Filed on behalf of: E-NUMERATE SOLUTIONS, INC.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
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`MERRILL COMMUNICATIONS LLC d/b/a MERRILL
`CORPORATION,
`Petitioner
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`
`v.
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`
` E-NUMERATE SOLUTIONS, INC.,
`Patent Owner
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`
`
`Case IPR2018-01392
`U.S. Patent 8,185,816
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`__________________
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`E-NUMERATE SOLUTIONS, INC’S PATENT OWNER RESPONSE
`PURSUANT TO 37 C.F.R. § 42.120
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`TABLE OF CONTENTS
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`I. INTRODUCTION .......................................................................................................................5
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`II. BACKGROUND ........................................................................................................................8
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`A.
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`B.
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`Prior Art Markup Language Documents ........................................................................8
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`The ‘816 Patent ............................................................................................................40
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`III. DESCRIPTION OF THE PRIOR ART ..................................................................................41
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`A.
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`B.
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`C.
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`Simpson (Ex. 1005) .....................................................................................................41
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`Goldfarb (Ex. 1006) .....................................................................................................43
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`Lyons (Ex. 1007) .........................................................................................................47
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`IV. CLAIM CONSTRUCTION ...................................................................................................49
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`A.
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`“Markup Document” ....................................................................................................50
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`V. PETITIONER FAILED TO DEMONSTRATE THAT THERE IS SUBSTANTIAL
`EVIDENCE THAT ANY OF THE CHALLENGED CLAIMS ARE OBVIOUS ................53
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`A.
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`Grounds 1 & 2: Simpson Or Simpson In View Of Goldfarb Does Not Render
`Claims 1, 10, 17, 26, And 27 Obvious .........................................................................55
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`1.
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`2.
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`Petitioner Fails To Establish That Either Simpson Or Goldfarb Disclose
`“automatically transforming the numerical values of at least one of the
`first markup document and the second markup document, so that the
`numerical values of the first markup document and the second markup
`document have a common format” ........................................................................55
`
`Petitioner Fails To Establish That Either Simpson Or Goldfarb Disclose “a
`first markup document and a second markup document, both the first
`markup document and the second markup document
`[including/containing] numerical values and tags reflecting characteristics
`of the numerical values” ........................................................................................67
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`B.
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`Grounds 3 & 4: Lyons Or Lyons In View Of Goldfarb Does Not Render
`Claims 1, 10, 17, 26, And 27 Obvious .........................................................................77
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`1.
`
`Petitioner Fails To Establish That Either Lyons Or Goldfarb Disclose
`“automatically transforming the numerical values of at least one of the
`first markup document and the second markup document, so that the
`numerical values of the first markup document and the second markup
`document have a common format” ........................................................................77
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`2
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`2.
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`Petitioner Fails To Establish That Either Lyons Or Goldfarb Disclose “a
`first markup document and a second markup document, both the first
`markup document and the second markup document
`[including/containing] numerical values and tags reflecting characteristics
`of the numerical values” ........................................................................................83
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`C.
`
`Grounds 2 & 4: A POSA Would Not Be Motivated To Modify Simpson or
`Lyons In View Of Goldfarb .........................................................................................86
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`1.
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`2.
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`3.
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`4.
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`Both Simpson And Lyon Disclose Existing Systems With Limitations The
`Claimed Invention Overcomes ..............................................................................90
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`The Proposed Modification Would Eliminate Goldfarb’s Stated
`Improvement ..........................................................................................................95
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`Petitioner Failed To Address The Inefficiencies Created ......................................97
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`Petitioner Fails To Show How A POSA Would Have Modified Lyons To
`Accept XML Data Files .........................................................................................99
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`VI. CONCLUSION.....................................................................................................................101
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`3
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`PATENT OWNER’S EXHIBIT LIST
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`Exhibit Number Description
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`2001
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`Expert Declaration of Dr. Michael J Smith
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`4
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`
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`I. INTRODUCTION
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`The Petitioner did not demonstrate that any of the claims of U.S. Patent
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`No. 8,185,816 (“the ‘816 patent”) are obvious because the Petitioner failed to
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`show that a person of ordinary skill in the art (“POSA”) would have been
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`motivated to modify the structure and components of either Simpson or Lyons
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`to achieve the claimed invention or that a POSA “would have had a
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`reasonable expectation of success in doing so.” OSRAM Sylvania, Inc. v. Am
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`Induction Techs., Inc., 701 F.3d 698, 706 (Fed. Cir. 2012). The Board has
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`consistently declined to conclude that a claim is obvious when the Petition fails
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`to identify any objective evidence such as experimental data, tending to
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`establish that two different structures can be combined to achieve the claimed
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`invention with a reasonable expectation of success.1 Here, the Petitioner did
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`not set forth any such objective evidence.2 Rather, the Petitioner’s own expert
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`made hand-waving arguments that the two database systems of Simpson and
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`Lyons, which did not support XML, and which required file-specific user-
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`1 Epistar, et al. v. Trustees Of Boston University, IPR2013-00298, Decision Not To
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`Institute, Paper No. 18 (P.T.A.B. November 15, 2103).
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`2 See e.g., Petition, pp. 34-36 and 61-62.
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`5
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`customized input_templates or multi-screen Import Wizards to “tag” data with
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`field names so they could be imported into a database system, could be
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`modified to accept XML-formatted markup documents by first running the
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`XML markup documents through an HTML converter (which would remove
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`all markup and structure from said XML markup document). However, such
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`an implementation would eliminate Goldfarb’s stated improvements of
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`“adding more structure to data files and providing a universal file structure that
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`would ease the exchange of data between programs and over the internet”3 by
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`flattening the XML data file of relevant metadata. Further, the Petitioner
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`failed to address the inefficiencies created by flattening the relevant data
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`structure out of the XML file when converting to HTML or how Lyons could
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`be modified to accept the XML data file.
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`Moreover, the Petitioner blatantly relied on expert testimony to meet
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`missing elements in the context of both single and double reference attacks. As
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`established by the Federal Circuit, “common sense is typically invoked to
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`provide a known motivation to combine,”4 not a claim limitation, like in this
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`situation. Further, relying on “common sense” to supply a claim limitation is
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`3 Exhibit 1003, 78; See also Exhibit 1006, xxxix-xl
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`4 Arendi S.A.R.L. v. Apple Inc., Appeal No. 2015-2073, (August 10, 2016) p. 10.
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`suspect when the missing limitation is not “simple” and the technology not
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`“straightforward,” and especially so when the limitation is central to the
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`claimed subject matter.
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`Still yet, the Arendi court warned that, especially in the context of a
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`missing claim limitation, resorting to common sense “cannot be used as a
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`wholesale substitute for reasoned analysis and evidentiary support.”5 In this
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`case and the related matters, as will be established below, the Petitioner
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`blatantly relied on expert testimony to meet complex missing elements that are
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`central to the claimed subject matter, via conclusory statements (not a
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`“reasoned analysis”) without evidentiary support, in blatant disregard of the
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`factors of Arendi. To this end, this Petition should fail.
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`For these reasons as explained more fully below, the Petitioner failed to
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`show that there is a substantial evidence to support its position that the claims
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`of the ‘816 patent are obvious over Simpson, Lyon and Goldfarb.
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`Accordingly, the Board should not cancel any of the claims of the ‘816 patent.
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`5 Id.
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`…Continued
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`II. BACKGROUND
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`A. Prior Art Markup Language Documents6
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`Inventor Russell T. Davis pioneered several inventions related to
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`Reusable Data Markup Language including, but not limited to, the ‘816
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`patent.7 As discussed below, these patents provided numerous advantages over
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`prior art Markup Languages.8
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`In the late 1990’s when numbers were treated the same as letters (text) in
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`software programs, both online and offline, e-Numerate’s key technical
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`advancements allowed numbers to be substantively treated as the numerical
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`values they represent.9 This opened the computer world, both online and
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`6 It should be noted that the following exemplary citations to the specification
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`and/or advantages are for illustrative purposes only, as there may be others
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`and some covered systems/methods may omit one or more of the same. Thus,
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`such exemplary citations should not be deemed limiting to the claim language
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`in any way.
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`7 Exhibit 1001, 1:5-19.
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`8 Id. at 2:6-16.
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`9 Id. at 1:49-51.
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`…Continued
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`8
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`offline, to vastly improve a user’s ability to identify, manipulate, compare,
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`convert and process numbers in software like never before.10 The technical
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`innovations of the ‘816 patent11 are embodied in software that improves and
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`enhances the functionalities of computer systems over the prior art.12 The
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`problem that they solve relates to the need for the intelligent identification and
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`processing of numerical information on the Internet.
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`
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`The Problem
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`In the late 1990’s, the Internet was replete with numerical data but (i)
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`there was no way of distinguishing this numerical data from text, (ii) data and
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`analytic routines were not standardized, and (iii) calculations occurred at too
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`low a conceptual level.13
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`10 Id. at 2:40-51.
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`11 Exhibit 1001.
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`12 See, e.g., Exhibit 2001, ¶ 34.
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`13 Exhibit 1001, 1:49-51.
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`9
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`…Continued
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`The advances of the inventions claimed in the ‘816 patent14 relate to
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`deficiencies in the prior-art markup languages that existed at the time of the
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`invention.15 These were Hyper Text Markup Language (HTML)16 and
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`Extensible Markup Language (XML).17
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`Internet browsers interpret and display documents formatted in
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`HTML.18 In order to distinguish the text characters to be displayed from the
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`information describing how the text characters are to be formatted,
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`“annotations” that are not visible to the viewer of the displayed document are
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`added to the document.19 The HTML specification describes the use of a
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`markup language to include these non-displayed annotations.20 A markup
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`language is a system for inserting information about the formatting and display
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`14 Exhibit 1001.
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`15 See, e.g., Exhibit 2001, ¶ 36.
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`16 Exhibit 1001, 1:33-43.
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`17 Id. at 1:65-2:4.
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`18 Id. at 1:44-51.
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`19 Id. at 1:51-52.
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`20 Id. at 1:38-51.
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`…Continued
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`10
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`of a group of text characters by placing non-displayed “markup” text before
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`and after the group of text characters.21 These markups, commonly known as
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`“tags” in online and other documents in digital format, describe the structure
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`and formatting of digital documents and instruct computer systems on how to
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`display them.22
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`HTML works only with text and images.23 Numbers in HTML
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`documents are read and displayed as text characters.24 There is no HTML tag
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`capable of annotating the context or meaning of numerical data appearing in a
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`markup document for computer systems to interpret these numerical data as
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`numbers representing a particular type of information instead of a simple string
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`of text characters.25 At most, HTML tags can be used only to indicate the
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`display format (e.g., font, size, color, alignment) of numerical data.26 For
`
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`21 Id.
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`22 Id. at 1:41-43.
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`23 Id. at 1:45-46.
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`24 Id. at 1:54-56.
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`25 Id. at 1:56-58.
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`26 Id. at 1:44-49.
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`…Continued
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`11
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`example, a financial statement showing numbers could be displayed by
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`computer systems running browsers, but HTML cannot be used to annotate a
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`given number as “revenue” or “expense,” or as “dollars” or “Euros,” or as
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`representing “thousands” or “millions,” but rather only as a text character to
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`be displayed in a certain way according to embedded formatting tags.27
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`Consequently, computer systems running web browsers could use HTML tags
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`to display documents containing numbers, but the HTML tags do not enable
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`computer systems to run analytical applications that read, manipulate,
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`combine, compare, transform or analyze the numbers, load them into a
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`spreadsheet, or display them in a graph directly from multiple online sources.28
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`XML version 1.0 was developed in the mid-to-late 1990s to help
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`overcome some of HTML’s limitations.29 XML, itself, does not include a set of
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`pre-defined tags, but rather is a specification that governs the creation of tags
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`by particular users or groups.30 The XML specification allows developers to
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`27 Id. at 9:47-53.
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`28 Id. at 1:58-64.
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`29 Id. at 1:65-2:1.
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`30 Id. at 2:1-4.
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`…Continued
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`create customized tags that, via a glossary of terms, describe the structure and
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`meaning of online content.31 In other words, XML allows developers to create
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`their own individual markup languages.32 Thus, a user can use XML to create
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`their own markup tags that annotate data characteristics that are meaningful to
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`that particular user.33 But at the time of the inventions of the ‘816 patent34, no
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`set of XML tags had been promulgated for general use, so any XML tag
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`taxonomy created by one user would not be compatible with the taxonomies
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`created by other users.35 One user’s XML tag taxonomy, whether individuals
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`or groups, is not ordinarily available to any other users or groups of users.36
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`XML’s lack of standardization, and its separation of data from its annotations
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`(metadata), left users with no way to manipulate, combine, compare,
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`transform or analyze numerical data from singular or multiple online sources
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`31 Id. at 2:7-12.
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`32 Id.
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`33 Id.
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`34 Exhibit 1001.
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`35 Id. at 2:12-16.
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`36 Id. at 2:12-16.
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`…Continued
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`13
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`

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`using differing custom created XML tag taxonomies.37 The only way to correct
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`the deficiency of XML was to convert unrelated documents by hand.38
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`
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`Various Embodiments Covered by The Claimed Invention
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`In contrast to XML, the Reusable Data Markup Language (“RDML”)
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`represented a significant advance over HTML and XML.39 The patents-at-issue
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`in this case solve these HTML- and XML-related problems with unique tools
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`that allowed users for the first time to easily view, compare and analyze
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`numerical data on the Internet.40 The Reusable Data Markup Language
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`(“RDML”) and RDML companion innovations pair the metadata directly
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`with the numerical data in machine-readable form so the numerical data could
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`be easily identified and used in different program applications.41 This is a
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`dramatically different approach than previously used, which was to keep
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`37 Id. at 2:40-43.
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`38 Id. at 2:43-46.
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`39 See, e.g., Exhibit 2001, ¶ 40.
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`40 Exhibit 1001, 8:17-21.
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`41 Id. at 5:49-53.
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`14
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`…Continued
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`document metadata and data itself separate from each other.42 Without the
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`pairing of metadata directly with the numerical data as described in the ‘816
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`patent43, the capabilities presented in the XBRL standard would not be
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`possible.44 RDML companion innovations also define standards for both data
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`formats and analytic routines45 and enhance analytical calculation power by
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`creating data objects at the line item and document levels.46 This overcomes
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`the limitations of traditional spreadsheets which operate only at the cell (single
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`number) level.47
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`Reusable Data Markup Language provides RDML tags for data
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`characteristics that HTML lacked and supplies a set of tags for content and
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`meaning of numbers for general use, which is missing in XML.48
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`42 Id. at 2:1-4.
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`43 Exhibit 1001.
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`44 Id. at pp. 2-3.
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`45 Id. at 10:41-43.
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`46 Id. at 15:59-63.
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`47 Id. at 2:35-39.
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`48 Id. at 9:7-14.
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`…Continued
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`15
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`A suite of software applications has been developed to create documents
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`with RDML tag markups, read or parse the RDML documents, display them
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`as graphs or in tree views, combine and compare data from multiple online
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`sources, and manipulate, transform and analyze numerical data from multiple
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`online sources.49 RDML permits the browsing and manipulation of numbers,
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`and allows the “RDML Data Viewer” to act as a combination Web browser
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`and spreadsheet/analytic application that automatically read numbers from
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`multiple online sources, understand their meaning, and manipulate them
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`without human intervention.50
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`RDML encodes information about numbers in tags that relate to each
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`number.51 The encoded information is connected with the numbers themselves
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`and the tags move with the numbers when the numbers are ported.52 By
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`49 Id. at 17:1-7.
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`50 Id. at 17:7-14.
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`51 Id. at 4:14-19.
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`52 Id.
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`…Continued
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`associating the numbers with the numbers’ attributes and making it machine-
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`readable, RDML facilitates browsing for and processing numbers.53
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`The RDML Data Viewer is an “Application” in accordance with the
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`XML Specifications.54 The RDML Data Viewer accesses information
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`contained in an XML-formatted document by invoking the XML Processor to
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`obtain individual data elements based on their “extended” tags that have been
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`defined in accordance with the “extensibility” features of XML.55 The RDML
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`Data Viewer automates the process of merging the tagged elements derived
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`from documents written in different formats and languages into a single,
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`standardized data set.56 Where there are conflicts, the RDML Data Viewer
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`automatically resolves the conflicts between the characteristics of the varying
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`documents to create a standard set of tags using the RDML taxonomy.57 The
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`RDML Data Viewer also provides a macro development and management
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`53 Id. at 3:54-64.
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`54 Id. at 8:49-55.
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`55 Id. at 9:7-14.
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`56 Id. at 9:53-55.
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`57 Id. at 11:24-30.
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`…Continued
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`17
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`scheme that allows users to create reusable custom routines for the
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`manipulation, transformation and display of RDML-formatted data.58 By
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`defining standards for data characteristics and content-analysis, RDML
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`addresses the problems caused by XML’s use of customized tagging making
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`RDML applicable for general use.59
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`
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`The Impact of the Improvements of the ‘816 Patent
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`One embodiment covered by the claimed invention includes “pairing the
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`metadata directly with the numerical data in machine-readable form so the
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`numerical data could be easily identified and used in different program
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`applications.”60 This has never been done before.
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`The inventions claimed in the ‘816 patent61 were invented prior to the
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`creation of the XBRL standard.62 Prior art, as embodied in HTML and XML
`
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`58 Id. at 8:63-65.
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`59 Id. at 10:20-22.
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`60 Id. at 5:49-53.
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`61 Id.
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`62 Id. at pp. 2-3.
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`…Continued
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`18
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`at the time of the filing of the ‘816 patent63, did not provide any metadata (i.e.,
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`information about the attributes or characteristics of a data element) beyond
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`simple display formatting.64 Without these attributes and characteristics, it was
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`not possible for a human or a computer to select, process, combine or output
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`data elements without resorting to human intervention to find, associate and
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`take into account how the appropriate attributes and characteristics would
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`affect the selection, processing, combination and outputting activities.65 For
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`example, financial statements, such as those submitted to the SEC, contain
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`numeric values for typical accounting data items types such as “Assets,”
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`“Balances,” “Cash,” etc.66 To organize the multiple occurrences of these items,
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`accountants would create financial statements such as “Balance Sheets,”
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`“Income Statements,” etc., that typically have formats that hierarchically
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`display and summarize these accounting items in a manner that reflects how
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`the individual organization or organizational unit represents its financial
`
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`63 Exhibit 1001.
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`64 Id. at 1:41-43.
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`65 Id. at 2:40-46.
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`66 Id. at 9:47-53.
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`…Continued
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`19
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`condition.67 Before the introduction of the inventive concepts contained in the
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`‘816 patent68, there were no tools that could automatically associate individual
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`accounting data items with the appropriate sections of the organization’s
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`financial statements.69 Typically, the organization would have to rely on its
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`senior financial accountants to manually select, analyze, combine, and format
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`accounting items in a manner that corresponded to that organization’s
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`Financial Statement situation.70 Thus, each iteration of Financial Statement
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`preparation required a large amount of human intervention to create a
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`Financial Statement that faithfully adhered to the “letter” and “intent” of the
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`generally accepted accounting standards due to the lack of a means to capture
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`and utilize the required metadata.71 The ‘816 patent72 provides these
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`67 Id. at 9:47-53.
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`68 Exhibit 1001.
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`69 Id. at 5:49-56.
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`70 See, e.g., Exhibit 2001, ¶ 46.
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`71 Id.
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`72 Exhibit 1001.
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`20
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`…Continued
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`capabilities which are not addressed by either HTML or XML.73 The
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`continuing significant efforts by the Financial Accounting Standards Board
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`(FASB) and the XBRL International organization to grow and expand the
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`Extensible Business Reporting Language are a testament to the necessity and
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`value of the inventions contained in the ‘816 patent.74 The SEC is currently
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`performing cross-financial entity and cross-industry “data mining” activities to
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`better understand financial trends and to better discover improprieties by
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`comparing financial entities.75 These activities would not be possible without
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`the ability of different program applications to utilize the inventions contained
`
`in the ‘816 patent.76
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`One embodiment covered by the claimed invention also seeks to “define
`
`standards for both data formats and analytic routines.”77
`
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`73 See, e.g., Exhibit 2001, ¶ 46.
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`74 Exhibit 1001.
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`75 See, e.g., Exhibit 2001, ¶ 46.
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`76 Exhibit 1001.
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`77 Id. at 10:41-43.
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`21
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`…Continued
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`Before the introduction of the inventions contained in the ‘816 patent78
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`the preparation of financial statements involved the manual selection, analysis,
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`combination, and outputting of numerical data items based on the best efforts
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`of the organization’s senior accountants and later accepted as appropriate by
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`Certified Public Accountants.79 Without defined standards for capturing and
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`accessing both numerical data attributes and characteristics, the selection of
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`appropriate data formats and analytic routines could not be performed
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`automatically by either human or machine.80 The ‘816 patent81 provides a
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`mechanism to capture the metadata required to identify the attributes and
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`characteristics of each numerical data element, and thereby allow the
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`automated selection of the appropriate analytic routines based on the metadata
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`associated with those analytical routines.82 For example, an international
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`organization may operate in several political jurisdictions, each having their
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`78 Exhibit 1001.
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`79 See, e.g., Exhibit 2001, ¶ 48.
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`80 Exhibit 1001, 10:20-22.
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`81 Exhibit 1001.
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`82 Id. at 12:62-13:5.
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`own financial regulations, reporting formats and analytical processing
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`procedures.83 For the international organization to produce a combined
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`Financial Statement of Condition, the financial statement within each
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`jurisdiction must first be created and then combined into a consolidated
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`financial statement.84 To facilitate this consolidation, senior international
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`accountants would have to manually identify the variations associated with
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`each jurisdiction and determine how these diverse statements of financial
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`condition could be combined.85 One embodiment covered by the claimed
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`invention provides a mechanism to capture the necessary numerical data, item
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`metadata, and analytical processing routine metadata to facilitate the required
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`association of numerical data to routines needed to automatically produce
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`combined financial statements without manual human intervention.
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`83 Id. at 49:58-62.
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`84 Id. at 49:58-62.
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`85 See, e.g., Exhibit 2001, ¶ 48.
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`One embodiment covered by the claimed invention involves “enhance
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`analytical calculation power by creating data objects at the line item and
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`document levels.”86
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`Prior art at the time of the filing of the ‘816 patent87 only provided for the
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`automated display of structured data using HTML88 or XML.89 While these
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`display structures provided an elementary “visual” representation of the
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`relationship between the data elements, there was no standard way of
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`capturing these relationships in a manner that this information could be stored
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`and accessed by human or automated processes.90 The ‘816 patent91 provides a
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`mechanism to capture and utilize these types of relationships.92 For example,
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`financial transactions typically might consist of a date, description, multiple
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`86 Id. at 15:59-63.
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`87 Exhibit 1001.
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`88 Id. at 1:33-43.
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`89 Id. at 1:65-2:4.
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`90 Id. at 10:20-22.
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`91 Exhibit 1001.
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`92 Id. at 12:62-13:5.
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`account identifiers (e.g., debit, credit, distribution, etc.) and amounts for
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`each.93 In a manual or automated accounting system, these components of a
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`financial transaction would typically be stored together in an information
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`processing system (e.g., “data base”).94 Without the inventions contained in
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`the ‘816 patent95, there would be no automated way of unambiguously
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`capturing these elements presented in an HTML or XML document due to the
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`lack of the necessary metadata.96
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`One possible embodiment of the Reusable Data Markup Language
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`(RDML) includes “A set of tags to encode attributes and meaning of
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`numbers.” 97 RDML encodes information about numbers in tags that relate to
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`each number, which is connected with the numbers themselves and the tags
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`move with the numbers when the numbers are ported.” 98
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`93 Id. at 9:47-53.
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`94 Id.
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`95 Exhibit 1001.
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`96 Id. at 2:40-46.
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`97 Id. at 9:7-14.
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`98 Id. at 4:14-19.
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`IPR2018-01392
`U.S. Patent No. 8,185,816
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`Prior art at the time of the filing of the ‘816 patent99 did not provide a
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`mechanism to identify numerical data element attributes, characteristics,
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`formats or relationships.100 For example, an information system would
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`typically store structured data, such as financial transactions, in a “database”
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`system that preserved record or “line item” relationships for a collection of
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`related transactions (i.e., a business document).101 Typically, the metadata
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`describing these record and data element characteristics would be stored in the
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`“schema” subsystem of the database system.102 However, there was no
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`universal mechanism to store and share the metadata describing the structure
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`of the records, the metadata of the individual data elements within each
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`record, the metadata describing the relationship among different records
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`representing a transaction, nor the semantic meaning of the data elements.103
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`For example, an “invoice” might consist of various information about the
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