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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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`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
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`v.
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`TELEFONAKTIEBOLAGET LM ERICSSON,
`Patent Owner
`
`
`
`
`U.S. PATENT NO. 9,509,440
`
`Case IPR2021-TBD
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`
`
`
`DECLARATION OF DR. JAMES L. MULLINS
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO.
`9,509,440
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`TABLE OF CONTENTS
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`Page
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`I.
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`II.
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`INTRODUCTION AND ENGAGEMENT ......................................................................1
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`BACKGROUND AND QUALIFICATIONS ..................................................................2
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`III.
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`BACKGROUND ON PUBLIC ACCESSIBILITY ..........................................................3
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`A.
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`B.
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`C.
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`D.
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`Scope of This Declaration ....................................................................................3
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`Person of Ordinary Skill in the Art .......................................................................5
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`Library Catalog Records and Other Resources .....................................................6
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`Monograph Publications .................................................................................... 11
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`OPINION REGARDING AUTHENTICITY AND PUBLIC ACCESSIBILITY ............ 13
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`RIGHT TO SUPPLEMENT .......................................................................................... 28
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`SIGNATURE ................................................................................................................ 28
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`IV.
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`V.
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`VI.
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`I, Dr. James L. Mullins, do hereby declare as follows:
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`I.
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`INTRODUCTION AND ENGAGEMENT
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`1. I have been retained in this matter by Samsung Electronics Co., Ltd (“Petitioner”
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`or “Samsung”) in the above-captioned inter partes review relating to U.S. Patent 9,509,440 to
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`provide an opinion on a specific document.
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`2. I am presently Dean Emeritus of Libraries and Esther Ellis Norton Professor
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`Emeritus at Purdue University. My career as a professional and academic/research spanned
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`more than 44 years including library positions at Indiana University, Villanova University,
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`Massachusetts Institute of Technology, and Purdue University. Appendix A is a true and
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`correct copy of my curriculum vitae describing my background and experience.
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`3. In 2018, I founded the firm Prior Art Documentation Librarian Services, LLC,
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`located at 106 Berrow, Williamsburg, VA 23188 after purchasing the intellectual property of
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`and successor to Prior Art Documentation, LLC located at 711 South Race Street, Urbana, IL
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`61801. Further information about my firm, Prior Art Documentation Librarian Services, LLC
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`(PADLS), is available at www.priorartdoclib.com.
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`4. I have been retained by Petitioner to offer my opinion on the authenticity and dates
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`of public accessibility of various documents. For this service, I am being paid my usual hourly
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`fee of $250.00. I have no stake in the outcome of this proceeding or any related litigation or
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`administrative proceedings, and my compensation in no way depends on the substance of my
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`testimony or the outcome of this proceeding.
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`II.
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`BACKGROUND AND QUALIFICATIONS
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`5. I received a Bachelor of Arts degree in History, Religion and Political Science in
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`1972 as well as a Master of Arts degree in Library Science in 1973 from the University of
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`Iowa. I received my Ph.D. in Academic Library Management in 1984 from Indiana University.
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`Over the past forty-four years, I have held various positions and as a leader in the field of
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`library and information sciences.
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`6. I am presently Dean Emeritus of Libraries and Esther Ellis Norton Professor
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`Emeritus at Purdue University, and have been since January 1, 2018. I have been previously
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`employed as follows:
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`•
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`Dean of Libraries and Professor and Esther Ellis Norton Professor, Purdue
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`University, West Lafayette, IN (2004-2017)
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`•
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`Assistant/Associate Director for Administration, Massachusetts Institute of
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`Technology (MIT) Libraries, Cambridge, MA (2000-2004)
`
`•
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`University Librarian and Director, Falvey Memorial Library, Villanova University,
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`Villanova, PA (1996-2000)
`
`•
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`Director of Library Services, Indiana University South Bend, South Bend, IN
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`(1978-1996)
`
`•
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`Part-time Instructor, School of Library and Information Science, Indiana
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`University, Bloomington, IN (1979-1996)
`
`•
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`Associate Law Librarian, and associated titles, Indiana University School of Law,
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`Bloomington, IN (1974-1978)
`
`•
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`Catalog Librarian, Assistant Professor, Georgia Southern College (now
`
`University), Statesboro, GA (1973-1974)
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`7. I am a member of the American Library Association (“ALA”), where I served as
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`the chair of the Research Committee of the Association of College and Research Libraries
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`(“ACRL”). My service to ALA included service on the editorial board of the most prominent
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`library journal, College and Research Libraries. I also served on the Standards Committee,
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`College Section of the Association of College and Research Libraries, where I was
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`instrumental in developing a re-issue of the Standards for College Libraries in 2000.
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`8. I am an author of numerous publications in the field of library science, and have
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`given presentations in library sciences at national and international conferences. During more
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`than 44 years as an academic librarian and library science scholar, I have gained extensive
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`experience with catalog records and online library management systems (LMS) built using
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`Machine-Readable Cataloging (“MARC”) standards. As an academic library administrator, I
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`have had responsibility to ensure that students were educated to identify, locate, assess, and
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`integrate information garnered from research library resources. I have also facilitated the
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`research of faculty colleagues either directly or through the provision of and access to the
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`requisite print and/or digital materials and services at the universities where I worked.
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`9. Based on my experience identified above and detailed in my curriculum vitae,
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`which is attached hereto as Appendix A, I consider myself to be an expert in the field of library
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`science and academic library administration. I have previously offered my opinions on the
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`public availability and authenticity of documents in over 40 cases. I have been deposed in one
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`case.
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`III. BACKGROUND ON PUBLIC ACCESSIBILITY
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`A.
`
`Scope of This Declaration
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`10. I am not a lawyer, and I am not rendering an opinion on the legal question of
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`whether a particular document is, or is not, a “printed publication” under the law. I am,
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`however, rendering my expert opinion on the authenticity of the document referenced herein
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`and when and how this document was disseminated or otherwise made available to the extent
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`that persons interested and ordinarily skilled in the subject matter or art, exercising reasonable
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`diligence, could have located the document.
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`11. I am informed by counsel that an item is considered authentic if there is sufficient
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`evidence to support a finding that the item is what it is claimed to be. I am also informed that
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`authenticity can be established based on the contents of the document itself, such as the
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`appearance, content, substance, internal patterns, or other distinctive characteristics of the item.
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`12. I am informed by counsel that a given reference qualifies as “publicly accessible”
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`if it was disseminated or otherwise made available such that a person interested in and
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`ordinarily skilled in the relevant subject matter could locate it through the exercise of ordinary
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`diligence.
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`13. While I understand that the determination of public accessibility under the
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`foregoing standard rests on a case-by-case analysis of the facts particular to an individual
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`publication, I also understand that a printed publication is rendered “publicly accessible” if it
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`is cataloged and indexed by a library such that a person interested in the relevant subject matter
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`could locate it (i.e., I understand that cataloging and indexing by a library is sufficient, though
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`there are other ways that a printed publication may qualify as “publicly accessible”). One
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`manner of sufficient indexing is indexing according to subject matter. I understand that it is
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`not necessary to prove someone actually looked at the printed publication in order to show it
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`was publicly accessible by virtue of a library’s cataloging and indexing thereof. I understand
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`that cataloging and indexing by a single library of a single instance of a particular printed
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`publication is sufficient. I understand that, even if access to a library is restricted, a printed
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`publication that has been cataloged and indexed therein is publicly accessible so long as a
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`presumption is raised that the portion of the public concerned with the relevant subject matter
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`would know of the printed publication. I also understand that the cataloging and indexing of
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`information that would guide a person interested in the relevant subject matter to the printed
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`publication, such as the cataloging and indexing of an abstract for the printed publication, is
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`sufficient to render the printed publication publicly accessible.
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`14. I understand that evidence showing the specific date when a printed publication
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`became publicly accessible is not necessary. Rather, routine business practices, such as general
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`library cataloging and indexing practices, can be used to establish an approximate date on
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`which a printed publication became publicly accessible.
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`B.
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`Person of Ordinary Skill in the Art
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`15. In forming the opinions expressed in this declaration, I have reviewed the
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`documents and appendices referenced herein. These materials are records created in the
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`ordinary course of business by publishers, libraries, indexing services, and others. From my
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`years of experience, I am familiar with the process for creating many of these records, and I
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`know that these records are created by people with knowledge of the information contained
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`within the record. Further, these records are created with the expectation that researchers and
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`other members of the public will use them. All materials cited in this declaration and its
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`appendices are of a type that experts in my field would reasonably rely upon and refer to in
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`forming their opinions.
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`16. I have been informed by counsel that the subject matter of this proceeding relates
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`to the use of modulation and coding schemes in a wireless communication network.
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`17. I have been informed by counsel that a “person of ordinary skill in the art at the
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`time of the inventions” (POSITA) is a hypothetical person who is presumed to be familiar with
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`the relevant field and its literature at the time of the inventions. This hypothetical person is
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`also a person of ordinary creativity, capable of understanding the scientific principles
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`applicable to the pertinent field.
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`18. I have been informed by counsel that persons of ordinary skill in this subject matter
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`or art would have included someone with a Master’s degree in Electrical Engineering,
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`Computer Science, Applied Mathematics, Physics or equivalent and three to five years of
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`experience working with wireless digital communication systems including physical layer of
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`such systems, and that additional education might compensate for less experience, and vice-
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`versa. It is my opinion that such a person would have been actively engaged in academic
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`research and learning through study and practice in the field, and possibly through formal
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`instruction through the bibliographic resources relevant to his or her research. By the 2000s,
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`such a person would have had access to a vast array of print resources, including at least the
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`documents referenced below, as well as to a fast-changing set of online resources.
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`C.
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`Library Catalog Records and Other Resources
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`19. Some background on MARC (Machine-Readable Cataloging) formatted records,
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`OCLC, and WorldCat is helpful to understand the library catalog records discussed in this
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`declaration. I am fully familiar with the library cataloging standard known as the MARC
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`standard, which is an industry-wide standard method of storing and organizing library catalog
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`information.1 MARC practices have been consistent since the MARC format was developed
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`by the Library of Congress in the 1960s, and by the early 1970s became the U.S. national
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`standard for disseminating bibliographic data. By the mid-1970s, MARC format became the
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`international standard, and persists through the present. A MARC-compatible library is one
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`that has a catalog consisting of individual MARC records for each of its items. The underlying
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`MARC format (computer program) underpins the online public access catalog (OPAC) that is
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`available to library users to locate a particular holding of a library. Today, MARC is the
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`primary communications protocol for the transfer and storage of bibliographic metadata in
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`libraries.2 The MARC practices discussed below were in place during the 2000s time frame
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`relevant to the documents referenced herein.
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`20. Online Computer Library Center (OCLC) is a not-for-profit worldwide consortium
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`of libraries. Similar to MARC standards, OCLC’s practices have been consistent since the
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`1970s through to the present. Accordingly, the OCLC practices discussed below were in place
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`during the time frame discussed in my opinions section. OCLC was created “to establish,
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`maintain and operate a computerized library network and to promote the evolution of library
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`use, of libraries themselves, and of librarianship, and to provide processes and products for the
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`1 The full text of the standard is available from the Library of Congress at
`http://www.loc.gov/marc/bibliographic/.
`2 Almost every major library in the world uses a catalog that is MARC-compatible.
`See, e.g., Library of Congress, MARC Frequently Asked Questions (FAQ),
`https://www.loc.gov/marc/faq.html (last visited Jan. 24, 2018) (“MARC is the
`acronym for MAchine-Readable Cataloging. It defines a data format that emerged
`from a Library of Congress-led initiative that began nearly forty years ago. It
`provides the mechanism by which computers exchange, use, and interpret
`bibliographic information, and its data elements make up the foundation of most
`library catalogs used today.”). MARC is the ANSI/NISO Z39.2-1994 (reaffirmed
`2009) standard for Information Interchange Format.
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`benefit of library users and libraries, including such objectives as increasing availability of
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`library resources to individual library patrons and reducing the rate of rise of library per-unit
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`costs, all for the fundamental public purpose of furthering ease of access to and use of the ever-
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`expanding body of worldwide scientific,
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`literary and educational knowledge and
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`information.”3 Among other services, OCLC and its members are responsible for maintaining
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`the WorldCat database (http://www.worldcat.org/), used by libraries throughout the world.
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`21. Libraries worldwide use the machine-readable MARC format for catalog records.
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`MARC-formatted records include a variety of subject access points based on the content of the
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`document being cataloged. A MARC record for a particular work comprises several fields,
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`each of which contains specific data about the work. Each field is identified by a standardized,
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`unique, three-digit code corresponding to the type of data that follows. For example, a work’s
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`title is recorded in field 245, the primary author of the work is recorded in field 100, a work’s
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`International Standard Book Number (“ISBN”) is recorded in field 020, and the work’s Library
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`of Congress call number (assigned by Library of Congress) is recorded in field 050. Some
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`fields can contain subfields, which are indicated by letters. For example, a work’s publication
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`date is recorded in field 260 under the subfield “c.”
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`22. The MARC Field 040, subfield “a,” identifies the library or other entity that created
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`the catalog record in the MARC format. The MARC Field 008 identifies the date when this
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`first MARC record was created. The MARC Field 005 identifies the most recent catalog
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`3 OCLC Online Computer Library Center, Inc., Amended Articles of Incorporation
`of OCLC Online Computer Library Center, Inc., Third Article (OCLC, Dublin,
`Ohio) Revised November 30, 2016,
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`https://www.oclc.org/content/dam/oclc/membership/articles-of-incorporation.pdf.
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`activity including location assignment, by the holding library, that is, the library which owns
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`the book and is identified in the OPAC.
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`23. MARC records also include several fields that include subject matter classification
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`information. An overview of MARC record fields is available through the Library of Congress
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`at http://www.loc.gov/marc/bibliographic/. For example, 6XX fields are termed “Subject
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`Access Fields.”4 Among these, for example, is the 650 field; this is the “Subject Added Entry
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`– Topical Term” field. See http://www.loc.gov/marc/bibliographic/bd650.html. The 650 field
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`is a “[s]ubject added entry in which the entry element is a topical term.” Id. The 650 field
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`entries “are assigned to a bibliographic record to provide access according to generally
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`accepted thesaurus-building rules (e.g., Library of Congress Subject Headings (LCSH),
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`Medical Subject Headings (MeSH)).” Id. Thus, a researcher can easily discover material
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`relevant to a topic of interest with a search using the terms employed in the MARC Fields
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`6XX.
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`24. Further, MARC records include call numbers, which themselves include a
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`classification number. For example, the 050 field is dedicated as the “Library of Congress Call
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`Number”5 as assigned by the Library of Congress. A defined portion of the Library of
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`Congress Call Number is the classification number, and “source of the classification number
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`is Library of Congress Classification and the LC Classification-Additions and Changes.” Id.
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`Thus, included in the 050 field is a subject matter classification. As an example: TK5105.59
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`indicates books on computer networks – security measures. When a local library assigns a
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`classification number, most often a Library of Congress derived classification number created
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`4 See http://www.loc.gov/marc/bibliographic/bd6xx.html.
`5 See http://www.loc.gov/marc/bibliographic/bd050.html.
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`by a local library cataloger or it could be a Dewey Decimal classification number for example,
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`005.8, computer networks – security measures, it appears in the 090 field. In either scenario,
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`the MARC record includes a classification number in the call number field that represents a
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`subject matter classification.
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`25. The 9XX fields, which are not part of the standard MARC 21 format,6 were defined
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`by OCLC for use by the Library of Congress, processing or holding notes for a local library,
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`and for internal OCLC use. For example, the 955 field is reserved for use by the Library of
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`Congress to track the progress of a new acquisition from the time it is submitted for Cataloging
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`in Publication (CIP) review until it is published and fully cataloged and publicly available for
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`use within the Library of Congress. Fields 901-907, 910, and 945-949 have been defined by
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`OCLC for local use and will pass OCLC validation. Fields 905, 910, 980 etc., are often used
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`by an individual library for internal processing purposes, for example the date of receipt or
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`cataloging and/or the initials of the cataloger.
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`26. WorldCat is the world’s largest public online catalog, maintained by the OCLC, a
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`not-for-profit international library consortium, and built with the records created by the
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`thousands of libraries that are members of OCLC. OCLC provides bibliographic and abstract
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`information to the public based on MARC-compliant records through its OCLC WorldCat
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`database. WorldCat requires no knowledge of MARC tags and code and does not require a
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`login or password. WorldCat is easily accessible through the World Wide Web to all who wish
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`to search it; there are no restrictions to be a member of a particular community, etc. The date
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`a given catalog record was created (corresponding to the MARC Field 008) appears in some
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`detailed WorldCat records as the Date of Entry but not necessarily all. WorldCat does not
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`6 See https://www.oclc.org/bibformats/en/9xx.html.
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`provide a view of the underlying MARC format for a specific WorldCat record. In order to
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`see the underlying MARC format the researcher must locate the book in a holding library listed
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`among those shown in WorldCat, and search the online public catalog (OPAC) of a holding
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`library. Whereas WorldCat records are widely available, the availability of library specific
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`MARC formatted records varies from library to library. When a specific library wishes to
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`make the underlying MARC format available there will be a link from the library’s OPAC
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`display, often identified as a MARC record or librarian/staff view.
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`27. When a MARC record is created by the Library of Congress or an OCLC member
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`institution, the date of creation for that record is automatically populated in the fixed field
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`(008), with characters 00 through 05 in year, month, day format (YYMMDD).7 Therefore, the
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`MARC record creation date reflects the date on which the publication associated with the
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`record was first cataloged. Thereafter, the local library’s computer system may automatically
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`update the date in field 005 every time the library updates the MARC record (e.g., to reflect
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`that an item has been moved to a different shelving location within the library, or a reload of
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`the bibliographic data with the introduction of a new library management system that creates
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`and manages the OPAC).
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`D. Monograph Publications
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`28. Monograph publications are written on a single topic, presented at length and
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`distinguished from an article and include books, dissertations, and technical reports. A library
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`typically creates a catalog record when the monograph is acquired by the library. First, it will
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`search OCLC to determine if a record has already been created by the Library of Congress or
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`7 Some of the newer library catalog systems also include hour, minute, second
`(HHMMSS).
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`another OCLC institution. If a record is found in OCLC, the record is downloaded into the
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`library’s LMS (Library Management System) that includes typically the OPAC (online public
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`access catalog by which researchers locate a particular library holding in a user-friendly
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`format), acquisitions, cataloging, and circulation integrated functions. Once the item is
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`downloaded into the library’s LMS, the library adds its identifier to the OCLC database so
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`when a search is completed on WorldCat, the library will be indicated as an owner of the title.
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`Once a record is created in a Library’s LMS, it is searchable and viewable through the library’s
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`OPAC, typically by author, title, and subject heading, at that library and from anywhere in the
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`world through the internet by accessing that library’s OPAC. The OPAC also connects with
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`the circulation function of the library, which typically indicates whether the record is available,
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`in circulation, etc., with its call number and location in a specific departmental/disciplinary
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`library, if applicable. The OPAC not only provides immediate bibliographic access on-site, it
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`also facilitates the interlibrary loan process, which is when one publication is loaned from one
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`library to another.
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`29. O’Reilly Online Learning - O’Reilly learning provides individuals, teams, and
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`businesses with expert-created and curated information covering all the areas that will shape
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`our future—including artificial intelligence, operations, data, UX design, finance, leadership,
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`and more. https://www.oreilly.com/online-learning/
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`30. Google Books - find a book, click on the "Buy this book" and "Borrow this book"
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`links to see where it can be purchased as an e-book from the Google Play Store.
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`https://books.google.com/googlebooks/about/index.html
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`31. Wisconsin TechSearch (WTS) – WTS is a set of services offered by the University
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`of Wisconsin Libraries. WTS offers an array of article delivery and research services to any
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`individual or organization who requests the specialized skills of WTS staff in locating and
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`retrieving information, regardless of whether the individual is affiliated with the University of
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`Wisconsin. (https://wts.wisc.edu/).
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`IV. OPINION
`ACCESSIBILITY
`
`REGARDING
`
`AUTHENTICITY
`
`AND
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`PUBLIC
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`Document A: Arunabha Ghosh, et al, Fundamentals of LTE. Prentice-Hall, 2011. 418
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`pages. (“Ghosh”)
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`32. I have been asked to opine on a book authored by Arunabha Ghosh, et al,
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`Fundamentals of LTE published by Prentice-Hall in 2011, “Ghosh”. Ghosh contains in 418
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`pages, 10 Chapters, and an Index.
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`33. I have evaluated Exhibit 1007, the Ghosh reference several ways: (1) by assessing
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`scans of a print copy of Ghosh owned by the University of Notre Dame Libraries, provided to
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`me at my request by the Wisconsin TechSearch (WTS) on January 21, 2021 (Attachment 1-
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`A); (2) by assessing a digital copy accessed through Purdue University Libraries (Attachment
`
`1-B) from the O’Reilly Online Learning; (3) by purchasing a digital copy of Ghosh through
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`Kindle (Attachment 1-C); and (4) accessing and assessing the OPAC and MARC records for
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`Ghosh at the Library of Congress (Attachments 1-H and Attachment 1-I).
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`34. Attachment 1-A is the scan provided to me at my request from the University of
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`Notre Dame Libraries by the Wisconsin Tech Search (WTS) on January 21, 2021. Attachment
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`1-A includes: Cover; title page; copyright page with handwritten call number that reads “Engin
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`TK5103.48325.F86 2011; Contents, includes pages: ix-xvi.
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`35. All identifying characteristics, such as stamps and notations on Attachment 1-A are
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`consistent with library practice and procedure that I have observed during my career as a
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`professional librarian. I have no cause for concern about the authenticity or accuracy of these
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`identifying attributes. In addition, Attachment 1-A was found within the custody of a research
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`library, the University of Notre Dame Libraries, one of the most likely locations for an
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`authentic publication to be located.
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`36. Attachment 1-B are screenshots from Ghosh that include: cover; title page;
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`copyright page; and contents. This digital version was accessible to me from the O’Reilly
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`Online Learning database through Purdue University Libraries, and was downloaded on
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`January 27, 2021, due to license limitations it was not possible to download Ghosh in its
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`entirety from O’Reilly Online Learning, hence the reason for screen shots, at this URL:
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`https://learning.oreilly.com/library/view/fundamentals-of-lte/9780137033638/title.html
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`37. Attachment 1-C is screenshots from Google Books. I purchased a digital copy of
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`Ghosh through Google Books on January 26, 2021. It was downloaded to my Kindle platform.
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`I did call up the copy that I downloaded to compare the content of Ghosh purchased from
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`Google Books and the copy I accessed through Purdue University Libraries from O’Reilly
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`Online Learning.
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`38. The digital version of Ghosh is available to anyone for a fee through Google books
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`at:
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`https://www.google.com/books/edition/_/HjxmKq5MABcC?hl=en&gbpv=1&pg=PT21&dq=
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`Fundamentals+of+LTE+
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`39. To verify authenticity of Attachment 1-A, Attachment 1-B, and Attachment 1-C, I
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`assessed the title page, copyright page and table of contents, from all three, they are identical.
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`Having located Ghosh in a research library, University of Notre Dame Libraries, and in a
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`publisher data base, O’Reilly Online Learning, and a digital copy through Google Books, I can
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`verify that Ghosh is an authentic document published by Prentice-Hall in 2011 in print and
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`made available in digital format.
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`40. I conclude and affirm that Ghosh is an authentic document.
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`Public Accessibility
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`41. Attachment 1-D is the University of Notre Dame Library OPAC (online catalog)
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`record that I downloaded on January 20, 2021. The document cataloged in this record is Ghosh
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`as verified by author: Arunabha Ghosh; title: Fundamentals of LTE; publisher and publication
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`date: Prentice Hall in 2011; and ISBN: 978-0-13-703311-9.
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`42. I also compared the LC Classification (call number): TK5103.48325.F86 2011 with
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`that handwritten on the copyright pages of Attachment 1-A and it is the same on both, and on
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`the OPAC record it indicates it is available in the “Lower Level Engineering Collection” also
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`identified as a part of the call number. Ghosh could have been located by searching on the
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`University of Notre Dame Libraries OPAC for the author: Arunabha Ghosh; title:
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`Fundamentals of LTE; or by searching the subject heading: Long-term Evolution
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`(Telecommunications).
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`43. As mentioned above the MARC Field 005 and 9XX often indicate the date of
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`receipt and cataloging, depending upon the practice and procedure of the library. Attachment
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`1-E is a download I made on January 20, 2021 of the MARC record from the University of
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`Notre Dame Libraries OPAC through the link: “Staff MARC View.” It provides detailed
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`information about the ordering/receipt/ cataloging/indexing of Ghosh.
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`44. In Attachment 1-E, the MARC 980 Field is: 20101018 (October 18, 2010) and the
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`MARC 005 Field is: 20101202123027, i.e., December 2, 2010 (the remaining digits are check
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`digits).
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`45. I contacted Diane Walker, University Librarian, University of Notre Dame on
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`January 22, 2021, to ask for clarification on the MARC 005 and MARC 980 fields as used by
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`the University of Notre Dame Libraries, specifically for the MARC record for Ghosh.
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`46. Attachment 1-F, is the email I received from Diane Walker, University Librarian
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`of the University of Notre Dame on January 24, 2021. In her email she included an email to
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`her from the head of Metadata Services of the University of Notre Dame in which she describes
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`the policy and practice of the Metadata Department on the use of the MARC 005 and MARC
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`980 fields:
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`Here is a summary of what happened with this title:
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`10/18/2010: Title invoiced by vendor and item prepared to ship from vendor.
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`10/29/2010: Bibliographic record loaded in Aleph system and order record created
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`automatically using the local 9XX MARC data. Shipment arrives in library Acquisitions sometime
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`around this date. After which, the shipment is unpacked, displayed for a two-week subject librarian
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`review, taken off display for final invoice processing, and sent to Cataloging for final processing
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`(just prior to Thanksgiving, I would guess).
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`12/2/2010: Cataloging of book is completed and it is sent to Labelling and delivery to the
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`Engineering Library. This date corresponds to the MARC 005.
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`
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`47. From Attachment 1-E and verified in Attachment 1-F, the date in the MARC 005
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`Field is the final cataloging of Ghosh at the University of Notre Dame Libraries, December 2,
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`2010. Consistent with library practice and procedures I witnessed during my professional work
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`as a librarian, Ghosh would have been available for public access within one week to ten days
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`after it finished processing (labeling and transfer to the shelf) at the University of Notre Dame
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`Libraries in the Engineering Collection on December 12, 2010.
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`48. Attachment 1-G is a download from WorldCat for holdings of Ghosh when
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`searched using the geographical location of Indiana. The University of Notre Dame, Hesbur