IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`COMCAST CABLE COMMUNICATIONS, LLC,
`Petitioner
`v.
`VEVEO, INC.
`
`Patent Owner
`________________
`
`Patent No. 7,937,394
`Filing Date: August 2, 2010
`Issue Date: May 3, 2011
`Title: METHOD AND SYSTEM FOR DYAMICALLY PROCESSING
`AMBIGUOUS, REDUCED TEXT SEARCH QUERIES AND HIGHLIGHTING
`RESULTS THEREOF
`________________
`
`Inter Partes Review No.: IPR2019-00290
`
`________________
`
`DECLARATION OF DR. EDWARD A. FOX IN SUPPORT OF
`PETITIONER COMCAST CABLE COMMUNICATIONS, LLC’S
`PETITION FOR
`INTER PARTES REVIEW OF U.S. PAT. NO. 7,937,394
`
`Declaration in Support of Petition 1 of 4
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`1
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`Comcast, Exhibit-1014
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`Table of Contents
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`I.         Introduction ...................................................................................................... 6 
`II.       Professional Background and Qualifications ................................................... 6 
`A. 
`Education and Certifications ................................................................. 7 
`B. 
`Career Synopsis ..................................................................................... 9 
`C. 
`Detailed Research Activity .................................................................. 12 
`D. 
`Invention .............................................................................................. 13 
`III.     Materials Reviewed ........................................................................................ 13 
`IV.     Understanding of Applicable Legal Standards .............................................. 15 
`A. 
`Person Having Ordinary Skill in the Art ............................................. 18 
`B. 
`Broadest Reasonable Interpretation .................................................... 20 
`V.       State of the Art and Overview of the ’394 Patent .......................................... 21 
`A. 
`State of the Art .................................................................................... 21 
`B. 
`Overview of the ’394 Patent ................................................................ 27 
`C. 
`Relevant Patent Prosecution History ................................................... 30 
`VI.     Claim Constructions ....................................................................................... 34 
`A. 
`“directly mapped” ................................................................................ 34 
`B. 
`“letters and numbers” .......................................................................... 39 
`C. 
`“caused the items to be associated with the strings of one or more
`unresolved keystrokes that directly mapped to the subset” ........................... 40 
`D.  Ordering of Steps ................................................................................. 42 
`VII.   Prior Art ........................................................................................................ 44 
`A.  U.S. Publication No. 2007/0027848 (Howard) ................................... 44 
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`U.S. Patent No. 6,011,554 (King) ....................................................... 46 
`B. 
`U.S. Patent No. 6,370,518 (Payne) ..................................................... 48 
`C. 
`D.  U.S. Patent No. 7,885,963 (Sanders) .................................................. 50 
`E. 
`U.S. Patent Publication No. 2004/0133564 (Gross) ........................... 53 
`F. 
`U.S. Patent No. 6,501,956 (“Weeren”) ............................................... 55 
`G.  U.S. Patent Publication No. 2005/0278741 (“Robarts”) ..................... 55 
`VIII.  Facts and Opinions Relevant to the Unpatentability Grounds Asserted
`in the Petition ........................................................................................................ 56 
`IX.    GROUND 1 – Claims 1, 2, 4-6, and 8-11 are Obvious Over Howard in
`View of King and Payne ......................................................................................... 58 
`A. 
`Independent Claim 1 ........................................................................... 58 
`1[Preamble].  “A method of processing unresolved keystroke
`entries by a user from a keypad with overloaded keys in
`which a given key is in fixed association with a number
`and at least one alphabetic character, the unresolved
`keystroke entries being directed at identifying an item
`from a set of items, each of the items being associated with
`information describing the item comprising one or more
`words, the method comprising” ................................................ 58 
`1[a].  “providing access to an index of the items, the index
`having an association between subsets of the items and
`corresponding strings of one or more unresolved
`keystrokes for overloaded keys so that the subsets of items
`are directly mapped to the corresponding strings of
`unresolved keystrokes for various search query prefix
`substrings” ................................................................................. 60 
`1[b].  “for at least one subset of items, determining which letters
`and numbers present in the information associated with
`and describing the indexed items of the subset caused the
`items to be associated with the strings of one or more
`unresolved keystrokes that directly mapped to the subset” ...... 72 
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`3
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`1[c].  “receiving from a user a search query for desired items
`composed of unresolved keystrokes, the search query
`comprising a prefix substring for at least one word in
`information associated with the desired item” .......................... 79 
`1[d].  “in response to each unresolved keystroke, identifying and
`displaying the subsets of items, and information associated
`therewith, that are associated with the strings of one or
`more unresolved keystrokes received from the user based
`on the direct mapping of strings of unresolved keystrokes
`to subsets of items” ................................................................... 82 
`1[e].  “in response to each unresolved keystroke, as the
`identified items are displayed, highlighting the letters and
`numbers present in the one or more words in the
`information describing the identified items that were
`determined to have caused the displayed items to be
`associated with the strings of unresolved keystrokes that
`are directly mapped to the items so as to illustrate to the
`user how the unresolved keystrokes entered match the
`information associated with the displayed items” .................... 85 
`Dependent Claim 2 .............................................................................. 92 
`B. 
`Dependent Claim 4 .............................................................................. 93 
`C. 
`D.  Dependent Claim 5 .............................................................................. 94 
`E. 
`Dependent Claim 6 .............................................................................. 95 
`F. 
`Dependent Claim 8 .............................................................................. 96 
`G.  Dependent Claim 9 .............................................................................. 99 
`H.  Dependent Claim 10 ............................................................................ 99 
`I. 
`Dependent Claim 11 .......................................................................... 100 
`X.       GROUND 2 – Claim 3 Is Obvious Over Howard in View of King and
`Payne and Further in View of Sanders ................................................................. 101 
`A.  Dependent Claim 3 ............................................................................ 101 
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`XI.    GROUND 3 – Claim 4 Is Obvious Over Howard in View of King and
`Payne and Further in View of Gross .................................................................... 107 
`A.  Dependent Claim 4 ............................................................................ 107 
`XII.   GROUND 4 – Claim 7 Is Obvious Over Howard in View of King and
`Payne and further in view of Weeren ................................................................... 110 
`A.  Dependent Claim 7 ............................................................................ 110 
`XIII. GROUND 5 – Claims 8 and 9 are Obvious Over Howard in View of
`King and Payne and further in view of Robarts ................................................... 112 
`A.  Dependent Claim 8 ............................................................................ 112 
`B. 
`Dependent Claim 9 ............................................................................ 114 
`XIV. Secondary Factors Related to Obviousness ................................................. 116 
`XV.   Conclusion ................................................................................................... 117 
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`5
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`I, Edward A. Fox, declare that I have personal knowledge of the facts set forth
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`in this declaration and, if called to testify as a witness, could and would do so
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`competently.
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`I.
`
`INTRODUCTION
`1.
`I have been retained as an expert witness on behalf of the Petitioner,
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`Comcast Cable Communications, LLC (“Petitioner”), for the above-referenced inter
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`partes review proceeding.
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`2.
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`3.
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`I reside in Blacksburg, Virginia.
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`I have been asked to provide testimony regarding the unpatentability
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`grounds set forth in this declaration pertaining to U.S. Patent No. 7,937,394 (“the
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`’394 Patent”).
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`4.
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`I am being compensated at my usual consulting rate of $500 per hour
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`($600 per hour for time spent testifying at a deposition or trial) for my work on this
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`matter. I also am being reimbursed for reasonable and customary expenses
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`associated with my work and testimony in this investigation. My compensation is
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`not dependent upon my opinions or testimony or the outcome of this proceeding.
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`II.
`
`PROFESSIONAL BACKGROUND AND QUALIFICATIONS
`5.
`I have extensive academic and industry experience and computer
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`science background in the field of information retrieval, and, in particular, regarding
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`techniques for performing searches for desired content.
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` Having
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`taught
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`undergraduate and graduate students in the field since 1983, I am familiar with the
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`relevant skill set that would have been possessed by a hypothetical person of
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`ordinary skill in the art (POSA) at the time of the alleged invention of the ’394 Patent
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`(in 2005).
`
`A. Education and Certifications
`6.
`I earned a bachelor’s degree in electrical engineering (in the computer
`
`science option) from the Massachusetts Institute of Technology in 1972, a master’s
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`degree in computer science from Cornell University in 1981, and a Ph.D. degree in
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`computer science from Cornell University in 1983. My undergraduate advisor was
`
`JCR Licklider, then Director of Project MAC, who, when working at DARPA,
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`managed projects that led to the Internet. My graduate advisor was Gerard Salton,
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`often called the father of information retrieval. Some of my bachelor’s work was in
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`the area of information storage and retrieval, and that area has been the focus of my
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`work since 1978.
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`7. My curriculum vitae, including my grants, publications, and patent, is
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`attached as Ex. 1019 to the Petition. As is detailed therein and below, I have led
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`development of a number of information retrieval (IR) systems, including but not
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`limited
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`to: SMART, REVTOLC, CODER (including LEND), MARIAN,
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`ENVISION, CITIDEL, CTRnet, and IDEAL/GETAR. I have published papers
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`about (hierarchical) thesauri and lexicons, query expansion (using both algorithmic
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`and AI methods), relevance feedback, automatic Boolean query construction,
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`extended Boolean retrieval, hashing, clustering, categorizing, parallel and
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`distributed approaches, advanced IR interfaces including those helping with the
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`management of result sets, metadata, digital libraries, Web archiving, text analysis,
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`and many other of the subtopics related to IR. By the mid-1980s my work in IR
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`connected with the field of human-computer interaction (HCI), by the late 1980s that
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`broadened into work on multimedia information and systems, and since the early
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`1990s my work has included a concentration on digital libraries. With regard to
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`HCI, I have worked with topics including user interfaces, portals, user studies,
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`interactive
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`systems
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`and
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`applications,
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`user-centered
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`databases,
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`hypertext/hypermedia, personalization,
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`recommendation, annotation, virtual
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`environments, and social networks. With regard to multimedia, I have worked with
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`technologies, systems, content, and applications, including digital video, electronic
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`publishing, multimedia databases, multimedia file systems, fingerprint matching,
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`indexing, and searching with image collections. With regard to digital libraries, I
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`have worked broadly, on theory, content, technologies, applications, and user
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`aspects, thus connecting the fields of IR, HCI, and multimedia.
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`8.
`
`I am a member of ACM (since 1967) and its Special Interest Group on
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`Information Retrieval (SIGIR), for which I served from 1987-1995 as vice chairman
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`and then chairman. I served from 1988-1992 on the ACM Publications Board, and
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`now again serve on that Board, also as co-chair of its Digital Libraries Committee.
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`ACM has awarded me seven recognition of service awards. I am a Fellow of ACM
`
`(cited for contributions in information retrieval and digital libraries) and a Fellow of
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`IEEE (cited for leadership in digital libraries and information retrieval), as well as a
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`member of IEEE-CS and its Technical Committee on Digital Libraries (including
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`serving on its Executive Committee, and its chairman from 2004-2008).
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`9.
`
`Since 1987, I have led activities so that theses and dissertations could
`
`be prepared, archived, and made accessible in electronic forms. Since 1996, I have
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`served as Executive Director of the Networked Digital Library of Theses and
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`Dissertations, which was incorporated in 2003; I also serve as Founder and
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`Chairman of the Board for NDLTD, which now has over 5 million electronic theses
`
`and dissertations in its Union Catalog.
`
`B. Career Synopsis
`10.
`I have been a professor at Virginia Polytechnic Institute & State
`
`University (“Virginia Tech”) since September 1983, in the Department of Computer
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`Science. Since February 2016, I also have had a courtesy appointment in the
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`Department of Electrical and Computer Engineering. Since January 1998, I have
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`been the Director of the Digital Library Research Laboratory at Virginia Tech. From
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`June 1990 to June 2014, I was the Associate Director for Research at Virginia Tech’s
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`Computing Center, a position that evolved to Faculty Advisor to Information
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`Technology.
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`11. Before that, during August 1982 to April 1983, I was Manager of
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`Information Systems at the International Institute of Tropical Agriculture, in Ibadan,
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`Nigeria.
`
`12. Before that, from September 1978 to August 1982, I was Instructor,
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`Research Assistant, and Teaching Assistant at the Department of Computer Science
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`at Cornell University.
`
`13. Before that, from September 1972 to August 1978, in Florence, SC, I
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`was Data Processing Manager in the Vulcraft Division of NUCOR Corporation.
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`14. Before that, from September 1971 to June 1972, I was Data Processing
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`Instructor at Florence Darlington Technical College.
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`15.
`
`I have been the recipient of a number of honors and awards relating to
`
`my work in information retrieval and other areas. One recent related honor I
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`received, at Virginia Tech, is the XCaliber Award 2016 “for extraordinary
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`contributions to technology-enriched learning activities” for the project “Enhanced
`
`problem-based learning connecting big data research with classes.” I have taught
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`classes on information retrieval since the early 1980s, and on multimedia since the
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`early 1990s.
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`16.
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`I have held numerous board positions in various editorial, professional,
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`and industry organizations and groups. For example, I served from 2010-2013 as an
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`elected member of the Computing Research Association Board, broadly representing
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`the U.S. computing research community.
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`17.
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`I have a strong background in many of the key areas related to handling
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`information with computers, including information retrieval, digital libraries, and
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`Web archiving. This work involves theory, algorithms, systems, and interfaces/user
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`studies. It also is described currently by buzz words such as search engines, big data,
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`data analytics, machine learning, and natural language processing.
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`18.
`
`In these areas, I have participated in, organized, and presented at
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`various conferences and workshops, and I have over 612 related keynotes, papers,
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`book chapters, posters, demonstrations, and reports, and over 336 other
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`presentations.
`
`19.
`
`20.
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`I have conducted over 83 tutorials in over 28 countries.
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`I have received over 127 grants to fund my research, (co)authored 19
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`books, and edited book series for two publishers. In addition, I have (co)authored
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`130 journal or magazine articles. Google Scholar reports my works have been cited
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`over 17,000 times, with an h-index of 59 and i10-index of 236.
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`21.
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`I have been involved in numerous software and information systems
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`projects and products over the years.
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`22.
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`I am a longstanding member of multiple professional societies. These
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`include ACM (which I joined in 1967) and IEEE, as explained above, as well as the
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`Association for Information Science & Technology and Sigma Xi (since 1972).
`
`23. My Curriculum Vitae (Ex. 1019) provides a more complete listing of
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`these honors, awards, and my activities.
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`C. Detailed Research Activity
`24. Paragraphs 25-28 describe in more detail some of the research work I
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`have been involved in, largely in the context of digital library or IR theories,
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`frameworks, and systems. Much of this research involves areas of technology that
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`are directly related to the subject matter of the patent at issue in the Petition.
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`25. One topic of research relates to queries, query operations, searching,
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`ranking, and related sub-topics.
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`26. Another topic of research relates to content, text, multimedia, and
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`related types of information and data, in collections.
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`27. Another topic of research relates to indexing and related work with
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`indexes and other data structures to improve retrieval performance.
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`28. Another topic of research relates to human-computer interaction,
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`presentation of results and content items, information visualization, and other
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`aspects of user interfaces and retrieval system usage.
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`D.
`29.
`
`Invention
`I am an inventor on U.S. Patent No. 7,346,621, issued March 18, 2008,
`
`and entitled “Method and System for Ranking Objects Based on Intra-type and Inter-
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`type Relationships.” I have a general understanding of the U.S. patent prosecution
`
`process and of the novelty and non-obviousness requirements for patentability.
`
`III. MATERIALS REVIEWED
`30. The analysis that I provide in this Declaration is based on my education,
`
`research, and experience in the field of information storage and retrieval, as well as
`
`the documents I have considered, including the ’394 Patent, that is Ex. 1021 to
`
`Petitioner’s Petition for Inter Partes Review (“the Petition”), and including U.S.
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`Patent No. 7,779,011 (“the ’011 Patent”) and two provisional applications filed on
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`August 26, 2005 (Ex. 1028 to the Petition), and September 12, 2005 (Ex.1003 to the
`
`Petition), to which the ’394 Patent claims priority. I have also reviewed the file
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`history for the ’394 Patent (Ex. 1022 to the Petition) and the ’011 Patent (Ex. 1002
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`to the Petition).
`
`31.
`
`In addition, I have reviewed a related patent owned by Patent Owner as
`
`well as relevant materials associated therewith. In particular, I have reviewed related
`
`U.S. Patent 8,433,696 (Ex. 1005 to the Petition) and a final written decision
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`invalidating U.S. Patent 8,433,696 in an IPR proceeding (Ex. 1006 to the Petition).
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`32. Furthermore, I have reviewed various relevant patents and publications
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`from the art at the time of the alleged invention of the ’394 Patent, to which this
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`Declaration relates. These publications include those listed below:
`
` U.S. Publication No. 2007/0027848 (“Howard”) (Ex. 1007 to the
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`Petition)
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` U.S. Patent No. 6,011,554 (“King”) (Ex. 1008 to the Petition)
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` U.S. Patent No. 6,370,518 (“Payne”) (Ex. 1009 to the Petition)
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` U.S. Patent No. 7,885,963 (“Sanders”) (Ex. 1010 to the Petition)
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` U.S. Publication No. 2004/0133564 (“Gross”) (Ex. 1011 to the Petition)
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` U.S. Patent No. 6,501,956 (“Weeren”) (Ex. 1025 to the Petition)
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` U.S. Publication No. 2005/0278741 (“Robarts”) (Ex. 1026 to the
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`Petition)
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`33.
`
`I have also reviewed all of the exhibits listed in Appendix B of this
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`declaration.
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`34.
`
`I may rely upon these materials and/or additional materials to rebut
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`arguments raised by Patent Owner in response to the Petition or as necessary to
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`address the Board’s decision on institution should the Board institute these
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`proceedings. Further, I also may consider additional documents and information in
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`forming any necessary opinions that were not yet available at the time of this
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`declaration.
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`35.
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`I reserve the right to revise, supplement, and/or amend my opinions
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`based on new information or further developments in these or related proceedings.
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`IV. UNDERSTANDING OF APPLICABLE LEGAL STANDARDS
`36. Although I am not an attorney, I have a general understanding of the
`
`applicable legal standards pertaining to the patentability issues presented in this
`
`proceeding. I understand that the Petitioner is challenging the patentability of the
`
`claims of the ’394 Patent based on the following grounds:
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` Claims 1, 2, 4-6, and 8-11 of the ’394 Patent would have been obvious
`
`under 35 U.S.C. § 103(a) based on U.S. Publication No.
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`2007/0027848 (“Howard”) in view of U.S. Patent No. 6,011,554
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`(“King”) and further in view of U.S. Patent No. 6,370,518 (“Payne”);
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` Claim 3 of the ’394 Patent would have been obvious under 35 U.S.C.
`
`§ 103(a) based on Howard in view of King and Payne and further in
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`view of U.S. Patent No. 7,885,963 (“Sanders”);
`
` Claim 4 of the ’394 Patent also would have been obvious under 35
`
`U.S.C. § 103(a) based on Howard in view of King and Payne and
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`further in view of U.S. Patent Publication No. 2004/0133564
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`(“Gross”);
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` Claim 7 of the ’394 Patent would have been obvious under 35 U.S.C.
`
`§ 103(a) based on Howard in view of King and Payne and further in
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`view of U.S. Patent No. 6,501,956 (“Weeren”); and
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` Claims 8 and 9 of the ’394 Patent also would have been obvious under
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`35 U.S.C. § 103(a) based on Howard in view of King and Payne and
`
`further in view of U.S. Publication No. 2005/0278741 (Robarts).
`
`37.
`
`I understand that, in this inter partes review, Petitioner has the burden
`
`of proving that each challenged claim is unpatentable by a preponderance of the
`
`evidence.
`
`38.
`
`I understand that a patent claim is unpatentable if, at the time of the
`
`invention, it would have been obvious to one of ordinary skill in the art to combine
`
`the teachings of the prior art to yield the patent claim. I also understand that it is not
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`required (although it is acceptable) that each element/limitation of a patent claim be
`
`found in a single reference in order to find a patent claim obvious. Rather, for a
`
`patent claim to be found obvious, all the elements/limitations of the patent claim
`
`must be found in teachings of one or more references that could be combined by a
`
`POSA with a reasonable expectation of success. I understand that a proper analysis
`
`of whether an invention is unpatentable for obviousness includes a review of the
`
`scope and content of the prior art, the differences between the patent claims at issue
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`and the prior art, the level of ordinary skill in the field of the invention at the time of
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`the invention, and other objective considerations.
`
`39.
`
`I understand that a showing of obviousness requires some articulated
`
`reasoning with a rational underpinning to support the combination of the references.
`
`I understand that in consideration of the issue of obviousness it is important to
`
`identify whether a reason existed at the time of the invention that would have led a
`
`POSA to combine elements of the references in a way that yielded the claimed
`
`invention.
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`40.
`
`I understand that a claim may be considered unpatentable for
`
`obviousness for various reasons. I have been informed that the following exemplary
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`rationales may support a finding of obviousness:
`
` combining prior art elements according to known methods to yield
`
`predictable results;
`
` simply substituting one known element for another to obtain
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`predictable results;
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` use of a known technique to improve similar devices in the same way;
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` applying a known technique to a known device ready for improvement
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`to yield predictable results;
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` choosing from a finite number of identified, predictable solutions with
`
`a reasonable expectation of success;
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` known work in a field that prompts variations in the work in the same
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`or a different field that leads to predictable results; and
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` some teaching, suggestion, or motivation in the prior art that would
`
`have led a POSA to modify a prior art reference or combine multiple
`
`prior art references or teachings to arrive at the claimed invention.
`
`41.
`
`I understand that various objective or “real world” factors may be
`
`indicative of non-obviousness. I understand that such factors include:
`
` the commercial success of the claimed invention;
`
` the existence of a long-felt, unresolved need for a solution to the
`
`problem solved by the claimed invention;
`
` failed attempts to solve the problem solved by the claimed invention;
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` copying of the claimed invention;
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` unexpected results of the claimed invention;
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` praise for the claimed invention by others in the relevant field; and
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` willingness of others to accept a license under the patent because of the
`
`merits of the claimed invention.
`
`A.
`42.
`
`Person Having Ordinary Skill in the Art
`I understand that my assessment of claims of the ’394 Patent must be
`
`undertaken from the perspective of what would have been known or understood by
`
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`18
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`a person having ordinary skill in the art as of the relevant filing date of the ’394
`
`Patent. I will refer to such a person as a “POSA”.
`
`43. For the relevant priority date for the ’394 Patent, I have used in this
`
`Declaration the earliest application date on the face of the patent: August 26, 2005.
`
`However, in this Declaration I do not analyze whether the ’394 Patent is entitled to
`
`that date for its priority.
`
`44. Counsel has advised me that to determine the appropriate level of one
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`of ordinary skill in the art, the following four factors may be considered: (a) the types
`
`of problems encountered by those working in the field and prior art solutions thereto;
`
`(b) the sophistication of the technology in question, and the rapidity with which
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`innovations occur in the field; (c) the educational level of active workers in the field;
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`and (d) the educational level of the inventor.
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`45. With 40 years of experience in information retrieval, I am well
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`acquainted with the level of ordinary skill required to implement the subject matter
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`of the ’394 Patent. I have direct experience with and am capable of rendering an
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`informed opinion on what the level of ordinary skill in the art was for the relevant
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`field as of August 26, 2005.
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`46. The relevant technology field for the ’394 Patent is search-query
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`processing techniques. Based on this, and the four factors above, it is my opinion
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`that a POSA would have had at least a bachelor’s degree in computer science and at
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`least two years of experience in the field of search-query processing spent designing,
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`constructing, and/or testing systems that utilize data and/or information search
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`techniques. My analysis and opinions regarding the ’394 Patent have been based on
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`the perspective of a POSA as of the ’394 Patent’s earliest claimed priority date of
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`August 26, 2005. Should the priority date to which the ’394 Patent is entitled be
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`earlier or later, my opinion on the level of ordinary skill in the art would not change.
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`47.
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`I understand that the law provides categories of information that
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`constitute prior art that may be used to anticipate or render obvious patent claims.
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`To be prior art to a particular patent claim under the relevant law, I understand that
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`a reference must have been published, or patented, or be the subject of a patent
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`application by another, before the priority date of the patent. I also understand that
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`the POSA is presumed to have knowledge of the relevant prior art. I further
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`understand that an application related to Howard, the King patent, the pre-grant
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`publication of Sanders, and an application related to Gross are cited on the ’394
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`Patent, but Payne is not cited on the ’394 Patent, and that none of the arguments
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`herein were presented to or considered by the U.S. Patent & Trademark Office.
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`B.
`48.
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`Broadest Reasonable Interpretation
`I understand that, in the present inter partes review proceeding, the
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`patent claims are given their broadest reasonable interpretation (BRI) in light of the
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`specification of the patent at issue.
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`V.
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`STATE OF THE ART AND OVERVIEW OF THE ’394 PATENT
`A.
`State of the Art
`49. A broad overview of the state of the art is covered by Modern
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`Information Retrieval (ACM Press Books, New York, 1999) (ISBN 0-201-39829-
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`X) (excerpted in Ex. 1004 to the Petition). I co-authored Chapter 15 (Digital
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`Libraries) with Ohm Sornil, then a Ph.D. student I advised. As is explained above
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`in Section II.C, much of my research connects with the topics covered in many of
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`the other chapters as well. As discussed in this book, “[i]nformation retrieval (IR)
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`deals with the representation, storage, organization of, and access to information
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`items. The representation and organization of the information items should provide
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`the user with easy access to the information in which he is interested.” Ex. 1004, p.
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`15. Germane to the discussion of obviousness in this matter is the focus of the book:
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`“We put great emphasis on the integration of the different areas which are closed
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`[sic] related to the information retrieval problem and thus, should be treated
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`together.” Id., p. 17. This is made clear in Fig. 1.3 (id., p. 24), copied below.
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`21
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`
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`Ex. 1004, Fig. 1.3
`50. Chapter 2 on “Modeling” includes in Section 2.5.1 a discussion on basic
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`concepts of classic information retrieval, and explains “[t]he classic models in
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`information retrieval consider that each document is described by a set of
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`representative keywords called index terms.” Id., p. 38.
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`51. Chapter 4, “Query Languages,” includes in Section 4.3 a discussion of
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`Pattern Matching
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`(including words, prefixes, substrings,
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`ranges,
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`regular
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`expressions), including the broad method considered in the ’394 Patent as successive
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`characters are entered and matched with terms that begin with the characters already
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`22
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`seen. Even more complex patterns are described than occur with overloaded
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`keyboards:
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`For instance, consider a query like ‘pro (blem | tein) (s | ) (0 | 1 | 2)*’ (where
` denotes the empty string). It will match words such as ‘problem02’ and
`‘proteins.’ As in previous cases, the matches can be restricted to comprise a
`whole word, to occur inside a word, or to match an arbitrary text segment.
`Id., p. 93.
`52. Chapter 8, on “Indexing and Searching,” in Section 8.2, explains
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`Inverted Files, illustrated in Fig. 8.1 (id., p. 129) below, showing how words are
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`mapped to their occurrence locations in storage.
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`53. Fig. 8.3 (id., p. 133), shown below, extends that discussion, including a
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`discussion about the use of a vocabulary trie, explaining the building of an inverted
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`index, which is an aid to fast retrieval, here organized so that prefixes of words are
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`23
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`mapped to sub-trees of sets of words starting with those prefixes, and to the
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`individual words and their occurrences.
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`54. Section 8.3.1, on Suffix Trees and Suffix Arrays, explains, and
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`illustrates in Fig. 8.6 (id., p. 136) belo