throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC. (“APPLE”)
`
`Petitioner
`
`- vs. -
`
`UNILOC LUXEMBOURG, S.A. (“UNILOC”)
`
`Patent Owner
`
`U.S. Patent No. 6,622,018
`———————
`
`
`DECLARATION OF INGRID HSIEH-YEE, PHD,
`UNDER 37 C.F.R. § 1.68
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`APPL-1005 / Page 1 of 60
`Apple v. Uniloc
`
`

`

`I, Ingrid Hsieh-Yee, Ph.D., do hereby declare as follows:
`
`1.
`
`I have been retained as an independent expert witness on behalf of
`
`Apple Inc. (“Apple”) for an Inter Partes Review (“IPR”) of U.S. Patent No.
`
`6,622,018 (“the ’018 patent”).
`
`2.
`
`I am being compensated for my work in this matter at my accustomed
`
`hourly rate of $160.00. I am also being reimbursed for reasonable and customary
`
`expenses associated with my work and testimony in this investigation. My
`
`compensation is not contingent on the results of my study, the substance of my
`
`opinions, or the outcome of this matter.
`
`3.
`
`In the preparation of this declaration, I have reviewed the exhibits
`
`referenced below, each of these is a type of material that experts in my field would
`
`reasonably rely upon when forming their opinions:
`
`(1) Gralla, P., (“Idiot’s Guide”), THE COMPLETE IDIOT’S GUIDE TO
`PALMPILOT AND PALM III (1999), obtained from the Library of
`Congress, APPL-1008;
`
`(2) MARC Record Information for THE COMPLETE IDIOT’S GUIDE TO
`PALMPILOT AND PALM III (1999), available at the Library of Congress
`online catalog at http://lccn.loc.gov/99060353, accessed October 27,
`2017, APPL-1014;
`
`(3) Bibliographic Record Information for THE COMPLETE IDIOT’S GUIDE
`TO PALMPILOT AND PALM III (1999), available at the Library of
`
`
`
`
`
`APPL-1005 / Page 2 of 60
`
`

`

`Congress online catalog at
`https://catalog.loc.gov/vwebv/staffView?searchId=9743&recPointer=
`0&recCount=25&searchType=1&bibId=4523004, accessed October
`27, 2017, APPL-1015;
`
`(4) Copyright Record Information for THE COMPLETE IDIOT’S GUIDE TO
`PALMPILOT AND PALM III (1999), available at the Copyright Office
`online catalog at http://cocatalog.loc.gov/cgi-
`bin/Pwebrecon.cgi?v1=7&ti=1,7&Search%5FArg=Gralla%2C%20Pr
`eston&Search%5FCode=NALL&CNT=25&PID=4cP14XXoDB4ta1c
`_FBjwOuGJlE2tq&SEQ=20171107115849&SID=2, accessed
`November 7, 2017, APPL-1016;
`
`(5) MICROSOFT COMPUTER DICTIONARY (4TH EDITION ), obtained from the
`Library of Congress, APPL-1012;
`
`(6) MARC Record Information for MICROSOFT COMPUTER DICTIONARY
`(4TH EDITION ), available at the Library of Congress online catalog at
`http://lccn.loc.gov/99020168, accessed October 27, 2017, APPL-
`1017; and
`
`(7) Bibliographic Record Information for MICROSOFT COMPUTER
`DICTIONARY (4TH EDITION ), available at the Library of Congress
`online catalog at
`https://catalog.loc.gov/vwebv/staffView?searchId=9974&recPointer=
`0&recCount=25&searchType=1&bibId=740701, accessed October
`27, 2017, APPL-1018.
`
`4.
`
`In forming the opinions expressed within this declaration, I have
`
`considered:
`
`
`
`
`
`APPL-1005 / Page 3 of 60
`
`

`

`(1) The documents listed above;
`
`(2) The reference materials cited herein; and
`
`(3) My own academic background and professional experiences, as
`
`described below.
`
`5. My complete qualifications and professional experience are described
`
`in my curriculum vitae, a copy of which is attached as Appendix A. The following
`
`is a brief summary of my relevant qualifications and professional experience.
`
`6.
`
`I am currently a Professor in the Department of Library and
`
`Information Science at the Catholic University of America. I have experience
`
`working in an academic library, a medical library, and a legislative library and
`
`have been a professor for more than 25 years. I hold a Ph.D. in Library and
`
`Information Studies from the University of Wisconsin-Madison and a Masters in
`
`Library and Information Studies from the University of Wisconsin-Madison.
`
`7.
`
`I am an expert on library cataloging and classification and have
`
`published two books on this subject, Organizing Audiovisual and Electronic
`
`Resources for Access: A Cataloging Guide (2000, 2006). I teach a variety of
`
`courses, including “Cataloging and Classification,” “Internet Searches and Web
`
`Design,” “Advanced Cataloging and Classification,” “Organization of Internet
`
`Resources,” “Advanced Information Retrieval and Analysis Strategies,” and
`
`“Digital Content Creation and Management.” My research interests cover
`
`
`
`
`APPL-1005 / Page 4 of 60
`
`

`

`cataloging and classification, information organization, metadata, information
`
`retrieval, information architecture, digital collections, scholarly communication,
`
`user interaction with information systems, and others.
`
`8.
`
`I am fully familiar with a library cataloging encoding standard known
`
`as the “Machine-Readable Cataloging” standard, also known as “MARC,” which
`
`became the national standard for sharing bibliographic data in the United States by
`
`1971 and the international standard by 1973. MARC is the primary
`
`communications protocol for the transfer and storage of bibliographic metadata in
`
`libraries. Experts in my field would reasonably rely upon MARC records when
`
`forming their opinions.
`
`9.
`
`A MARC record comprises several fields, each of which contains
`
`specific data about the work. Each field is identified by a standardized, unique,
`
`three-digit code corresponding to the type of data that follows. Appendix B is a
`
`true and correct copy of Parts 7 to 10 of “Understanding MARC Bibliographic”
`
`(http://www.loc.gov/marc/umb/) from the Library of Congress that explains
`
`commonly used MARC fields. For example, the personal author of the work is
`
`recorded in Field 100, the title is recorded in Field 245, publisher information is
`
`recorded in Field 260, and the physical volume and characteristics of a publication
`
`are recorded in Field 300, and topical subjects are recorded in the 650 fields.
`
`10. Online Computer Library Center (OCLC) is the largest bibliographic
`
`
`
`
`APPL-1005 / Page 5 of 60
`
`

`

`network of the world, with more than 380 million records and more than 16,900
`
`member institutions (many of which are libraries of some type) from 122 countries.
`
`OCLC was created “to establish, maintain and operate a computerized library
`
`network and to promote the evolution of library use, of libraries themselves, and of
`
`librarianship, and to provide processes and products for the benefit of library users
`
`and libraries, including such objectives as increasing availability of library
`
`resources to individual library patrons and reducing the rate of rise of library per-
`
`unit costs, all for the fundamental public purpose of furthering ease of access to
`
`and use of the ever-expanding body of worldwide scientific, literary and
`
`educational knowledge and information.”1
`
`11. OCLC members can contribute original cataloging records in MARC
`
`to the system or derive cataloging records from existing records, an activity
`
`referred to as “copy cataloging”. When an OCLC participating institution acquires
`
`a work, it can create an original MARC record for this work in OCLC’s Connexion
`
`system (a system for catalogers to create and share MARC records), and the
`
`system will automatically generate a code for the date of record creation in the
`
`yymmdd format, and the creating library’s OCLC symbol is recorded in subfield a
`
`1 Third Article, Amended Articles of Incorporation of OCLC Online Computer Library Center,
`
`Inc. Revised May 20, 2008 (available at
`
`https://www.oclc.org/content/dam/oclc/membership/articles-of-incorporation.pdf)
`
`
`
`
`
`APPL-1005 / Page 6 of 60
`
`

`

`of the 040 field. Once the MARC record is in Connexion, it becomes available to
`
`other OCLC members for adoption to their local online catalogs. The record—
`
`presented in a labeled format, not MARC—also becomes searchable and viewable
`
`on WorldCat, which is a web portal to more than 10,000 libraries worldwide.
`
`12. Library online catalogs are based on MARC records that represent
`
`their collections and help the public understand what materials are publicly
`
`accessible in those libraries. Most libraries with online catalogs have made their
`
`catalogs freely available on the Web. These online catalogs offer user-friendly
`
`search interfaces, often in the form of a single search box, to support searching by
`
`author, title, subject, keywords and other data elements. They also offer features
`
`for users to narrow their search results by language, year, format, and other
`
`elements. Many libraries display MARC records on their online catalogs with
`
`labels for the data elements to help the public interpret MARC records. Many
`
`libraries also offer an option to display MARC records in MARC fields. For non-
`
`serial publications such as monographs, after a MARC record is created and made
`
`searchable on a library catalog, it is customary library practice to have the physical
`
`volume processed for public access soon after, usually within a week.
`
`13.
`
`I used authoritative information systems such as WorldCat
`
`(http://www.worldcat.org), the online catalog at the Library of Congress
`
`(https://catalog.loc.gov) and the public catalog of the United States Copyright
`
`
`
`
`
`APPL-1005 / Page 7 of 60
`
`

`

`Office (http://cocatalog.loc.gov/cgi-bin/Pwebrecon.cgi?DB=local&PAGE=First) to
`
`search for records. These records are identified and discussed in this declaration.
`
`Experts in the field would reasonably rely on the data described herein to form
`
`their opinions.
`
`APPL-1008
`
`14. APPL-1008 is a true and correct photocopy of portions of THE
`
`COMPLETE IDIOT’S GUIDE TO PALMPILOT AND PALM III (the “Idiot’s Guide”), that I
`
`made on October 31, November 9, 2017, December 7, and December 13 during my
`
`personal visits to the Library of Congress. When I was originally asked to prepare
`
`this declaration, I accessed WorldCat for “Complete Idiot’s Guide to PalmPilot and
`
`Palm III” and identified the Library of Congress as one of the libraries that hold
`
`this monograph. I then searched the Library of Congress online catalog to confirm
`
`the holdings information. The search results informed me that the Library of
`
`Congress provides access to the Idiot’s Guide.
`
`15. APPL-1008 is a true and correct copy of portions of the Idiot’s Guide
`
`that I made on October 31, November 9, 2017, December 7, and December 13,
`
`while the book was in my possession at the Library of Congress. I obtained APPL-
`
`1008 by personally scanning the front matter (the front cover, the title page, the
`
`copyright page, and the back cover) and select content pages from the Idiot’s
`
`Guide, specifically, the interior page describing the Graffiti Strokes, Writing
`
`
`
`
`APPL-1005 / Page 8 of 60
`
`

`

`Symbols, and Extended Characters, pages 13-37; 39-52; 83-99; 221-229; 245-252,
`
`301-305, of the book.
`
`a. Library of Congress – MARC & Bibliographic Records
`
`16. APPL-1014 is a true and correct copy of the MARC record for THE
`
`COMPLETE IDIOT’S GUIDE TO PALMPILOT AND PALM III book (APPL-1008) that I
`
`retrieved from the online catalog of the Library of Congress after searching for the
`
`book by “Complete Idiot’s Guide to PalmPilot and Palm III.” I personally
`
`identified and located this record, which experts in my field would reasonably rely
`
`upon when forming their opinions.
`
`17. APPL-1015 is a true and correct copy of the Bibliographic record
`
`for THE COMPLETE IDIOT’S GUIDE TO PALMPILOT AND PALM III book (APPL-1008)
`
`that I retrieved from the online catalog of the Library of Congress, which experts in
`
`my field would reasonably rely upon when forming their opinions. APPL-1015
`
`shows the holdings of this book and indicates interested users should “See
`
`Reference Staff. By Appt in Jefferson Main RR (MRC).” On my visit to the
`
`Library of Congress, I learned the access policy is that for titles in the MRC
`
`collection, users have to request needed titles in person at the Microform and
`
`Electronic Resources Center, and the titles will be brought to the Jefferson Main
`
`Reading Room of the Library of Congress. I was able to access THE COMPLETE
`
`IDIOT’S GUIDE TO PALMPILOT AND PALM III book at MRC during my visits on
`
`
`
`
`APPL-1005 / Page 9 of 60
`
`

`

`October 31, November 9, 2017, December 7, and December 13.
`
`18. Field 245 of the MARC record (APPL-1014) and the title of the
`
`Bibliographic record (APPL-1015) identify the book title as “The complete idiot’s
`
`guide to PalmPilot and Palm III.” Field 100 of the MARC record (APPL-1014)
`
`and the personal name of the Bibliographic record (APPL-1015) identify the book
`
`author as Preston Gralla. Field 260 of the MARC record (APPL-1014) and the
`
`published/created field of Bibliographic record (APPL-1015) show that the Idiot’s
`
`Guide was published by Que in Indianapolis, IN in 1999. Field 010 shows the
`
`book’s Library of Congress control number as “99060353,” which matches the
`
`Library of Congress card number on the copyright page of APPL-1008. Field 020
`
`shows the book’s the International Standard Book Number (ISBN) as
`
`“0789719673,” which matches the ISBN listed on the copyright page of APPL-
`
`1008.
`
`19. The first six digits of Field 008 of the MARC record (APPL-1014)
`
`inform me that the record for the book was first created on “990119” (i.e., January
`
`19, 1999) by “pcn” (i.e., the Preassigned Control Number program) that assigns
`
`control numbers in advance of publication to titles that are most likely to be
`
`acquired by the Library of Congress. Subfield a of Field 040 identifies “DLC” (i.e.,
`
`Library of Congress) as the creator of this MARC record. Field 955 shows the
`
`cataloging processing dates of this title at Library of Congress. It indicates the
`
`
`
`
`
`APPL-1005 / Page 10 of 60
`
`

`

`book was sent to the cataloging unit on “05-04-99” and the last cataloging date was
`
`“5-17-99 to ddc” meaning the book was sent on May 17, 1999 to the Dewey
`
`Decimal Classification (DDC) unit for a Dewey Decimal Classification number to
`
`be assigned to the record. This step usually takes less than a week. After material
`
`processing, this title would have become publicly accessible at Library of Congress
`
`soon after May 17, 1999. It is customary library practice to make new publications
`
`available to the public soon after the MARC record is added to the cataloging
`
`system, and in academic libraries it usually takes about a week after record
`
`creation for a new title to become publicly available. The large volume of materials
`
`for processing at Library of Congress means it may take longer than a week for this
`
`new publication to be processed for public access. My conservative estimate is that
`
`it could take two to three months for the item to be shelf-ready. This means THE
`
`COMPLETE IDIOT’S GUIDE TO PALMPILOT AND PALM III book would have been
`
`publicly available at Library of Congress at least by the end of August 1999, three
`
`months after the last cataloging task was completed in May 1999.
`
`20. Field 050 of the MARC Record (APPL-1014) and the LC
`
`classification field of the Bibliographic record (APPL-1015) show that the Idiot’s
`
`Guide has a Library of Congress Classification number of “QA76.8.P138 G73
`
`1999,” and QA76.8 is the class number for “special computers, computer systems,
`
`and microprocessors.” Field 082 shows the book has a Dewey Decimal
`
`
`
`
`
`APPL-1005 / Page 11 of 60
`
`

`

`Classification number of “004.165” which refers to the class number for “specific
`
`personal computers.” The subject heading in Field 650 indicates the book is about
`
`“PalmPilot (Computer).” Field 300 shows the book is accompanied by a computer
`
`laser optical disc. A local holdings note in Field 991 indicates the book is part of
`
`the collection of MRC. The MARC record of the Library of Congress makes the
`
`Idiot’s Guide book (APPL-1008) searchable on its library catalog. Interested users
`
`can search for and retrieve this book by author, title, Library of Congress control
`
`number, ISBN, subject areas represented by LC Classification number and DDC
`
`number, and subject terms in Field 650.
`
`21. Based on the information above, it is my opinion that THE COMPLETE
`
`IDIOT’S GUIDE TO PALMPILOT AND PALM III book (APPL-1008) is a book that has
`
`been made available by the Library of Congress, meaning that anyone who was
`
`interested in the topic would be able to search for and access the Idiot’s Guide.
`
`b. Library of Congress – Date Stamp
`
`22. The copyright page of the Idiot’s Guide in APPL-1008 bears a stamp
`
`of “LIBRARY OF CONGRESS MAR 24 1999 CIP” that indicates the date when
`
`the Cataloging in Publication Program (CIP) of the Library of Congress received
`
`the book. CIP is different from PCN in that CIP creates bibliographic records for
`
`forthcoming titles likely to be purchased by American libraries, while PCN assigns
`
`Library of Congress Control Numbers to titles likely to be added to the LC
`
`
`
`
`APPL-1005 / Page 12 of 60
`
`

`

`collection. This date stamp and the PCN information in Field 955 of APPL-1014
`
`inform me that PCN assigned the LC control number and created the MARC
`
`record on January 19, 1999 based on information provided by the publisher in
`
`advance of publication, and the physical volume was received by CIP on March
`
`24, 1999.
`
`c. United States Copyright – Copyright Registration
`
`23. APPL-1016 is a true and accurate copy of the copyright registration
`
`record obtained from the Library of Congress that evidences that the book authored
`
`by Preston Gralla titled “The Complete Idiot’s Guide to PalmPilot and Palm III,”
`
`with ISBN: 0-7897-1967-3 was published at least as of March 1, 1999. APPL-
`
`1016 was obtained by first accessing the http://www.copyright.gov/ website,
`
`selecting the hyperlink “Search Copyright Records,” and performing a search by
`
`the author, “Gralla, Preston,” to retrieve the record for “The Complete Idiot’s
`
`Guide to PalmPilot and Palm III.” I personally identified and located this record,
`
`which experts in my field would reasonably rely upon when forming their
`
`opinions. The date of publication shows the book was published on “1999-03-01”
`
`and the registration number/date shows “TX0004894198/ 1999-05-07.”
`
`24.
`
`In summary, based on the date stamp on the copyright page of APPL-
`
`1008, the cataloging dates in Field 955 of APPL-1014, and the copyright
`
`publication date of March 1, 1999 in APPL-1016, and my understanding of the
`
`
`
`
`APPL-1005 / Page 13 of 60
`
`

`

`ordinary and customary cataloging and processing practices of libraries, it is my
`
`opinion that the Idiot’s Guide (APPL-1008) was accessible at the Library of
`
`Congress to the public soon after the last cataloging work was completed in May
`
`1999, and no later than August 1999.
`
`APPL-1012
`
`25. APPL-1012 is a true and correct photocopy of portions of the
`
`MICROSOFT COMPUTER DICTIONARY (4TH EDITION ) (the “Microsoft Dictionary”),
`
`that I made on October 31, 2017 and November 16, 2017 during my personal visit
`
`to the Library of Congress. When I was originally asked to prepare this declaration,
`
`I searched WorldCat for “Microsoft Computer Dictionary” and identified the
`
`Library of Congress as one of the libraries that hold this monograph. I then
`
`searched the Library of Congress online catalog to confirm the holdings
`
`information. The search results informed me that the Library of Congress provides
`
`access to the Microsoft Dictionary.
`
`26. APPL-1012 is a true and correct copy of portions of the Microsoft
`
`Dictionary that I made on October 31, 2017 and November 16, 2017, while the
`
`book was in my possession at the Library of Congress. I obtained APPL-1012 by
`
`personally scanning the front matter (the front cover, the title page, the copyright
`
`page, and the back cover) and select content pages from Microsoft Computer
`
`Dictionary, specifically, pages 62, 115, and 290, of the book.
`
`
`
`
`APPL-1005 / Page 14 of 60
`
`

`

`a. Library of Congress – MARC and Bibliographic Records
`
`27. APPL-1017 is a true and correct copy of the MARC record for the
`
`MICROSOFT COMPUTER DICTIONARY (4TH EDITION ) (APPL-1012) that I retrieved
`
`from the online catalog of the Library of Congress after searching for the book by
`
`“Microsoft Computer Dictionary.” I personally identified and located this record,
`
`which experts in my field would reasonably rely upon when forming their
`
`opinions.
`
`28. APPL-1018 is a true and correct copy of the Bibliographic record
`
`for the MICROSOFT COMPUTER DICTIONARY (4TH EDITION ) (APPL-1012) that I
`
`retrieved from the online catalog of the Library of Congress, which experts in my
`
`field would reasonably rely upon when forming their opinions. APPL-1018 shows
`
`the holdings of this book and indicates it can be requested “By Appt in Jefferson
`
`Main RR (MRC),” meaning the Microform and Electronic Resources Center of the
`
`Jefferson Main Reading Room of the Library of Congress.
`
`29. Field 245 of the MARC record (APPL-1017) and the title of the
`
`Bibliographic record (APPL-1018) identify the book title as “Microsoft computer
`
`dictionary.” Field 260 of the MARC record (APPL-1017) and the
`
`published/created field of Bibliographic record (APPL-1018) show that the
`
`Microsoft Dictionary was published by Microsoft Press in Redmond, WA in 1999.
`
`Field 010 shows the Library of Congress control number as “99020168,” which
`
`
`
`
`APPL-1005 / Page 15 of 60
`
`

`

`matches the number on the copyright page of APPL-1012. Field 020 shows the
`
`International Standard Book Number as “0735606153,” which matches the ISBN
`
`on the copyright page and the back cover of APPL-1012.
`
`30. The first six digits of Field 008 of the MARC record (APPL-1017)
`
`inform me that the record for the book was first created on “990223” (i.e.,
`
`February 23, 1999), and subfield a of Field 040 indicates “DLC” (i.e., Library of
`
`Congress) was the creator. Field 955 shows the cataloging processing dates and the
`
`last date is “07/07/9” (i.e., July 7, 1999), which is congruent with the last record
`
`modification date recorded in Field 005 “19990709” (i.e., July 9, 1999). The large
`
`volume of materials for processing at the Library of Congress means it could take
`
`some time for the cataloged title to be ready for public access, but that time is
`
`unlikely to be more than three months. These dates inform my opinion that
`
`Microsoft Computer Dictionary would have been publicly available at the Library
`
`of Congress no later than October 1999, three months after the last cataloging work
`
`was completed.
`
`31. Field 050 of the MARC Record (APPL-1017) and the LC
`
`classification field of the Bibliographic record (APPL-1018) show that the
`
`Microsoft Dictionary has a Library of Congress Classification number of
`
`“QA76.15 .M538 1999,” and QA76.15 represents the class number for “Computer
`
`Science. Dictionaries and encyclopedias.” Field 082 shows the book has a Dewey
`
`
`
`
`
`APPL-1005 / Page 16 of 60
`
`

`

`Decimal Classification number of “004.03,” which represents the class number for
`
`“Computer science-Dictionaries.” Two subject headings in Field 650s indicate this
`
`book is about “Computers—Dictionaries” and “Microcomputers—Dictionaries.”
`
`In addition to the title, Field 246 shows this book is also searchable as “Computer
`
`dictionary.” A general note in Field 500 explains the previous editions had a title
`
`“Microsoft Press computer dictionary” and Field 730 makes that title searchable
`
`and link that title to this record. Field 300 shows this book is accompanied by a
`
`computer laser optical disc, and the local holdings information in Field 991 shows
`
`it is part of the collection of MRC. The MARC record makes the Microsoft
`
`Dictionary (APPL-1012) searchable in the Library of Congress online catalog.
`
`Users interested in dictionaries of computers or microcomputers would be able to
`
`search for and retrieve this book by the subject areas represented by the LC
`
`classification number and the DDC number, by the subject headings in Field 650s.
`
`They could also find this book by ISBN, title, variant title (field 246), and title of
`
`earlier edition.
`
`32. Based on the information above, it is my opinion that the MICROSOFT
`
`COMPUTER DICTIONARY (4TH EDITION ) (APPL-1012) is a book that has been made
`
`available by the Library of Congress, meaning that anyone who was interested in
`
`the topic would be able to search for and access the Microsoft Dictionary.
`
`a. Library of Congress – Date Stamp
`
`
`
`
`
`APPL-1005 / Page 17 of 60
`
`

`

`33. The copyright page of the Microsoft Dictionary in APPL-1012 bears
`
`a stamp of “LIBRARY OF CONGRESS JUL 1 1999 CIP” that indicates the date
`
`when the Cataloging in Publication program of the Library of Congress received
`
`the book.
`
`34. Based on the date stamp placed on the copyright page of APPL-1012,
`
`which has a date of July 1, 1999, the last cataloging completion date in Field 955
`
`and the last record modification date in Field 005 of APPL-1017, and my
`
`understanding of the ordinary and customary cataloging and processing practices
`
`of libraries, it is my opinion that Microsoft Computer Dictionary (APPL-1012)
`
`was publicly available at the Library of Congress no later than October 1999, three
`
`months after the cataloging work was completed.
`
`CONCLUSION
`
`35.
`
`In signing this declaration, I recognize that the declaration will be
`
`filed as evidence in a contested case before the Patent Trial and Appeal Board of
`
`the United States Patent and Trademark Office. I also recognize that I may be
`
`subject to cross-examination in the case. If cross-examination is required of me, I
`
`will appear.
`
`36.
`
`I hereby declare that all statements made herein on my own
`
`knowledge are true and that all statements made on information and belief are
`
`
`
`
`
`APPL-1005 / Page 18 of 60
`
`

`

`believed to be true, and further, that these statements were made with the
`
`knowledgethat willful false statements and the like so made are punishableby fine
`
`or imprisonment, or both, under Section 1001 of Title 18 of the United States
`
`Code.
`
`Date:
`
`/c6? -/Y -20/7
`
`
`
`Executed: ogee /Logit (donbpor
`
`
`
`Ingrid Hsieh-Yee, Ph
`
`APPL-1005 / Page 19 of 60
`
`APPL-1005 / Page 19 of 60
`
`

`

`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`APPENDIX A
`APPENDIX A
`
`APPL-1005 / Page 20 of 60
`
`APPL-1005 / Page 20 of 60
`
`

`

`
`
`Ingrid Hsieh-Yee
`Professor
`Dept. of Library and Information Science
`Catholic University of America
`Washington, D.C. 20064
`E-mail: hsiehyee@cua.edu
`Phone: (202) 319-5085
`Fax: (202) 319-5574
`
`
`Education
`
`Ph.D. Library and Information Studies, University of Wisconsin-Madison
`
`Minors: Sociology and Psychology
`
`M.A. Library and Information Studies, University of Wisconsin-Madison.
`
`M.A. Comparative Literature, University of Wisconsin-Madison.
`
`B.A. Foreign Languages and Literature, National Taiwan University.
`
`
`Work Experience
`
`Professor, School/Dept. of Library and Information Science, Catholic University of America,
`2004- (Assistant Professor, 1990-1996; Associate Professor, 1997-2004)
`
`
`Co-Chair, Dept. of Library and Information Science, Catholic University of America, June 2015-
`August 2016.
`
`
`Acting Dean, School of Library and Information Science, Catholic University of America,
`January 2010-June 2012.
`
`
`Cataloger, Dept. of Legislative Reference Library, Annapolis, Maryland, 1989-1990.
`
`Lecturer, School of Library and Information Studies, University of Wisconsin-Madison, 1988.
`
`Teaching Assistant, School of Library and Information Studies, University of Wisconsin-
`Madison, 1986-1988.
`
`
`Cataloger, Health Sciences Library, University of Wisconsin-Madison, 1984-1986.
`
`Areas of Teaching and Research Interests
`
`Information Organization and Access; Metadata; Cataloging & Classification; Information
`Architecture; Information Retrieval; Digital Collections; Scholarly Communication; Information
`
`APPL-1005 / Page 21 of 60
`
`

`

`
`Behavior; Health Informatics; Human Computer Interaction; Usability Studies
`
`Grants & Honors
`
`Cultural Heritage Information Management Project. IMLS grant. Amount: $498,741. Period:
`Aug. 2012 to July 2015. Co-PI with Dr. Youngok Choi.
`
`2
`
`
`D.C. Health Information Technology (HIT4): Building Capacity & Providing Access in Our
`Nation’s Capital. Dept. of Labor H2B Training Grant. Grant amount: $4,175,500. Grant
`period: Nov. 2011 to Dec. 2015. Partner with the Metropolitan School of Professional
`Studies of the Catholic University of America, Children’s National Medical Center, D.C.
`Department of Employment Services, Holy Cross Hospital, Howard University, Center
`for Urban Progress, Providence Hospital, and Sibley Memorial Hospital.
`
`
`Capital Health Careers Project. Department of Labor Healthcare Sector and Other High Growth
`and Emerging Industries Grant. Grant amount: $4,953,999. Grant period: March 2010 –
`February 2013. Awarded to a group of healthcare organizations and educational
`institutions in Washington, D.C. Providence Health Foundation of Providence Hospital
`(Lead institution). Part of the grant supported the development of a Master’s degree
`program in Information Technology with a concentration in Health Information
`Technology offered by the School of Library and Information Science.
`
`
`The Washington D.C. School Librarians Project. IMLS grant. Grant amount: $412,660. Grant
`period: Aug. 2007 – June 2011. The School partnered with the District of Columbia
`Public Schools (DCPS) and the District of Columbia Library Association to educate and
`mentor school media specialists for the DCPS system. PI, Jan. 2010 to June 2011.
`
`
`SIG Member of the Year, American Society for Information Science and Technology (2009).
`
`Most Outstanding Paper of OCLC Systems & Services (2001).
`
`ALISE Research Grant (2001).
`
`Most Outstanding Paper of OCLC Systems & Services (2000).
`
`Research Grant from ERIC (1999-2000).
`
`Best Research Paper Award; Association for Library and Information Science Education (1998).
`
`Research Grants, Catholic University of America. 1991, 1992, 1993, 1996, 1998, 1999, 2004,
`2005, 2006, 2007, 2013-14.
`
`
`Cooperative Faculty Research Grant, Consortium of Universities in the Washington
`Metropolitan Area (1993-1994).
`
`
`
`APPL-1005 / Page 22 of 60
`
`

`

`3
`
`
`Cooperative Research Grant, Council on Library Resources (1993-1994).
`
`Journal of the American Society for Information Science Best Paper Award (1993).
`
`ASIS/ISI Information Science Doctoral Dissertation Scholarship (1989).
`
`HEA Title IIB Fellowship (Dept. of Education) (1989)
`
`Chinese-American Librarians Association Scholarship (1987).
`
`Beta Phi Mu (1985).
`
`Vilas Fellowship, University of Wisconsin-Madison. 1984
`
`
`Publications
`
`Choi, Y., and Hsieh-Yee, I. (2010). Finding Images in an OPAC: Analysis of User Queries,
`Subject Headings, and Description Notes. Canadian Journal of Information and Library
`Science, 34(3): 271 – 295.
`
`
`Hsieh-Yee, I. (2008). Educating Cataloging Professionals in a Changing Information
`Environment. Journal of Education for Library and Information Science, 46(2): 93-106.
`
`
`Vellucci, S. L., Hsieh-Yee, I., and Moen, W.E. (2007). The Metadata Education and Research
`Information Commons (MERIC): A Collaborative Teaching and Research Initiative.
`Education for Information, 25(3&4): 169-178.
`
`
`NISO Framework for Guidelines for Building Good Digital Collections. 3rd ed. Baltimore, MD:
`National Information Standards Organization, 2007. Also available online:
`http://www.niso.org/framework/framework3.pdf (NISO Working Group members:
`Priscilla Caplan (chair), Grace Agnew, Murtha Baca, Tony Gill, Carl Fleischhauer, Ingrid
`Hsieh-Yee, Jill Koelling, and Christie Stephenson.)
`
`
`Choi, Y., Hsieh-Yee, I., and Kules, B. (2007). Retrieval Effectiveness of TOC and LCSH.
`Proceedings of the Joint Conference on Digital Libraries, pp. 233-234.
`
`
`Vellucci, S., and Hsieh-Yee, I. (2007). They Didn’t Teach Me That in Library School! Building
`a Digital Teaching Commons to Enhance Metadata Teaching, Learning and Research.
`Proceedings of the National Conference of the Association of College and Research
`Libraries, Baltimore, MD, pp. 26-31.
`
`
`Mitchell, Vanessa, and Ingrid Hsieh-Yee. (2007). Converting Ulrich’s Subject Headings to
`FAST Headings: A Feasibility Study. Cataloging & Classification Quarterly, 45(1): 59-
`85.
`
`APPL-1005 / Page 23 of 60
`
`

`

`
`
`Hsieh-Yee, I., Tang, R., and Zhang, S. (2007). User Perceptions of a Federated Search System.
`IEEE Technical Committee on Digital Libraries Bulletin, Summer 3(2) (URL =
`http://www.ieee-tcdl.org).
`
`4
`
`
`Tang, R., Hsieh-Yee, I., and Zhang, S. (2007). User Perceptions of MetaLib Combined Search:
`An Investigation of How Users Make S

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