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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`SNAP INC.,
`Petitioner
`
`v.
`
`BLACKBERRY LIMITED
`Patent Owner
`
`____________________
`
`Patent No. 8,326,327
`____________________
`
`DECLARATION OF DR. SAMRAT BHATTACHARJEE
`
`
`
`
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`Snap Inc. Ex. 1002 Page 0001
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`Declaration of Dr. Bobby Bhattacharjee
`U.S. Patent No. 8,326,327
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`TABLE OF CONTENTS
`TABLE OF CONTENTS ........................................................................................... i
`I.
`INTRODUCTION .......................................................................................... 1
`II.
`QUALIFICATIONS ....................................................................................... 1
`III.
`SUMMARY OF OPINIONS .......................................................................... 5
`IV. LEVEL OF ORDINARY SKILL IN THE ART ............................................ 6
`V.
`BACKGROUND OF THE RELEVANT FIELD .......................................... 7
`VI. OVERVIEW OF THE ’327 PATENT ........................................................... 8
`VII. CLAIM CONSTRUCTION ......................................................................... 10
`A.
`“determine at least one action spot within a predetermined
`distance from the current location of the first mobile device” ........... 10
`“display the image with the at least one activity spot” ...................... 12
`B.
`VIII. OVERVIEW OF THE PRIOR ART ............................................................ 14
`A. Winkler ............................................................................................... 14
`B.
`Altman................................................................................................. 17
`C.
`Lemmela ............................................................................................. 19
`D.
`Crowley .............................................................................................. 21
`E. Waldman ............................................................................................. 22
`IX. THE PRIOR ART Teaches OR SUGGESTS ALL OF THE
`FEATURES OF CLAIMS 1-3, 8-11, 13-15, and 20 OF THE ’327
`PATENT ....................................................................................................... 23
`F.
`Ground 1: Claims 1-3, 8, 10-11, and 13-15 Are Obvious Over
`Winkler in View of Altman ................................................................. 23
`1.
`Claim 1 ..................................................................................... 24
`2.
`Claim 2 ..................................................................................... 44
`3.
`Claim 3 ..................................................................................... 45
`4.
`Claim 8 ..................................................................................... 46
`5.
`Claim 10 ................................................................................... 47
`i
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`Declaration of Dr. Bobby Bhattacharjee
`U.S. Patent No. 8,326,327
`
`
`B.
`
`6.
`Claim 11 ................................................................................... 49
`Claim 13 ................................................................................... 50
`7.
`Claim 14 ................................................................................... 51
`8.
`Claim 15 ................................................................................... 52
`9.
`Ground 2: Claims 1-3, 8, and 13-15 Are Obvious Over
`Lemmela in View of Crowley ............................................................. 53
`10. Claim 1 ..................................................................................... 53
`11. Claim 2 ..................................................................................... 67
`12. Claim 3 ..................................................................................... 68
`13. Claim 8 ..................................................................................... 68
`14. Claim 13 ................................................................................... 69
`15. Claim 14 ................................................................................... 71
`16. Claim 15 ................................................................................... 71
`Ground 3: Claims 10-11 Are Obvious Over Lemmela in View
`of Crowley, in Further View of Winkler ............................................ 72
`17. Claim 10 ................................................................................... 72
`18. Claim 11 ................................................................................... 78
`D. Ground 4: Claims 9 and 20 Are Obvious Over Lemmela in
`View of Crowley, in Further View of Waldman ................................ 78
`19. Claim 9 ..................................................................................... 79
`20. Claim 20 ................................................................................... 87
`CONCLUSION ............................................................................................. 88
`
`C.
`
`ii
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`X.
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`
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`I, Dr. Samrat Bhattacharjee, declare as follows:
`
`I.
`
`INTRODUCTION
`I have been retained by Snap Inc. (“Petitioner”) as an independent
`
`1.
`
`expert consultant in this proceeding before the United States Patent and Trademark
`
`Office (“PTO”) regarding U.S. Patent No. 8,326,327 (“the ’327 patent”) (Ex.
`
`1001). I have been asked to consider whether certain references teach or suggest
`
`the features recited in claims 1-3, 8-11, 13-15, and 20 (“the challenged claims”) of
`
`the ’327 patent. My opinions are set forth below.
`
`2.
`
`I am being compensated at my rate of $600 per hour for the time I
`
`spend on this matter. My compensation is in no way contingent on the nature of
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`my findings, the presentation of my findings in testimony, or the outcome of this or
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`any other proceeding. I have no other interest in this proceeding.
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`II. QUALIFICATIONS
`3. My qualifications for forming the opinions in this report are
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`summarized here and explained in more detail in my curriculum vitae, which I
`
`understand is provided as Exhibit 1003.
`
`4.
`
`I earned a Ph.D. in Computer Science from Georgia Institute of
`
`Technology in 1999. Before that, I earned Bachelor of Science degrees in
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`Mathematics and Computer Science from Georgia College and State University in
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`
`
`
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`1
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
`
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`1994. I was a Teaching Assistant at the Georgia Institute of Technology from
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`1994 to 1995 and an Instructor in 1998.
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`5.
`
`From 1999 through 2005, I was an Assistant Professor at the
`
`University of Maryland, College Park, in the Department of Computer Science,
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`and then an Associate Professor with tenure from 2005 through 2009. In 2006, I
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`was a Visiting Professor at Max Planck Institüt für Software Systems in
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`Saarbrücken, Germany. In 2007, I was a Visiting Researcher at AT&T Labs in
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`Florham Park, New Jersey.
`
`6.
`
`Since 2009, I have been a tenured Professor at the University of
`
`Maryland. My teaching and research have focused on systems, security, and
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`computer networking,
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`including mobile systems, and all aspects of
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`the
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`technologies pertaining to the ’327 patent.
`
`7.
`
`I have served as a reviewer for ACM/IEEE Transactions on
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`Networking, IEEE Journal on Selected Areas in Communications, Computer
`
`Communications Journal (Special Issue on Network Security), ACM Transactions
`
`on Computer
`
`Systems,
`
`Performance Evaluation
`
`Journal, Computer
`
`Communications Review, European Transactions on Telecommunications, IEEE
`
`Transactions on Parallel and Distributed Systems, and ACM Transactions on
`
`Internet Technology.
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`
`
`
`
`2
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
`
`
`I am the author of numerous publications in the field of computer
`
`8.
`
`networking, including journal articles, book chapters, publications in proceedings,
`
`technical reports, and invited papers.
`
`9.
`
`I have been active in a number of professional organizations and
`
`conferences. I have served with the National Science Foundation (NSF) Workshop
`
`on Network Testbeds, the NSF Networking Research Panel, the Department of
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`Education High Performance Networking Panel, and as an Evaluator for the Intel
`
`Science Talent Search.
`
`10.
`
`I have received several honors and awards. These include: the Alfred
`
`P. Sloan Jr. Fellowship; the Best Paper Award, 14th Annual IEEE International
`
`Conference on High Performance Computing (HiPC) (with Vijay Gopalakrishnan,
`
`Ruggero Morselli, Peter Keleher, and Aravind Srinivasan); the Best Paper Award,
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`7th IEEE/ACM Conference on Grid Computing (with Jiksoo Kim, Byomsuk Nam,
`
`Peter Keleher, Michael Marsh, and Alan Sussman); and the NSF CAREER Award.
`
`I also received Teaching Excellence Awards in 2004, 2008, and 2012.
`
`11.
`
`In 2017, along with colleagues from Cornell University and the Max
`
`Planck Society in Germany, I started an annual school for introducing
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`undergraduate students from across the world to research. This school is partially
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`supported by the NSF and had student participants from 29 countries.
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`3
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
`
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`I am the co-director of a new joint Ph.D program in computer science
`
`12.
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`between the University of Maryland and the Max Planck Society in Germany.
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`13.
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`I am the co-inventor of four patents: U.S. Patent No. 7,181,623
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`(entitled “Scalable Wide-Area Upload System and Method”); U.S. Patent No.
`
`7,940,850 (entitled “Method for Encoding Frame Data”); U.S. Patent No.
`
`8,397,284 (entitled “Detection of Distributed Denial of Service Attacks in
`
`Autonomous System Domains”); and U.S. Patent No. 8,554,941 (entitled “Systems
`
`and Methods for Distributing Video on Demand”).
`
`14.
`
`I have been involved in other non-University Panels and Positions. I
`
`was Co-Chair of the Internet Research Task Force (IRTF) Peer-to-Peer Research
`
`Group from 2003-2009. I was Co-Program Committee Chair for NetEcon 2009
`
`Workshop and was Committee Member for INFOCOM in 2008-2009 and for
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`Sigmetrics in 2007-2009.
`
`15.
`
`I have served as an advisor to several Ph.D., Master’s, and
`
`Undergraduate’s degree candidates. I am currently an advisor to two Ph.D.
`
`candidates.
`
`16. As shown in Exhibit 1003, I have published extensively in the field of
`
`computer networking, wireless systems, mobile systems, operating systems, and
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`
`
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`4
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
`
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`computer security. A more complete list of my publications, authorships, and
`
`editorial positions can be found in Exhibit 1003.
`
`III. SUMMARY OF OPINIONS1
`17. All of the opinions contained in this Declaration are based on the
`
`documents I reviewed and my professional judgment, as well as my education,
`
`experience, and knowledge regarding commuter networking.
`
`18.
`
`In forming my opinions expressed in this Declaration, I reviewed the
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`’327 patent (Ex. 1001); U.S. Patent No. 8,750,906 to Winkler et al. (“Winkler”)
`
`(Ex. 1004); U.S. Patent Application Publication 2008/0250337 A1 to Lemmela et
`
`al. (“Lemmela”) (Ex. 1005); U.S. Patent Application Publication 2007/0281716 A1
`
`to Altman et al. (“Altman”) (Ex. 1006); the prosecution file history for the ’327
`
`patent (Ex. 1007); U.S. Patent No. 7,593,740 to Crowley et al. (“Crowley”) (Ex.
`
`1008); and U.S. Patent Application Publication 2011/0199479 (“Waldman”) (Ex.
`
`1011.) My opinions are additionally guided by my appreciation of how a person of
`
`ordinary skill in the art would have understood the claims of the ’327 patent at the
`
`
`1 My citations to non-patent publications are to the original page numbers of the
`
`publication, and my citations to U.S. Patents are to the column:line number or
`
`paragraph number of the patents or published patent applications, as applicable.
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`5
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
`
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`time of the alleged invention, which I assume, for the purposes of this petition, is
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`August 27, 2010.
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`19. Based on my experience and expertise, it is my opinion that certain
`
`references teach or suggest all the features recited in claims 1-3, 8-11, 13-15 and
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`20 of the ’327 patent.
`
`IV. LEVEL OF ORDINARY SKILL IN THE ART
`20. At the time of the alleged invention, in August 2010, a person of
`
`ordinary skill in the art would have had at least a B.S. degree in computer science,
`
`electrical engineering, or equivalent thereof, and at least two years of experience in
`
`the relevant field, e.g., computer networking. More education can substitute for
`
`practical experience and vice versa. I apply this understanding in my analysis
`
`herein.
`
`21.
`
`In determining the level of ordinary skill, I have been asked to
`
`consider, for example, the types of problems encountered in the art, prior solutions
`
`to those problems, the rapidity with which innovations are made, the sophistication
`
`of the technology, and the educational level of active workers in the field.
`
`22. My analysis of the ’327 patent and my opinions in this declaration are
`
`from the perspective of one of ordinary skill in the art, as I have defined it above,
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`during the relevant time frame stated above. During this time frame, I possessed at
`
`least the qualifications of a person of ordinary skill in the art, as defined above
`
`V. BACKGROUND OF THE RELEVANT FIELD
` The ’327 patent generally relates to mobile devices, and in particular
`
`23.
`
`determining what the patentee refers to as “action spots” based on the locations and
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`activities of mobile devices.
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`24. At the time the patent was filed, the basic technology for determining
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`the location of a mobile device was well known.
`
`25.
`
`Logging the actions undertaken by a mobile device, perhaps at the
`
`behest of its user, was also well known. Such actions included, for instance,
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`sending emails, sending text messages, and capturing photographs or videos.
`
`26.
`
`Sending information from a mobile device to a server connected to a
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`network was also well known. Such information could include the device's
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`location, or a log of the device's activity. Similarly, receiving information at a
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`mobile device from a server was also commonly known.
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`27. Applications that displayed a map, directions, or bearing were also
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`well known, and denoting points of interests on a display of a mobile device by
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`overlaying information on a map was common.
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`7
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
`
`
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`VI. OVERVIEW OF THE ’327 PATENT
`The ’327 patent, titled “System and Method for Determining Action
`
`28.
`
`Spot Locations Relative to the Location of a Mobile Device” is generally directed
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`to determining and displaying the location of mobile device activity on a map.
`
`(Ex. 1001, Abstract.) The ’327 patent recognizes that previously existing mobile
`
`devices could retrieve maps and directions for locations relative to a mobile device.
`
`(Id., 1:29-32.) The ’327 patent also recognizes that prior device users could
`
`determine “events and happenings” occurring proximate to a mobile device’s
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`location and manually compare the location of such events to the mobile device’s
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`location, which could be “tedious.” (Id., 3:4-16.) According to Patent Owner, the
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`patented concept differs from the prior art by disclosing “action spots” determined
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`using location data and the activity of other mobile devices.2 (Ex. 1010, ¶ 77.)
`
`29.
`
`The ’327 patent explains that an “action spot” refers to a location or
`
`an event where at least one other mobile device engages in certain types of activity.
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`(Id., 2:63-65.) This “activity” may include a “documenting action” (such as text
`
`
`2 This statement in the complaint is made in reference to U.S. Patent No. 8,825,084
`
`(“the ’084 patent), rather than the ’327 patent. However, the ’084 patent is a
`
`continuation of the ’327 patent and shares a common specification.
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`8
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`messaging, emailing, blogging, posting a message on a social networking internet
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`site), a “recording action” (such as video recording, audio recording, or
`
`photographing), or “any other action where a mobile device is being used to
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`observe and make note of a location or an event currently occurring at the location
`
`of the mobile device.” (Id., 2:54-63.)
`
`30.
`
`The ’327 patent also teaches that action spots may be determined
`
`within a “predetermined distance” from a mobile device and may correspond to
`
`device activity occurring within a “predetermined period of time.” (Id., 3:23-29,
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`3:32-35.) This predetermined distance and predetermined period of time can be set
`
`manually by the user, or can be predefined by the software application developer,
`
`the server provider, the manufacturer of the mobile device, or the communication
`
`network service provider. (Id., 8:15-23, 8:28-35.) This predetermined distance can
`
`be any specific distance from the current location of the mobile device; this
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`predetermined period of time can be any specific time period that is measured from
`
`the time the mobile device arrived at the current location. (Id., 8:23-27, 8:35-39.)
`
`31.
`
`Further, the ’327 patent teaches that action spots may be displayed
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`with an indication of activity level occurring at each spot. (Id., Abstract.)
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`Graphical items associated with action spots may employ colors, shapes, or sizes,
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`to display the relative level of activity occurring at the spot. (Id., 10:1-5.) For
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`example, “the graphical item associated with the action spot 410 can have a green
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`color to indicate that the most activity is occurring at that action spot 410. The
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`graphical item associated with the action spot 406 can be orange to indicate that
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`the action spot 406 has the second most activity.” (Id., 10:5-10.)
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`VII. CLAIM CONSTRUCTION
`I understand that a claim subject to inter partes review is construed in
`
`32.
`
`accordance with the ordinary and customary meaning, as understood by one of
`
`ordinary skill in the art and the prosecution history pertaining to the patent. I have
`
`followed these principles in forming my opinions in this declaration.
`
`A.
`“determine at least one action spot within a predetermined
`distance from the current location of the first mobile device”
`
`33. All challenged claims recite “determine at least one action spot within
`
`a predetermined distance from the current location of the first mobile device.” Ex.
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`1001, 19:17-20:64.)
`
`34.
`
`I understand that Petitioner has offered that this phrase should mean
`
`“determine each action spot within a specific distance from the current location of
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`the first mobile device, the specific distance being set prior to the determining
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`step.” I have used this construction unless otherwise noted.
`
`35.
`
`I agree that this construction is consistent with the ’327 patent’s
`
`claims and specification.
`
` For example,
`
`’327 patent
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`repeatedly and
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`exclusivelydescribes the predetermined distance as specific distances: “[t]he
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`predetermined distance can be within five blocks, ten blocks, ten yards, one
`
`hundred yards, one hundred feet, thirty feet, ten meters, fifteen meters, five miles,
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`ten miles, twelve miles, twenty miles, or any other distance from the current
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`location 302 of the mobile device 100.” (Id., 8:23-28.) Beyond a fixed specific
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`distance, the ’327 patent does not provide guidance as to the meaning of
`
`“predetermined distance.” In particular, the specification does not contemplate
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`that a “predetermined distance” could be a range, or the output of a computer
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`algorithm.
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`36. Also, a person of ordinary skill in the art would understand that the
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`“predetermined distance” must be set prior to the determination of action spots.
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`The determination of action spots is limited to action spots “within a
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`predetermined distance from the current location of the mobile device.” (Id.,
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`19:17-20:64.) Therefore, the “distance” must be determined before action spots
`
`are determined.
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`37. A person of ordinary skill would also understand that each action spot
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`within a specific distance from the current location of the first mobile device must
`
`be determined. This limitation recites “at least one action spot,” but the
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`specification does not explain how a system would treat action spots within the
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`“predetermined distance from the mobile device” differently so that some action
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`spots within that distance would be “determined” and others would not. Without
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`interpreting this limitation as applying to each action spot, the ’327 patent thus
`
`fails to inform a person of ordinary skill in the art about the claim’s scope.
`
`B.
`“display the image with the at least one activity spot”
`38. Claims 9 and 20 recite “display the image with the at least one activity
`
`spot.” (Ex. 1001, 19:62-20:1, 20:59-54.)
`
`39.
`
`I understand that Petitioner has offered that this phrase should mean
`
`“display the viewfinder image from the camera module with action spots
`
`superimposed thereupon.” I have used this construction unless otherwise noted,
`
`40.
`
`I agree that this construction is consistent with the ’327 patent’s
`
`claims and specification. Claims 9 and 20 depend from claims 1 and 13,
`
`respectively. Claims 9 and 20 both require:
`
`run/running an image acquisition application of the mobile device;
`display/displaying an image from a camera module on the display
`screen; and
`display/displaying the image with the at least one activity spot
`
`
`The specification discusses an “image acquisition application” and “camera
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`module” in connection with Figure 8 (below). (Id., 13:41-63.)
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`(Id., FIG. 8.) Figure 8 illustrates “determining action spot relative to the location
`
`of a mobile device that utilizes the camera viewfinder of an integrated camera of
`
`the mobile device 100.” (Id., 13:41-44.) Figure 8 displays “a graphical user
`
`interface for an image acquisition application 800.” (Id., 13:44-46.) Here, “the
`
`viewfinder 802 displays an image from a camera module. For example, the
`
`viewfinder displays the landscape, cityscape, or locations captured by the lens of a
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`camera of the mobile device 100.” (Id., 13:47-50.) “Action spots 804, 806, 808
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`13
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`(represented by the cloud-shaped icons) can be superimposed on the viewfinder
`
`802 signifying the locations of action spots 804, 806, 808 located within the
`
`vicinity shown in the viewfinder 802.” (Id., 13:56-59.) Thus, in view of the
`
`specification and in particular the surrounding limitations of claims 9 and 20,
`
`which delineate the recited process, a person of ordinary skill in the art would have
`
`understood the recited “image” to be the “viewfinder image from the camera
`
`module” and “display[ing] the image with the at least one activity spot” to be
`
`displaying that image “with action spots superimposed thereupon.”
`
`VIII. OVERVIEW OF THE PRIOR ART
`A. Winkler
` Winkler generally relates to a system for determining and displaying
`
`41.
`
`dynamic elements on a mobile device’s map application. (Ex. 1004, Abstract.)
`
`Winkler labels these elements as “map elements,” which may correspond to
`
`locations where mobile devices have performed actions at various locations (Id.,
`
`1:8-12; 2:14-26; 10:40-52; 12:5-10.)
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`42.
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`“Map elements” may be dynamically modified based on “events”
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`occurring at a user’s mobile device or at other locations associated with map
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`elements. (Id., 10:1-7.) “Events” can reflect movement of mobile devices near a
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`“map element” and/or user device activity associated with a “map element,” such
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`as posting comments. (Id., 10:40-47). When the occurrence of an event is
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`detected, the associated “map element” can change color, blink, or issue an audible
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`signal, and an updated “map element” will be displayed. (Id., 10:54-64; 11:6-26.)
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`For example, Figures 6A-6C display mobile device screens with a “map element”
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`dynamically changing based on the occurrence of an “event”:
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`(Id., FIG. 6.)
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`43. Winkler also teaches use of “map elements” to display additional
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`information on a map, such as the range of user device activity in different
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`locations. (Id., 11:66-12:2.) For example, Winkler teaches “heat map[s],” which
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`display zones with varying concentrations of user activity:
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`(Id., FIG. 7A; 12:4-10.) The highlighted areas 710, 720, 730 represent different
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`zones. (Id., 12:4-10, 12:45-46.) The zones are colored based on the amount of
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`activity in each region. (Id., 12:45-51.) Activity in a zone may equate to, for
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`example, the number of “map elements,” mobile device users, or comments posted
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`about locations within that region. (Id., 12:5-10.) The Winkler system can also
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`filter information shown on a map based on user feedback and/or input. (Id.,
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`12:25-26.) Although different examples of the Winkler system are described,
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`Winkler emphasizes that all examples are part of the same system. (See, e.g., id.
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`14:17-41 (“The elements and acts of the various examples described [] can be
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`combined to provide further implementations of the system.”))
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`Altman
`Altman generally relates to a system for location-based mobile
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`B.
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`44.
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`communications. (Ex. 1006, ¶¶ 2, 5-6.) Altman discusses how existing methods
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`of mobile communication are not optimized based on the relative locations of
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`communicating users. (Id., ¶ 4.) Specifically, these systems are not optimized for
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`facilitating communication when users are within certain proximity of a particular
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`location or to one another. (Id.) Altman thus teaches a mobile communication
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`system that initiates communication among users based on the users’ current
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`device location. (Id., Abstract.)
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`45.
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`Altman teaches a “location-based social network manager process”
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`and a “mobile communication device that incorporates a real-time map.” (Id., ¶
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`29.) In general, the process first determines the current location of a mobile
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`device. (Id., ¶ 7.) It then displays a map representation of an area, for example,
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`the area surrounding the mobile device. (Id.) The process then superimposes on
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`the map the locations of other user devices within a specific radius. (Id., ¶¶ 7, 60.)
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`Messaging using the communications capability of a mobile device can then
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`incorporate this location information. (Id., ¶ 7.) This allows users’ interactions to
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`be based on their relative location to each other. (Id.)
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`Altman teaches one embodiment in which the location-based social
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`46.
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`network manager includes a point of interest (POI) feature. (Id., ¶ 54.) This
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`feature allows device users to program and share POI with one another. (Id.) It
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`also allows the system to use a users’ location to determine which POI might be of
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`interest to her. (Id.) Altman teaches that the POI feature can also include an auto
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`messaging mechanism which sends an alert to a user based on the POI of another
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`user. (Id., ¶ 59.) For example, one user can tag a location as a POI, and then be
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`alerted when her friend gets within a specific distance of this POI:
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`(Id., FIG. 9; ¶ 59.) In Figure 9, the system alerts the user when her friend Cindy is
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`within 0.5 miles from her. (Id.) This specific distance may be set by the user in
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`advance. (Id., ¶ 60.)
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`Lemmela
`Lemmela generally relates to determining and displaying information
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`C.
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`47.
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`regarding location-based electronic postings. (Ex. 1005, ¶ 1.) Lemmela teaches
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`determining “interesting locations” by utilizing other device users’ location-based
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`electronic postings. (Id., ¶¶ 7, 9.) “Interesting locations” are determined by
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`analyzing other users’ location-based postings and identifying information which is
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`common in postings within a geographic area. (Id.) For example, if various
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`neighboring postings contain the same salient word(s), those words are determined
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`to be common to postings in the area, and therefore are likely to be reliable and
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`useful. (Id.) The taught system then groups postings which exist within a
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`particular geographic area and contain the same salient words. (Id., ¶¶ 7, 9, 11.)
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`48.
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`Lemmela teaches a mobile device that can display graphics
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`representing information based on groups of location-based postings:
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`(Id., FIG. 1; ¶ 26.) In Figure 1, a “display 20 shows a map of an area of interest.”
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`(Id.) To illustrate “an overall picture of the activities, services, sights and
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`atmosphere” of the area, the information regarding the most salient words used in
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`public postings can be presented to the user. (Id.) This information “may [be] in
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`the form of a cloud 24 or 26.” (Id., ¶ 27.) In this illustration, “cloud 24 indicates
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`an area with several shopping opportunities,” as determined by postings within the
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`bordered area. (Id., ¶¶ 26, 27.) Similarly, “cloud 26 indicat[es] an area [where
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`location postings mention] one or more cafes.” (Id.)
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`49.
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`Lemmela teaches signifying the relative amount of device activity at
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`each grouped posting location. (See id. ¶¶ 12, 28.) For example, a mobile device’s
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`20
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,326,327
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`display of grouped posting information may take the form of a “heat map,” in
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`which certain areas are colored based on information corresponding to posts within
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`that area. (Id., ¶¶ 12, 28.) The heat map may use different colors to illustrate the
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`density of location postings in different areas. (Id.) In another example, size
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`variations may be used to show the popularity of a certain word within an area’s
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`location-based electronic postings. (Id., ¶ 29.) Although different examples of the
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`Lemmela system are described, Lemmela emphasizes that all examples are part of