue Code (I.R.C.) section 41(d).
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`Services included:
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`
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` Exhibit 2001 / Page 8 of 52
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
`o Review information on the software products and prepare report in detail
`opine on whether, as a matter of computer science, each project met the
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`requirement of the statute and regulations.
`o Review the reports of the plaintiff's experts and identify any issues with their
`analysis, methodology and/or conclusions.
`o Write expert witness report.
`Prepare to testify at deposition.
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`The case was settled before trail.
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`• 2012—2014
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`Microsoft Corp and Google Inc. v. GeoTag Inc. (D. Del, Case No 11-cv-175).
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`Defended Microsoft Corp. and Google against GeoTag Inc.
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`Provided expert opinion that U.S. Patent No. 5,930,474 (J.A. 89-133) is invalid as
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`well as GeoTag's counterclaims that alleged that Google infringed the '474 patent.
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`See Microsoft Corp. v. GeoTag, Inc., No. 11-175-RGA, 2014 WL 4312167 (D.Del.
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`Aug. 29, 2014.
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`I was deposed by GeoTag attorney and defended Google and Microsoft based on
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`my published research work on Co-Base and Co-GIS resulting in the non-
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`infringement of the ‘474 patent.
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`• 2013
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`Oracle Corporation v. Parent of Clouding; Case IPR 2013-00073 (JL), Patent
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`6,738,799.
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`Participated in Inter Partes Review.
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` Exhibit 2001 / Page 9 of 52
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`Expert consultant for Clouding in patent litigation. Tasks included analysis,
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`conclusion, and preparation report of declaration.
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`• 2014-2015
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`GeoTag Inc. v. Classified Ventures LLC, U.S. District Court for Northern District of
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`Illinois, cv-00633.
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`Expert consultant for Apple Inc. in patent litigation.
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`Based on our research on Natural Language Processing, the case was settled
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`without going to trial.
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`III.
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`Level of Ordinary Skill in the Art and Relevant Legal Standards
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`19.
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`I understand that the level of ordinary skill may be reflected by the prior art of
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`record, and that a person having ordinary skill in the art (“PHOSITA”) to which the claimed
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`subject matter pertains would have the capability of understanding the scientific and
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`engineering principles applicable to the pertinent art. I understand that one of ordinary
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`skill in the art has ordinary creativity, and is not an automaton.
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`20.
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`I understand there are multiple factors relevant to determining the level of ordinary
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`skill in the pertinent art, including (1) the levels of education and experience of persons
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`working in the field at the time of the invention; (2) the sophistication of the technology;
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`(3) the types of problems encountered in the field; and (4) the prior art solutions to those
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`problems.
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`21.
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`I am familiar with all the subject matter of the ‘423 Patent. I am also aware of the
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`state of the art at the time the application resulting in the ‘423 Patent was filed. I have
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`been informed that while, based on filing applications with the U.S. Patent Office, the
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`priority date for the ‘423 Patent may be as early as February 25, 2000, in fact, the
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`
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` Exhibit 2001 / Page 10 of 52
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`inventions disclosed in the ‘423 Patent were conceived at least as early as mid-May,
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`1999. I have reviewed the inventor’s Declaration (Ex. 2003) on this subject, and believe
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`the facts stated in the Declaration do support mid-May, 1999 as the date of conception.
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`Based on the inventions disclosed in the ‘423 Patent, and my experience with software
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`engineers at that time, I believe that a PHOSITA would be someone who had, at the
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`conception date, at least a bachelor’s degree in Computer Science or an equivalent field
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`(or equivalent industry experience) and at least one year of experience designing,
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`implementing, and using database management systems. I believe that I possessed at
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`least such experience and knowledge at the mid-May 1999 conception date of the ‘423
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`patent, and that I am qualified to opine on the ‘423 Patent.
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`22.
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`For purposes of this Declaration, in general, and unless otherwise noted, my
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`statements and opinions, such as those regarding my experience and the understanding
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`of a PHOSITA generally (and specifically related to the references I consulted herein),
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`reflect the knowledge that existed in the field before the priority date of the ‘423 Patent.
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`23.
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`I have been asked to provide my opinions regarding whether claims 1-9 and 13 of
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`the ‘423 Patent would have been nonobvious to a PHOSITA at the time of invention, in
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`light of the prior art.
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`24.
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`I am not an attorney. In preparing and expressing my opinions and considering the
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`subject matter of the ‘423 Patent, I relied on certain legal principles that counsel has
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`explained to me.
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`25.
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`I have been informed and understand that under 35 U.S.C. § 103, a patent may
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`be invalid for obviousness if the differences between the subject matter sought to be
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`patented and the prior art are such that the subject matter as a whole would have been
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` Exhibit 2001 / Page 11 of 52
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`obvious, at the time the invention was made, to a person having ordinary skill in the art to
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`which said subject matter pertains. I understand that although it is well settled that the
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`ultimate determination of obviousness is a question of law, it is also well understood that
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`there are factual issues underlying the ultimate obviousness decision. I understand that
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`the obviousness analysis is based on four underlying factual inquiries:  (1) the scope and
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`content of the prior art;  (2) the differences between the claims and the prior art;  (3) the
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`level of ordinary skill in the pertinent art;  and (4) secondary considerations, if any, of
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`nonobviousness.
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`26.
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`I understand that because inventions often involve a combination of known
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`elements that in hindsight seems preordained, to prevent hindsight invalidation of patent
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`claims, the law requires some “teaching, suggestion or motivation” to combine cited
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`references. I understand that motivation to combine references may be found in the cited
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`references themselves, in the knowledge of a PHOSITA, and in the nature of the problem
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`to be solved.
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`27.
`
`I understand that the Supreme Court has recognized other rationales for combining
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`references or modifying a reference to show obviousness of claimed subject matter.
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`Some of these other rationales are: (a) combining prior art elements according to known
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`methods to yield predictable results; (b) simple substitution of one known element for
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`another to obtain predictable results; (c) use of a known technique to improve a similar
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`device (method, or product) in the same way; (d) applying a known technique to a known
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`device (method, or product) ready for improvement to yield predictable results; (e)
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`choosing from a finite number of identified, predictable solutions, with a reasonable
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`expectation of success.
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` Exhibit 2001 / Page 12 of 52
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`I understand that obviousness does not require physical combination/bodily
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`28.
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`incorporation, but rather consideration of what the combined teachings would have
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`suggested to a PHOSITA at the time of the invention.
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`29.
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`I further understand that an asserted motivation to combine references can be
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`overcome based on a showing that those references together “teach away” from their
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`combination. I understand that if the references taken in combination would produce a
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`“seemingly inoperable device,” such references teach away from the combination and
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`thus cannot serve as a basis for obviousness.
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`30.
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`I understand that within the framework of an obviousness analysis, it is
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`impermissible to pick and choose from any one reference only so much of it as will support
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`a given position to the exclusion of other parts necessary to the full appreciation of what
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`such reference fairly suggests to a PHOSITA. Thus, a reference must be considered in
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`its entirety, including those portions of the reference that argue against obviousness.
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`31.
`
`Finally, I understand that the Board has discretion to reject a petition that presents
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`the same or substantially the same prior art or arguments that were previously presented
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`to the Office during prosecution.
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`IV.
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`U.S. PATENT 7,302,423 (THE ‘423 PATENT)
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`32.
`
`The following discusses aspects of the ‘423 Patent and its prosecution history that
`
`are relevant to the claims subject to the Petition.
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`A. Specification and Prosecution History
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`1. Specification
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`33.
`
`The ‘423 Patent discloses a dynamic search engine and corresponding dynamic
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`search methods. The search engine may be applied to databases for which prior
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` Exhibit 2001 / Page 13 of 52
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`knowledge of database schemas is not available to the search engine. That is, the search
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`engine determines the database schema. See Exhibit 1001: 6: 32-33; 7: 3-5.
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`34.
`
`In response to a query, the search engine returns search results. In an
`
`embodiment, the search results may be returned in a tabular form that consists of a
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`column with multiple rows. See id., Figure 4. Each search result may be termed an
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`“entry” in the column. See id., 7: 19-33. An entry may consist of text composed of a
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`number of characters (for example, numbers, numerals, symbols, spaces and icons).
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`See, e.g., id., Fig. 30; 17: 14-15. Thus, entries are not limited to text.
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`35.
`
`The search engine may return so many entries that the search results cannot be
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`displayed within the limited real estate of a display screen or on a single page. To contend
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`with a such a possibility, the search engine may perform operations on the returned
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`search results. One such operation involves truncation. The specification provides
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`numerous example truncation embodiments. See id., 7:19-16:40 and Figures 4, 10 – 16,
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`18 – 24, 27 – 38, 40 -49, and 52.
`
`36. One example truncation involves determining a number of characters in each entry
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`in a data base field, and if for a specific entry, the number of characters exceeds a
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`specified limit, deleting a character from the entry. The process of determining and
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`deleting executes in an iterative fashion until all entries may be represented on the display
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`screen or page. See id.
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`37.
`
`The following drawing (Figure 11) from the ‘423 Patent shows truncation by
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`determining a number of characters in each entry in a database field.
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` Exhibit 2001 / Page 14 of 52
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`Case IPR2018-00044
`Patent No. 7,302,423
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`38.
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`The list of available data fields shows categories by which a search for books may
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`be narrowed. One available data field is “Titles,” which, as can be seen, was selected by
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`the user. A search for books by title produces so many results that the titles are truncated
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`so that only the first character (1 – 9 and A – Z) of the title is displayed. This first interim
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`result list is generated by successive, or iterative truncation, as disclosed for example in
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`Exhibit 1001, 8:22 – 9:6. An example of the actual truncation process used to generate
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`the interim result lists of Figure 11 is provided in Exhibit 1001, 12:33 – 65. Figure 11
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`shows three sequential interim result lists. Using the interim result lists, the user selects,
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`in sequence, “C,” “Ce,” and finally, “Cells.” “Cells” is in the last sequential interim result
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` Exhibit 2001 / Page 15 of 52
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`list. Thus, each of the three sequential interim result lists produce entries that may be
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`Case IPR2018-00044
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`searched further – that is, for example, entry “Ce,” which is a truncation of titles that start
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`with words having the first characters “Ce” (e.g., “Cells”) can be further searched to
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`produce the column I have labeled as interim result list (actually the last sequential interim
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`result list). As can be seen in Figure 11, the user selects “Cells” in the interim result list,
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`and a final search result is displayed with the full titles of each of three books that are
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`available from the Web site.
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`39.
`
`The above description and Figure 11 itself clearly show truncation by determining
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`a number of characters in a data field entry and then iteratively reducing the number of
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`characters until a displayable result list is produced. Note the entry “Cell an” in the column
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`I labeled interim result list. The entry “Cell an” consists of seven characters and conveys
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`much information to a user. For example, the user knows there is a book with the title
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`“Cell an****,” where the asterisks mean additional characters have been removed from
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`the title. A user might presume the “an” is a truncation of “and.” I discuss infra in
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`paragraphs 63 - 70 Bertram’s method for reducing column width. Had Bertram’s method
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`been used, all spaces and vowels would have been removed, and the entry “Cell_an”
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`would have been reduced to “Clln,” a result that in my opinion would have been
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`meaningless to the user.
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`40.
`
`In my opinion, as explained in more detail in paragraphs 103 – 142, infra, the
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`inventions recited in claims 1 and 3 are markedly different from what Maloney in view of
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`Bertram and Excel in view of Bertram disclose or suggest, and a PHOSITA would
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`understand that Maloney in view of Bertram and Excel in view of Bertram do not render
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`claims 1 and 3 invalid as obvious.
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`
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` Exhibit 2001 / Page 16 of 52
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`

`

`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
`
`
`
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`2. Prosecution History
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`41. Claims 1-9 and 13 were examined extensively by the Office.
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`42. Claim 1 recites, inter alia, “determining a number of characters included in each
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`entry in the selected database field.” See Ex. 1001, claim 1.
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`43. Claim 3 recites, inter alia, executing an iterative truncation process,
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`“comprising:
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`performing a truncation that reduces the number of characters to be
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`displayed from the selected data field,
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`comparing the reduced number of characters to the specified limit, and if
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`the number of characters exceeds the specified limit,
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`repeating the truncation and comparing steps until the reduced number of
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`characters to be displayed from the selected database field is less than or eciual [sic] to
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`the specified limits.” See Ex 1001, claim 3.
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`44.
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`In a June 1, 2007 final Office Action, claim 1 was allowed. However, claim 3 was
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`rejected over Maloney in view of U.S. Patent 6,593,949 to Chew et al. (Chew), Exhibit
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`2005. See Ex. 1002, Office Action dated June 1, 2007. The rejection of claim 3 states:
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`Maloney et al. does not explicitly teaches [sic] a step wherein if the quantity
`exceeds a specified limit, reducing a number of characters to be displayed
`for each entry from the selected data field, and displaying the reduced
`number of characters for each entry from of the database field.
`Chew et al., however, teaches wherein if the quantity exceeds a specified
`limit, reducing a number of characters to be displayed for each entry from
`the selected data field, and displaying the reduced number of characters for
`each entry from of the database field (col. 5, lines 30-41; col. 6, lines 62-66;
`col. 3, lines 60-64).
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` Exhibit 2001 / Page 17 of 52
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`

`

`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
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`In response to this rejection, Patent Owner amended claim 3 to recite the limitation
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`45.
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`quoted above in paragraph 43, thereby gaining allowance of claim 3. See Ex. 1002,
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`September 4, 2007 Office Action Response.
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`46.
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`I have reviewed Chew in detail, as well as the June 1, 2007 final Office Action.
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`Chew does disclose a truncation step but merely states that an entry may be truncated.
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`For example, Chew discloses “the right half of a name for a particular record is truncated.”
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`The result is that it is difficult to distinguish one entry from another. See Ex. 2005, 5: 33-
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`34.
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`47.
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`As I discuss in paragraphs 63 – 70 below, Bertram discloses an optional truncation
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`step that occurs after its iterative abbreviation steps are completed. Bertram’s truncation
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`executes to remove a portion of a right-hand entry, if needed.
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`48.
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`The following table lists and compares the totality of portions of the “Description of
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`the Drawings” and the “Detailed Descriptions” in Chew and Bertram that relate to
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`“truncation” or any variation of “truncation” (with emphasis added).
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`Chew
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`Bertram
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`FIGS. 8 and 9 are screen-shots of a
`display showing a feature of the invention
`in which truncated names in the Contacts
`list are shown more fully upon deployment
`of a smart column sub-list.
`2: 22 – 24.
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`Due to horizontal screen constraints and
`the use of some horizontal space for smart
`column 420 and the associated preferred
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`FIG. 3 is a flow chart depicting one
`conventional method
`for
`truncating a
`column heading.
`FIG. 4 is a block diagram of a table after
`column headings have been truncated.
`3: 15 – 18.
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`In order to reduce the horizontal space
`occupied by text data in an entry, such as
`a column heading, some conventional
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`
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` Exhibit 2001 / Page 18 of 52
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`

`

`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Wesley W. Chu, Ph.D.
`
`Chew
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`Bertram
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`information, sometimes the right half of a
`name for a particular record is truncated.
`This is particularly true for long company
`names. The result may be that it is difficult
`to distinguish one entry from another. This
`can be seen for example in FIG. 8 in which
`the names in each of records 502 and 504
`have been truncated. In this instance each
`of "American Express Customer Service"
`in record 502 and "American Express
`Travel Services" in record 504 have been
`truncated to "American Express."
`5: 31 – 40.
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`FIG. 9 illustrates a method used by the UI
`of the present invention to aid the user in
`this situation. For truncated name records,
`when the smart column sub-list 440 is
`deployed for record 502, the duplicate
`smart column information (e.g. phone
`number for American Express Customer
`Service) is removed from view because it
`is also available in the sub-list 440. This
`area is then used to as fully as possible
`show the previously truncated name on
`the line occupied by record 502.
`5: 41 – 50.
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`methods truncate the width of the column.
`For example, to allow the user to avoid
`horizontal scrolling and more efficiently
`display information, some conventional
`applications
`truncate headings
`for a
`column 31, 32, 34, 36, and 38. FIG. 3
`depicts a conventional method 50 for
`truncating column headings.
`4: 58 – 65.
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`The user enters the desired width of the
`column heading via step 52. A column is
`then retrieved via step 54. It is then
`determined via step 56 if the column is
`wider than the width set by the user. If the
`column is wider, then the column is
`truncated via step 58.
`4: 66 – 5: 3.
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`FIG. 4 depicts a table 70 displayed after
`the conventional method 50 has been
`used to truncate the columns to be five
`characters in width. The table 70 contains
`the same information as the table 30.
`Thus, the column 71 has a column
`heading for the "Syste" for the system. The
`column 72 has a heading "Bytes" for the
`bytes received. The column 74 has a
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` Exhibit 2001 / Page 19 of 52
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`Case IPR2018-00044
`Patent