IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re Inter Partes Review of:
`U.S. Patent No. 10,417,275
`Issued: Sep. 17, 2019
`Application No.: 15/933,531
`Filing Date: Mar. 23, 2018
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`For: Artificial Intelligence Assisted Tagging of Users in Digital Media Online
`FILED VIA P-TACTS
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`DECLARATION OF DR. BENJAMIN B. BEDERSON IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 10,417,275
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`Meta Platforms, Inc.
`Exhibit 1003
`Page 001
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`Declaration of Dr. Benjamin B. Bederson in Support of
`Petition for Inter Partes Review of USP No. 10,417,275
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`TABLE OF CONTENTS
`INTRODUCTION..................................................................................... 7
`I.
`EXPERIENCE AND QUALIFICATIONS .............................................. 8
`II.
`III. UNDERSTANDING OF RELEVANT LEGAL PRINCIPLES ............ 22
`Claim Construction ....................................................................... 22
`Obviousness .................................................................................. 23
`IV. SUMMARY OF MATERIALS REVIEWED AND CONSIDERED .... 25
`V.
`LEVEL OF SKILL IN THE ART AND PERSPECTIVE APPLIED
`IN THIS DECLARATION ..................................................................... 27
`VI. THE ’275 PATENT ................................................................................ 29
`Prosecution History ...................................................................... 34
`Challenged Claims of the ’275 patent .......................................... 38
`Effective Priority Date .................................................................. 39
`VII. CLAIM TERMS...................................................................................... 40
`A.
`“user identifier” (all claims) ......................................................... 40
`B.
`“contact list” (all claims) .............................................................. 41
`VIII. THE PRIOR ART AND BACKGROUND EVIDENCE ....................... 42
`Prior Art Relied Upon For Obviousness Combinations ............... 42
`U.S. Patent No. 7,461,099 (“Sharpe”) (“Ex. 1005”) .......... 42
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`U.S. Patent No. 6,687,878 (“Eintracht”) (“Ex. 1006”) ...... 45
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`FotoFile (Ex. 1011) ............................................................ 49
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`U.S. Patent No. 6,714,793 (“Carey”) (“Ex. 1007”) ........... 51
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`Technology Overview .................................................................. 52
`Photo Management Software ............................................. 53
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`Groupware and Annotation Systems .................................. 64
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`Social Networks / Databases of People with Tagging in
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`Content ............................................................................... 70
`Databases ............................................................................ 76
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`IX. GROUND 1: SHARPE IN VIEW OF EINTRACHT AND
`FOTOFILE RENDERS OBVIOUS CLAIMS 1-12 ............................... 88
` Motivation to Combine Sharpe with Eintracht ............................. 88
` Motivation to Combine Sharpe and Eintracht with FotoFile ....... 91
`Reasonable Expectation of Success .............................................. 92
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`Independent Claim 1: .................................................................... 94
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`1[pre]: “A method implemented within a computer
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`system including a plurality of computing devices
`connected via a communications network, the method
`associating users of the computer system with digital
`media accessible to the computer system, the method
`comprising:” ....................................................................... 94
`1[a]: “distinguishing between users of the computer
`system via one or more unique user identifiers stored in
`a computer-readable medium accessible to the
`computer system, the users of the computer system
`including a named user and an identifying user, the
`named user being different from the identifying user,
`the named user having naming information associated
`with a unique user identifier of the named user;” .............. 98
`a.
`“distinguishing between users of the computer system via
`one or more unique user identifiers” ...................................... 98
`“stored in a computer-readable medium accessible to the
`computer system”................................................................. 104
`“the users of the computer system including a named user
`and an identifying user, the named user being different
`from the identifying user” .................................................... 106
`“the named user having naming information associated
`with a unique user identifier of the named user” ................. 108
`1[b]: “in response to an input from the identifying user
`indicating a selection of an image, determining a
`unique image identifier corresponding to the image
`selected” ........................................................................... 110
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`b.
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`Declaration of Dr. Benjamin B. Bederson in Support of
`Petition for Inter Partes Review of USP No. 10,417,275
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`c.
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`d.
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`1[c]: “receiving, from the identifying user, an input
`indicating a selection of the named user from a list of
`other users of the computer system, the list of other
`users including naming information previously
`provided by other users, the list of other users including
`one or more users in a contact list associated with the
`identifying user, the identifying user’s contact list
`including the named user” ................................................ 113
`a.
`“receiving, from the identifying user, an input indicating
`a selection of the named user from a list of other users of
`the computer system” ........................................................... 114
`“the list of other users including naming information
`previously provided by other users” .................................... 115
`”the list of other users including one or more users in a
`contact list associated with the identifying user, the
`identifying user’s contact list including the named user” .... 117
`1[d]: “in response to receiving from the identifying
`user the input indicating the selection of the named user
`from the list of other users, determining a unique user
`identifier of the named user;” ........................................... 119
`1[e]: “receiving, from the identifying user, one or more
`inputs indicating a set of coordinates corresponding to
`a location of the named user within the image; and” ...... 121
`1[f]: “applying artificial intelligence algorithms to
`image data of other images accessible to said computer
`system to locate images matching characteristics of a
`subset of image data bound by the set of coordinates
`corresponding to the location of the named user within
`the image, wherein the set of coordinates
`corresponding to the location of the named user within
`the image is associated with the unique user identifier
`of the named user and the unique image identifier” ........ 125
`a.
`“applying artificial intelligence algorithms to image data
`of other images accessible to said computer system to
`locate images matching characteristics of a subset of
`image data bound by the set of coordinates corresponding
`to the location of the named user within the image” ........... 125
`“wherein the set of coordinates corresponding to the
`location of the named user within the image is associated
`with the unique user identifier of the named user and the
`unique image identifier” ...................................................... 131
`Dependent Claims 2-12 .............................................................. 133
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`b.
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`c.
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`b.
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`Declaration of Dr. Benjamin B. Bederson in Support of
`Petition for Inter Partes Review of USP No. 10,417,275
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`Claim 2: The method of claim 1, wherein the artificial
`intelligence algorithms include an image recognition
`algorithm .......................................................................... 133
`Claim 3, 4: providing information indicating that
`named user has been associated with one or more
`images via email in response to locating image ............... 135
`Claims 5, 6: set of coordinates define polygonal or
`circular area ...................................................................... 138
`Claim 7: The method of claim 1, further comprising
`providing, via one or more of the plurality of computing
`devices, a graphical user interface for presentation to a
`user of the computer system, the graphical user
`interface configured to display a representation of the
`set of coordinates, thereby indicating the location of the
`named user within the image ............................................ 140
`Claim 8: The method of claim 1, further comprising in
`response to locating an image matching image
`characteristics of a subset of image data bound by the
`coordinates corresponding to the location of the named
`user within the image, providing to a computing device
`of the named user an interface configured for the
`named user to select or deselect users of the computer
`system for which to store an association with the unique
`image identifier. ................................................................ 142
`Claim 9: The method of claim 1, further comprising:
`determining photo album associated with the named
`user, the digital photo album including a collection of
`images; and in response to locating an image matching
`image characteristics of a subset of image data bound
`by the coordinates corresponding to the location of the
`named user within the image, adding image to the
`digital photo album associated with first named user. .... 144
`Claim 10: The method of claim 1, wherein the naming
`information includes one or more of a name, e-mail
`address, other naming information, or a home page
`address. ............................................................................. 145
`Claim 11: The method of claim 1, wherein the naming
`information includes a screen name ................................. 146
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`Declaration of Dr. Benjamin B. Bederson in Support of
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`Claim 12: The method of claim 1, wherein a located
`image matching characteristics of the subset of image
`data does not have a prior stored association with the
`named user. ....................................................................... 147
`X. GROUND 2: SHARPE IN VIEW OF EINTRACHT AND
`FOTOFILE, AND IN FURTHER VIEW OF CAREY RENDERS
`OBVIOUS CLAIMS 1-12 .................................................................... 148
` Motivation to Combine Sharpe, Eintracht, and FotoFile with
`Carey ........................................................................................... 148
`Reasonable Expectations of Success .......................................... 150
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`Independent Claim 1 ................................................................... 151
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` Dependent Claims ....................................................................... 153
`Claim 10: The method of claim 1, wherein the naming
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`information includes one or more of a name, e-mail
`address, other naming information, or a home page
`address. ............................................................................. 153
`Claim 11: The method of claim 1, wherein naming
`information includes a screen name. ................................ 154
`Claims 2-9, 12 .................................................................. 154
`XI. SECONDARY CONSIDERATIONS .................................................. 155
`XII. CONCLUSION ..................................................................................... 155
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`Declaration of Dr. Benjamin B. Bederson in Support of
`Petition for Inter Partes Review of USP No. 10,417,275
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`I.
`
`INTRODUCTION
`I have been retained by Meta Platforms, Inc. (“Petitioner”) to provide
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`my opinions concerning the validity of U.S. Patent No. 10,417,275 (“the ’275
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`patent”) in support of this Petition for Inter Partes Review of U.S. Patent
`
`No. 10,417,275.
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`
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`I am simultaneously engaged by Petitioner to provide declarations for
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`IPR petitions challenging U.S. Patent Nos. 8,954,432; 9,959,291; and 10,628,480.
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`This Declaration summarizes the opinions I have formed to date. I
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`reserve the right to modify my opinions, if necessary, based on further review and
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`analysis of information that I receive subsequent to the filing of this report, including
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`in response to positions taken by Angel Technologies Group LLC (“Angel Tech”)
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`or its experts that I have not yet seen, including any secondary consideration
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`evidence that Angel Tech or its expert may consider and present.
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`It is my opinion that claims 1-12 of the ’275 patent are invalid based on
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`the following grounds:
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`Ground 1
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`Ground 2
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`Sharpe in view of Eintracht and FotoFile renders obvious claims 1-
`12
`Sharpe in view of Eintracht and FotoFile, and in further view of
`Carey renders obvious claims 1-12
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`Declaration of Dr. Benjamin B. Bederson in Support of
`Petition for Inter Partes Review of USP No. 10,417,275
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`II.
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`EXPERIENCE AND QUALIFICATIONS
` My curriculum vitae, which includes a more detailed summary of my
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`background, experience, and publications, is attached to the accompanying Petition
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`as Ex. 1004.
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`
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`I received a Bachelor of Science degree in Computer Science with a
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`minor in Electrical Engineering from Rensselaer Polytechnic Institute (“RPI”) in
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`1986. I received a Master of Science degree and a Ph.D. in Computer Science from
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`New York University (“NYU”) in 1989 and 1992, respectively.
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`Since 1998, I have been a Professor of Computer Science at the
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`University of Maryland (“UMD”), where I have joint appointments at the Institute
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`for Advanced Computer Studies and the College of Information Studies (Maryland’s
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`“iSchool”) and am currently Professor Emeritus. I was also Associate Provost of
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`Learning Initiatives and Executive Director of the Teaching and Learning
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`Transformation Center from 2014 to 2018. I am a member and previous director of
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`the Human-Computer Interaction Lab (“HCIL”), the oldest and one of the best
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`known Human-Computer Interaction research groups in the country. I was also co-
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`founder and Chief Scientist of Zumobi, Inc. from 2006 to 2014, a Seattle-based
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`startup that is a publisher of content applications and advertising platforms for
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`smartphones. I am also co-founder and co-director of the International Children’s
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`Digital Library (“ICDL”), a web site launched in 2002 that provides the world’s
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`Declaration of Dr. Benjamin B. Bederson in Support of
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`largest collection of freely available online children’s books from around the world
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`with an interface aimed to make it easy for children and adults to search and read
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`children’s books online. I am also co-founder and prior Chief Technology Officer
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`of Hazel Analytics, a data analytics company whose product sends alerts in
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`warranted circumstances. In addition, I have for more than 25 years consulted for
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`numerous companies in the area of user interfaces, including Logitech, Microsoft,
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`the Palo Alto Research Center, Sony, Lockheed Martin, and NASA Goddard Space
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`Flight Center.
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`For more than 30 years, I have studied, designed, and worked in the
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`field of computer science and human-computer interaction. My experience includes
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`30 years of teaching and research, with research interests in human-computer
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`interaction and the software and technology underlying today’s interactive
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`computing systems. This includes the design and implementation of user interfaces
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`and software applications on mobile devices, including smart phones and PDAs,
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`such as my work on DateLens, LaunchTile, and StoryKit described below.
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`At UMD, my research is in the area of Human-Computer Interaction
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`(“HCI”), a field that relates to the development and understanding of computing
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`systems to serve users’ needs. Researchers in this field are focused on making
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`universally usable, useful, efficient, and appealing systems to support people in their
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`wide range of activities. My approach is to balance the development of innovative
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`Declaration of Dr. Benjamin B. Bederson in Support of
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`technology that serves people’s practical needs. Example systems following this
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`approach that I have built include Pad++ (1994 software for zoomable user
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`interfaces), KidPad (1997 software to support children collaboratively writing
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`stories), and PadPrints (1998 software to graphically show interactive web browsing
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`histories), PhotoMesa (2001 software for end users to browse personal photos),
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`Pocket PhotoMesa (2004 software for browsing of personal photos on a mobile
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`device), DateLens (2002 software for end users to use their mobile devices to
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`efficiently access their calendar information), LaunchTile (2005 “home screen”
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`software for mobile devices to allow users to navigate apps in a zoomable
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`environment), SpaceTree (2001 software for end users to efficiently browse very
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`large hierarchies), ICDL (as described above), and StoryKit (a 2009 iPhone app for
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`children to create stories).
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` Pad++, which I wrote in 1994, included a number of techniques to
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`support high performance interactive visualization.1 Pad++ included a custom web
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`browser that I built from scratch and distributed as open source software at the Pad++
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`web site. That web browser was described in numerous publications including
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`“Pad++: A Zoomable Graphical Interface for Exploring Alternate Interface
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`1 Bederson, B.B., & Meyer, J. (1998). Implementing a Zooming User Interface:
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`Experience Building Pad++. Software: Practice and Experience, 28(10), 1101-1135.
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`Physics.”2 I implemented a rendering engine from scratch for that web browser
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`which supported the version of HTML available at the time (HTML 1.0) as well as
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`an embedded scripting language. That web browser included the ability to display
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`embedded web pages that could be zoomed along with the rest of the pages. The
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`following images are from that custom web browser that I built, which used a
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`“zoomable user interface” so one page could be shown larger while other recently
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`visited pages would be displayed smaller:
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`2 Bederson, B. B. and Hollan, J. D. (1994). “Pad++: A Zooming Graphical Interface
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`for Exploring Alternate Interface Physics,” ACM Conference on User Interface
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`Software and Technology, 17-26.
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`Figure 5 from “Pad++: A Zoomable Graphical Sketchpad for Exploring
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`Alternate Interface Physics”3
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` By 1998, my team had combined Pad++ with Netscape Navigator (a
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`standard web browser of the time) to offer a graphical web history, visually showing
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`3 Bederson, B. B., Hollan, J. D., Perlin, K., Meyer, J., Bacon, D., & Furnas, G.
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`(1996). Pad++: A zoomable graphical sketchpad for exploring alternate interface
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`physics. Journal of Visual Languages & Computing, 7(1), 3-32.
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`what pages a user had visited with an application we called “PadPrints.”4 We did
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`this by implementing a web “proxy,” which was a standard way at the time to modify
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`the built-in behavior of web browsers. Some proxies work by intercepting all web
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`traffic coming from and going to a web browser. Once intercepted, the proxy can
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`do whatever it wants with the traffic, caching it for better performance, simply
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`passing the traffic through and monitoring it, modifying the data itself, or holding
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`that connection and opening new connections. PadPrints’ proxy worked by
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`monitoring the traffic and letting PadPrints know what the user was doing so
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`PadPrints could display the web history.
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`4 Ron R. Hightower, Laura T. Ring, Jonathan I. Helfman, Benjamin B. Bederson,
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`and James D. Hollan. 1998. PadPrints: graphical multiscale Web histories. In
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`Proceedings of the 11th annual ACM symposium on User interface software and
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`technology (UIST '98). Association for Computing Machinery, New York, NY,
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`USA, 121–122. https://doi.org/10.1145/288392.288582
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`Petition for Inter Partes Review of USP No. 10,417,275
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`Figure 1 from PadPrints paper
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`In January 2000, I personally bought and started using a Kodak DC280
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`digital camera, and at that point started collaborating with my colleague Ben
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`Shneiderman on the PhotoFinder project. I joined group meetings, participated in
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`group emails, and was an active participant in the project as a whole, using and
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`testing PhotoFinder and giving feedback about its development throughout the year
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`2000. For example, in September 2000, I provided feedback about the details of the
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`interaction, including how annotation should be performed, how annotations should
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`be displayed, and numerous details about the PhotoFinder interface as a whole.
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` After being involved with the PhotoFinder project, I decided to develop
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`my own project that was focused on the visual presentation and interaction with
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`photos. I started this project in January 2001 and called it PhotoMesa. I wrote a
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`2001 paper5 that describes PhotoMesa, a zoomable image browser using a novel 2D
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`layout algorithm I called “quantum treemaps” to position the images on the screen
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`in a way that attempted to fill the screen while keeping groups of related images
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`together. As indicated in the figure below, PhotoMesa could display many hundreds
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`of images at a time by showing small thumbnails, by showing larger thumbnails
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`when the mouse hovered over a small thumbnail, and by allowing a user to zoom in
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`to see a high-resolution version of the images:
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`5 Benjamin B. Bederson, PhotoMesa: A Zoomable Image Browser Using Quantum
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`Treemaps and Bubblemaps, UIST ’01: PROCEEDINGS OF THE 14TH ANNUAL ACM
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`SYMPOSIUM ON USER INTERFACE SOFTWARE AND TECHNOLOGY, Nov. 2001, at 71–
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`80, https://doi.org/10.1145/502348.502359.
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`Declaration of Dr. Benjamin B. Bederson in Support of
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` One of the reasons for designing the interface with zooming was to
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`support devices with different screen sizes. A 2004 paper6 describes a later version
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`of PhotoMesa that I co-created called “Pocket PhotoMesa” that adapted the image
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`browser to a Personal Digital Assistant (PDA) display:
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`6 Amir Khella and Benjamin B. Bederson, Pocket PhotoMesa: a Zoomable Image
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`Browser for PDAs, MUM ’04: PROCEEDINGS OF THE 3RD INTERNATIONAL
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`CONFERENCE ON MOBILE AND UBIQUITOUS MULTIMEDIA, Oct. 2004, at 19–24,
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`https://doi.org/10.1145/1052380.1052384.
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`Declaration of Dr. Benjamin B. Bederson in Support of
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` LaunchTile led to my creation of Zumobi in 2006, where I was
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`responsible for investigating new software platforms and developing new user
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`interface designs that provide efficient and engaging interfaces to permit end users
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`to access a wide range of content on mobile platforms (including the iPhone and
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`Android-based devices). For example, I designed and implemented software called
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`“Ziibii,” a “river” of news for iPhone, software called “ZoomCanvas,” a zoomable
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`user interface for several iPhone apps, and iPhone apps including “Inside Xbox” for
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`Microsoft and Snow Report for REI. At the International Children’s Digital Library
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`(ICDL), I have since 2002 been the technical director responsible for the design and
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`implementation of
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`the web site, www.childrenslibrary.org
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`(originally at
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`www.icdlbooks.org). In particular, I have been closely involved in designing the
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`user interface as well as the software architecture for the web site since its inception
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`in 2002.
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`Declaration of Dr. Benjamin B. Bederson in Support of
`Petition for Inter Partes Review of USP No. 10,417,275
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` Beginning in the mid-1990s, I have been responsible for the design and
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`implementation of numerous other web sites in addition to the ICDL. For example,
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`I designed and built my own professional web site when I was an Assistant Professor
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`of Computer Science at the University of New Mexico in 1995 and have continued
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`to design, write the code for, and update both that site (which I moved to the
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`University of Maryland in 1998, currently at http://www.cs.umd.edu/~bederson/) as
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`well
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`as
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`numerous
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`project
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`web
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`sites,
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`such
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`as
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`Pad++,
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`http://www.cs.umd.edu/hcil/pad++/. I received the Janet Fabri Memorial Award
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`for Outstanding Doctoral Dissertation for my Ph.D. work in robotics and computer
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`vision. I have combined my hardware and software skills throughout my career in
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`Human-Computer Interaction research, building various interactive electrical and
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`mechanical systems that couple with software to provide an innovative user
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`experience.
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` My work has been published extensively in more than 160 technical
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`publications, and I have given about 100 invited talks, including 9 keynote lectures.
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`I have won a number of awards including the Brian Shackel Award for “outstanding
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`contribution with international impact in the field of HCI” in 2007, and the Social
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`Impact Award in 2010 from Association for Computing Machinery’s (“ACM”)
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`Special Interest Group on Computer Human Interaction (“SIGCHI”). ACM is the
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`primary international professional community of computer scientists, and SIGCHI
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`Declaration of Dr. Benjamin B. Bederson in Support of
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`is the primary international professional HCI community. I have been honored by
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`both professional organizations. I am an “ACM Distinguished Scientist,” which
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`“recognizes those ACM members with at least 15 years of professional experience
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`and 5 years of continuous Professional Membership who have achieved significant
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`accomplishments or have made a significant impact on the computing field.” I am
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`a member of the “CHI Academy,” which is described as follows: “The CHI
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`Academy is an honorary group of individuals who have made substantial
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`contributions to the field of human-computer interaction. These are the principal
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`leaders of the field, whose efforts have shaped the disciplines and/or industry, and
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`led the research and/or innovation in human-computer interaction.” The criteria for
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`election to the CHI Academy are: (1) cumulative contributions to the field; (2)
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`impact on the field through development of new research directions and/or
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`innovations; and (3) influence on the work of others.
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`
`
`I have appeared on radio shows numerous times to discuss issues
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`relating to user interface design and people’s use and frustration with common
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`technologies, web sites, and mobile devices. My work has been discussed and I have
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`been quoted by mainstream media around the world over 120 times, including by
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`the NEW YORK TIMES, the WALL STREET JOURNAL, the WASHINGTON POST,
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`NEWSWEEK, the SEATTLE POST-INTELLIGENCER, the INDEPENDENT, LE MONDE,
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`19
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`
`Meta Platforms, Inc.
`Exhibit 1003
`Page 019
`
`

`

`Declaration of Dr. Benjamin B. Bederson in Support of
`Petition for Inter Partes Review of USP No. 10,417,275
`
`
`NPR’s All Things Considered, NEW SCIENTIST MAGAZINE, and MIT’s TECHNOLOGY
`
`REVIEW.
`
`
`
`I have designed, programmed, and publicly deployed dozens of user-
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`facing software products that have cumulatively had millions of users.
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`
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`I am the co-inventor of 14 U.S. patents and 19 U.S. patent applications.
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`The patents are generally directed to user interfaces/experience with some directed
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`to mobile devices, including U.S. Patent No. 9,778,810 (2017), entitled “Techniques
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`to Modify Content and View Content on Mobile Devices.”
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` As I have already touched on above, I was heavily involved in the
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`research and development of visual content management software (including photo
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`management) and networked applications during the time period that encompassed
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`(before and after) the November 15, 2000 claimed priority date of the ’275 patent.
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`As I described above, I built photo displays in web browsers and then in children’s
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`storytelling tools in the 1990s, and I was a participant in the PhotoFinder project in
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`2000. Then starting in 2001, I designed and built the PhotoMesa image browser,
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`and then a range of other tools. That included DateLens in 2002 to create a richer
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`and more usable calendar for the Microsoft PocketPC platform as well as desktops.
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`One of its innovations was its design that enabled it to scale between small (mobile)
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`and large (desktop) computers. I started DateLens as a research project and
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`eventually sold it commercially. DateLens displayed calendar data that came
`
`20
`
`
`Meta Platforms, Inc.
`Exhibit 1003
`Page 020
`
`

`

`Declaration of Dr. Benjamin B. Bederson in Support of
`Petition for Inter Partes Review of USP No. 10,417,275
`
`
`straight from the Microsoft PocketOutlook database and allowed modification and
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`viewing of appointments. The research website from that time period that describes
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`DateLens is still available at http://www.cs.umd.edu/hcil/datelens/ which shows
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`screenshots and a picture of me demonstrating DateLens to Bill Gates. The
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`commercial website
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`from
`
`that
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`time period
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`is
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`also
`
`available
`
`at
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`http://www.windsorinterfaces.com/datelens.shtml which shows a number of news
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`articles reviewing DateLens at that time.
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`
`
`I have been asked to provide my technical opinions regarding the
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`understanding of a person of ordinary skill in the art as it relates to the ’275 patent
`
`and other reference documents.
`
`
`
`I have also been asked to provide my technical opinions on concepts
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`discussed in the ’275 patent and other reference documents, as well as my technical
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`opinions on how these concepts relate to several claim limitations of the ’275 patent
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`in the context of the specification.
`
`
`
`In reaching the opinions stated herein, I have considered the ’275
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`patent, its prosecution history, and the references below, and have also drawn upon
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`my own education, training, research, knowledge, and personal and professional
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`experience as appropriate.
`
`21
`
`
`Meta Platforms, Inc.
`Exhibit 1003
`Page 021
`
`

`

`
`
`Declaration of Dr. Benjamin B. Bederson in Support of
`Petition for Inter Partes Review of USP No. 10,417,275
`
`
`
`I am being compensated at my standard consulting rate of $600 per hour
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`for my services. My compensation does not depend on the outcome of this review
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`proceeding or of any pending litigation.
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`
`
`I have no direct financial interest in Meta Platforms. I have been
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`informed that Angel Tech claims ownership of the ’275 patent. I have no direct
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`financial interest in Angel Tech.
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`III. UNDERSTANDING OF RELEVANT LEGAL PRINCIPLES