Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 10
`
`alphanumeric data, andof arbitrary length.); modifying, using a controller device, a selected
`
`first one of the tags of the metadatainafirst of the digital files to include thefirst tag
`
`label (See Sections 2.1-2.3 and 4.1 which clearly disclose that the digital files may be tagged with
`
`various forms of information including at least names of people, dates, relationships, and categories.
`
`Further see Section 2.1 and Figure 1 which clearly disclose that tags may be embeddedinto the files
`
`using the interface, either through a drag and crop interaction or a selection and labeling interaction.);
`
`receiving, via the userinterface device or another user interface device, an instruction to
`
`searchfor all of the digital files having at least the first tag label (See Sections 4.1, 4.3, 4.4
`
`which clearly disclose that images may be searched for based at least on data relating to a person,
`
`relationship, event, and date. Further see Section 2.1 and Figure 1 which clearly disclose thatfiles may
`
`be selected and sorted based on embedded tag information including at least name and category
`
`information. Examiner further notes that at least Figure 1 discloses that multiple tags may be sorted and
`
`retrieved at a time, as can be seen within the multiple tags displayed in the tree-view based sidebar at a
`
`time.); and responsiveto receiving the instruction, automatically searching for all of the
`
`digital files having at least the first tag label (See Sections 4.1, 4.3, 4.4 which clearly disclose that
`
`images may be searched for based at least on data relating to a person, relationship, event, and date.
`
`Further see Section 2.1 and Figure 1 which clearly disclose thatfiles may be selected and sorted based
`
`on embedded tag information including at least name and category information. Examiner further notes
`
`that at least Figure 1 discloses that multiple tags may be sorted and retrieved at a time, as can be seen
`
`within the multiple tags displayed in the tree-view based sidebarat a time.).
`
`Kustanowitz fails to disclose displaying, on a video display device associated
`
`with the client device a representation of an interactive map, all of the digital files having
`
`at leastthe first tag label being membersofa first set of digital files, the first set of digital
`
`files including at least a first geotag and a second geotag; and displaying, overlaid on
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`374 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`374 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 11
`
`the interactive map, (i) a first user selectable thumbnail imageatafirst location
`
`corresponding to the geographic coordinatesofthe first geotag on the interactive map,
`
`(ii) a first count value proximateto the first user selectable thumbnail image
`
`corresponding to the numberof digital photographs or imagesor videosin the first set of
`
`digital files having the first geotag, (iii) a second user selectable thumbnail image at a
`
`second location corresponding to the geographic coordinates of the second geotag on
`
`the interactive map, and (iv) a second count value proximate to the second user
`
`selectable thumbnail image corresponding to the numberof digital photographs or
`
`images or videosin the first set of digital files having the second geotag, the first user
`
`selectable thumbnail image including a scaled representation of at least one of the
`
`digital imagesin thefirst set of digital files having the first geotag, and the second user
`
`selectable thumbnail image including a scaled representation of at least one of the
`
`digital imagesin the first set of digital files having the second geotag; responsive to
`
`receiving a selection of the first user selectable thumbnail image, displaying, on the
`
`video display device, all of the digital photographs or imagesor videosin thefirst set of
`
`digital files having the first geotag.
`
`Meulen discloses displaying, on a video display device associated with the client
`
`device a representation of an interactive map,all of the digital files having at least the
`
`first tag label being membersofa first set of digital files, the first set of digital files
`
`including at least a first geotag and a second geotag (See Paragraphs 27 and 34-37 which
`
`clearly disclose that GPS coordinates may be recorded for digital photographs and used to create map
`
`display which displays photographs, photographs representative of collections of photographs, or
`
`metadata of the photographson aninteractive digital map according to the GPS coordinate information.) ;
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`375 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`375 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 12
`
`and displaying, overlaid on the interactive map, (i) a first thumbnail image ata first
`
`location corresponding to the geographic coordinatesof the first geotag on the
`
`interactive map (See Paragraphs 27 and 34-37 whichclearly disclose that GPS coordinates may be
`
`recorded for digital photographs and used to create map display which displays photographs,
`
`photographs representative of collections of photographs, or metadata of the photographson a digital
`
`map according to the GPS coordinate information.), (ili) a thumbnail image at a second location
`
`corresponding to the geographic coordinates of the second geotag on the interactive
`
`map (See Paragraphs 27 and 34-37 which clearly disclose that GPS coordinates may be recordedfor
`
`digital photographs and used to create map display which displays photographs, photographs
`
`representative of collections of photographs, or metadata of the photographs on a digital map according
`
`to the GPScoordinate information.), the first user selectable thumbnail image including a
`
`scaled representation of at least one of the digital imagesin the first set of digital files
`
`having the first geotag, and the second user selectable thumbnail image including a
`
`scaled representation of at least one of the digital imagesin the first set of digitalfiles
`
`having the second geotag (See Paragraphs 27 and 34-37 whichclearly disclose that GPS
`
`coordinates may be recordedfor digital photographs and used to create map display which displays
`
`photographs, photographs representative of collections of photographs, or metadata of the photographs
`
`on a digital map according to the GPS coordinate information.).
`
`It would have been obvious to one skilled in the art at the time of Applicant’s
`
`invention to modify the teachings of Kustanowitz with the teachings of Meulen to include
`
`displaying, on a video display device associated with the client device a representation
`
`of an interactive map, all of the digital files having at least the first tag label being
`
`membersofa first set of digital files, the first set of digital files including at leasta first
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`376 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`376 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 13
`
`geotag and a second geotag; and displaying, overlaid on the interactive map, (i) a first
`
`thumbnail image at a first location corresponding to the geographic coordinates of the
`
`first geotag on the interactive map, (iii) a thumbnail image at a second location
`
`corresponding to the geographic coordinates of the second geotag on the interactive
`
`map, the first user selectable thumbnail image including a scaled representation of at
`
`least one of the digital imagesin thefirst set of digital files having the first geotag, and
`
`the second userselectable thumbnail imageincluding a scaled representation of at
`
`least one of the digital imagesin the first set of digital files having the second geotag
`
`with the motivation of classifying and categorizing media using metadata (Meulen,
`
`Abstract).
`
`Kisilevich discloses that the thumbnail images are user selectable (See Sections
`
`5.1, 5.2, and 5.5 as well as Figure 1 which disclose that the map visualization may include thumbnail
`
`images representative of a cluster and a count of images within a cluster. Examiner further notes that
`
`selection of a cluster, as represented by the thumbnail images may reveal more detailed information such
`
`as the location and information for each photo within the cluster.), (ii) a first count value proximate
`
`to the first user selectable thumbnail image corresponding to the numberofdigital
`
`photographs or imagesor videosin the first set of digital files having the first geotag
`
`(See Sections 5.1, 5.2, and 5.5 as well as Figure 1 which disclose that the map visualization may include
`
`thumbnail images representative of a cluster and a count of images within a cluster. Examiner further
`
`notes that selection of a cluster, as represented by the thumbnail images may reveal more detailed
`
`information such as the location and information for each photo within the cluster.), (iv) a second
`
`count value proximate to the second user selectable thumbnail image corresponding to
`
`the numberof digital photographs or imagesor videosin thefirst set of digitalfiles
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`377 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`377 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 14
`
`having the second geotag (See Sections 5.1, 5.2, and 5.5 as well as Figure 1 which disclosethat the
`
`map visualization may include thumbnail images representative of a cluster and a count of images within
`
`a cluster. Examiner further notes that selection of a cluster, as represented by the thumbnail images may
`
`reveal more detailed information such as the location and information for each photo within the cluster.);
`
`responsive to receiving a selection of the first user selectable thumbnail image,
`
`displaying, on the video display device, all of the digital photographs or imagesor
`
`videosin the first set of digital files having the first geotag (See Sections 5.1, 5.2, and 5.5 as
`
`well as Figure 1 which disclose that the map visualization may include thumbnail images representative of
`
`a cluster and a count of images within a cluster. Examiner further notes that selection of a cluster, as
`
`represented by the thumbnail images may reveal more detailed information such as the location and
`
`information for each photo within the cluster.).
`
`It would have been obvious to one skilled in the art at the time of Applicant's
`
`invention to modify the teachings of Kustanowitz with the teachings of Kisilevich to
`
`include that the thumbnail images are user selectable, (ii) a first count value proximate
`
`to the first user selectable thumbnail image corresponding to the numberofdigital
`
`photographs or imagesor videosin the first set of digital files having the first geotag, (iv)
`
`a second count value proximate to the second user selectable thumbnail image
`
`corresponding to the numberof digital photographs or imagesor videosin the first set of
`
`digital files having the second geotag; responsiveto receiving a selection of the first
`
`user selectable thumbnail image, displaying, on the video display device, all of the
`
`digital photographs or imagesor videosin the first set of digital files having the first
`
`geotag with the motivation of creating an exploratory visual analysis environmentfor
`
`large geotagged photo collections (Kisilevich, Abstract).
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`378 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`378 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 15
`
`As per Claim 2, Kustanowitz fails to disclose subsequent to receiving the
`
`selection of the first user selectable thumbnail image, receiving a selection of a first one
`
`of the digital photographsor imagesor videosin the first set of digital files having the
`
`first geotag and displaying, on the video display device, indicia of each and every tag
`
`label created and inputted by the user and embeddedin the metadataofthe first one of
`
`the digital photographs or imagesor videosin thefirst set of digital files having the first
`
`geotag, togetherwith thefirst geotag.
`
`Kisilevich discloses subsequentto receiving the selection of the first user
`
`selectable thumbnail image, receiving a selection of a first one of the digital
`
`photographs or imagesor videosin the first set of digital files having the first geotag and
`
`displaying, on the video display device, indicia of each and every tag label created and
`
`inputted by the user and embeddedin the metadata ofthe first one of the digital
`
`photographs or imagesor videosin the first set of digital files having the first geotag,
`
`together with the first geotag (See Sections 5.1, 5.2, and 5.5 as well as Figure 1 which disclosethat
`
`the map visualization may include thumbnail images representative of a cluster and a count of images
`
`within a cluster. Examiner further notes that selection of a cluster, as represented by the thumbnail
`
`images may reveal more detailed information such as the location and information for each photo within
`
`the cluster. Examiner notes that the detailed information may include any tags assigned to the selected
`
`photographincluding owner id, photo id, title, ect.).
`
`It would have been obvious to one skilled in the art at the time of Applicant's
`
`invention to modify the teachings of Kustanowitz with the teachings of Kisilevich to
`
`include subsequent to receiving the selection of the first user selectable thumbnail
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`379 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`379 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 16
`
`image, receiving a selection ofa first one of the digital photographs or imagesor videos
`
`in the first set of digital files having the first geotag and displaying, on the video display
`
`device, indicia of each and every tag label created and inputted by the user and
`
`embeddedin the metadata ofthe first one of the digital photographs or images or
`
`videosin the first set of digital files having the first geotag, together with the first geotag
`
`with the motivation of creating an exploratory visual analysis environmentfor large
`
`geotagged photocollections (Kisilevich, Abstract).
`
`As per Claim 3, Kustanowitz discloses receiving, via the user interface device, a
`
`second tag label containing alphanumeric text created and inputted by the user (See
`
`Sections 2.1-2.3 and 4.1 which clearly disclose that the digital files may be tagged with various formsof
`
`information including at least namesof people, dates, relationships, and categories. Further see Section
`
`2.1 and Figure 1 which clearly disclose that multiple tags may be embeddedinto the files using the
`
`interface, either through a drag and drop interaction or a selection and labeling interaction. Examiner
`
`notes that the tags are clearly user generated, comprised of alohanumeric data, and of arbitrary length.);
`
`modifying, using the controller device, a selected second oneofthe tags of the
`
`metadata embeddedin a second ofthe digital files to include the second tag label (See
`
`Sections 2.1-2.3 and 4.1 which clearly disclose that the digital files may be tagged with various formsof
`
`information including at least namesof people, dates, relationships, and categories. Further see Section
`
`2.1 and Figure 1 which clearly disclose that multiple tags may be embeddedinto the files using the
`
`interface, either through a drag and drop interaction or a selection and labeling interaction. Examiner
`
`notes that the tags are clearly user generated, comprised of alphanumeric data, and of arbitrary length.);
`
`receiving, via the userinterface device or the other user interface device, a second
`
`instruction to searchfor all of the digital files having at least the second tag label (See
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`380 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`380 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 17
`
`Sections 4.1, 4.3, 4.4 which clearly disclose that images may be searched for based at least on data
`
`relating to a person, relationship, event, and date. Further see Section 2.1 and Figure 1 which clearly
`
`disclose thatfiles may be selected and sorted based on embedded tag information including at least
`
`name and category information. Examiner further notes that at least Figure 1 discloses that multiple tags
`
`may be sorted and retrieved at a time, as can be seen within the multiple tags displayed in the tree-view
`
`based sidebar at a time.); responsive to receiving the second instruction, automatically
`
`searching for all of the digital files having at least the second tag label (See Sections 4.1,
`
`4.3, 4.4 which clearly disclose that images may be searched for based at least on data relating to a
`
`person, relationship, event, and date. Further see Section 2.1 and Figure 1 which clearly disclose that
`
`files may be selected and sorted based on embedded tag information including at least name and
`
`category information. Examiner further notes that at least Figure 1 discloses that multiple tags may be
`
`sorted and retrieved at a time, as can be seen within the multiple tags displayed in the tree-view based
`
`sidebarat a time.); and displaying, on a video display device associated with the client
`
`device, a first indication of the first tag label (See Sections 4.1, 4.3, 4.4 whichclearly disclose
`
`that images may be searched for based at least on data relating to a person, relationship, event, and
`
`date. Further see Section 2.1 and Figures 1-2 which clearly disclose that files may be selected and
`
`sorted based on embedded tag information including at least name and category information. Examiner
`
`further notes that at least Figure 1 discloses that multiple tags may be sorted and retrieved at a time, as
`
`can be seen within the multiple tags displayed in the tree-view based sidebar at a time. Examiner notes
`
`that the tags are further displayed in the photo information and in the sidebar.); and displaying, on
`
`the video display device associated with the client device, an indication of the second
`
`tag label (See Sections 4.1, 4.3, 4.4 which clearly disclose that images may be searchedfor based at
`
`least on data relating to a person, relationship, event, and date. Further see Section 2.1 and Figures 1-2
`
`whichclearly disclose that files may be selected and sorted based on embedded tag information including
`
`at least name and category information. Examiner further notes that at least Figure 1 discloses that
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`381 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`381 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 18
`
`multiple tags may be sorted and retrieved at a time, as can be seen within the multiple tags displayed in
`
`the tree-view based sidebar at a time. Examiner notes that the tags are further displayed in the photo
`
`information andin the sidebar.).
`
`As per Claim 4, Kustanowitz discloses displaying, on the video display device,
`
`indicia of each and everyothertag label, if any, created and inputted by the user and
`
`embedded in the metadata of the seconddigital file, together with the indication of the
`
`second tag label (See Sections 4.1, 4.3, 4.4 which clearly disclose that images may be searchedfor
`
`based at least on data relating to a person, relationship, event, and date. Further see Section 2.1 and
`
`Figures 1-2 which clearly disclose thatfiles may be selected and sorted based on embedded tag
`
`information including at least name and category information. Examiner further notes that at least Figure
`
`1 discloses that multiple tags may be sorted and retrieved at a time, as can be seen within the multiple
`
`tags displayed in the tree-view based sidebar at a time. Examiner notes that the tags are further
`
`displayed in the photo information andin the sidebar.).
`
`As per Claim 5, Kustanowitz disclosesthe first tag label along with each and
`
`every othertag label, if any, created and inputted by the user and embeddedin the
`
`metadataofthe first digital file comprise a first set of tags, and wherein the second tag
`
`label along with each and everyother tag label, if any, created and inputted by the user
`
`and embeddedin the metadata of the seconddigital file comprise a second set of tags
`
`distinct from the first set of tags (See Sections 4.1, 4.3, 4.4 which clearly disclose that images may
`
`be searched for based at least on data relating to a person, relationship, event, and date. Further see
`
`Section 2.1 and Figure 1 which clearly disclose thatfiles may be selected and sorted based on embedded
`
`tag information including at least name and category information. Examiner further notes that at least
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`382 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`382 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 19
`
`Figure 1 discloses that multiple tags may be sorted andretrieved at a time, as can be seen within the
`
`multiple tags displayed in the tree-view based sidebar at a time. Examiner notes that, although group
`
`annotation is supported, each file may be assigned a distinct set of tags.).
`
`As per Claim 6, Kustanowitz discloses receiving, via the user interface device, an
`
`instruction to associate the second tag label with thefirst tag label, wherein the
`
`association indicates a relationship between the content data of the first of the digital
`
`files and the corresponding content data of the second ofthe digital files (See Sections 4.1-
`
`4.4 which clearly describe several applications which make useofthe digital tags and which include at
`
`least the application described in Section 4.3 which associates individuals based on which photographs
`
`they are tagged in together, and which therefor creates a relationship between the individuals and the
`
`between the photographsin which they appear. Examiner further notes the family trees of Section 4.1,
`
`the individualized timelines of Section 4.2, and the events of Section 4.4, which serve similar purposed in
`
`retrieving multiple related content items in responseto selection a single tag or photograph.);
`
`responsiveto receiving the instruction, associating the second tag label with the first tag
`
`label (See Sections 4.1-4.4 which clearly describe several applications which make useofthe digital
`
`tags and whichinclude at least the application described in Section 4.3 which associates individuals
`
`based on which photographs they are tagged in together, and which therefor creates a relationship
`
`between the individuals and the between the photographs in which they appear. Examiner further notes
`
`the family trees of Section 4.1, the individualized timelines of Section 4.2, and the events of Section 4.4,
`
`which serve similar purposed in retrieving multiple related content items in response to selection a single
`
`tag or photograph.); and responsive to an automatic search through the digitalfiles
`
`returning eitherthe first of the digital files or the second of the digital files, displaying, on
`
`the video display device, an indication of the association betweenthe first of the digital
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`383 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`383 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 20
`
`files and the second of the digital files (See Sections 4.1-4.4 which clearly describe several
`
`applications which make useof the digital tags and whichinclude at least the application described in
`
`Section 4.3 which associates individuals based on which photographs they are tagged in together, and
`
`which therefor creates a relationship between the individuals and the between the photographsin which
`
`they appear. Examiner further notes the family trees of Section 4.1, the individualized timelines of
`
`Section 4.2, and the events of Section 4.4, which serve similar purposed in retrieving multiple related
`
`content items in responseto selection a single tag or photograph.).
`
`As per Claim 7, Kustanowitz discloses displaying, on the video display device, a
`
`count value corresponding to the numberofthe digital files having the second tag label
`
`(See Figure 6 which clearly indicates that counts of the number of photographs having each tag are
`
`displayed.).
`
`As per Claim 10, Kustanowitz fails to disclose receiving a request from the client
`
`device to export thefirst of the digital files from the storage media to another storage
`
`medium; and responsiveto receiving the request to export, causing the first of the digital
`
`files to be communicated, without removing the first tag label, from the storage media to
`
`the other storage medium.
`
`Meulen discloses receiving a request from the client device to exportthe first of
`
`the digital files from the storage media to another storage medium (See Paragraph 27 which
`
`clearly discloses that data may be embedded within image files in EXIF format and that user created
`
`fields may be defined. Examiner further notes that EXIF information is well knownto the art to be
`
`embeddable within the image files themselves, such that the EXIF information may be transferred along
`
`with the file. Further see Paragraph 36 which indicates that the images may be usedby at least a map
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`384 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`384 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 21
`
`generator which uses the metadata of the files to create a digital map used for sharing the digital
`
`photographs. Examiner further notes any of the applications of the art of Kustanowitz mayutilize
`
`embedded metadata. Examiner notes that Paragraphs 11, 19, 27, and 73-74 whichclearly indicate that
`
`the media objects and metadata maybe transferred from one device to another (i.e. exported).); and
`
`responsiveto receiving the request to export, causing the first of the digital files to be
`
`communicated, without removing thefirst tag label, from the storage media to the other
`
`storage medium (See Paragraph 27 which clearly discloses that data may be embeddedwithin image
`
`files in EXIF format and that user created fields may be defined. Examiner further notes that EXIF
`
`information is well known to the art to be embeddable within the image files themselves, such that the
`
`EXIF information may be transferred along withthe file. Further see Paragraph 36 whichindicates that
`
`the images may be used by at least a map generator which uses the metadata ofthe files to create a
`
`digital map used for sharing the digital photographs. Examiner further notes any of the applications of the
`
`art of Kustanowitz may utilize embedded metadata. Examiner notes that Paragraphs 11, 19, 27, and 73-
`
`74 which clearly indicate that the media objects and metadata may betransferred from one device to
`
`another (i.e. exported).).
`
`It would have been obvious to one skilled in the art at the time of Applicant's
`
`invention to modify the teachings of Kustanowitz with the teachings of Meulen to include
`
`receiving a requestfrom the client device to export the first of the digital files from the
`
`storage media to another storage medium; and responsiveto receiving the request to
`
`export, causing thefirst of the digital files to be communicated, without removing the
`
`first tag label, from the storage media to the other storage medium with the motivation of
`
`classifying and categorizing media using metadata (Meulen, Abstract).
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`385 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`385 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 22
`
`As per Claim 11, Kustanowitz discloses the content data ofthefirst of the digital
`
`files is of a first type, the method further comprising: displaying, on the video display
`
`device, a first count value corresponding to the numberofthe digital files having the first
`
`tag label (See Figure 6 which clearly indicates that counts of the number of photographs having each
`
`tag are displayed.); associating the first tag label with a further one of the digital files having
`
`embedded therein content data of a secondtypethatis different than the first type,
`
`wherein the displayedfirst count value includes the further one of the digital files (See
`
`Sections 4.1, 4.3, 4.4 which clearly disclose that images may be searched for based at least on data
`
`relating to a person, relationship, event, and date. Further see Section 2.1 and Figure 1 which clearly
`
`disclose thatfiles may be selected and sorted based on embedded tag information including at least
`
`name and category information. Examiner further notes that at least Figure 1 discloses that multiple tags
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`may be sorted and retrieved at a time, as can be seen within the multiple tags displayed in the tree-view
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`based sidebar at a time. Examiner notes that each photograph mayinclude different content at leastin
`
`that it may feature different persons, locations, events, etc. See Figure 6 which clearly indicates that
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`counts of the number of photographs having each tag are displayed.).
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`As per Claim 12, Kustanowitz disclosesthe first type is a digital photograph or
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`image or a video, and wherein the secondtypeis a digital audio file, a digital document,
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`or a digital food recipe (Sections 2.1 and 4.1-4.4 and Figure 1 of Kustanowitz clearly indicate that
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`multiple images may be displayed in a single interface and that the images may be associated with co-
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`displayed annotation information and information linking photographs and annotations. Examiner notes
`
`that this enables the display of pictures of recipes (e.g. digital documents or recipes), annotations
`
`regarding those recipes, and pictures and annotation of the creators of recipes).
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`386 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`386 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 23
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`As per Claim 13, Kustanowitz disclosesthe first tag label is indicative of an
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`identity of a person associated with the content data, a digital collection related to the
`
`content data, a geographic location associated with the content data, or a date
`
`associated with the content data (See Sections 4.1, 4.3, 4.4 which clearly disclose that images may
`
`be searched for based at least on data relating to a person, relationship, event, and date. Further see
`
`Section 2.1 and Figure 1 which clearly disclose thatfiles may be selected and sorted based on embedded
`
`tag information including at least name and category information.).
`
`As per Claim 16, Kustanowitz fails to disclose the first user selectable thumbnail
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`image including a scaled representation of at least one of the digital imagesin the first
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`set of digital files having the first geotag, and the second user selectable thumbnail
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`image including a scaled representation of at least one of the digital imagesin the first
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`set of digital files having the second geotag.
`
`Meulen disclosesthe first thumbnail image including a scaled representation of at
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`least one of the digital imagesin thefirst set of digital files having the first geotag, and
`
`the second thumbnail image including a scaled representation of at least one of the
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`digital imagesin the first set of digital files having the second geotag (See Paragraphs 27
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`and 34-37 which clearly disclose that GPS coordinates may be recorded for digital photographs and used
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`to create map display which displays photographs, photographs representative of collections of
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`photographs, or metadata of the photographs on a digital map according to the GPS coordinate
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`information. Examiner notes that the image may be a thumbnail image.).
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`It would have been obvious to one skilled in the art at the time of Applicant's
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`invention to modify the teachings of Kustanowitz with the teachings of Meulen to include
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb — IPR2021-01413
`387 of 746
`
`MemoryWeb Ex. 2007
`Unified Patents v. MemoryWeb – IPR2021-01413
`387 of 746
`
`

`

`Application/Control Number: 14/193,426
`Art Unit: 2165
`
`Page 24
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`the first thumbnail including a scaled representation of at least one of the digital images
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`in the first set of digital files having the first geotag, and the second thumbn