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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`VILOX TECHNOLOGIES, LLC.
`Patent Owner
`
`Case IPR2018-00044
`Patent No. 7,302,423
`
`DECLARATION OF LUCILLE MARIE DE BELLIS
`
`
`
`
`
`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Lucille Marie De Bellis
`
`I, Lucille Marie De Bellis, declare as follows:
`
`1. My name is Lucille Marie (“Missy”) De Bellis, and I live in Palm Beach,
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`Florida. I am over the age of 18, and I make this declaration based on my
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`personal knowledge.
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`2.
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`I make this Declaration in support of Patent Owner’s Reply to Petitioner’s
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`Opposition to Patent Owner’s Motion to Amend in the matter of IPR2018-
`
`00044.
`
`3.
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`I am not being compensated for this Declaration. I hold no interest in Vilox,
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`LLC or in the patent that I understand is the subject of this matter.
`
`4. My prior Declaration, Exhibit 2022, provides my relevant employment,
`
`experience, and connection to Dr. Joseph L. De Bellis, including my
`
`acquisition of information and evidence corroborating conception of the
`
`inventions disclosed and claimed in U.S. Patents 6,760,720 and 7,302,423, the
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`later patent being the subject of this IPR.
`
`5.
`
`In addition to the conceptual descriptions noted in my prior Declaration, Dr.
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`De Bellis described his truncation processes, as well as his iterative search
`
`processes, as enabling the display of all data entries that might be returned,
`
`for example, from a data base search, on a single display page. The truncation
`
`process would reduce the number of characters in an entry, which in turn
`
`Exhibit 2029 / Page 2
`f 10
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Lucille Marie De Bellis
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`would result in fewer lines of data. As an example, he described a search of
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`all cities in a State as collapsing to the alphabetic spectrum, A – P and R – Z,
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`assuming that State had no city starting with the letter Q. Absence of the letter
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`Q in the returned list would provide information that may be helpful to the
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`user.
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`6.
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`Dr. De Bellis further explained that the displayed result list could be adapted
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`to fit on any size display. For example, on a large computer screen, the search
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`result list would have more entries than would a list for the same search but
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`displayed on a small screen device such as on a wrist device.
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`7.
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`At the same time as he conceived of his truncation processes, Dr. De Bellis
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`conceived of ways to make an iterative search displayable on any display by
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`using an overlapping structure. Exhibit 2025, Figure 10 of the ‘720 Patent,
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`referenced with my prior Declaration, shows this concept. As Exhibit 2025
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`shows, each successive list slightly overlaps the preceding list. This overlap
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`was forced because the horizontal space available for the display of the
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`iterative search of Figure 10 had been reached; any further searches would
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`have caused even greater overlap – what Dr. De Bellis referred to as
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`“stacking.”
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`8.
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`Throughout the September-November 1999 timeframe, I witnessed the
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`
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`progress made by Dr. De Bellis and Mr. Freire in developing the search-on-
`Exhibit 2029 / Page 3
`f 10
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Lucille Marie De Bellis
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`the-fly system.
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`9.
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`By November 1999, Dr. De Bellis and Mr. Freire had created a database of
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`movies and demonstrated how the database could be searched using the
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`search-on-the- fly process and system. Mr. Freire also developed data bases
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`from a phone book and from Federal databases related to health plans. The
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`search-on-the-fly system used recognition rather than recall as the basis for its
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`operation. Thus, a user could find the desired results from any starting point,
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`such as searching the first name even if the last name was unknown. The user
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`also could derive useful information from truncated data as well as “missing
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`data” such as the lack of a Q is a truncated list of city names.
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`10. As I stated in my prior Declaration, during a December 1999 visit by his patent
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`attorneys, Dr. De Bellis demonstrated a fully functional version of his search-
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`on-the-fly process and system. Exhibit 2025 is Figure 10 to U.S. Patent
`
`6,760,720, which I previously noted is a marked-up reproduction of a
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`screenshot of an iterative search enabled by the search-on-the-fly system
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`developed and demonstrated by Dr. De Bellis and Mr. Freire. Exhibit 2025
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`shows an iterative search of the telephone book data base with truncated
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`intermediate results and culminating in a display of (fictional) contact data for
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`Dr. De Bellis.
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`Exhibit 2029 / Page 4
`f 10
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`11.
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`Case IPR2018-00044
`Patent No. 7,302,423
`Declaration of Lucille Marie De Bellis
`
`I declare that all statements made herein based on my own knowledge are true
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`and correct to the best of my knowledge and that I made all statements with
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`the knowledge that willful false statements are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the United States
`
`Code.
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`Date October 22, 2018
`
`
`
`
`Lucille M. De Bellis
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`Exhibit 2029 / Page 5
`f 10
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`
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`
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