`
`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
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`Home Depot
`Ex. 1002 - Page 1
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`
`
`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.
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`
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`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.
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`1605307314
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`Ex. 1002 - Page 3
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`
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`E.
`
`F.
`
`G.
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`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.
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`1605307314
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`Home Depot
`Ex. 1002 - Page 4
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`
`
`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.
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`1605307314
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`Ex. 1002 - Page 5
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`
`
`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
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`Ex. 1002 - Page 6
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`
`
`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
`
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`Ex. 1002 - Page 7
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`
`
`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
`
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`Home Depot
`Ex. 1002 - Page 8
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`
`
`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
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`Home Depot
`Ex. 1002 - Page 9
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`
`
`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
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`Home Depot
`Ex. 1002 - Page 10
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`
`
`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
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`Home Depot
`Ex. 1002 - Page 11
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`
`
`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.
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`
`
`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
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`Home Depot
`Ex. 1002 - Page 13
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`
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` 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
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`Home Depot
`Ex. 1002 - Page 14
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`
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`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.
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`Home Depot
`Ex. 1002 - Page 15
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`
`
`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
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`applications that helped people build more modern graphical user interface (GUI)
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`applications that could run on Windows or Macintosh systems, and still connect to
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`traditional corporate computer systems, such as mainframes and database servers. I
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`also designed document authoring and editing applications to compile interactive,
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`multimedia hypertext systems within the GUI operating systems. These systems
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`provided software users interactive, pop-up help in a graphical browser window
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`that included hyperlinks and a search function, much like the emerging Web
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`browser applications and interfaces. As part of my work, I used and prototyped
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`applications in the first World Wide Web browser on the NeXT Computer. The
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`NeXT Web browser, the first Web browser, provided the framework and interface
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`for what we use now as more advanced Web browsers, and displayed documents
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`as their authors wanted them, with a WYSIWYG interface as well as links to other
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`documents that could be hosted anywhere over the world accessible via the
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`internet.
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`12.
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`I returned to graduate school in 1994 at the Georgia Institute of
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`Technology (“Georgia Tech”) in a new graduate-only research department that
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`focused on Internet technologies. This was when the Internet had started to become
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`very popular, and my own work with hypertext, graphical interactive Web browsers
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`and application programming had already prepared me to move in this research
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`direction. As a graduate student at Georgia Tech, I worked on several projects that
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`focused on hypermedia design and the Internet. In late 1994, I configured and ran a
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`very early Web site (approximately the 8500th site on the Web). This early Web
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`site with Web pages programmed to work as an interactive survey, which utilized a
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`database system and email-processing application working in concert with the
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`interactive Web browser. I also worked on a new kind of automated, agent-like
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`Internet search tool, which (while not ready for commercial use) illustrated many
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`ideas related to smarter Internet searching and understanding user preferences to
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`present recommended resources. In early 1995, I also worked with a research team
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`at Georgia Tech that developed a modified NCSA Mosaic Web browser that
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`offered a Graphic History View of browsing history in a separate window, which
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`featured a tree-like structure of the links followed on Web pages, including
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`thumbnail graphics of each Web page in the background.
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`13. My master’s thesis at Georgia Tech focused on a method and
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`system to automatically generate large interactive hypermedia Web through stored
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`multimedia Web content in a database, which could be used to “publish” a subset
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`of pages onto the Web, based on a query or filtering criteria. In 1995, I earned an
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`M.S. in Information Design and Technology from the Georgia Institute of
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`Technology with my thesis, entitled “Object- Oriented Information Development:
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`A Methodology and System for Large-Scale Hypertext Documents.”
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`14. After Georgia Tech, I went to IBM’s first U.S. Internet group, where I
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`was a Lead Technical Architect and worked on several related projects that dealt
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`with graphical user interfaces, interactive multimedia and networked systems using
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`Internet technology. I also contributed to designs and advised on numerous other
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`ongoing Internet-focused projects at IBM, including Web site development tools
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`for eCommerce small business Web sites, large enterprise (intranet) Web sites
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`including portals, as well as the foundations for a Web site usability practice at
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`IBM to evaluate Web use of IBM software and server-based applications.
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`15.
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`In 1997, pursuant to my doctoral studies at the University of Toronto,
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`I researched I