Declaration of Dr. Ingrid Hsieh-Yee In Support Of
`Petition for Inter Partes Review of USP 7,489,786
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`In re Inter Partes Review of:
`U.S. Patent No. 7,489,786
`Issued: February 10, 2009
`Application No.: 10/316,961
`Filing Date: December 11, 2002
`
`)
`)
`)
`)
`)
`
`For: Audio Device Integration System
`FILED VIA E2E
`
`DECLARATION OF INGRID HSIEH-YEE, PH.D,
`UNDER 37 C.F.R. § 1.68
`
`Jaguar Land Rover
`Exhibit 1012
`Page 001
`
`
`Petition for Inter Partes Review of USP 7,489,786
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`In re Inter Partes Review of:
`U.S. Patent No. 7,489,786
`Issued: February 10, 2009
`Application No.: 10/316,961
`Filing Date: December 11, 2002
`
`)
`)
`)
`)
`)
`
`For: Audio Device Integration System
`FILED VIA E2E
`
`DECLARATION OF INGRID HSIEH-YEE, PH.D,
`UNDER 37 C.F.R. § 1.68
`
`Jaguar Land Rover
`Exhibit 1012
`Page 001
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`I, Ingrid Hsieh-Yee, Ph.D., do hereby declare as follows:
`
`
`1.
`
`I have been retained as an independent expert witness on behalf
`
`of JAGUAR LLC (“Jaguar”) for Inter Partes Review (“IPR”) of U.S. Patent
`
`No. 7,489,786.
`
`2.
`
`I am being compensated for my work in this matter at my
`
`accustomed hourly rate. 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) Mufid, A.M. (2000). Future Automotive Multimedia Subsystem
`
`Interconnect Technologies (“Mufid”), in Automotive Electronics :
`
`Delivering Technology’s Promise, SAE Conference Proceedings,
`
`no. 360 (2000), pp. 167-182, obtained from Library of Congress
`
`on May 11, 2018, Exhibit-1;
`
`(2) Bibliographic record for Automotive Electronics available at the
`
`online catalog of Library of Congress at
`
`Jaguar Land Rover
`Exhibit 1012
`Page 002
`
`
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`https://lccn.loc.gov/2001269738, accessed May 8, 2018, Exhibit-
`
`2;
`
`(3) MARC record for Automotive Electronics available at the online
`
`catalog of Library of Congress at
`
`https://catalog.loc.gov/vwebv/staffView?searchId=9511&recPoint
`
`er=0&recCount=25&searchType=0&bibId=12452747, accessed
`
`May 8, 2018, Exhibit-3;
`
`(4) Mufid, A.M. (2000). Future Automotive Multimedia Subsystem
`
`Interconnect Technologies (“Mufid”), in Automotive Electronics :
`
`Delivering Technology’s Promise, SAE Conference Proceedings,
`
`no. 360 (2000), pp. 167-182, obtained from the library of the
`
`Massachusetts Institute of Technology through WTS (Wisconsin
`
`TechSearch) on May 22, 2018, Exhibit-4;
`
`(5) Bibliographic record for Automotive Electronics available at the
`
`online catalog of the Massachusetts Institute of Technology
`
`Libraries at http://library.mit.edu/item/000959917, accessed May
`
`22, 2018, Exhibit-5;
`
`(6) MARC record for Automotive Electronics available at the online
`
`catalog of the Massachusetts Institute of Technology Libraries at
`
`http://library.mit.edu/F/37UUX4LQB1MHNPQFHSLA7TP5S212
`
`Jaguar Land Rover
`Exhibit 1012
`Page 003
`
`
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`MH7YAKU66UGES4DCSECHG6-01482?func=full-set-
`
`set&set_number=018233&set_entry=000001&format=001,
`
`accessed on May 22, 2018, Exhibit-6;
`
`(7) Mufid, A.M. (2000). Future Automotive Multimedia Subsystem
`
`Interconnect Technologies (“Mufid”), in Automotive Electronics :
`
`Delivering Technology’s Promise, SAE Conference Proceedings,
`
`no. 360 (2000), pp. 167-182, obtained from the library of the
`
`Pennsylvania State University through WTS on May 22, 2018,
`
`Exhibit-7;
`
`(8) Bibliographic record for Automotive Electronics available at the
`
`online catalog of the Pennsylvania State University Libraries at
`
`https://cat.libraries.psu.edu/ from a title search on May 22, 2018,
`
`Exhibit-8;
`
`(9) MARC record for Automotive Electronics available at the online
`
`catalog of the Pennsylvania State University Libraries at
`
`https://cat.libraries.psu.edu/ from a title search and a display of
`
`detailed information in MARC on May 22, 2018, Exhibit-9.
`
`4.
`
`In forming the opinions expressed within this declaration, I
`
`have considered:
`
`Jaguar Land Rover
`Exhibit 1012
`Page 004
`
`
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`(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 provided 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, Advanced Cataloging and
`
`Jaguar Land Rover
`Exhibit 1012
`Page 005
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`Classification, Organization of Internet Resources, Organization of
`
`Information, Digital Content Creation and Management, Internet Searches
`
`and Web Design, Information Literacy Instruction, and Advanced
`
`Information Retrieval and Analysis Strategies. My research interests cover
`
`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 of 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/)
`
`Jaguar Land Rover
`Exhibit 1012
`Page 006
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`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,
`
`the physical volume and characteristics of a publication are recorded in Field
`
`300, and topical subjects are recorded in the 650 fields.
`
`10. The Online Computer Library Center (OCLC) is the largest
`
`bibliographic network of the world, with more than 380 million records and
`
`more than 16,964 member institutions (many of which are libraries of some
`
`type) from 122 countries. According to the “Third Article, Amended
`
`Articles of Incorporation of OCLC Online Computer Library Center, Inc.,”
`
`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.” The Third Article, Amended Articles of Incorporation of
`
`OCLC Online Computer Library Center, Inc. was last revised on November
`
`Jaguar Land Rover
`Exhibit 1012
`Page 007
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`30, 2016 and is available at
`
`https://www.oclc.org/content/dam/oclc/membership/articles-of-
`
`incorporation.pdf (presented as Appendix C).
`
`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 ǂa of the 040 field. Once the MARC
`
`record is in Connexion, it becomes available (i.e., copy cataloging) to other
`
`OCLC members for adoption to their local online catalogs.
`
`12. OCLC uses a master record system in which the creation date
`
`of an original record (i.e., the master record) is never changed in the OCLC
`
`Connexion cataloging system unless the master record is replaced by another
`
`record. When a library uses a master record to create a copy cataloging
`
`record, changes made to the master record will result in a copy cataloging
`
`record, which is saved in the copy cataloging agency’s account and exported
`
`Jaguar Land Rover
`Exhibit 1012
`Page 008
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`into the local cataloging system and displayed in that library’s online
`
`catalog, but the master record remains unchanged in the OCLC Connexion
`
`cataloging system. In most library catalogs, copy cataloging records
`
`exported from OCLC Connexion retain the creation date of the original
`
`record in Field 008, and libraries use other internal systems to keep track of
`
`the time when a copy cataloging record is added to the local cataloging
`
`system. The practice varies. Some libraries use local note fields to
`
`document their copy cataloging activities, while others use holdings records
`
`to document the time when a record is added to a local system. The catalog
`
`of Library of Congress uses a slightly different approach in that the system
`
`uses Field 008 to record the time a record, original or copy cataloging, is
`
`added to the system, and uses Field 955 to document cataloging and
`
`processing activities associated with a publication.
`
`13. After a MARC record is created in Connexion, it also becomes
`
`searchable and viewable on WorldCat, which is a web portal to more than
`
`10,000 libraries worldwide. The record in WorldCat, however, is not
`
`presented in MARC fields. Instead, the data elements are labeled to help
`
`users interpret the record.
`
`14. WorldCat (http://www.worldcat.org) is “the world’s largest
`
`Jaguar Land Rover
`Exhibit 1012
`Page 009
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`network of library content and services” and its features are summarized in
`
`“What is WorldCat” (http://www.worldcat.org/whatis/default.jsp). Through
`
`WorldCat users can search for information in their local libraries and
`
`libraries around the world. WorldCat allows users to search for books, CDs,
`
`videos, and many new types of digital content, such as audiobooks, in many
`
`languages. Users can also retrieve research materials and article citations
`
`with links to their full text. After an item is retrieved, WorldCat helps users
`
`identify a library nearby that holds the item or all the libraries that hold the
`
`item. WorldCat is an efficient way to explore the content held by more than
`
`10,000 libraries around the world.
`
`15. Library online catalogs are based on MARC records that
`
`represent their collections in order to 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. Strong user interest in
`
`keyword searches and the popularity of Google have led to the
`
`“googlization” of library search systems. As a result, many library catalogs
`
`now provide a single search box for users to conduct keyword searches, with
`
`additional support for searches by author, title, subject terms, and other data
`
`elements such as ISBN (International Standard Book Number). Library
`
`Jaguar Land Rover
`Exhibit 1012
`Page 010
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`catalogs these days 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 the
`
`option to display MARC records in MARC fields.
`
`16.
`
`I am personally familiar with many online catalogs, databases,
`
`and search engines. In preparing for this declaration I used authoritative
`
`information systems such as WorldCat, the online catalog of the Library of
`
`Congress, the online catalog of the Massachusetts Institute of Technology
`
`(MIT) Libraries and the online catalog of the Pennsylvania State University
`
`(Penn State) Libraries 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.
`
`Exhibit-1 (Library of Congress)
`
`17.
`
` Exhibit-1 is a true and correct copy of Future Automotive
`
`Multimedia Subsystem Interconnect Technologies (“Mufid”), in Automotive
`
`Electronics : Delivering Technology’s Promise, SAE Conference
`
`Proceedings, no. 360 (2000), pp. 167-182, which I obtained from Library of
`
`Congress on May 11, 2018. When I was originally asked to prepare this
`
`Jaguar Land Rover
`Exhibit 1012
`Page 011
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`declaration, I searched WorldCat (http://www.worldcat.org) for this article
`
`by its title “Future Automotive Multimedia Subsystem Interconnect
`
`Technologies” and the search results informed me that Library of Congress
`
`holds the physical volume of the conference proceedings that contains this
`
`article. I then searched the online catalog of the Library of Congress at
`
`https://catalog.loc.gov for “automotive electronics delivering technology’s
`
`promise” and the search results confirmed that Library of Congress holds
`
`this publication. Library of Congress records inform me the publication is
`
`assigned “TL272.5 .I577 2000” as its call number and the library has one
`
`copy that is available for request at the “Jefferson or Adams Building
`
`Reading Rooms.” I requested access to this copy and visited Library of
`
`Congress on May 11, 2018 to use it. While the physical volume was in my
`
`possession at the Jefferson Reading Room I personally scanned the cover,
`
`title page, copyright page, Conference Committee page, introduction, table
`
`of contents, and the “Mufid” article (presented as Exhibit-1).
`
`18. The cover of Exhibit-1 presents “Convergence 2000
`
`Proceedings,” “Automotive electronics delivering technology’s promise,”
`
`and “International Congress on Transportation Electronics” together with the
`
`date and place of the conference. The title page presents “AUTOMOTIVE
`
`ELECTRONICS Delivering Technology’s Promise” as the title with a
`
`Jaguar Land Rover
`Exhibit 1012
`Page 012
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`subtitle “proceedings of the 2000 International Congress on Transportation
`
`Electronics” and a number “P-360.” The title page also presents the Society
`
`of Automotive Engineers, Inc. in Warrendale, PA as the publisher and lists
`
`“October 2000” as the publication date. The copyright page shows a written
`
`call number for this volume, “TL272.5 .I577 2000,” an ISBN (International
`
`Standard Book Number) of “0-7680-0667-8” and an LC control number of
`
`“2001 269738.” The Conference Committee page shows a date stamp of
`
`“Library of Congress December 11 2000 Copyright Office.” The table of
`
`contents shows on page 8 of Exhibit-1 “2000-01-C028 Future Automotive
`
`Multimedia Subsystem Interconnect Technologies” by “Akram M. Mufid,
`
`Visteon Automotive Systems” that appears from pages 167 to 182. Page 14
`
`of Exhibit-1 shows the document number “2000-01-C028,” the article title,
`
`and the company “Visteon Automotive Systems” but not the name of Akram
`
`M. Mufid.
`
`Exhibit-2 (Library of Congress)
`
`19. Exhibit-2 is a true and correct copy of the Bibliographic record
`
`for Automotive Electronics : Delivering Technology’s Promise, SAE
`
`Conference Proceedings, no. 360 (2000), which contains the Mufid article,
`
`Future Automotive Multimedia Subsystem Interconnect Technologies (pp.
`
`Jaguar Land Rover
`Exhibit 1012
`Page 013
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`167-182). I personally identified and located this record on May 8, 2018,
`
`which experts in my field would reasonably rely upon when forming their
`
`opinion. Exhibit-2 informs me Library of Congress holds the Convergence
`
`2000 conference proceedings, which has a call number of “TL272.5 .I577
`
`2000.” Copy 1 is held at one of the reading rooms, while Copy 2 is stored
`
`offsite at Fort Meade, and users can request access to these copies at the
`
`“Jefferson or Adams Building Reading Rooms.”
`
`Exhibit-3 (Library of Congress)
`
`20. Exhibit-3 is a true and correct copy of the MARC record for
`
`Automotive Electronics : Delivering Technology’s Promise, SAE Conference
`
`Proceedings, no. 360 (2000), which contains the Mufid article, Future
`
`Automotive Multimedia Subsystem Interconnect Technologies (pp. 167-
`
`182). I personally identified and located this MARC record on May 8, 2018,
`
`which experts in my field would reasonably rely upon when forming their
`
`opinion. Subfield ǂa of Field 040 of the MARC record informs me the
`
`record was originally created by “EYG,” the OCLC symbol for the General
`
`Motors R&D Center Library in Michigan, according to the Directory of
`
`OCLC Members (https://www.oclc.org/en/contacts/libraries.html); and
`
`subfield ǂd indicates “DLC,” the OCLC symbol for Library of Congress,
`
`Jaguar Land Rover
`Exhibit 1012
`Page 014
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`modified the original record. Field 042 clarifies this record is “lccopycat”
`
`meaning the Library of Congress record is a copy cataloging record that is
`
`based on a record created earlier by another agency. While most copy
`
`cataloging agencies display their copy catalog record with the master
`
`record’s creation date in Field 008, Library of Congress does not do that.
`
`Instead, Library of Congress uses Field 008 to indicate the date a record is
`
`added to the Library of Congress system and Field 955 to keep track of their
`
`cataloging activities. Field 008 shows the LC record was created on
`
`“010626” (i.e., June 26, 2001) and Field 955, a field for local notes on the
`
`cataloging process at Library of Congress, shows the record was forwarded
`
`to the DDC unit on “2001-09-26” for a Dewey Decimal number to be
`
`assigned, which is typically the last step of cataloging at Library of
`
`Congress. In most academic libraries, newly cataloged books are made
`
`available soon after cataloging records are completed, usually within a week.
`
`The volume of materials for processing at Library of Congress means it may
`
`take longer than a week for a newly cataloged publication to be available to
`
`the public. My conservative estimate is that after the record was completed
`
`on September 26, 2001, the publication would have been available to the
`
`public at Library of Congress no later than December 26, 2001, three months
`
`after record completion.
`
`Jaguar Land Rover
`Exhibit 1012
`Page 015
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`21. Field 010 shows the LC control number (LCCN) for this
`
`
`
`publication is “2001269738,” which is the same as the number printed on the
`
`copyright page of Exhibit-1. Library of Congress has used LCCN to control
`
`its cataloging records since 1898. LCCN is a unique identifier that enables
`
`users to locate a catalog record for a publication quickly. The year portion
`
`of LCCN typically represents the year when the control number was
`
`assigned. The reason that a 2000 publication carries a 2001 control number
`
`is due to the fact that Library of Congress has a Preassigned Control Number
`
`Program (PCN) that assigns “control numbers in advance of publication to
`
`those titles that may be added to the Library's collections” (see more about
`
`PCN at https://www.loc.gov/publish/pcn/about/).
`
`22. Field 020 shows the ISBN (International Standard Book
`
`Number) for this publication is “0768006678,” which is identical to the
`
`ISBN printed on the copyright page of Exhibit-1. Field 111 informs me the
`
`name of the conference established for cataloging purposes is “International
`
`Congress on Transportation Electronics (2000 : Detroit, Mich.)” and Field
`
`245 shows the main title is “Automotive electronics : delivering technology's
`
`promise : proceedings of the 2000 International Congress on Transportation
`
`Electronics.” Two 246 fields show the publication has two variant titles--
`
`“Proceedings of the 2000 International Congress on Transportation
`
`Jaguar Land Rover
`Exhibit 1012
`Page 016
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`Electronics” and “Convergence 2000”--and users can use these titles, in
`
`addition to the main title in Field 245, to locate this publication. Field 260
`
`shows the Society of Automotive Engineers in Warrendale, PA published
`
`this book in 2000. Field 490 and Field 830 show the publication belongs to
`
`a series “P (Society of Automotive Engineers)” and its number is “P-360.”
`
`Field 050 shows this publication has a call number by which users can
`
`request the item. Subfield ǂa of Field 050, “TL272.5” in this case, indicates
`
`the subject matter of this publication. The number is assigned from the
`
`Library of Congress Classification (LCC) system, which is used by most
`
`research and academic libraries in the United States and many other
`
`countries. LCC consists of 21 main classes covering many disciplines, such
`
`as philosophy, religion, arts, science, technology, and military science.
`
`“TL272.5” represents the “Electronic equipment” in motor vehicles category
`
`of the LCC scheme. Users interested in this topic could explore a library’s
`
`materials in this topic area by entering this number in a library catalog as a
`
`keyword. The Library of Congress online catalog, for example, will retrieve
`
`materials that have been assigned this subject number when a user enter
`
`“TL272.5” in its single search box. Field 082 shows the publication is
`
`assigned a Dewey Decimal Classification (DDC) number of “629.27,” which
`
`represents the “other equipment” of motor vehicles category of the DDC
`
`Jaguar Land Rover
`Exhibit 1012
`Page 017
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`system. DDC is another major classification system for library materials. It
`
`was originally designed by Melvil Dewey in 1876 and has been expanded
`
`through 23 editions. DDC consists of 10 classes that represent many
`
`disciplines and subjects. It is used by more than 200,000 libraries in more
`
`than 135 countries. DDC is mainly used by public and school libraries.
`
`Users interested in a topic represented by a DDC number, such as “629.27”
`
`in this case, could search it as a keyword in the Library of Congress catalog
`
`to retrieve materials that have been assigned the same DDC number.
`
`Subjects of this publication are also represented by three Library of
`
`Congress subject headings: Automobiles with a topical subdivision,
`
`Electronic equipment; Intelligent control systems; and Intelligent
`
`transportation systems. Subfield ǂv “Congresses” indicates these topics were
`
`presented at a conference. These subject terms can be searched in library
`
`catalogs as keywords to retrieve like items. This MARC record (Exhibit-3)
`
`makes this publication searchable at the online catalog of Library of
`
`Congress, and users interested in the topics of the book can find it by the
`
`subject terms listed in Field 650 or the classification numbers listed in Field
`
`050 and Field 082. Field 035 indicates this MARC record has an OCLC
`
`control number of “45252210,” which makes this publication searchable on
`
`WorldCat. In other words, when users locate this publication on WorldCat,
`
`Jaguar Land Rover
`Exhibit 1012
`Page 018
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`they will learn that Library of Congress holds this publication, as I did
`
`during my research on WorldCat.
`
`23. Taken together, the date stamp, the bibliographic record and the
`
`MARC record inform my opinion that Library of Congress received their
`
`copy of Automotive Electronics : Delivering Technology’s Promise on
`
`December 11, 2000. The records, together with my knowledge of cataloging
`
`practices and standards and the customary library practices for processing
`
`materials for user access, inform my opinion that the physical volume of
`
`Automotive Electronics : Delivering Technology’s Promise : proceedings of
`
`the 2000 International Congress on Transportation Electronics, which
`
`contains the Mufid article, was available (e.g., searchable in the library
`
`catalog and available in the library) for public access at Library of Congress
`
`no later than Dec. 26, 2001, three months after the cataloging process was
`
`completed. The three months estimate for processing materials for user
`
`access is a conservative estimate because of the large volume of materials
`
`that are processed at Library of Congress.
`
`Exhibit-4 (MIT Libraries)
`
`24. Exhibit-4 is a true and correct copy of Future Automotive
`
`Multimedia Subsystem Interconnect Technologies (“Mufid”), in Automotive
`
`Jaguar Land Rover
`Exhibit 1012
`Page 019
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`Electronics : Delivering Technology’s Promise, SAE Conference
`
`Proceedings, no. 360 (2000), pp. 167-182, which I obtained, with the
`
`assistance of Wisconsin TechSearch (WTS), a document delivery service of
`
`the University of Wisconsin-Madison, from the Massachusetts Institute of
`
`Technology (MIT) Libraries on May 22, 2018. When I was originally asked
`
`to prepare this declaration, I searched WorldCat (http://www.worldcat.org)
`
`for the conference title “Automotive electronics : delivering technology's
`
`promise” and found more than 20 holding libraries. To provide evidence
`
`that the 2000 conference proceedings, which includes the “Mufid” article,
`
`was available soon after its publication in 2000, I asked WTS to deliver
`
`scanned pages from two separate libraries beyond my local libraries.
`
`Exhibit-4 is the true and correct copy WTS obtained from the MIT Libraries
`
`according to my specifications. The file includes the cover, title page,
`
`copyright page, page with the date stamp, table of contents and the Mufid
`
`article. I have examined Exhibit-4 and Exhibit-1 closely, which I
`
`personally scanned at Library of Congress, and found that the two files have
`
`the same content. The only differences are that Exhibit-4 has an MIT
`
`barcode sticker on the cover, a call number “TL272.5 .I57 2000” written on
`
`the copyright page (p.4), and a date stamp of “M.I.T. Libraries Nov 8 2000
`
`RECEIVED” on the copyright page (p. 4).
`
`Jaguar Land Rover
`Exhibit 1012
`Page 020
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`Exhibit-5 (MIT Libraries)
`
`25. Exhibit-5 is a true and correct copy of the Bibliographic record
`
`for Automotive Electronics : Delivering Technology’s Promise, SAE
`
`Conference Proceedings, no. 360 (2000), which contains the “Mufid”
`
`article, Future Automotive Multimedia Subsystem Interconnect
`
`Technologies (pp. 167-182). I personally identified and located this record
`
`from the online catalog of the MIT Libraries at http://library.mit.edu on May
`
`22, 2018, which experts in my field would reasonably rely upon when
`
`forming their opinion. Exhibit-5 presents bibliographic information about
`
`this publication, including the conference name, title, publisher, description,
`
`series, format, note, bibliography, subjects, other author, other title, and
`
`ISBN. In addition, it presents information specific to the MIT Libraries. A
`
`permalink informs me the record can be located consistently at
`
`http://library.mit.edu/item/000959917. The “Shelf Access” field has a link
`
`for users to find the item in the library or request it, and the “Shelf Location”
`
`field indicates it is shelved at “Barker Library - Stacks | TL272.5.I57 2000.”
`
`The “local system number” indicates this item’s number is “000959917.”
`
`Exhibit-6 (MIT Libraries)
`
`26. Exhibit-6 is a true and correct copy of the MARC record for
`
`Jaguar Land Rover
`Exhibit 1012
`Page 021
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`Automotive Electronics : Delivering Technology’s Promise, SAE Conference
`
`Proceedings, no. 360 (2000), which contains the “Mufid” article, Future
`
`Automotive Multimedia Subsystem Interconnect Technologies (pp. 167-
`
`182). I personally identified and located this record from the online catalog
`
`of the MIT Libraries at
`
`http://library.mit.edu/F/37UUX4LQB1MHNPQFHSLA7TP5S212MH7YA
`
`KU66UGES4DCSECHG6-01482?func=full-set-
`
`set&set_number=018233&set_entry=000001&format=001 on May 22,
`
`2018, which experts in my field would reasonably rely upon when forming
`
`their opinion. Subfield ǂa of Field 040 informs me the original creator of the
`
`record is “EYG” and Subfield ǂd informs me “MYG” is the library that
`
`modifies this record. According to the Directory of OCLC Members
`
`(https://www.oclc.org/en/contacts/libraries.html), “EYG” is the OCLC
`
`symbol for the General Motors R&D Center Library and “MYG” the OCLC
`
`symbol for the MIT Libraries. This means the MIT record is a copy
`
`cataloging record based on the EYG record. Field 008 informs me the
`
`original record by EYG was created on “001030” (i.e., Oct. 30, 2000). Most
`
`libraries do not clearly indicate the date when a copy cataloging record is
`
`added to the cataloging system on their MARC bibliographic records. In
`
`this case, the MIT MARC record (Exhibit-6) itself does not indicate the
`
`Jaguar Land Rover
`Exhibit 1012
`Page 022
`
`
`
`Declaration of Dr. Ingrid Hsieh-Yee in Support of
`Petition for Inter Partes Review of USP 7,489,786
`
`
`copy cataloging date, but the MARC holdings record attached to the bottom
`
`of Exhibit-6 has an 008 field date of “010623” (i.e., June 23, 2001) that
`
`indicates the date the record was entered into the system.
`
`27. Because the MIT MARC record (Exhibit-6), like the LC
`
`MARC record (Exhibit-2), is a copy cataloging record based on the record
`
`originally created by EGY, the General Motors R&D Center Library, it is
`
`not surprising that the MIT MARC record and the LC MARC record are
`
`very similar in content. From Field 111 to Field 830 the two records provide
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