throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`HOME DEPOT USA, INC., and
`HOME DEPOT SOLUTIONS LLC
`Petitioner,
`
`v.
`
`INNOVAPORT, LLC
`Patent Owner.
`
`
`Case IPR2024-00011
`
`U.S. Patent No. 9,990,670
`Issue Date: June 5, 2018
`Title: APPARATUS AND METHOD FOR PROVIDING
`PRODUCT LOCATION INFORMATION TO CUSTOMERS IN A STORE
`
`DECLARATION OF DON TURNBULL, PHD
`
`1605307314
`
`Home Depot
`Ex. 1002 - Page 1
`
`

`

`TABLE OF CONTENTS
`
`Page
`
`INDEX OF EXHIBITS ........................................................................................... vii
`670 PATENT LIST OF CLAIMS IN CONTENTION ............................................ ix
`I.
`Background and Qualifications ....................................................................... 2
`A. Qualifications ........................................................................................ 2
`B.
`Technology Background ....................................................................... 9
`C. Materials Reviewed ............................................................................. 16
`Relevant Legal Standards .............................................................................. 16
`II.
`III. The 670 Patent ............................................................................................... 20
`A. Overview of the 670 Patent ................................................................. 20
`B. Overview of the 670 patent’s File History .......................................... 21
`C.
`Person of Ordinary Skill in the Art ..................................................... 22
`D.
`Claim Construction.............................................................................. 23
`E.
`Non-Functional Descriptive Material ................................................. 28
`IV. Overview of the Prior Art References ........................................................... 29
`A.
`EX1004- Shanman .............................................................................. 29
`B.
`EX1005- Ogasawara............................................................................ 32
`C.
`EX1006 - Beach .................................................................................. 35
`D.
`EX1030 - Bezos ................................................................................... 37
`E.
`EX1031 - Shelton ................................................................................ 37
`V. Ground 1: Shanman Renders Obvious Claims 1, 2, 4, 6-10, 12 and 14 ....... 39
`A.
`Claim 1 ................................................................................................ 39
`1.
`[1pre] A method of providing product location information
`within a store, the method comprising the steps of: ................. 39
`[1a] providing at least one information storage device including
`a database, wherein the at least one information storage device
`is configured to be at least indirectly in communication with at
`least one other device that includes at least one user interface,
`and wherein at least one of the at least one information storage
`device and the at least one other device with respect to which
`the at least one information storage device is configured to be at
`i
`
`2.
`
`1605307314
`
`Home Depot
`Ex. 1002 - Page 2
`
`

`

`5.
`
`6.
`
`7.
`
`8.
`
`3.
`
`4.
`
`least indirectly in communication is or includes a mobile
`device; ....................................................................................... 40
`[1b] wherein the at least one information storage device
`includes both product location information and additional
`product-related information linking a product with another
`product in a cross-referential manner; ...................................... 41
`[1c] receiving a product location inquiry signal regarding the
`product, the product location inquiry signal being at least
`indirectly based upon a product location inquiry received by
`way of the at least one user interface; ....................................... 44
`[1d] processing the product location inquiry signal at a signal
`processing device to determine a processed product location
`inquiry signal; ........................................................................... 46
`[1e] querying the at least one information storage device to
`obtain portions of the product location information and
`additional product-related information in response to the
`processed product location inquiry signal; ............................... 48
`[1f] providing a product location information signal that is at
`least indirectly responsive to the processed product location
`inquiry signal; ........................................................................... 50
`[1g] wherein the product location information signal is
`configured to enable, at least indirectly, a providing of an
`output signal at an output device as a response to the product
`location inquiry that includes location information concerning
`the product and also provides at least one suggestion related to
`the other product. ...................................................................... 51
`Claim 2. The method of claim 1, wherein the product location
`information signal is configured to enable, at least indirectly, the
`providing of the output signal at the least one user interface, which
`includes the output device in addition to an input device. .................. 52
`Claim 4. The method of claim 2, wherein the at least one user
`interface includes a mobile user interface. .......................................... 52
`Claim 6. The method of claim 4, wherein the product location
`information signal is configured to enable, at least indirectly, the at
`least one user interface to provide information concerning one or more
`products that are being specially promoted or that are located close by
`the at least one user interface. ............................................................. 53
`ii
`
`B.
`
`C.
`
`D.
`
`1605307314
`
`Home Depot
`Ex. 1002 - Page 3
`
`

`

`E.
`
`F.
`
`G.
`
`Claim 7. The method of claim 4, wherein the product location
`information signal is configured to enable, at least indirectly, the
`providing of the output signal so that the output signal provides at
`least one further suggestion to a customer in accordance with one or
`more customer preferences. ................................................................. 55
`Claim 8. The method of claim 4, wherein the product location
`information signal is configured to enable, at least indirectly, the at
`least one user interface to provide further additional product-related
`information, and wherein the further additional product-related
`information includes at least one of: product promotion information; a
`current stock of the product; a price of the product; a presence or
`absence of the product within the store; a time at which the product
`should be available at the store if the product is currently absent from
`the store; and an alternate way of obtaining the product if the product
`is currently absent from the store. ....................................................... 56
`Claim 9. The method of claim 8, wherein the further additional
`product-related information relates to either the time at which the
`product should be available at the store if the product is currently
`absent from the store, or the alternate way of obtaining the product if
`the product is currently absent from the store. .................................... 59
`Claim 10. The method of claim 8, wherein the further additional
`product-related information relates to either the current stock of the
`product, or the presence or absence of the product within the store. .. 59
`Claim 12. The method of claim 4, further comprising one or both of:
`receiving an additional inquiry signal that relates to something other
`than a product location-type inquiry; or obtaining identification
`information concerning the customer that at least in part allows for the
`providing of an additional suggestion to the customer. ...................... 60
`Claim 14. The method of claim 1, wherein either (a) the mobile device
`is able to provide at least some of the information to the at least one
`user interface, or (b) at least a first one of the at least one user
`interface is in wireless communication with either a central hub or at
`least a second one of the at least one user interface, or (c) one or more
`words associated with the product location inquiry received by way of
`the at least one user interface are determined by way of a voice
`recognition process. ............................................................................. 62
`VI. Ground 2: Ogasawara and Beach Render Obvious Claims 1, 2, 4, 6-10, 12
`and 14 ............................................................................................................. 64
`iii
`
`H.
`
`I.
`
`J.
`
`1605307314
`
`Home Depot
`Ex. 1002 - Page 4
`
`

`

`2.
`
`3.
`
`4.
`
`Claim 1 ................................................................................................ 64
`1.
`[1pre] A method of providing product location information
`within a store, the method comprising the steps of: ................. 64
`[1a] providing at least one information storage device including
`a database, wherein the at least one information storage device
`is configured to be at least indirectly in communication with at
`least one other device that includes at least one user interface,
`and wherein at least one of the at least one information storage
`device and the at least one other device with respect to which
`the at least one information storage device is configured to be at
`least indirectly in communication is or includes a mobile device
` ................................................................................................... 64
`[1b] wherein the at least one information storage device
`includes both product location information and additional
`product-related information linking a product with another
`product in a cross-referential manner; ...................................... 67
`[1c] receiving a product location inquiry signal regarding the
`product, the product location inquiry signal being at least
`indirectly based upon a product location inquiry received by
`way of the at least one user interface; ....................................... 71
`[1d] processing the product location inquiry signal at a signal
`processing device to determine a processed product location
`inquiry signal ............................................................................. 72
`[1e] querying the at least one information storage device to
`obtain portions of the product location information and
`additional product-related information in response to the
`processed product location inquiry signal ................................ 73
`[1f] providing a product location information signal that is at
`least indirectly responsive to the processed product location
`inquiry signal; ........................................................................... 75
`[1g] wherein the product location information signal is
`configured to enable, at least indirectly, a providing of an
`output signal at an output device as a response to the product
`location inquiry that includes location information concerning
`the product and also provides at least one suggestion related to
`the other product. ...................................................................... 76
`
`A.
`
`5.
`
`6.
`
`7.
`
`8.
`
`1605307314
`
`iv
`
`Home Depot
`Ex. 1002 - Page 5
`
`

`

`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`H.
`
`I.
`
`Claim 2. The method of claim 1, wherein the product location
`information signal is configured to enable, at least indirectly, the
`providing of the output signal at the least one user interface, which
`includes the output device in addition to an input device. .................. 78
`Claim 4. The method of claim 2, wherein the at least one user
`interface includes a mobile user interface. .......................................... 78
`Claim 6. The method of claim 4, wherein the product location
`information signal is configured to enable, at least indirectly, the at
`least one user interface to provide information concerning one or more
`products that are being specially promoted or that are located close by
`the at least one user interface. ............................................................. 79
`Claim 7. The method of claim 4, wherein the product location
`information signal is configured to enable, at least indirectly, the
`providing of the output signal so that the output signal provides at
`least one further suggestion to a customer in accordance with one or
`more customer preferences. ................................................................. 80
`Claim 8. The method of claim 4, wherein the product location
`information signal is configured to enable, at least indirectly, the at
`least one user interface to provide further additional product-related
`information, and wherein the further additional product-related
`information includes at least one of: product promotion information; a
`current stock of the product; a price of the product; a presence or
`absence of the product within the store; a time at which the product
`should be available at the store if the product is currently absent from
`the store; and an alternate way of obtaining the product if the product
`is currently absent from the store. ....................................................... 81
`Claim 9. The method of claim 8, wherein the further additional
`product-related information relates to either the time at which the
`product should be available at the store if the product is currently
`absent from the store, or the alternate way of obtaining the product if
`the product is currently absent from the store. .................................... 85
`Claim 10. The method of claim 8, wherein the further additional
`product-related information relates to either the current stock of the
`product, or the presence or absence of the product within the store. .. 85
`Claim 12. The method of claim 4, further comprising one or both of:
`receiving an additional inquiry signal that relates to something other
`than a product location-type inquiry; or obtaining identification
`
`1605307314
`
`v
`
`Home Depot
`Ex. 1002 - Page 6
`
`

`

`J.
`
`information concerning the customer that at least in part allows for the
`providing of an additional suggestion to the customer. ...................... 86
`Claim 14. The method of claim 1, wherein either (a) the mobile device
`is able to provide at least some of the information to the at least one
`user interface, or (b) at least a first one of the at least one user
`interface is in wireless communication with either a central hub or at
`least a second one of the at least one user interface, or (c) one or more
`words associated with the product location inquiry received by way of
`the at least one user interface are determined by way of a voice
`recognition process. ............................................................................. 88
`VII. Ground 3: Ogasawara, Beach, and Shanman Render Obvious Claim 9 ....... 89
`A.
`Claim 9. The method of claim 8, wherein the further additional
`product-related information relates to either the time at which the
`product should be available at the store if the product is currently
`absent from the store, or the alternate way of obtaining the product if
`the product is currently absent from the store. .................................... 89
`VIII. Secondary Considerations ............................................................................. 91
`IX. Availability for Cross-Examination .............................................................. 91
`X.
`Right To Supplement ..................................................................................... 92
`XI. Conclusion ..................................................................................................... 92
`
`1605307314
`
`vi
`
`Home Depot
`Ex. 1002 - Page 7
`
`

`

`INDEX OF EXHIBITS
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`Exhibit No. Description
`U.S. Patent No. 9,990,670 (“670 patent”)
`1001
`1002
`[RESERVED]
`1003
`File History of 670 patent
`U.S. Patent No. 7,231,357 (“Shanman”)
`1004
`U.S. Patent No. 6,123,259 (“Ogasawara”)
`1005
`U.S. Patent No. 6,084,528 (“Beach”)
`1006
`1007
`https://www.uscourts.gov/statistics/table/na/federal-court-
`management-statistics/2023/06/30-1
`Innovaport LLC v. Home Depot U.S.A., Inc., No. 3:23-cv-00225,
`Dkt. 1 (W.D. Wis. April 11, 2023)
`Innovaport LLC v. Home Depot U.S.A., Inc., No. 3:23-cv-00225,
`Dkt. 16 (W.D. Wis. Aug. 4, 2023)
`Innovaport LLC v. Target Corp., No. 3:22-cv-00425, Dkt. 18
`(W.D. Wis. Nov. 2, 2022))
`Innovaport LLC v. Best Buy Co., Inc., No. 3:23-cv-00016,
`Dkt. 27 (W.D. Wis. June 28, 2023)
`Innovaport LLC v. Target Corp., No. 3:22-cv-00425, Dkt. 1
`(W.D. Wis. Aug. 4, 2022))
`Innovaport LLC v. Best Buy Co., Inc., No. 3:23-cv-00016, Dkt. 1
`(W.D. Wis. Jan. 6, 2023)
`Innovaport LLC v. IKEA North America Services, LLC et al., No.
`2:21-cv-00789, Dkt. 1 (E.D. Wis. June 25, 2021)
`Innovaport LLC v. IKEA North America Services, LLC et al., No.
`2:21-cv-00789, Dkt. 31 (E.D. Wis. Sept. 8, 2022)
`Innovaport LLC v. IKEA North America Services, LLC et al., No.
`2:21-cv-00789, Dkt. 41 (E.D. Wis. Jan. 26, 2023)
`Alternative Service of Complaint Acceptance Email (May 5,
`2023)
`Interim Procedure for Discretionary Denials in AIA Post-Grant
`Proceedings with Parallel District Court Litigation” dated June
`21, 2022
`Innovaport LLC v. Target Corp., No. 3:22-cv-00425, Dkt. 38
`(W.D. Wis. Sept. 28, 2023))
`U.S. Patent No. 7,010,498 (“Berstis”)
`Jennifer Rowley, Multimedia kiosks in retailing, 23 INT’L J. OF
`RETAIL & DISTRIB. MGMT. 5: 32-40 (1995) (“Rowley”)
`
`1016
`
`1017
`
`1018
`
`1019
`
`1020
`1021
`
`1605307314
`
`vii
`
`Home Depot
`Ex. 1002 - Page 8
`
`

`

`1023
`
`1024
`
`1025
`
`Exhibit No. Description
`James R. Otto & Q. B. Chung, A Framework for Cyber-enhanced
`1022
`Retailing: Integrating E-Commerce Retailing with Brick-and-
`Mortar Retailing, 10 ELEC. MKTS. 3: 185-191 (2000)
`Review and Assessment of Information Kiosk Systems, U.S.
`Dep’t of Transp. (March 1997)
`Greg Kearsley, Public Access Systems: Bringing Computer
`Power to the People (1994)
`Lucy A. Tedd, OPACs through the Ages, LIBR. REV. 43: 27-37
`(1994)
`Bo Doub, Community Memory: Precedents in Social Media and
`Movements, Computer History Museum, February 26, 2016,
`https://computerhistory.org/blog/community-memory-
`precedents-in-social-media-and-movements/
`Apple iBook G3/300 (Original/Clamshell) Specs, EveryMac.com,
`https://everymac.com/systems/apple/ibook/specs/ibook.html
`File History of U.S. Patent No. 9,489,690
`[RESERVED]
`U.S. Patent No. 6,029,141 (“Bezos”)
`U.S. Patent No. 5,345,501 (“Shelton”)
`U.S. Patent No. 8,787,933 file history
`
`1026
`
`1027
`
`1028
`1029
`1030
`1031
`1032
`
`1605307314
`
`viii
`
`Home Depot
`Ex. 1002 - Page 9
`
`

`

`670 PATENT LIST OF CLAIMS IN CONTENTION
`
`1a
`
`1b
`
`1c
`
`Claim Limitation
`1pre A method of providing product location information within a store, the
`method comprising the steps of:
`providing at least one information storage device including a database,
`wherein the at least one information storage device is configured to be
`at least indirectly in communication with at least one other device that
`includes at least one user interface, and wherein at least one of the at
`least one information storage device and the at least one other device
`with respect to which the at least one information storage device is
`configured to be at least indirectly in communication is or includes a
`mobile device,
`wherein the at least one information storage device includes both
`product location information and additional product-related
`information linking a product with another product in a cross-
`referential manner
`receiving a product location inquiry signal regarding the product, the
`product location inquiry signal being at least indirectly based upon a
`product location inquiry received by way of the at least one user
`interface
`processing the product location inquiry signal at a signal processing
`device to determine a processed product location inquiry signal
`querying the at least one information storage device to obtain portions
`of the product location information and additional product-related
`information in response to the processed product location inquiry
`signal
`providing a product location information signal that is at least
`indirectly responsive to the processed product location inquiry signal
`wherein the product location information signal is configured to
`enable, at least indirectly, a providing of an output signal at an output
`device as a response to the product location inquiry that includes
`location information concerning the product and also provides at least
`one suggestion related to the other product
`The method of claim 1, wherein the product location information
`signal is configured to enable, at least indirectly, the providing of the
`
`1d
`
`1e
`
`1f
`
`1g
`
`2
`
`1605307314
`
`ix
`
`Home Depot
`Ex. 1002 - Page 10
`
`

`

`4
`
`6
`
`7
`
`8
`
`9
`
`10
`
`12
`
`output signal at the least one user interface, which includes the output
`device in addition to an input device
`Claim 4. The method of claim 2, wherein the at least one user interface
`includes a mobile user interface.
`Claim 6. The method of claim 4, wherein the product location
`information signal is configured to enable, at least indirectly, the at
`least one user interface to provide information concerning one or more
`products that are being specially promoted or that are located close by
`the at least one user interface.
`Claim 7. The method of claim 4, wherein the product location
`information signal is configured to enable, at least indirectly, the
`providing of the output signal so that the output signal provides at least
`one further suggestion to a customer in accordance with one or more
`customer preferences.
`Claim 8. The method of claim 4, wherein the product location
`information signal is configured to enable, at least indirectly, the at
`least one user interface to provide further additional product-related
`information, and wherein the further additional product-related
`information includes at least one of: product promotion information; a
`current stock of the product; a price of the product; a presence or
`absence of the product within the store; a time at which the product
`should be available at the store if the product is currently absent from
`the store; and an alternate way of obtaining the product if the product
`is currently absent from the store.
`Claim 9. The method of claim 8, wherein the further additional
`product-related information relates to either the time at which the
`product should be available at the store if the product is currently
`absent from the store, or the alternate way of obtaining the product if
`the product is currently absent from the store.
`Claim 10. The method of claim 8, wherein the further additional
`product-related information relates to either the current stock of the
`product, or the presence or absence of the product within the store.
`Claim 12. The method of claim 4, further comprising one or both of:
`receiving an additional inquiry signal that relates to something other
`than a product location-type inquiry; or obtaining identification
`
`1605307314
`
`x
`
`Home Depot
`Ex. 1002 - Page 11
`
`

`

`14
`
`information concerning the customer that at least in part allows for the
`providing of an additional suggestion to the customer.
`Claim 14. The method of claim 1, wherein either (a) the mobile device
`is able to provide at least some of the information to the at least one
`user interface, or (b) at least a first one of the at least one user interface
`is in wireless communication with either a central hub or at least a
`second one of the at least one user interface, or (c) one or more words
`associated with the product location inquiry received by way of the at
`least one user interface are determined by way of a voice recognition
`process.
`
`1605307314
`
`xi
`
`Home Depot
`Ex. 1002 - Page 12
`
`

`

`1.
`
`I, Dr. Don Turnbull, have been engaged by Home Depot U.S.A, Inc.
`
`as an independent expert in this action. I expect to testify concerning the subjects
`
`outlined in this report.
`
`2.
`
`As part of that engagement, I have been asked to provide analysis and
`
`expert opinions on U.S. Pat. No. 9,990,670 (the “670 Patent”).
`
`3.
`
`I am being compensated for the time I have spent on this matter at the
`
`rate of $775 per hour. My compensation does not depend in any way upon the
`
`outcome of this proceeding.
`
`4.
`
`In reaching the conclusions described herein, I have considered the
`
`documents and materials identified in the Index of Exhibits that is attached to this
`
`report, in addition to any materials cited in this report. My opinions are also based
`
`upon my education, training, research, knowledge, and personal and professional
`
`experience.
`
`5.
`
`Based on my review of the 670 Patent and its prosecution history, the
`
`other materials I have considered, and my knowledge and experience, my opinions
`
`are as follows:
`
` Claims 1, 2, 4, 6-10, 12, and 14 are unpatentable due to obvious based
`
`on Shanman in view of the knowledge of a POSITA
`
` Claims 1, 2, 4, 6-10, 12, and 14 are unpatentable due to obvious based
`
`on Ogasawara in view of Beach
`
`1605307314
`
`1
`
`Home Depot
`Ex. 1002 - Page 13
`
`

`

` Claim 9 is unpatentable due to obvious based on Ogasawara and
`
`Beach in further view of Shanman
`
`I.
`
`BACKGROUND AND QUALIFICATIONS
`
`A.
`
`6.
`
`Qualifications
`
`A full description of my educational background, professional
`
`achievements, qualifications, and publications in the past 30+ years are set forth
`
`more fully in my curriculum vitae, which is attached to this Declaration as Exhibit
`
`A. Here, I provide a brief summary of my background and qualifications.
`
`7.
`
`I am an accomplished researcher and creator of innovative,
`
`patented and trade-secreted technologies related to information retrieval, e-
`
`commerce, personalization, mobile interfaces, behavioral modeling, content
`
`organization, and analytics. I am also the author of numerous academic
`
`publications, including: a textbook on Web-based information seeking (i.e., how
`
`people search and browse the Internet) and knowledge work (i.e., how technology
`
`enables people to create and work together); articles on human-computer interaction
`
`design, personalization for Web information retrieval and recommender systems;
`
`and numerous definitive works on information architecture methodologies,
`
`software interface design, and software development.
`
`8.
`
`My experience includes helping software companies, from small
`
`startups to large corporations, create new technologies and applications. To advise
`
`1605307314
`
`2
`
`Home Depot
`Ex. 1002 - Page 14
`
`

`

`these companies, I research and monitor academic and industry technology
`
`developments to keep up-to-date regarding advances in the field. I am also aware
`
`of the history of software development from my professional and academic
`
`experience over the past 30 years.
`
`9.
`
`I also have experience and knowledge working with graphical user
`
`interfaces, such as on mobile apps, and their integration into assisting users in
`
`their environment. I have also taught a number of software design and development
`
`courses at the graduate level including mobile systems, networked multimedia,
`
`interaction design, the semantic web and data analytics among others. In particular,
`
`I have been heavily involved with computing systems that collect data on user
`
`behavior (such as selecting content in an interactive computing environment) and
`
`use that data to make browsing and searching information easier. I have presented
`
`at numerous industry and academic conferences on information systems
`
`development, mobile technologies, search systems, and personalization, including
`
`on data collection and evaluation of user interactions and analytics.
`
`10.
`
`I received my undergraduate degree at the University of Texas at
`
`Arlington in 1988, with an emphasis in computer science. Upon graduating, I took
`
`a position at a small software company in Dallas that developed expert systems
`
`software that automated the processing and using digital documents for either print
`
`or screen, based on a sets of programmatic rules and heuristics.
`
`1605307314
`
`3
`
`Home Depot
`Ex. 1002 - Page 15
`
`

`

`11.
`
`In 1993, I moved to Atlanta to work in an emerging, exciting area of
`
`software called CASE (Computer Aided Software Engineering). I designed and
`
`programmed software that helped other programmers build their own software
`
`applications. Since I had researched and built document-oriented applications, and
`
`had an understanding of hypermedia and hypertext, I also worked on specific
`
`applications that helped people build more modern graphical user interface (GUI)
`
`applications that could run on Windows or Macintosh systems, and still connect to
`
`traditional corporate computer systems, such as mainframes and database servers. I
`
`also designed document authoring and editing applications to compile interactive,
`
`multimedia hypertext systems within the GUI operating systems. These systems
`
`provided software users interactive, pop-up help in a graphical browser window
`
`that included hyperlinks and a search function, much like the emerging Web
`
`browser applications and interfaces. As part of my work, I used and prototyped
`
`applications in the first World Wide Web browser on the NeXT Computer. The
`
`NeXT Web browser, the first Web browser, provided the framework and interface
`
`for what we use now as more advanced Web browsers, and displayed documents
`
`as their authors wanted them, with a WYSIWYG interface as well as links to other
`
`documents that could be hosted anywhere over the world accessible via the
`
`internet.
`
`1605307314
`
`4
`
`Home Depot
`Ex. 1002 - Page 16
`
`

`

`12.
`
`I returned to graduate school in 1994 at the Georgia Institute of
`
`Technology (“Georgia Tech”) in a new graduate-only research department that
`
`focused on Internet technologies. This was when the Internet had started to become
`
`very popular, and my own work with hypertext, graphical interactive Web browsers
`
`and application programming had already prepared me to move in this research
`
`direction. As a graduate student at Georgia Tech, I worked on several projects that
`
`focused on hypermedia design and the Internet. In late 1994, I configured and ran a
`
`very early Web site (approximately the 8500th site on the Web). This early Web
`
`site with Web pages programmed to work as an interactive survey, which utilized a
`
`database system and email-processing application working in concert with the
`
`interactive Web browser. I also worked on a new kind of automated, agent-like
`
`Internet search tool, which (while not ready for commercial use) illustrated many
`
`ideas related to smarter Internet searching and understanding user preferences to
`
`present recommended resources. In early 1995, I also worked with a research team
`
`at Georgia Tech that developed a modified NCSA Mosaic Web browser that
`
`offered a Graphic History View of browsing history in a separate window, which
`
`featured a tree-like structure of the links followed on Web pages, including
`
`thumbnail graphics of each Web page in the background.
`
`13. My master’s thesis at Georgia Tech focused on a method and
`
`system to automatically generate large interactive hypermedia Web through stored
`
`1605307314
`
`5
`
`Home Depot
`Ex. 1002 - Page 17
`
`

`

`multimedia Web content in a database, which could be used to “publish” a subset
`
`of pages onto the Web, based on a query or filtering criteria. In 1995, I earned an
`
`M.S. in Information Design and Technology from the Georgia Institute of
`
`Technology with my thesis, entitled “Object- Oriented Information Development:
`
`A Methodology and System for Large-Scale Hypertext Documents.”
`
`14. After Georgia Tech, I went to IBM’s first U.S. Internet group, where I
`
`was a Lead Technical Architect and worked on several related projects that dealt
`
`with graphical user interfaces, interactive multimedia and networked systems using
`
`Internet technology. I also contributed to designs and advised on numerous other
`
`ongoing Internet-focused projects at IBM, including Web site development tools
`
`for eCommerce small business Web sites, large enterprise (intranet) Web sites
`
`including portals, as well as the foundations for a Web site usability practice at
`
`IBM to evaluate Web use of IBM software and server-based applications.
`
`15.
`
`In 1997, pursuant to my doctoral studies at the University of Toronto,
`
`I researched I

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket