UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`ABB INC.,
`
`Petitioner
`v.
`ROBOTIC VISION TECHNOLOGIES, LLC,
`Patent Owner
`
`Patent No. 8,095,237
`Inter Partes Review No.
`IPR2023-01426
`
`DECLARATION OF SYLVIA HALL-ELLIS, PH.D.
`
`ABB Inc. Exhibit 1010, Page 1 of 53
`ABB Inc. v. Roboticvisiontech, Inc.
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`_______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`ABB INC.,
`
`Petitioner
`v.
`ROBOTIC VISION TECHNOLOGIES, LLC,
`Patent Owner
`
`Patent No. 8,095,237
`Inter Partes Review No.
`IPR2023-01426
`
`DECLARATION OF SYLVIA HALL-ELLIS, PH.D.
`
`ABB Inc. Exhibit 1010, Page 1 of 53
`ABB Inc. v. Roboticvisiontech, Inc.
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`I.
`1.
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`INTRODUCTION
`My name is Sylvia D. Hall-Ellis. I have been retained as an expert on
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`behalf of ABB Inc. (“Petitioner”).
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`2.
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`I have written this Declaration on behalf of Petitioner to provide my
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`expert opinion regarding the authenticity and public availability of two publications.
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`My Declaration sets forth my opinions in detail and provides the basis for my
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`opinions regarding the public availability of these publications.
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`3.
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`I reserve the right to supplement or amend my opinions, and basis for
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`them, in response to any additional evidence, testimony, discovery, argument, and/or
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`other additional information that may be provided to me after the date of this
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`Declaration.
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`4.
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`I am being compensated for my time spent working on this matter at
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`my normal consulting rate of $350 per hour, plus reimbursement for any additional
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`reasonable expenses. My compensation is not in any way tied to the content of this
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`Declaration, the substance of my opinions, or the outcome of this litigation. I have
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`no other interests in this proceeding or with any of the parties.
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`5.
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`All of the materials that I considered are discussed explicitly in this
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`Declaration.
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`II. QUALIFICATIONS
`6.
`I am currently an Adjunct Professor in the School of Information at San
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`José State University. I obtained a Master of Library Science from the University
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`of North Texas in 1972 and a Ph.D. in Library Science from the University of
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`Pittsburgh in 1985. Over the last 50-plus years, I have held various positions in the
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`field of library and information resources. I was first employed as a librarian in 1966
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`and have been involved in the field of library sciences since, holding numerous
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`positions.
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`7.
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`I am a member of the American Library Association (ALA) and its
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`Association for Library Collections & Technical Services (ALCTS) Division, and I
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`served on the Committee on Cataloging: Resource and Description (which wrote the
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`new cataloging rules) and as the chair of the Committee for Education and Training
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`of Catalogers and the Competencies and Education for a Career in Cataloging
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`Interest Group. I also served as the Chair of the ALCTS Division’s Task Force on
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`Competencies and Education for a Career in Cataloging. Additionally, I have served
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`as the Chair for the ALA Office of Diversity’s Committee on Diversity, as a member
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`of the REFORMA National Board of Directors, as a member of the Editorial Board
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`for the ALCTS premier cataloging journal, Library Resources and Technical
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`Services, as a Co-Chair of the Library Research Round Table (LRRT) for the
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`American Library Association, and as a member of the LRRT Nominating
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`Committee.
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`8.
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`I have also given over one hundred presentations in the field, including
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`several on library cataloging systems and Machine-Readable Cataloging (“MARC”)
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`standards. My current research interests include library cataloging systems,
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`metadata, and organization of electronic resources.
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`9. My full curriculum vitae is attached hereto as Exhibit A.
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`III. LIBRARY CATALOGING PRACTICES
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`A. MARC RECORDS AND THE ONLINE LIBRARY CATALOG
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`10.
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`I am fully familiar with the library cataloging standard known as the
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`MARC standard, which is an industry-wide standard method of storing and
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`organizing library catalog information.1 MARC was first developed in the 1960s by
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`the Library of Congress. A MARC-compatible library is one that has a catalog
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`consisting of individual MARC records for each of its items. Today, MARC is the
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`primary communications protocol for the transfer and storage of bibliographic
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`metadata in libraries.
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`11. MARC is a framework into which descriptive bibliographic data are
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`transcribed to interact with the software in online library catalogs to provide access
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`1 The full text of the standard is available from the Library of Congress at
`http://www.loc.gov/marc/bibliographic/ (last visited July 5, 2023).
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`to books, journals, and other resources in the collection. The bibliographic data
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`provide points of access and can be searched by a person of ordinary skill in the art
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`at the time of the invention (“POSITA,” see paragraphs 35-37 below) to identify and
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`obtain resources in the library collection. An information seeker (or POSITA) can
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`search a local online library catalog or the holdings of a group of libraries in a state
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`or region or in the global catalog WorldCat.
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`12. MARC records are not designed for public viewing. Although a
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`significant number of libraries provide access to the MARC version of a
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`bibliographic record, the public display is designed to show information in a succinct
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`manner that is quickly understood and useful to the information seeker. Libraries
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`determine the default search for the online catalog to make the entry of search terms
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`efficient and result in a successful search. Information seekers can enter a keyword,
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`title, author, or standard number for the item. Libraries may also provide a search
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`capability called “Summon” that allows the information seeker to enter known
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`information about the item to conduct a search.
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`13. Since at least the early 1970s and continuing to the present day, MARC
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`has been the primary communications protocol for the transfer and storage of
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`bibliographic metadata in libraries.2 As explained by the Library of Congress:
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`2 A complete history of the development of MARC can be found in MARC: Its
`History and Implications by Henrietta D. Avram (Washington, DC: Library of
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`You could devise your own method of organizing the
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`bibliographic information, but you would be isolating your library,
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`limiting its options, and creating much more work for yourself. Using
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`the MARC standard prevents duplication of work and allows libraries
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`to better share bibliographic resources. Choosing to use MARC enables
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`libraries to acquire cataloging data that is predictable and reliable. If a
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`library were to develop a “home-grown” system that did not use MARC
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`records, it would not be taking advantage of an industry-wide standard
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`whose primary purpose is to foster communication of information.
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`Using the MARC standard also enables libraries to make use of
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`commercially available library automation systems to manage library
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`operations. Many systems are available for libraries of all sizes and are
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`designed to work with the MARC format. Systems are maintained and
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`improved by the vendor so that libraries can benefit from the latest
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`advances in computer technology. The MARC standard also allows
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`libraries to replace one system with another with the assurance that their
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`data will still be compatible.
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`Congress, 1975) and available online from the Hathi Trust (https://babel.
`hathitrust.org/cgi/pt?id=mdp.39015034388556;view=1up;seq=1; last visited July 5,
`2023).
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`Why Is a MARC Record Necessary? LIBRARY OF CONGRESS.3
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`14. Thus, almost every major library in the world is MARC-compatible.
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`See, e.g., MARC Frequently Asked Questions (FAQ), LIBRARY OF CONGRESS.4
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`(“MARC is the acronym for MAchine-Readable Cataloging. It defines a data format
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`that emerged from a Library of Congress-led initiative that began fifty years ago. It
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`provides the mechanism by which computers exchange, use, and interpret
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`bibliographic information, and its data elements make up the foundation of most
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`library catalogs used today.”). MARC is the ANSI/NISO Z39.2-1994 standard
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`(reaffirmed in 2016) for Information Interchange Format. The full text of the
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`standard is available from the Library of Congress.5
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`15. Examining the MARC records for a specific item reveals the
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`comprehensive data transcribed about a particular item at the time that cataloging
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`and classification occurred. In addition to the creator, title, subjects, and standard
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`numbers, additional information may provide additional and relevant data depending
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`on the type of resource. Understanding the full extent of bibliographic data for an
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`item and the points of access associated with it provides essential information that
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`can be used to determine the indexing and public availability for documents
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`3 http://www.loc.gov/marc/umb/um01to06.html#part2
`4 https://www.loc.gov/marc/faq.html
`5 http://www.loc.gov/marc/bibliographic/
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`described in this Declaration.
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`B. MARC RECORDS
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`16. A MARC record comprises several fields, each of which contains
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`specific data about the work. Each field is identified by a standardized, unique, three-
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`digit code corresponding to the type of data that follow. For example, a work’s title
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`is recorded in Field 245; the primary author of the work is transcribed in Field 100;
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`an item’s International Standard Book Number (“ISBN”) consisting of ten or
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`thirteen digits is transcribed in Field 020; an item’s International Standard Serial
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`Number (“ISSN”) is transcribed in Field 022; the Library of Congress classification
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`notation is recorded in Field 050; and the publication date is recorded in Field 260
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`under the subfield “c.” If a work is a periodical, then its publication frequency is
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`recorded in Field 310, and the publication dates (e.g., the first and last publication)
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`are recorded in Field 362, which is also referred to as the enumeration/chronology
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`field.6
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`17. The library that created the record is recorded in Field 040 in subfield
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`“a” with a unique library code. When viewing the MARC record online via Online
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`Computer Library Center’s (“OCLC”) bibliographic database, hovering over this
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`code with the mouse reveals the full name of the library. I used this method of
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`6 http://www.loc.gov/marc/bibliographic/bd3xx.html
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`
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`“mousing over” the library codes in the OCLC database to identify the originating
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`library for the MARC records discussed in this Declaration. Where this “mouse
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`over” option was not available, I consulted the Directory of OCLC Libraries to
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`identify the institution that created the MARC record.7
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`18. MARC records also include several fields that include subject matter
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`classification information. An overview of MARC record fields is available through
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`the Library of Congress.8 For example, 6XX fields are termed “Subject Access
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`Fields.”9 Among these, for example, is the 650 field; this is the “Subject Added Entry
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`– Topical Term” field.10 The 650 field is a “[s]ubject added entry in which the entry
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`element is a topical term.” These entries “are assigned to a bibliographic record to
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`provide access according to generally accepted thesaurus-building rules (e.g.,
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`Library of Congress Subject Headings (LCSH), Medical Subject Headings
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`(MeSH)).” Id. Further, MARC records include call numbers, which themselves
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`include a classification number. For example, the 050 field is the “Library of
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`Congress Call Number.”11 A defined portion of the Library of Congress Call (LCC)
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`7 https://www.oclc.org/en/contacts/libraries.html
`8 http://www.loc.gov/marc/bibliographic/
`9 http://www.loc.gov/marc/bibliographic/bd6xx.html
`10 http://www.loc.gov/marc/bibliographic/bd650.html
`11 http://www.loc.gov/marc/bibliographic/bd050.html
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`Number is the classification number, and “source of the classification number is
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`Library of Congress Classification and the LC Classification-Additions and
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`Changes.” Thus, included in the 050 field is a subject matter classification. Further,
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`the 082 field is the “Dewey Decimal Call Number.”12 A defined portion of the
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`Dewey Decimal Call (DDC) Number is the classification number, and “source of
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`the classification number is the Dewey Decimal Classification and Relative Index.”
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`Thus, included in the 082 field is a subject matter classification. Each item in a
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`library has a single classification number. A library selects a classification scheme
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`(e.g., the Library of Congress classification scheme just described or a similar
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`scheme such as the Dewey Decimal classification scheme) and uses it consistently.
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`When the Library of Congress assigns the LCC classification number, it appears as
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`part of the 050 field. When the Library of Congress assigns the DDC classification
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`number, it appears as part of the 082 field. If a local library assigns the classification
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`number, it appears in a 090 field. In either scenario, the MARC record includes a
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`classification number that represents a subject matter classification.
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`C. OCLC
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`19. The OCLC was created “to establish, maintain and operate a
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`computerized library network and to promote the evolution of library use, of libraries
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`12 http://www.loc.gov/marc/bibliographic/bd082.html
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`themselves, and of librarianship, and to provide processes and products for the
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`benefit of library users and libraries, including such objectives as increasing
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`availability of library resources to individual library patrons and reducing the rate of
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`rise of library per-unit costs, all for the fundamental public purpose of furthering
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`ease of access to and use of the ever-expanding body of worldwide scientific, literary
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`and educational knowledge and information.”13 Among other services, OCLC and
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`its members are
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`responsible
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`for maintaining
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`the WorldCat database
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`(http://www.worldcat.org/), used by
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`independent and
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`institutional
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`libraries
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`throughout the world.
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`20. OCLC also provides its members online access to MARC records
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`through its OCLC bibliographic database. When an OCLC member institution
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`acquires a work, it creates a MARC record for this work in its computer catalog
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`system in the ordinary course of its business. MARC records created at the Library
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`of Congress are tape-loaded into the OCLC database through a subscription to
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`MARC Distribution Services daily or weekly. Once the MARC record is created by
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`a cataloger at an OCLC member institution or is tape-loaded from the Library of
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`Congress, the MARC record is then made available to any other OCLC members
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`13 Third Article, Amended Articles of Incorporation of OCLC Online Computer
`Library Center, Incorporated (available at https://www.oclc.org/content/dam/oclc/
`membership/articles-of-incorporation.pdf).
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`online, and therefore made available to the public. Accordingly, once the MARC
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`record is created by a cataloger at an OCLC member institution or is tape-loaded
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`from the Library of Congress or another library anywhere in the world, any
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`publication corresponding to the MARC record has been cataloged and indexed
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`according to its subject matter such that a person interested in that subject matter
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`could, with reasonable diligence, locate and access the publication through any
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`library with access to the OCLC bibliographic database or through the Library of
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`Congress.
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`21. When an OCLC member institution creates a new MARC record,
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`OCLC automatically supplies the date of creation for that record. The date of
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`creation for the MARC record appears in the fixed Field (008), characters 00 through
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`05. The MARC record creation date reflects the date on which, or shortly after
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`which, the item was first acquired or cataloged. Initially, Field 005 of the MARC
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`record is automatically populated with the date the MARC record was created in
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`year, month, day format (YYYYMMDD) (some of the newer library catalog systems
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`also include hour, minute, second (HHMMSS)). Thereafter, the library’s computer
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`system may automatically update the date in Field 005 every time the library updates
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`the MARC record (e.g., to reflect that an item has been moved to a different shelving
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`location within the library). Field 005 is visible when viewing a MARC record via
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`an appropriate computerized interface, but when a MARC record is printed to
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`hardcopy, no “005” label appears. The initial Field 005 date (i.e., the date the MARC
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`record was created) does appear, however, next to the label “Entered.”14 The date
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`upon which the most recent update to Field 005 occurred also appears, next to the
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`label “Replaced.” Thus, when an item’s MARC record has been printed to
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`hardcopy—as is the case with the MARC attachments to this Declaration—the date
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`reflected next to the label “Entered” is necessarily on or after the date the library first
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`cataloged and indexed the underlying item.
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`22. Once one library has cataloged and indexed a publication by creating a
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`MARC record for that publication, other libraries that receive the publication do not
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`create additional MARC records—the other libraries instead rely on the original
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`MARC record. They may update or revise the MARC record to ensure accuracy, but
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`they do not replace or duplicate it. This practice does more than save libraries from
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`duplicating labor. It also enhances the accuracy of MARC records. Further, it allows
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`librarians around the world to know that a particular MARC record is authoritative
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`(in contrast, a hypothetical system wherein duplicative records were created would
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`result in confusion as to which record is authoritative).
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`14 Field 005 is visible when viewing a MARC record via an appropriate
`computerized interface. But when a MARC record is printed directly to hardcopy
`from the OCLC database, the “005” label is not shown. The date in the 005 field
`instead appears next to the label “Replaced.”
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`23. Catalogers can create MARC records for all types of print, online, and
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`digital resources. The date of creation of the MARC record by a cataloger at an
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`OCLC member institution reflects when the underlying item is accessible to the
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`public. Upwards of two-thirds to three-quarters of book sales and magazine
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`subscriptions to libraries come from a jobber or wholesaler for online and print
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`resources. These resellers make it their business to provide items to their customers
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`as fast as possible, often providing turnaround times of only a single day after
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`publication. Libraries purchase a significant portion of the balance of their books
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`and journals directly from publishers themselves, which provide delivery on a
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`similarly expedited schedule. In general, libraries make these purchases throughout
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`the year and shelve the newly received items as soon thereafter as possible to make
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`them available to their patrons.
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`24.
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`In preparing this Declaration, I used authoritative databases, such as the
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`OCLC bibliographic database and the Library of Congress Online Catalog, to
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`confirm citation details of the various publications discussed.
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`25.
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`Indexing. A researcher may discover material relevant to his or her
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`topic in a variety of ways. One common means of discovery is to search for relevant
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`information in an index of periodical and other publications. Having found relevant
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`material, the researcher will then normally obtain it online, look for it in libraries, or
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`purchase it from a publisher, a bookstore, a document delivery service, or other
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`provider. Sometimes, the date of a document’s public accessibility will involve both
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`indexing and library date information. However, date information for indexing
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`entries is often unavailable. This is especially true for online indices.
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`26.
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`Indexing services use a wide variety of controlled vocabularies to
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`provide subject access and other means of discovering the content of documents.
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`The formats in which these access terms are presented vary from service to service.
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`27. Online indexing services commonly provide bibliographic information,
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`abstracts, and full-text copies of the indexed publications, along with a list of the
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`documents cited in the indexed publication. These services also often provide lists
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`of publications that cite a given document. A citation of a document is evidence that
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`the document was publicly available and in use by researchers no later than the
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`publication date of the citing document.
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`28. Before the widespread development of online databases to index
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`articles in journals, magazines, conference papers, and technical Declarations,
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`libraries purchased printed volumes of indices. Graduate library school education
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`mandated that students learn about the bibliographic control of disciplines, the
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`prominent indexing volumes, and searching strategies required to use them
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`effectively and efficiently. Half of the courses that I studied in library school were
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`focused on the bibliography and resources in academic disciplines.
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`29. Librarians consulted with information seekers to verify citations, check
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`availability in union catalogs, printed books catalogs, the OCLC database, and make
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`formal requests for materials (e.g., books, conference proceedings, journal articles).
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`Requests were transmitted using Telex machines, rudimentary email systems, and
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`the United States Postal Service. During my career, I have performed and supervised
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`staff who handled these resource sharing tasks.
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`30. A citation of a document by another is evidence that the document was
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`publicly available and in use no later than the publication date of the citing
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`document.
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`IV. PRELIMINARIES
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`31.
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`Scope of this Declaration. I am not an attorney and will not offer
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`opinions on the law. I am, however, rendering my expert opinion on the authenticity
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`of the documents referenced herein and on when and how each of these documents
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`was disseminated or otherwise made available to the extent that persons interested
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`and ordinarily skilled in the subject matter or art, exercising reasonable diligence,
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`could have located the documents before on or around the listed dates of their
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`respective publications below.
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`32.
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`I am informed by counsel that a printed publication qualifies as publicly
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`accessible as of the date it was disseminated or otherwise made available such that
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`a person interested in and ordinarily skilled in the relevant subject matter could
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`locate it through the exercise of ordinary diligence.
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`33. While I understand that the determination of public accessibility under
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`the foregoing standard rests on a case-by-case analysis of the facts particular to an
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`individual publication, I also understand that a printed publication is rendered
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`“publicly accessible” if it is cataloged and indexed by a library such that a person
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`interested in the relevant subject matter could locate it (i.e., I understand that
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`cataloging and indexing by a library is sufficient, though there are other ways that a
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`printed publication may qualify as publicly accessible). One manner of sufficient
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`indexing is indexing according to subject matter category. I understand that the
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`cataloging and indexing by a single library of a single instance of a particular printed
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`publication is sufficient, even if the single library is in a foreign country. I
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`understand that, even if access to a library is restricted, a printed publication that has
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`been cataloged and indexed therein is publicly accessible so long as a presumption
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`is raised that the portion of the public concerned with the relevant subject matter
`
`would know of the printed publication. I also understand that the cataloging and
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`indexing of information that would guide a person interested in the relevant subject
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`matter to the printed publication, such as the cataloging and indexing of an abstract
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`for the printed publication, is sufficient to render the printed publication publicly
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`accessible.
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`34.
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`I understand that routine business practices, such as general library
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`cataloging and indexing practices, can be used to establish an approximate date on
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`which a printed publication became publicly accessible.
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`35. Persons of ordinary skill in the art. I am told by counsel that the subject
`
`matter of this proceeding generally relates to 3D robotic vision and more specifically
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`to techniques and systems for three-dimensional object location using robotic vision.
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`36.
`
`I have been informed by counsel that a “person of ordinary skill in the
`
`art at the time of the inventions” is a hypothetical person who is presumed to be
`
`familiar with the relevant field and its literature at the time of the inventions. This
`
`hypothetical person is also a person of ordinary creativity, capable of understanding
`
`the scientific principles applicable to the pertinent field.
`
`37.
`
`I am told by counsel that persons of ordinary skill in this subject matter
`
`or art would have had a Bachelor’s degree in robotics, mechanical engineering,
`
`computer science, electrical engineering, or an equivalent, and at least three years of
`
`professional experience working in the field of computer vision or three years of
`
`graduate level education, including a focus on computer vision applications. The
`
`POSITA would have knowledge about machine vision and camera calibration
`
`techniques.
`
`38.
`
`It is my opinion that such a person would have been engaged in
`
`research, learning through study and practice in the field and possibly through formal
`
`
`
`ABB Inc. Exhibit 1010, Page 18 of 53
`ABB Inc. v. Roboticvisiontech, Inc.
` IPR2023-01426
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`
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`instruction the bibliographic resources relevant to his or her research. In the 2011
`
`timeframe, such a person would have had access to a vast array of long-established
`
`print resources in the area of payment systems.
`
`V.
`
`DOCUMENT 1: EXHIBIT 1004 (“CORKE”)
`Exhibit 1004 is a true and correct copy of the book titled Visual Control
`39.
`
`of Robots: High-Performance Visual Servoing by Peter I. Corke (hereafter “Corke”)
`
`and issued by John Wiley and Sons with a 1996 copyright date. The text of Exhibit
`
`1004 is complete; no pages are missing, and the text on each page appears to flow
`
`seamlessly from one page to the next; further, there are no visible alterations to the
`
`document. Exhibit 1004 was found within the custody of a library (the Morgan
`
`Library at Colorado State University (Fort Collins, Colorado) – a place where, if
`
`authentic, a copy of this book would likely be. Exhibit 1004 is a true and correct
`
`copy in a condition that creates no suspicion about its authenticity.
`
`40. Attached hereto as Attachment 1A is a true and correct copy of the
`
`MARC record for this book from the Morgan Library at Colorado State University
`
`(Fort Collins, Colorado). Library ownership is indicated by the presence of the
`
`library’s code (“COF”) in field 049. I personally identified and retrieved the library
`
`catalog record which is Attachment 1A.
`
`41. Based on finding a print copy of Exhibit 1004 in the Morgan Library at
`
`Colorado State University (Fort Collins, Colorado) and MARC record in its online
`
`ABB Inc. Exhibit 1010, Page 19 of 53
`ABB Inc. v. Roboticvisiontech, Inc.
` IPR2023-01426
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`
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`library catalog attached as Attachment 1A, it is my opinion that the book titled Visual
`
`Control of Robots: High-Performance Visual Servoing (Exhibit 1004) was
`
`created using a Library of Congress MARC record that was created on August 29,
`
`1996, as
`part of the Cataloging in Publication (CIP) Program (see paragraph 43). Attachment
`
`1A indicates that the Corke book was added to the Morgan Library collection on
`
`July 9, 1997, as shown in field 945 (“07-09-97”). Therefore, the book titled Visual
`
`Control of Robots: High-Performance Visual Servoing (Exhibit 1004) was
`
`present and cataloged in the Morgan Library at Colorado State University (Fort
`
`Collins, Colorado) on July 9, 1997. It would have been able to be located by a
`
`person of ordinary skill in the art using the library catalog system and was
`
`accessible as of this date.
`thus publicly
`
`42. Attachment 1A further includes an entry in field 050 (“TJ211.35 $b
`
`C68 1996”), a subject matter classification number consistent with the Library of
`
`Congress classification system. Attachment 1A further includes a descriptor term
`
`reading “Robots $x Control systems” (see Attachment 1B, Library of Congress
`
`subject heading sh89001406) in the 650 field. Thus, as of its cataloging, the Corke
`
`book (Exhibit 1004), which is the publication corresponding to the MARC record
`
`attached hereto as Attachment 1A, was indexed according to its subject matter by
`
`virtue of at least two independently sufficient classifications: the field 050 entry and
`
`the field 650 entry.
`
`ABB Inc. Exhibit 1010, Page 20 of 53
`ABB Inc. v. Roboticvisiontech, Inc.
` IPR2023-01426
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`
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`43. Attached hereto as Attachment 1C is a true and correct copy of the
`
`MARC record for the book titled Visual Control of Robots: High-Performance
`
`Visual Servoing by Corke (Exhibit 1004) obtained from the OCLC bibliographic
`
`database. I personally identified and retrieved the MARC record that is Attachment
`
`1C. As previously noted, the library that created the record is recorded in field 040
`
`with a unique library code. For Attachment 1C, that library code is “DLC,” which
`
`means that the MARC record for this book was created at the Library of Congress.
`
`The presence of CIP data on the copyright page of Exhibit 1004 indicates that the
`
`Corke book was cataloged as part of the CIP Program.15 A cataloger prepares basic
`
`information about the forthcoming book which is included on the verso of the title
`
`page (also called the copyright page). The information is provided to save time
`
`needed for the cataloging process at the library after the book is purchased. The CIP
`
`data includes the author (field 100), title and subtitle (field 245), ISBN (field 022),
`
`suggested subject headings (field 650), classification numbers for the Library of
`
`Congress classification number (field 050), and the Dewey Decimal classification
`
`number (field 082). These data elements are included in the MARC record that the
`
`Library of Congress contributes to the OCLC bibliographic database. As can be seen
`
`in the “Entered” field in the MARC record for this exhibit, a cataloger at the Library
`
`15 https://www.loc.gov/publish/cip/
`
`ABB Inc. Exhibit 1010, Page 21 of 53
`ABB Inc. v. Roboticvisiontech, Inc.
` IPR2023-01426
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`
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`of Congress created OCLC record number 35364719 on August 29, 1996, as shown
`
`in the “Entered” field (“19960829”). The library continues to update and enhance
`
`this MARC record to meet current cataloging rules. The most recent enhancement
`
`to Attachment 1C occurred on May 30, 2022, as shown in the “Replaced” field
`
`(“20220530”). I personally identified and retrieved the MARC record that is
`
`Attachment 1C.
`
`44. Attachment 1C further includes an entry in field 050 (“TJ211.35 $b C68
`
`1996”)—as described above, this includes a subject matter classification number
`
`consistent with the Library of Congress classification system (analogous to the
`
`Dewey Decimal classification system) and an entry in field 082 (“629.8/92”), a
`
`subject matter consistent with
`
`the Dewey Decimal classification sy
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