Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`___________________
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________
`
`
`
`AMERICAN AIRLINES, INC.,
`Petitioner
`
`v.
`
`ADVANCED TRANSACTIONS, LLC
`Patent Owner
`
`___________________
`
`
`U.S. Patent No. 7,065,555 B2
`Issue Date: June 20, 2006
`
`Title: SYSTEM AND METHOD RELATED TO GENERATING AND TRACKING
`AN EMAIL CAMPAIGN
`
`DECLARATION OF ERIC COLE, PH.D.
`
`
`
`
`
`
`American Airlines, Ex. 1006, p.1
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`IPR2023-01366
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`

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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
`
`
`TABLE OF CONTENTS
`
`I.
`
`II.
`
`QUALIFICATIONS ........................................................................................ 1
`
`SCOPE OF WORK.......................................................................................... 9
`
`III. BASIS FOR OPINIONS ................................................................................. 9
`
`A.
`
`Level of Ordinary Skill in the Art ....................................................... 10
`
`B. Obviousness ......................................................................................... 12
`
`IV. OVERVIEW OF THE CHALLENGED PATENT ....................................... 15
`
`A. U.S. Patent No. 7,065,555 B2 (the ’555 patent) ................................. 15
`
`B. Assumed Effective Filing and Invention Dates .................................. 21
`
`V.
`
`PRIOR ART REFERENCES ........................................................................ 21
`
`A.
`
`B.
`
`C.
`
`Bergh (Ex.1002) .................................................................................. 21
`
`Calloway (Ex.1003)............................................................................. 27
`
`Lerner (Ex.1004) ................................................................................. 52
`
`D. Nagda (Ex.1005) ................................................................................. 56
`
`VI. Application of Prior art to Challenged Claims .............................................. 61
`
`A. Ground 1: Claims 1-6 and 9-15 are obvious over Bergh
`in view of Nagda ................................................................................. 61
`
`1.
`
`2.
`
`3.
`
`4.
`
`Claim 1 ...................................................................................... 63
`
`Claim 2 ...................................................................................... 73
`
`Claim 3 ...................................................................................... 75
`
`Claim 4 ...................................................................................... 79
`
`- i -
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`Claim 5 ...................................................................................... 80
`
`Claim 6 ...................................................................................... 81
`
`Claim 9 ...................................................................................... 83
`
`Claim 10 .................................................................................... 86
`
`Claim 11 .................................................................................... 89
`
`10. Claim 12 .................................................................................... 93
`
`11. Claim 13 .................................................................................. 103
`
`12. Claim 14 .................................................................................. 105
`
`13. Claim 15 .................................................................................. 106
`
`B. Ground 2: Claims 1-6 and 9-15 are obvious over
`Calloway in view of Nagda ............................................................... 107
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`Claim 1 .................................................................................... 108
`
`Claim 2 .................................................................................... 115
`
`Claim 3 .................................................................................... 117
`
`Claim 4 .................................................................................... 122
`
`Claim 5 .................................................................................... 123
`
`Claim 6 .................................................................................... 125
`
`Claim 9 .................................................................................... 126
`
`Claim 10 .................................................................................. 129
`
`Claim 11 .................................................................................. 133
`
`10. Claim 12 .................................................................................. 136
`
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`
`11. Claim 13 .................................................................................. 144
`
`12. Claim 14 .................................................................................. 145
`
`13. Claim 15 .................................................................................. 146
`
`C. Ground 3: Claims 7-8 and 16-17 are obvious over
`Calloway in view of Lerner ............................................................... 147
`
`1.
`
`2.
`
`3.
`
`4.
`
`Claim 7 .................................................................................... 149
`
`Claim 8 .................................................................................... 153
`
`Claim 16 .................................................................................. 158
`
`Claim 17 .................................................................................. 160
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`VII. CONCLUSION ............................................................................................ 164
`
`
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`I, Eric Cole, of Ashburn, Virginia, declare that:
`
`I.
`
`QUALIFICATIONS
`
` My academic credentials include a master’s degree in computer science
`
`and a doctorate in information security, and I have worked in the cyber and technical
`
`information security industry for over twenty-five years. The details of my
`
`education and experience are summarized in my curriculum vitae (“CV”), which is
`
`attached as Exhibit 1007. My CV also includes a list of my publications over the
`
`past ten years.
`
`
`
`I have worked in computer security for over twenty-five years. To
`
`briefly summarize my career, I have: 1) been responsible for the security of sensitive
`
`government projects; 2) managed security at major private sector companies;
`
`3) consulted for major private sector companies; 4) been actively involved in
`
`designing, building, and deploying intrusion detection systems; 5) worked on
`
`protecting and securing critical information including trade secrets; 6) continually
`
`taught and written about cybersecurity.
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`
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`
`
`
`I am the founder and president of Secure Anchor Consulting, LLC,
`
`located in Ashburn, Virginia. Secure Anchor Consulting provides cybersecurity
`
`consulting services and lead research and development initiatives to advance
`
`information systems security. Many of the clients I work with are responsible for
`
`protecting sensitive client and/or consumer information and implementing effective
`
`security.
`
`
`
`At Secure Anchor Consulting, I also actively work on incidents, and I
`
`have a detailed understanding of measures that organizations can take to both
`
`prevent and detect breaches. In addition, I have worked with organizations to design,
`
`build, and implement security measures that would be classified as both fixes and
`
`compensating controls, and I have detailed knowledge of the effort that is required
`
`to implement various remediation measures.
`
`
`
`I worked for the U.S. government for eight years as an employee and
`
`have held various contracting jobs with government agencies, which involved
`
`working with classified information. I have worked for a wide range of government
`
`organizations, including the Federal Bureau of Investigation (FBI), the National
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`Security Agency (NSA), the Central Intelligence Agency (CIA), the Department of
`
`Energy, the Department of Defense (DOD), the Treasury Department, the Secret
`
`Service, and the Nuclear Regulatory Commission (NRC). I have held various top-
`
`secret security clearances with the DOD, the CIA, and the NRC. I also was involved
`
`in funded research from the Defense Advanced Research Projects Agency
`
`(DARPA), an agency of the DOD responsible for the development of new intrusion
`
`detection technologies for use by the military. During this time, I have reviewed,
`
`edited, and created numerous security policies. On several occasions, I have also
`
`reviewed the reasonableness of measures intended to protect and secure Confidential
`
`Information through various types of documentation to include policies, procedures,
`
`standards, and baselines.
`
` While serving as a Senior Officer for the CIA as Program Manager /
`
`Technical Director for the Internet Program Team with the Office of Technical
`
`Services, I implemented the Internet Program Team that designs, develops, tests, and
`
`deploys internet security products in three- to six-month intervals. In this role, I
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`received a letter of appreciation from the Director of Central Intelligence and six
`
`Exceptional Performance Awards.
`
`
`
`As a member of the Information Security Assessment Team with the
`
`Office of Security, I evaluated and performed security assessments of network
`
`operating systems to identify potential vulnerabilities and solutions. I also designed
`
`a large-scale auditing system with an automated review capability and worked on
`
`several virus investigations for the Office of Security.
`
`
`
`In my role as Chief Information Officer for the American Institutes for
`
`Research, I repaired and developed IT infrastructures for various organizations. I
`
`was also responsible for building out the entire data classification program to ensure
`
`that critical and proprietary data was properly protected and secured. I was also one
`
`of the principal leads on research funding from DARPA. In this role, I was
`
`responsible for understanding the current state of the art in intrusion detection and
`
`designing and building a new cybersecurity system that could catch attacks that were
`
`targeting organizations.
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`
`
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`As Chief Scientist and Senior Fellow for Lockheed Martin, I performed
`
`research and development in information systems security. I also specialized in
`
`evaluating and designing secure network design, perimeter defense, vulnerability
`
`discovery, penetration testing, and intrusion detection systems. At Lockheed Martin,
`
`I served as a technical advisor in high-profile security projects for government
`
`clients including the DOD, the FBI Sentinel case management systems, Department
`
`of Homeland Security Enterprise Acquisition Gateway for Leading Edge solutions,
`
`Jet Propulsion Labs, Hanford Labs, and FBI Information Assurance Technology
`
`Infusion programs.
`
` As Chief Technical Officer for McAfee, I executed the strategy for
`
`technology platforms, partnerships, and external relationships to establish product
`
`vision and achieve McAfee’s goals and business strategies. In this capacity, I
`
`worked closely with groups tasked with the development of intellectual property.
`
`While at McAfee, I worked with many business customers responsible for protecting
`
`clients’ information, helping them implement effective security solutions.
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`

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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
`
`
`
`
`I was a fellow and instructor for twenty years with the SANS Institute,
`
`a research and education organization consisting of
`
`information security
`
`professionals. SANS is the largest source for information security training and
`
`security certifications in the world. I am an author of several security courses, such
`
`as SEC401-Security Essentials and SEC501-Enterprise Defender. SEC401-Security
`
`Essentials is a required course for agents of the FBI and the NSA. These courses
`
`have been taken by over 30,000 people, and I have taught more than 50% of these
`
`students via live and online training. The courses that I have written have multiple
`
`modules and lessons on security policies, employee agreements, and protection of
`
`intellectual property. As one of the top-rated instructors at SANS, I have delivered
`
`keynote addresses around the world.
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`
`
`I am a member of the European InfoSec Hall of Fame, a professional
`
`membership awarded by nomination and election by a panel of industry experts.
`
`
`
`I hold a Certified Information System Security Professional (CISSP)
`
`certification and was the creator of the Global Information Assurance Certification
`
`(GIAC) Security Essentials Certification (GSEC).
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`
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`

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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
`
`
`
`
`I am a contributing author of “Securing Cyberspace for the 44th
`
`President” and served as a Commissioner on cybersecurity for President Obama. My
`
`Nine books on cybersecurity include “Online Danger,” “Network Security Bible -
`
`2nd Edition,” “Advanced Persistent Threat,” and “Insider Threat,” which have
`
`become recognized as industry-standard sources. They are used in many classrooms
`
`and colleges around the world as authoritative texts on cybersecurity. I have also
`
`published several articles in the field.
`
` The focus of my work over the last ten years has been on data protection
`
`for commercial organizations. I am very familiar with best practices in cybersecurity
`
`and have developed many of the standard practices.
`
` Today, my consulting efforts help organizations properly protect client
`
`information and relate to various alternative methods of security that can be
`
`implemented. This includes hardening of systems, securing servers, proper
`
`configuration, patching, and compensating controls. In cases where a fix cannot be
`
`made because it would negatively impact the business, I have extensive experience
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`in understanding various compensating controls as an alternative to minimize the
`
`risk to an acceptable level and how to implement those controls.
`
`
`
`I routinely help clients develop and implement company-wide policies,
`
`training, and best practices to prevent potential cybersecurity incidents. My work
`
`addresses threats from both internal and external sources, including accidental and
`
`intentional incidents.
`
`
`
`I have led, and been involved in working on, responses to many
`
`cybersecurity incidents. This includes performing root cause analysis, verifying the
`
`reasonableness of security measures, and validating the implementation of additional
`
`remediation measures.
`
`
`
`In my consulting work and in the various positions that I have held, I
`
`have been responsible for protecting organizations to minimize and prevent data
`
`breaches, in addition to responding to breaches post detection. I have a very detailed
`
`understanding of what is and is not a reasonable level of security based on the
`
`hundreds of organizations with which I have worked and the various security task
`
`forces with which I have been involved.
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
`
`II.
`
`SCOPE OF WORK
`
`
`
`I have been asked to consider and provide my opinions on the claims
`
`of U.S. Patent No. 7,065,555 B2—the Challenged Patent—including the technical
`
`subject matter and the application of various references that predate the priority date
`
`of the patent. In particular, I have been asked to consider what one of ordinary skill
`
`in the art would have understood from the claims and specification of the Challenged
`
`Patent, whether certain references disclose or suggest the features recited in the
`
`claims of the Challenged Patent, and whether one of ordinary skill in the art would
`
`have had reason to combine certain references to arrive at the claimed subject matter.
`
`
`
`I am compensated at a rate of $800/hour for my work. My
`
`compensation is in no way contingent on the nature of my findings, the presentation
`
`of my findings in testimony, or the outcome of any proceeding.
`
`III. BASIS FOR OPINIONS
`
` My opinions set forth below are based on my education, training,
`
`experience, and the content of the references considered. I have considered the
`
`available prior art, the ’555 patent in its entirety, the prosecution history of the ’555
`
`
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`patent, and the general knowledge of those familiar with the field of email marketing
`
`around April 2001. I also considered the exhibits and any other materials cited
`
`herein.
`
`A. Level of Ordinary Skill in the Art
`
` My opinions are provided based on what a person of ordinary skill in
`
`the art in the technical field of the purported invention would have understood at the
`
`time of the purported invention of the Challenged Patent.
`
`
`
`I have been informed and understand that the content of a patent and
`
`prior art should be interpreted the way a person of ordinary skill in the art would
`
`have interpreted those references at the time of the invention of the patent. I
`
`understand that the person of ordinary skill is a hypothetical concept referring to one
`
`who thinks along the lines of conventional wisdom at the time.
`
`
`
`I was asked to provide an opinion as to the level of one of ordinary skill
`
`in the art pertinent to the subject matter set forth in the Challenged Patent at the time
`
`of the priority date. Around April 2001, it is my opinion that a person of ordinary
`
`skill in the art in the field of the Challenged Patent would have been a person with a
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`bachelor’s degree in computer science, computer engineering, or electrical
`
`engineering and at least three years of experience in networking operating systems
`
`and cybersecurity, or a person with a master’s degree in one of the foregoing and at
`
`least two years of experience in the aforementioned fields. Throughout this
`
`declaration, I use the term “POSITA” to refer to a person with these or similar
`
`qualifications. To have similar qualifications, an individual with additional
`
`education or additional industrial experience could still be of ordinary skill in the art
`
`if that additional education or experience compensates for a deficit in one of the
`
`other aspects of the requirements stated above.
`
` The basis for my familiarity with the level of ordinary skill is my
`
`interaction with large numbers of workers in the computer security industry who
`
`were at this level of skill. In reaching this opinion as to the hypothetical person of
`
`ordinary skill in the art, I have considered the types of problems encountered in the
`
`art, the prior art solutions to those problems, the rapidity with which innovations are
`
`made, the sophistication of the technology, and the educational level and
`
`professional capabilities of workers in the field.
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`
`B. Obviousness
`
`
`
`I have been informed and understand that subject matter claimed in a
`
`patent is obvious under 35 U.S.C. § 103 if a person of ordinary skill in the art at the
`
`time the alleged invention was made would have had reason to combine or modify
`
`the disclosures of one or more prior art references to arrive at the claimed subject
`
`matter. A claim may be unpatentable even if each and every claim limitation is not
`
`present or disclosed in a single prior art item.
`
`
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`I have been informed and understand that, under the doctrine of
`
`obviousness, a claim is unpatentable if the differences between the invention and the
`
`prior art are such that the subject matter as a whole would have been obvious at the
`
`time the invention was made to a person having ordinary skill in the art to which the
`
`subject matter pertains. A person of ordinary skill in the art is presumed to have
`
`knowledge of the relevant prior art at the time of the claimed invention.
`
`
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`I have been informed and understand that obviousness is based on the
`
`scope and content of the prior art, the differences between the prior art and the claim,
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`the level of ordinary skill in the art, and secondary indicia of obviousness and non-
`
`obviousness to the extent such indicia exist.
`
`
`
`I have been informed and understand the determination of whether the
`
`asserted claims would have been obvious to a person of ordinary skill in the art and,
`
`therefore, invalid is not governed by any rigid test or formula. A determination that
`
`a claim is obvious is, instead, based on a common-sense determination that the
`
`claimed invention is merely a combination of known limitations to achieve
`
`predictable results. Any of the following rationales are acceptable justifications to
`
`conclude that a claim would have been obvious: (1) the claimed invention is simply
`
`a combination of known prior art methods to yield predictable results; (2) the
`
`claimed invention is a simple substitution of one known element for another to
`
`obtain predictable results; (3) the claimed invention uses known techniques to
`
`improve similar devices (methods or products) in the same way; (4) the claimed
`
`invention applies a known technique to a known device (method or product) ready
`
`for improvement to yield predictable results; (5) the claimed invention was “obvious
`
`to try”—choosing from a finite number of identified, predictable solutions with a
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`reasonable expectation of success; (6) there is known work in one field of endeavor
`
`that may prompt variations of it for use in either the same field or a different one
`
`based on design incentives or other market forces if the variations would have been
`
`predictable to one of ordinary skill in the art; or (7) there is some teaching,
`
`suggestion, or motivation in the prior art that would have led one of ordinary skill in
`
`the art to modify the prior art reference to combine prior art teachings to arrive at the
`
`claimed inventions.
`
`
`
`I have been informed and understand that a claim may be obvious in
`
`light of a single reference, without the need to combine references, if the elements
`
`of the claim that are not found in the reference can be supplied by the common sense
`
`or knowledge of one of ordinary skill in the art or taught in different areas of the
`
`single reference.
`
`
`
`I have been informed and understand that an analysis of whether a
`
`claimed invention is obvious must not rely on a hindsight combination of prior art.
`
`The analysis must proceed in the context of the time of the invention or claimed
`
`priority date and consider whether the invention as a whole would have been obvious
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`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`to a person of ordinary skill in the art, taking into consideration any interrelated
`
`teachings of the prior art, the effects of demands known to the design community or
`
`present in the marketplace, and the background knowledge possessed by a person
`
`having ordinary skill in the art, all in order to determine whether there was an
`
`apparent reason to combine any known elements in the fashion claimed by the patent
`
`at issue.
`
`IV. OVERVIEW OF THE CHALLENGED PATENT
`
`A. U.S. Patent No. 7,065,555 B2 (the ’555 patent)
`
` The ’555 patent “is directed to marketing via email, and, in particular,
`
`to generating and tracking marketing related email.” Ex.1001 (1:11-13). I have
`
`considered its file history, attached as Exhibit 1008, including the examiner’s
`
`rejections. The examiner initially rejected the ’555 patent’s claims as obvious over
`
`U.S. Patent No. 5,937,162 (Funk) and Funk in view of U.S. Patent No. 5,937,162
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`(Melchione), U.S. Patent No. 6,360,254 (Linden), and U.S. Patent No. 6,377,936
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`(Henrick). Ex.1008 at 107-113. Applicants amended their claims to further limit how
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`the “email campaign template” is generated, including requiring that “a
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`American Airlines, Ex. 1006, p.19
`American Airlines v. Advanced Transactions
`IPR2023-01366
`
`

`

`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
`
`configuration file to contain data related to each of the at least one email target,
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`wherein the data is insertable in the generated message template” be used. Ex.1008
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`at 90. Applicants argued to the examiner that the configuration-file limitation
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`overcame the examiner’s rejections. Ex.1008 at 97. The examiner rejected that the
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`configuration-file limitation rendered the claims non-obvious over Funk. Ex.1008 at
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`72. Applicants primarily responded that “Funk fails to teach or suggest sending to
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`each of the at least one email target a corresponding custom email, wherein the
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`custom email is formed from the email campaign template, as set forth in Applicants’
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`claim 1.” Ex.1008 at 59. The examiner apparently accepted Applicants’ argument
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`and later issued the ’555 patent. Ex.1008 at 41. Even so, nothing in the file history
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`suggests that the examiner considered the prior art I discuss herein. Ex.1008 at 43;
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`Ex.1001 at References Cited. And as I explain below, the prior art I discuss herein
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`discloses or suggests the ’555 patent’s configuration-file limitation as well as
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`forming custom emails from it. As issued, the ’555 patent claims “[a] method and
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`system for generating and tracking an email campaign.” Ex.1001 at Abstract. The
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`specification further explains that “an email campaign” is used “for sending email
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`American Airlines, Ex. 1006, p.20
`American Airlines v. Advanced Transactions
`IPR2023-01366
`
`

`

`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
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`to a target set of email addresses for purposes such as marketing, information
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`acquisition, and otherwise.” Ex.1001 (1:21-22, 1:25).
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` The ’555 patent explains that “[t]he ability to market a product or
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`service to individuals who are accessible on the Internet is becoming increasingly
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`important.” Ex.1001 (1:15-17). To that end, “[e]ffective ways of contacting these
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`individuals are being sought.” Ex.1001 (1:17-18). While “[e]mail campaign[s]” then
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`existed, see Ex.1001 (1:20-25), they “suffer[ed] from difficulties in locating a pool
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`of relevant individuals to be contacted,” Ex.1001 (1:26-27). “[E]ach email sent is
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`critical to the success of the campaign, and needs to be carefully created.” Ex.1001
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`(1:28-29). That causes “increased difficulty” when an email campaign requires a
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`“large number” of “email messages” to be sent. Ex.1001 (1:31-33). And, once
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`“initiated, difficulties in measuring success of the email campaign are presented.”
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`Ex.1001 (1:34-36).
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` For those reasons, the ’555 patent explains, “[e]ffective ways for
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`determining whether email recipients have received email from the email
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`campaign,” and “for allowing the email recipients to provide feedback have . . . been
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`American Airlines, Ex. 1006, p.21
`American Airlines v. Advanced Transactions
`IPR2023-01366
`
`

`

`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
`
`sought.” Ex.1001 (1:36-39). And it was likewise “desirable for the email recipients
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`to be able to respond with feedback, and for the quantity and content of the responses
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`to be monitored and tracked.” Ex.1001 (1:40-42). In sum, according to the ’555
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`patent, “what is needed is an efficient way to create and track a email campaign
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`[sic].” Ex.1001 (1:43-44).
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` The specification further describes the system of its purported
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`“invention” as including:
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`An email campaign generator generates an email campaign template
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`from an email target database. The email target database includes at
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`least one email target. An email campaign engine generates a custom
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`email corresponding to each of the email targets in the email target
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`database. The custom email are formed from the email campaign
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`template. The email campaign engine sends each custom email to the
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`corresponding email target. A campaign tracker receives at least one
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`response corresponding to one or more of the sent custom email. The
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`American Airlines, Ex. 1006, p.22
`American Airlines v. Advanced Transactions
`IPR2023-01366
`
`

`

`Declaration of Eric Cole, PH.D. in Support of
`Petition for Inter Partes Review of
`U.S. Patent No. 7,065,555 B2
`
`
`campaign tracker creates a campaign tracking list that includes the
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`received at least one response.
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`Ex.1001 (1:48-60).
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` The specification further describes the method of its purported
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`“invention” as including:
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`The present invention is further directed to a method for an email
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`campaign. An email target database is received. An email campaign
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`template related to at least one email target in the received email target
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`database is generated. An email customized for each email target is sent
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`to the respective email target. Each customized email is formed from
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`the email campaign template. The sent custom email is tracked.
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`Ex.1001 (1:61-67).
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` The specification further describes that:
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`The email