throbber
Declaration of Benjamin B. Bederson
`
`IPR2023-00757
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`NETFLIX, INC.,
`Petitioner,
`
`v.
`
`GOTV STREAMING, LLC
`Patent Owner.
`________________________
`Case No. IPR2023-00757
`U.S. Patent No. 8,989,715
`________________________
`
`DECLARATION OF BENJAMIN B. BEDERSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 8,989,715
`
`Netflix v. GoTV
`IPR2023-00757
`Netflix. Ex. 1002
`
`

`

`Declaration of Benjamin B. Bederson
`
`IPR2023-00757
`
`TABLE OF CONTENTS
`PETITIONERS EXHIBIT LIST ................................................................................. i 
`I. 
`INTRODUCTION ........................................................................................... 1 
`II. 
`QUALIFICATIONS ........................................................................................ 2 
`III. 
`SCOPE OF OPINIONS ................................................................................. 16 
`IV.  MATERIALS REVIEWED AND CONSIDERED ...................................... 16 
`V. 
`LEVEL OF ORDINARY SKILL IN THE ART ........................................... 16 
`VI.  STATEMENT OF LEGAL PRINCIPLES .................................................... 18 
`A. 
`Claim Construction ............................................................................. 18 
`B. 
`Anticipation ......................................................................................... 18 
`C. 
`Obviousness ......................................................................................... 19 
`VII.  TECHNOLOGY BACKGROUND AND DISCUSSION OF THE
`STATE OF THE ART ................................................................................... 20 
`B.  Wireless Devices ................................................................................. 24 
`C. 
`Client-Server Architectures ................................................................. 25 
`D.  Overview of U.S. Patent Application Publication No.
`2007/0150617 to Hariki, filed on July 25, 2006 (“Hariki”). .............. 31 
`Overview of U.S. Patent Application Publication No.
`2003/0023755 to Harris et al., filed on December 18, 2001
`(“Harris”). ........................................................................................... 33 
`Other Evidence Regarding the State of the Art ................................... 37 
`F. 
`VIII.  SUMMARY OF THE ’715 PATENT ........................................................... 37 
`A. 
`Background of the Patented Subject Matter ........................................ 37 
`B. 
`The ’715 Patent Specification ............................................................. 47 
`C. 
`The ’715 Patent File History (Ex. 1004) ............................................. 51 
`i
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`E. 
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`Declaration of Benjamin B. Bederson
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`IPR2023-00757
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`Challenged Claims .............................................................................. 52 
`D. 
`Claim Construction (37 C.F.R. § 42.104(b)(3)) .................................. 57 
`E. 
`IX.  PRIORITY DATE OF THE ’715 PATENT ................................................. 58 
`X.  APPLICATION OF THE PRIOR ART TO CLAIMS 1–20 ......................... 59 
`A.  Ground 1: Hariki in view of Harris renders obvious Claims 1-
`20 ......................................................................................................... 59 
`1. 
`Claim 1 A method of generating content that is
`renderable by a wireless device, said method comprising:
`transmitting, to said wireless device, an identification of
`a custom configuration of a plurality of rendering blocks
`of said wireless device, wherein said custom
`configuration is associated with an application and
`configures said plurality of rendering blocks to render
`content in a manner customized to said application; and
`transmitting, to said wireless device, compiled content
`comprising (i) first compiled content specific to a first
`page of said application and (ii) second compiled content
`specific to a second page of said application, wherein
`said compiled content is generated in part from execution
`of said application, wherein said compiled content
`comprises render commands expressed in a syntax that is
`generic to said wireless device, and wherein said custom
`configuration is applicable to said first and second
`compiled content, wherein said compiled content and
`said custom configuration are usable by a graphical user
`interface comprising said plurality of rendering blocks to
`generate renderable content based on said compiled
`content and said custom configuration. .................................... 59 
`Claim 2 “An apparatus according to claim 1, wherein the
`terminal comprises a memory, and wherein the processor
`is configured to send, to the terminal, a response to the
`content status that instructs the terminal to at least one of
`delete at least one piece of content from the memory of
`the terminal, or download at least one piece of content
`from the source.” ....................................................................... 87 
`
`2. 
`
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`Declaration of Benjamin B. Bederson
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`IPR2023-00757
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`3. 
`
`4. 
`
`5. 
`
`6. 
`
`7. 
`
`8. 
`
`9. 
`
`Claim 3 “A method as described in claim 1 wherein said
`compiled content is partially resultant from said
`application operating on a remote server.” ............................... 88 
`Claim 4 “A method as described in claim 1 wherein said
`compiled content is specific to the rendering capabilities
`of said wireless device.” ........................................................... 89 
`Claim 5 “A method as described in claim 1 wherein each
`of said plurality of rendering blocks operates specific to a
`wireless device type of said wireless device and each is
`instructed using a syntax that is generic to said wireless
`device type.” .............................................................................. 90 
`Claim 6 “A method as described in claim 5 wherein said
`custom configuration comprises a syntax that is generic
`regarding said wireless device type.” ....................................... 94 
`Claim 7 “A method as described in claim 1 wherein said
`custom configuration comprises configuration
`information and content specific to said application.” ............. 94 
`Claim 8 “A method as described in claim 1 wherein said
`custom configuration is one of a plurality of memory-
`stored custom configurations stored by said wireless
`device, and wherein said method further comprises
`transmitting an identifier that identifies said custom
`configuration.” .......................................................................... 96 
`Claim 9 “A non-transitory computer readable medium
`comprising instructions therein that when executed by a
`processor implement a method of generating content that
`is renderable by a wireless device, said method
`comprising: transmitting, to said wireless device, an
`identification of a custom configuration of a plurality of
`rendering blocks of said wireless device, wherein said
`custom configuration is associated with an application
`and configures said plurality of rendering blocks to
`render content in a manner customized to said
`application; and transmitting, to said wireless device,
`compiled content comprising (i) first compiled content
`specific to a first page of said application and (ii) second
`compiled content specific to a second page of said
`application, wherein said compiled content is generated
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`Declaration of Benjamin B. Bederson
`
`IPR2023-00757
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`in part from execution of said application, wherein said
`compiled content comprises render commands expressed
`in a syntax that is generic to said wireless device, and
`wherein said custom configuration is applicable to said
`first and second compiled content, wherein said custom
`configuration is applicable to said first and second
`compiled content, wherein said compiled content and
`said custom configuration are usable by a graphical user
`interface comprising said plurality of rendering blocks to
`generate renderable content based on said compiled
`content and said custom configuration.” ................................... 97 
`10.  Claim 10 “A non-transitory computer readable medium
`as described in claim 9 wherein said renderable content
`comprises audio content and display content.” ....................... 100 
`11.  Claim 11 “A non-transitory computer readable medium
`as described in claim 9 wherein said compiled content is
`partially resultant from said application operating on a
`remote server.” ........................................................................ 100 
`12.  Claim 12 “A non-transitory computer readable medium
`as described in claim 9 wherein said compiled content is
`specific to the rendering capabilities of said wireless
`device.” ................................................................................... 100 
`13.  Claim 13 “A non-transitory computer readable medium
`as described in claim 9 wherein each of said plurality of
`rendering blocks operates specific to a wireless device
`type of said wireless device and each is instructed using a
`syntax that is generic to said wireless device type.” ............... 100 
`14.  Claim 14 “A non-transitory computer readable medium
`as described in claim 13 wherein said custom
`configuration comprises a syntax that is generic
`regarding said wireless device type.” ..................................... 101 
`15.  Claim 15 “A non-transitory computer readable medium
`as described in claim 9 wherein said custom
`configuration comprises configuration information and
`content specific to said application.” ...................................... 101 
`16.  Claim 16 “A non-transitory computer readable medium
`as described in claim 9 wherein said method further
`
`
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`Declaration of Benjamin B. Bederson
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`IPR2023-00757
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`comprises transmitting an identifier that identifies said
`custom configuration.” ............................................................ 101 
`17.  Claim 17 “A server that is programmed to generate
`content that is renderable by a wireless device,
`comprising: a library of applications a library of custom
`configuration data comprising a custom configuration
`that configures a plurality of rendering blocks of said
`wireless device to render content in a manner customized
`to an application from said library of applications
`requested by said wireless device; and a layout solver
`that transmits compiled content to said wireless device,
`said compiled content comprising (i) first compiled
`content specific to a first page of said application and (ii)
`second compiled content specific to a second page of said
`application, wherein said compiled content is generated
`in part from execution of said application by said server,
`wherein said compiled content comprises render
`commands expressed in a syntax that is generic to said
`wireless device, and wherein said custom configuration is
`applicable to said first and second compiled content,
`wherein said compiled content and said custom
`configuration are usable by a graphical user interface
`comprising said plurality of rendering blocks to generate
`renderable content based on said compiled content and
`said custom configuration. ...................................................... 101 
`18.  Claim 18 “A server as described in claim 17 wherein said
`renderable content comprises audio content and display
`content.” .................................................................................. 108 
`19.  Claim 19 “A server as described in claim 17 wherein said
`compiled content is specific to the rendering capabilities
`of said wireless device.” ......................................................... 108 
`20.  Claim 20 “A server as described in claim 17 wherein said
`custom configuration comprises configuration
`information and content specific to said application.” ........... 109 
`21.  Motivation to Combine ........................................................... 109 
`
`
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`Declaration of Benjamin B. Bederson
`
`IPR2023-00757
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`XI.  Secondary Considerations ........................................................................... 109 
`XII.  CONCLUSION ............................................................................................ 110 
`
`
`
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`Declaration of Benjamin B. Bederson
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`IPR2023-00757
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`Exhibit
`Number
`1001
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`1016
`
`1017
`
`
`
`PETITIONERS EXHIBIT LIST
`Description
`
`U.S. Patent No. 8,989,715 (“’715Pat”)
`
`Curriculum Vitae of Benjamin B. Bederson, Ph.D.
`
`File History of U.S. Patent No. 8,989,715 (“’715FH”))
`
`File History of U.S. Patent No. 8,478,245 (“’245FH”))
`
`U.S. Patent Application Publication No. 2007/0150617 (“Hariki”)
`
`U.S. Patent Application Publication No. 2003/0023755 (“Harris”)
`
`U.S. Patent No. 7,447,486 (“Tamura”)
`
`U.S. Patent No. 6,996,627 (“Carden”)
`
`U.S. Patent No. 6,669,564 (“Young”)
`
`U.S. Patent No. 6,732,183 (“Graham”)
`
`U.S. Patent No. 6,507,727 (“Henrick”)
`
`Webpage excerpt from Computer History Museum at
`https://www.computerhistory.org/tdih/april/6/ (last accessed March 29,
`2023)
`
`https://www.webdesignerdepot.com/2009/05/the-evolution-of-cell-phone-
`design-between-1983-2009/
`
`Excerpts from Dan R. Olsen, Jr., Developing user interfaces (1998)
`
`Alok Sinha, Client-server computing, in Communications of the ACM, 35, 7
`(1992)
`
`Tim Berners-Lee, Robert Cailliau, Ari Luotonen, Henrik Frystyk Nielsen,
`and Arthur Secret, The World-Wide Web. Communications of the ACM 37,
`8 76-82 (August 1994), available at
`http://dx.doi.org/10.1145/179606.179671
`
`i
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`Declaration of Benjamin B. Bederson
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`IPR2023-00757
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`Eric Kasten, HTML: A Gentle Introduction, Linux Journal (July 1995),
`available at https://www.linuxjournal.com/article/1081
`
`U.S. Patent Application Publication No. 2013/0124961 (“Linburn”)
`
`U.S. Patent No. 8,111,326 (“Talwar”)
`
`Docket Control Order, GovTV Streaming, LLC v. Netflix, Inc., No. 2:22-cv-
`07556-RGK-SHK, Dkt. 61 (C.D. Cal. Feb. 13, 2023)
`
`Complaint in GovTV Streaming, LLC v. Netflix, Inc., No. 2:22-cv-07556-
`RGK-SHK (C.D. Cal. October 17, 2022)
`
`https://web.archive.org/web/20070406171650/http://www.zenzui.com/produ
`cts.html
`
`1018
`
`1019
`
`1020
`
`1021
`
`1022
`
`1023
`
`
`
`
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`Declaration of Benjamin B. Bederson
`
`IPR2023-00757
`
`I.
`
`INTRODUCTION
`1. My name is Benjamin B. Bederson, and I have been retained by counsel
`
`for Netflix Inc. (“Netflix” or “Petitioner”) to submit this Declaration in support of
`
`Netflix’s petition for Inter Partes Review (“IPR”) and cancellation of claims 1–20
`
`(the “Challenged Claims”) of U.S. Patent No. 8,989,715 (“the ’715 patent” or
`
`“’715Pat”) (Ex. 1001), which I understand has been assigned to GoTV Streaming,
`
`LLC (“GoTV” or “Patent Owner”).
`
`2.
`
`I have been asked to opine on whether the ’715 patent is anticipated
`
`and/or rendered obvious by the prior art. My opinions are based on my years of
`
`education, research and experience, as well as my investigation and study of relevant
`
`materials. The materials that I considered for this Declaration include all exhibits
`
`cited in this Declaration.
`
`3.
`
`I may rely upon these materials, my knowledge and experience, and/or
`
`additional materials to rebut arguments raised by Patent Owner. Further, I may also
`
`consider additional documents and information in forming any necessary opinions,
`
`including documents that may not yet have been provided to me.
`
`4. My analysis of the materials produced in this investigation is ongoing
`
`and I will continue to review any new material as it is provided. This Declaration
`
`represents only those opinions I have formed to date. I reserve the right to revise,
`
`
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`Declaration of Benjamin B. Bederson
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`IPR2023-00757
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`supplement, and/or amend my opinions stated herein based on new information and
`
`on my continuing analysis of the materials already provided.
`
`5.
`
`I am being compensated at my standard consulting rate of $600/hour
`
`for my time spent working on issues in this matter. I am also being reimbursed for
`
`any reasonable and customary expenses associated with my work and testimony. I
`
`have no financial interest in, or affiliation with, Petitioner or Patent Owner. My
`
`compensation is not dependent upon the outcome of, or my testimony in, the present
`
`IPR or any litigation proceedings.
`
`II. QUALIFICATIONS
`6.
`I am currently Professor Emeritus of Computer Science at the
`
`University of Maryland (“UMD”). From 2014 to 2018, I was the Associate Provost
`
`of Learning Initiatives and Executive Director of the Teaching and Learning
`
`Transformation Center at the UMD. I am a member and previous director of the
`
`Human-Computer Interaction Lab (“HCIL”), the oldest and one of the best known
`
`Human-Computer Interaction (“HCI”) research groups in the country.
`
`7.
`
`Last year, I co-founded the J.S. Bryant School, a therapeutic high
`
`school to launch in 2025. I was also co-founder and Chief Scientist of Zumobi, Inc.
`
`from 2006 to 2014, a Seattle-based startup that is a publisher of content applications
`
`and advertising platforms for smartphones. I am also co-founder and co-director of
`
`the International Children’s Digital Library (“ICDL”), a web site launched in 2002
`
`
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`Declaration of Benjamin B. Bederson
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`IPR2023-00757
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`that provides the world’s largest collection of freely available online children’s
`
`books from around the world with an interface aimed to make it easy for children
`
`and adults to search and read children’s books online. I am also co-founder and prior
`
`Chief Technology Officer of Hazel Analytics, a data analytics company to improve
`
`food safety and better public health whose product sends alerts in warranted
`
`circumstances.
`
`8.
`
`In addition, I have for more than 25 years consulted for numerous
`
`companies in the area of user interfaces, including EPAM, Hillcrest Labs, Lockheed
`
`Martin, Logitech, Microsoft, NASA Goddard Space Flight Center, the Palo Alto
`
`Research Center, and Sony.
`
`9.
`
`The devices and methods claimed in the ’715 Patent generally relate to
`
`human-computer interaction, graphics and rendering on wireless devices. For more
`
`than 30 years, I have studied, designed, and worked in the field of computer science
`
`and HCI. My experience includes 30 years of teaching and research, with research
`
`interests in HCI and the software and technology underlying today’s interactive
`
`computing systems with a focus on wireless devices, graphics and rendering.
`
`10. At UMD, I have been focused primarily on the area of HCI, a field that
`
`relates to the development and understanding of computing systems to serve users’
`
`needs. Researchers and practitioners in this field are focused on making universally
`
`usable, useful, efficient, and appealing systems to support people in their wide range
`
`
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`Declaration of Benjamin B. Bederson
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`of activities. My approach is to balance the development of innovative technology
`
`that serves people’s practical needs.
`
`11. Example systems following this approach that I have built include
`
`Cortex-I (1992 embedded computer vision system that sensed licensed plates with
`
`custom motor, camera and controller), Audio Augmented Reality (1995 embedded
`
`system for sensing a user’s location and playing audio suited to that location),
`
`Fisheye Menus (2000 software for sensing movement within and selection of linear
`
`list of items in a menu), PhotoMesa (2001 software for end users to browse personal
`
`photos), DateLens (2002 software for end users to use their mobile devices to
`
`efficiently access their calendar information), SlideBar (2005 linear sensor to control
`
`scrolling), LaunchTile (2005 “home screen” software for mobile devices to allow
`
`users to navigate apps in a zoomable environment), SpaceTree (2002 software for
`
`end users to efficiently browse very large hierarchies), ICDL (2001 International
`
`Children’s Digital Library), and StoryKit (a 2009 iPhone app for children to create
`
`stories).
`
`12. LaunchTile led to my co-founding of Zumobi Inc. in 2006, where I was
`
`responsible for investigating new software platforms and developing new user
`
`interface designs that provided efficient and engaging interfaces to permit end users
`
`to access a wide range of content on mobile platforms (including the iPhone and
`
`Android-based devices). For example, I designed and implemented software called
`
`
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`Declaration of Benjamin B. Bederson
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`“Ziibii,” a “river” of news for iPhone that used a capacitive sensor for controlling
`
`linear movement through news, software called “ZoomCanvas,” a zoomable user
`
`interface for several iPhone apps, and iPhone apps including “Inside Xbox” for
`
`Microsoft and Snow Report for REI.
`
`13. Starting in the mid-1990s and going through the 2000s, I worked on a
`
`range of “zoomable user interfaces” (ZUIs) that supported users in navigating large
`
`information spaces by zooming in and out of the information on the screen. I built
`
`several different ZUI systems over the years, including Pad++, Jazz, and Piccolo. I
`
`wrote Pad++ in C++ using the X Windows System including a number of techniques
`
`to support high performance interactive visualization.1
`
`14. Pad++ included a custom web browser which I built from scratch in
`
`1994 and distributed as open source software at the Pad++ web site. That web
`
`browser was described in numerous publications including “Pad++: A Zoomable
`
`Graphical Interface for Exploring Alternate Interface Physics”2.
`
`
`1 Bederson, B.B., & Meyer, J. (1998). Implementing a Zooming User Interface:
`Experience Building Pad++. Software: Practice and Experience, 28(10), 1101-1135.
`
` 2
`
` Bederson, B. B. and Hollan, J. D. (1994). “Pad++: A Zooming Graphical Interface
`for Exploring Alternate Interface Physics,” ACM Conference on User Interface
`Software and Technology, 17-26.
`
`
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`15.
`
` It supported the version of HTML available at the time (HTML 1.0) as
`
`well as an embedded scripting language. The following images are from a custom
`
`web browser that I built that used a “zoomable user interface” to show a visual
`
`representation of which pages a user visited.3
`
`
`
`16. By 1998, my team had combined our web browser with Netscape
`
`
`
`Navigator (a standard web browser of the time) to offer a graphical web history,
`
`visually showing what pages a user had visited with an application we called
`
`
`3 Bederson, B. B., Hollan, J. D., Perlin, K., Meyer, J., Bacon, D., & Furnas, G.
`(1996). Pad++: A zoomable graphical sketchpad for exploring alternate interface
`physics. Journal of Visual Languages & Computing, 7(1), 3-32.
`
`
`
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`Declaration of Benjamin B. Bederson
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`“PadPrints”.4 We did this by implementing a web “proxy,” which was a standard
`
`way at the time to modify the built-in behavior of web browsers. Some proxies work
`
`by intercepting all web traffic coming from and going to a web browser. Once
`
`intercepted, the proxy can do whatever it wants with the traffic, caching it for better
`
`performance, simply passing the traffic through and monitoring it, it can modify the
`
`data itself, or hold that connection and open new connections. PadPrints’ proxy
`
`worked by monitoring the traffic and letting PadPrints know what the user was doing
`
`so PadPrints could display the web history.
`
`Figure 1 from PadPrints paper
`
`
`
`
`4 Hightower, R.R., et. al., “Graphical Multiscale Web Histories: A Study of
`PadPrints,” Proceedings of the ninth ACM conference on hypertext and hypermedia:
`links, objects, time and space---structure in hypermedia systems, 58-65, 59 (1998).
`
`
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`17. Starting in 2001 and continuing for several years, I worked on photo
`
`management systems. I wrote a paper5 in 2001 describing PhotoMesa, a zoomable
`
`image browser using a novel 2D layout algorithm I called “quantum treemaps” to
`
`position the images on the screen in a way that attempted to fill the screen while
`
`keeping groups of related images together. As indicated in the figure below,
`
`PhotoMesa could display many hundreds of images at a time by showing small
`
`thumbnails, by showing larger thumbnails when the mouse hovered over a small
`
`thumbnail, and by allowing a user to zoom in to see a high resolution version of the
`
`images.
`
`
`5 Benjamin B. Bederson. 2001. PhotoMesa: a zoomable image browser using
`quantum treemaps and bubblemaps. In Proceedings of the 14th annual ACM
`symposium on User interface software and technology (UIST ’01). Association for
`Computing Machinery, New York, NY, USA,
`71–80. DOI:
`https://doi.org/10.1145/502348.502359
`
`
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`Declaration of Benjamin B. Bederson
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`
`18. At the ICDL, I have since 2002 been the technical director responsible
`
`
`
`for the design and implementation of the web site, www.childrenslibrary.org
`
`(originally at www.icdlbooks.org). In particular, I have been closely involved in
`
`designing the user interface as well as the software architecture for the web site since
`
`its inception in 2002. The ICDL includes a display of search results that include
`
`thumbnails of book covers where 8 of the book covers are shown at a time. Pressing
`
`the right arrow uses AJAX web technology to dynamically retrieve and display the
`
`next 8 book covers from the server without having to reload the entire page. We
`
`switched from a similar version of this interface to this AJAX-based approach in
`
`about 2006.
`
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`Declaration of Benjamin B. Bederson
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`IPR2023-00757
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`Screen capture taken February 19, 2017 by Ben Bederson from
`http://www.childrenslibrary.org/icdl/SimpleSearchCategory?ids=25&langid=&pnu
`m=1&cnum= 1&text=&lang=English&ilang=English
`
`I was heavily involved in the research and development of mobile
`
`19.
`
`device applications during the early 2000’s. For example, I envisioned, designed and
`
`built DateLens in 2002-2004 to create a richer and more usable calendar for the
`
`Microsoft PocketPC platform as well as desktops. One of its innovations was its
`
`design that enabled it to scale between small (mobile) and large (desktop) computers.
`
`It also had a special double-headed scroll bar that allowed a user to touch scroll and
`
`also control how much information was presented on the screen at a time. I started
`
`
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`Declaration of Benjamin B. Bederson
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`IPR2023-00757
`
`DateLens as a research project and eventually sold it commercially. DateLens
`
`displayed calendar data that came straight from the Microsoft PocketOutlook
`
`database and allowed modification and viewing of appointments. The research
`
`website from that time period that describes DateLens is still available at
`
`http://www.cs.umd.edu/hcil/datelens/ which shows screenshots and a picture of me
`
`demonstrating DateLens to Bill Gates. The commercial website from that time
`
`period is also available at http://www.windsorinterfaces.com/datelens.shtml, which
`
`shows a number of news articles reviewing DateLens at that time.
`
`20.
`
`In approximately 2004-2005, in collaboration with graduate students
`
`Amy Karlson and John SanGiovanni of Microsoft, I worked on a prototype software
`
`called LaunchTile. LaunchTile allowed zooming and scrolling of multiple
`
`applications on a handheld touchscreen PDA. The interface offered a grid of
`
`applications that could be zoomed and scrolled. It included several different methods
`
`of scrolling, including gestures where the scrolling continued after a finger was lifted
`
`from the touch screen, and then slowed to a stop.6
`
`
`6Amy K. Karlson, Benjamin B. Bederson, and John SanGiovanni. AppLens and
`LaunchTile: two designs for one-handed thumb use on small devices. In Proceedings
`of the SIGCHI Conference on Human Factors in Computing Systems (CHI '05)
`(2005).
`ACM,
`New
`York,
`NY,
`USA,
`201-210.
`DOI:
`https://doi.org/10.1145/1054972.105500.
`
`
`
`
`11
`
`Netflix. Ex. 1003
`
`

`

`Declaration of Benjamin B. Bederson
`
`IPR2023-00757
`
`21.
`
`In 2007 and 2008, I wrote an app for Apple iOS called “ICDL on
`
`iPhone” which provided a scrollable and zoomable interface for reading children's
`
`picture books from my International Children's Digital Library on iPhones. At the
`
`time, this was the only effort of its kind to provide the ability read children's picture
`
`books on phones.
`
`22. That led to my design and development of StoryKit starting in 2009.
`
`StoryKit is an iOS app that supports children to write their own stories, including
`
`text, images, drawings and sound. It has become quite popular among school
`
`teachers and for many years has gotten about 10,000 hours a month of use of children
`
`writing stories.
`
`23. Beginning in the mid-1990s, I have been responsible for the design and
`
`implementation of numerous other web sites in addition to the ICDL. For example,
`
`I designed and built my own professional web site when I was an Assistant Professor
`
`of Computer Science at the University of New Mexico in 1995 and have continued
`
`to design, write the code for, and update both that site (which I moved to the UMD
`
`in 1998, currently at http://www.cs.umd.edu/~bederson/) as well as numerous
`
`project web sites, such as Pad++, http://www.cs.umd.edu/hcil/pad++/.
`
`24. More recently, I have worked on complex web “apps,” some of which
`
`include search results. These include a system called “Q&A” which used AJAX to
`
`support real-time support for classroom interactive response by students, with
`
`
`
`12
`
`Netflix. Ex. 1003
`
`

`

`Declaration of Benjamin B. Bederson
`
`IPR2023-00757
`
`collaborative annotation of each other’s responses. The following shows the “Q&A”
`
`interactive student response web site. This screenshot shows the results of 50
`
`students simultaneously answering a question and then annotating each other’s
`
`annotations.
`
`Screen capture taken July 18, 2014 by Ben Bederson from
`http://qaumd.appspot.com/results/73849
`
`I received the Janet Fabri Memorial Award for Outstanding Doctoral
`
`
`
`25.
`
`Dissertation for my Ph.D. work in robotics and computer vision. I have combined
`
`my hardware and software skills throughout my career in HCI research, building
`
`various interactive electrical and mechanical systems that couple with software to
`
`provide an innovative user experience.
`
`
`
`13
`
`Netflix. Ex. 1003
`
`

`

`Declaration of Benjamin B. Bederson
`
`IPR2023-00757
`
`26. My work has been published extensively in more than 160 technical
`
`publications, and I have given about 100 invited talks, including 9 keynote lectures.
`
`I have won a number of awards including the Brian Shackel Award for “outstanding
`
`contribution with international impact in the field of HCI” in 2007, and the Social
`
`Impact Award in 2010 from the Association for Computing Machinery’s (“ACM”)
`
`Special Interest Group on Computer Human Interaction (“SIGCHI”). ACM is the
`
`primary international professional community of computer scientists, and SIGCHI
`
`is the primary international professional HCI community.
`
`27.
`
`I have been honored by both professional organizations. I am an “ACM
`
`Distinguished Scientist,” which “recognizes those ACM members with at least 15
`
`years of professional experience and 5 years of continuous Professional Membership
`
`who have achieved significant accomplishments or have made a significant impact
`
`on the computing field.”
`
`28.
`
`I am a member of the “CHI Academy,” which is described as follows:
`
`“The CHI Academy is an honorary group of individuals who have made substantial
`
`contributions to the field of HCI. These are the principal leaders of the field, whose
`
`efforts have shaped the disciplines and/or industry, and led the research and/or
`
`innovation in human-computer interaction.” The criteria for election to the CHI
`
`Academy are: (1) cumulative contributions to the field; (2) impact on the field
`
`through development of new research directions and/or innovations; and

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