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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`——————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`——————————
`
`GOOGLE LLC,
`
`Petitioner,
`
`v.
`
`UNILOC 2017 LLC,
`
`Patent Owner.
`
`——————————
`
`Case No. IPR2020-00755
`U.S. Patent No. 6,366,908
`Filing Date: December 30, 1999
`Issue Date: April 2, 2002
`
`
`
`DECLARATION OF BERNARD J. JANSEN, PH.D.
`
`(Exhibit 1003)
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`
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`Page 1 of 212
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`GOOGLE EXHIBIT 1003
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`

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`Declaration of Dr. Bernard. J. Jansen
`
`U.S. Patent No. 6,366,908
`
`TABLE OF CONTENT
`
`I.
`Introduction ...................................................................................................... 1
`Qualifications ................................................................................................... 2
`II.
`Scope of Opinion ............................................................................................. 5
`III.
`IV. Materials Reviewed and Considered ............................................................... 6
`V.
`LEGAL STANDARDS FOR PATENTABILITY .......................................... 6
`A. Anticipation Analysis: 35 U.S.C. § 102 .................................................. 8
`B. Obviousness Analysis: 35 U.S.C. § 103 .................................................. 8
`C. Step-Plus-Function Claims: 35 U.S.C. § 112, paragraph 6 ................... 13
`State of the Art Prior to the ’908 Patent ........................................................ 14
`VI.
`VII. Overview of Prior Art .................................................................................... 19
`A. Overview of Braden-Harder ................................................................. 19
`B. Overview of Heidorn ............................................................................. 25
`C. Overview of Messerly ............................................................................ 30
`D. Grossman ............................................................................................... 36
`E. Kucera .................................................................................................... 39
`F. Miller ...................................................................................................... 40
`VIII. Overview of the ’908 Patent and Prosecution History .................................. 41
`IX.
`Level of Ordinary Skill in the Art ................................................................. 48
`X.
`Claim Construction ........................................................................................ 50
`XI.
`Summary of My Opinions ............................................................................. 59
`XII. Ground 1: Claims 6-12 Would Have Been Obvious over Braden-
`Harder (incorporating Heidorn and Messerly) and in view of
`
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`Declaration of Dr. Bernard. J. Jansen
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`
`U.S. Patent No. 6,366,908
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`Grossman; Ground 2: Claims 6-12 Would Have Been Obvious over
`Braden-Harder in view of Heidorn, Messerly, and Grossman ..................... 60
`A.
`Independent claim 6 ............................................................................... 61
`B. Claim 7 ................................................................................................... 98
`C. Claim 8 ................................................................................................. 102
`D. Claim 9 ................................................................................................. 107
`E. Claim 10 ............................................................................................... 109
`F. Claim 11 ............................................................................................... 119
`G. Claim 12 ............................................................................................... 125
`XIII. Ground 3: Claim 7-9 Would Have Been Obvious Over Braden-
`Harder in View of Grossman, as Set Forth in Ground 1, and Further
`in View of Kucera; Ground 4: Claim 7-9 Would Have Been Obvious
`Over Braden-Harder in View of Heidorn, Messerly, and Grossman,
`as Set Forth in Ground 2, and Further in View of Kucera .......................... 127
`A. Claim 7 ................................................................................................. 127
`B. Claims 8-9 ............................................................................................ 132
`XIV. Ground 5: Claim 9 Would Have Been Obvious Over Braden-Harder
`in View of Grossman, as Set Forth in Ground 1, and Further in View
`of Miller; Ground 6: Claim 9 Would Have Been Obvious Over
`Braden-Harder in View of Heidorn, Messerly, and Grossman, as Set
`Forth in Ground 2, and Further in View of Miller ...................................... 133
`A. Claim 9 ................................................................................................. 133
`XV. Ground 7: Claim 9 Would Have Been Obvious Over Braden-Harder
`in View of Grossman and Kucera, as Set Forth in Ground 3, and
`Further in View of Miller; Ground 8: Claim 9 Would Have Been
`Obvious Over Braden-Harder in View of Heidorn, Messerly,
`Grossman, and Kucera, as Set Forth in Ground 4, and Further in View
`of Miller ....................................................................................................... 138
`A. Claim 9 ................................................................................................. 138
`
`ii
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`XVI. Conclusion ................................................................................................... 140
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`U.S. Patent No. 6,366,908
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`iii
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`Declaration of Dr. Bernard. J. Jansen
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`I, Dr. Jim Jansen, declare as follows:
`
`U.S. Patent No. 6,366,908
`
`I.
`
`Introduction
`1. My name is Bernard J. (Jim) Jansen, and I have been retained by
`
`Finnegan, Henderson, Farabow, Garrett & Dunner, LLP, counsel for Google LLC
`
`(“Google”), as an expert witness in the case GOOGLE LLC v. UNILOC 2017
`
`LLC, Case No. IPR2020-00755 with respect to U.S. Patent No. 6,366,908.
`
`2. My opinions are based on my years of education, research, and
`
`experience, as well as my investigation and study of relevant materials. The
`
`materials that I have studied for this declaration include the documents identified
`
`in Appendix B of this declaration.
`
`3.
`
`I may rely upon these materials, my knowledge and experience,
`
`and/or additional materials to rebut arguments raised by the patent owner. Further,
`
`I may also consider additional documents and information in forming any
`
`necessary opinions, including documents that may not yet have been provided to
`
`me.
`
`4. My analysis of the materials produced in this investigation is ongoing,
`
`and I will continue to review any new material as it is provided. This declaration
`
`represents only those opinions I have formed to date. I reserve the right to revise,
`
`supplement, and/or amend my opinions stated herein based on new information
`
`and my continuing analysis of the materials already provided.
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`1
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`Declaration of Dr. Bernard. J. Jansen
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`
`U.S. Patent No. 6,366,908
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`5.
`
`I understand that the Petition for Inter Partes Review involves U.S.
`
`Patent No. 6,366,908 (“the ’908 patent”), Ex. 1001.1
`
`6.
`
`I am being compensated on a per hour basis for my time spent
`
`working on issues in this case. My compensation does not depend on the outcome
`
`of this matter or the opinions I express.
`
`II. Qualifications
`I am currently a Principal Scientist in the Social Computing Group at
`7.
`
`Qatar Computing Research Institute (QCRI) at Hamad Bin Khalifa University
`
`(HBKU), Doha, Qatar.
`
`8.
`
`I am also an adjunct professor at the College of Information Sciences
`
`and Technology (IST) at The Pennsylvania State University (Penn State
`
`University), University Park, Pennsylvania, since 2017, where I have been
`
`employed since 2001. I was a tenure-track professor at Penn State from 2002
`
`through 2016, departing as a tenured full professor in 2017 to join my current
`
`organization.
`
`9.
`
`Prior to my employment at the Penn State University, I was a Lecturer
`
`in the Computer Science Program at the University of Maryland (Asian Division)
`
`
`All references to “Ex. __” in this declaration refer to the Google Exhibits
`
`1
`
`concurrently filed with Google’s petition.
`
`2
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`Declaration of Dr. Bernard. J. Jansen
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`for one year, and before that, I was an Assistant Professor and Lecturer in the
`
`U.S. Patent No. 6,366,908
`
`Department of Electrical Engineering and Computer Science at the United States
`
`Military Academy (West Point), for three years.
`
`10.
`
`I was a Senior Fellow at the Pew Internet & American Life Project,
`
`which is part of the Pew Research Center, from 2010 to 2012.
`
`11.
`
`I received my Master’s degree in Computer Science from Texas A&M
`
`University in 1996. As part of my Master’s program, I designed and coded a text-
`
`based search engine.
`
`12.
`
`I received my Ph.D. in Computer Science from Texas A&M
`
`University in 1999, where I developed a software interface application for Web
`
`search engines and implemented it on the Gigabyte search engine. In subsequent
`
`research, I have worked with the Microsoft Internet Information Services (IIS) and
`
`Verity commercial searching systems.
`
`13. Much of my research has been in the area of information searching,
`
`where I have study how people interact with searching systems. During this
`
`research, I have conduct query log analysis to understand how people formulate
`
`searches, how search engine response to those queries, and how people then
`
`reformulate their search.
`
`14.
`
`I have extensive research, teaching, and industry experience in the
`
`areas of information indexing and retrieval, along with related areas.
`
`3
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`U.S. Patent No. 6,366,908
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`15. My professional experience includes more than twenty years of
`
`practice in the U.S. military, working primarily in a variety of communication
`
`related technologies. Among other projects, this included experience in designing a
`
`large institutional website and performing search engine optimization techniques to
`
`improve search engine rankings, increase website traffic, increase the number of
`
`unique visitors to the website, and improve the website experience for customers.
`
`16.
`
`I have authored more than 350 academic publications, most focusing
`
`on the areas of information searching, Web data, Web search, Web analytics, and
`
`other aspects of search engines and searching.
`
`17.
`
`I am the editor-in-chief of Information Processing & Management,
`
`published by Elsevier, one of the leading journals in the field of information
`
`science. In addition, I serve on editorial boards of seven other journals and was
`
`previously the editor-in-chief of the journal, Internet Research, a top ranked journal
`
`in the web science domain.
`
`18.
`
`I have visited and presented research talks at many of the world’s
`
`major search engine companies, including Google, Yahoo!, Yandex, and NAVER.
`
`I have also worked with or given research presentations at other smaller search-
`
`engine companies or search agencies.
`
`19.
`
`I have authored, co-authored, or co-edited four books, including Web
`
`Search: Public Searching of the Web, Handbook of Research on Search Log
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`4
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`Analysis, Understanding User – Web Interactions Via Web Analytics, and
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`U.S. Patent No. 6,366,908
`
`Understanding Sponsored Search: Coverage of the Core Elements of Keyword
`
`Advertising. My fields of professional interest include web searching, information
`
`searching, and keyword advertising. In the course of my career, I have worked
`
`with a variety of search engines and information searching applications.
`
`20. Additional details about my employment history, fields of expertise,
`
`and publications are further included in my curriculum vitae, attached herewith as
`
`Appendix A.
`
`III. Scope of Opinion
`I have been asked to provide my opinions regarding whether claims 6-
`21.
`
`12 of the ’908 patent would have been unpatentable to a person of ordinary skill in
`
`the art (POSITA) as of June 28, 1999, or somewhat before June 28, 1999 in view
`
`of:
`
`• U.S. Patent No. 5,933,822 to Braden-Harder et al. (Ex. 1020, “Braden-
`Harder”);
`• U.S. Patent Application No. 08/674,610 to Heidorn et al. (Ex. 1021,
`“Heidorn patent application”);
`• U.S. Patent No. 5,966,686 to Heidorn et al. (Ex. 1022, “Heidorn”);
`• U.S. Patent Application No. 08/886,814 to Messerly et al. (Ex. 1024,
`“Messerly patent application”);
`• U.S. Patent No. 6,076,051 to Messerly et al. (Ex. 1025, “Messerly”);
`
`5
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`Declaration of Dr. Bernard. J. Jansen
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`U.S. Patent No. 6,366,908
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`• David A. Grossman & Ophir Frieder, Information Retrieval: Algorithms
`and Heuristics, Kluwer International Series in Engineering and Computer
`Science (Kluwer Academic Publishers, Springer Science+Business
`Media New York prtg.) (1st ed. 1998) (Ex. 1010, “Grossman”);
`• U.S. Patent No. 4,868,750 to Kucera et al. (Ex. 1011, “Kucera”); and
`• George A. Miller, Richard Beckwith, Christiane Fellbaum, Derek Gross
`& Katherine J. Miller, Introduction to WordNet: An On-line Lexical
`Database, International Journal of Lexicography, Vol. 3 No. 4, 235-244
`(1990) (“Miller”).
`
`22. This declaration, including the exhibits hereto, sets forth my opinion
`
`on this topic.
`
`IV. Materials Reviewed and Considered
`In connection with my work on this matter, I have reviewed and
`23.
`
`considered the materials identified in Appendix B.
`
`24.
`
`I also have relied on my academic and professional experience in
`
`reaching the opinions expressed in this declaration.
`
`V. LEGAL STANDARDS FOR PATENTABILITY
`I have been asked to provide my opinions as to whether the asserted
`25.
`
`art teaches or renders obvious the limitations of claims 6-12 of the ’908 patent
`
`from the perspective of a person of ordinary skill in the art in the 1999 timeframe.
`
`26.
`
`I am a computer scientist and researcher by training and profession.
`
`The opinions I express in this declaration involve the application of my technical
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`knowledge and experience to the evaluation of certain prior art with respect to the
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`U.S. Patent No. 6,366,908
`
`’908 patent.
`
`27. My opinions are also formed by my understanding of the relevant law.
`
`I am not an attorney. For purposes of this declaration, I have been informed about
`
`certain aspects of the law as it relates to my opinions.
`
`28.
`
`I understand that for an invention claimed in a patent to be found
`
`patentable, it must be (among other things) new and not obvious based on what
`
`was known before the invention was made.
`
`29.
`
`I understand that the information that is used to evaluate whether an
`
`invention was new and not obvious when made is generally referred to as “prior
`
`art.” I understand that the prior art includes patents and printed publications that
`
`existed before the earliest filing date of the patent (which I have been informed is
`
`called the “effective filing date”). I also understand that a patent or published
`
`patent application is prior art if it was filed before the effective filing date of the
`
`claimed invention and that a printed publication is prior art if it was publicly
`
`available before the effective filing date.
`
`30.
`
`I understand that in this inter partes review proceeding, the
`
`information that may be evaluated is limited to patents and printed publications.
`
`My analysis, which is set out in detail below, compares the claims to printed
`
`publications that I understand are prior art to the claims.
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`Declaration of Dr. Bernard. J. Jansen
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`U.S. Patent No. 6,366,908
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`A. Anticipation Analysis: 35 U.S.C. § 102
`I understand that a person cannot obtain a patent on an invention if the
`31.
`
`prior art included that invention. If an invention is not new, then the invention has
`
`been “anticipated” by the prior art. A claim is “anticipated” by the prior art if each
`
`and every limitation of the claim is disclosed, expressly or inherently, in a single
`
`item of prior art, from which a person of ordinary skill in the art could practice the
`
`invention. I have applied this standard in my evaluation of whether claims 6-12 of
`
`the ’908 patent are anticipated in light of the prior art.
`
`B. Obviousness Analysis: 35 U.S.C. § 103
`It is my understanding that a claim is unpatentable if the claimed
`32.
`
`subject matter as a whole would have been obvious to a person of ordinary skill in
`
`the art at the time of the alleged invention. I also understand that an obviousness
`
`analysis takes into account the scope and content of the prior art, the differences
`
`between the claimed subject matter and the prior art, and the level of ordinary skill
`
`in the art at the time of the invention.
`
`33.
`
`I understand that a claimed invention is not patentable if it would have
`
`been “obvious” to a person of ordinary skill in the field of the invention at the time
`
`the invention was made. This means that even if all the requirements of a claim are
`
`not found in a single prior art reference, the claim is not patentable if the
`
`differences between the subject matter in the prior art and the subject matter in the
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`claim would have been obvious to a person of ordinary skill in the art at the time
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`U.S. Patent No. 6,366,908
`
`the application was filed.
`
`34.
`
`In determining the scope and content of the prior art, it is my
`
`understanding that a reference is considered relevant prior art to the ’908 patent if
`
`it falls within the field of the inventor’s endeavor. In addition, a reference is prior
`
`art if it is reasonably pertinent to the particular problem with which the inventor
`
`was involved. A reference is reasonably pertinent if it logically would have
`
`commended itself to an inventor’s attention in considering his problem. Thus, if a
`
`reference relates to the same problem as the claimed invention, that supports the
`
`use of the reference as prior art in an obviousness analysis.
`
`35.
`
`In my opinion, the prior art references identified herein seek to solve
`
`the same types of problems as the ’908 patent and logically would have
`
`commended themselves to an inventor’s attention considering the problems of the
`
`’908 patent. In particular, the ’908 patent and the cited prior art concern techniques
`
`and systems for natural language processing and information retrieval, and their
`
`associated challenges.
`
`36.
`
`I understand that a determination as to whether a claim would have
`
`been obvious should be based on four factors (though not necessarily in the
`
`following order): (i) the level of ordinary skill in the art at the time the application
`
`was filed; (ii) the scope and content of the prior art; (iii) the differences between
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`the claimed invention and the prior art; and (iv) any objective factors indicating
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`U.S. Patent No. 6,366,908
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`obviousness or non-obviousness that may exist in a particular case.
`
`37.
`
`It is my understanding that an obviousness analysis cannot be based
`
`on hindsight, but it must be done using the perspective of a person of ordinary skill
`
`in the relevant art as of the effective filing date of the patent claim.
`
`38.
`
`I understand the objective factors indicating obviousness or
`
`nonobviousness may include: commercial success of products covered by the
`
`patent claims; a long-felt but unaddressed need for the invention; failed attempts
`
`by others to make the invention; copying of the invention by others in the field;
`
`expressions of surprise by experts and those skilled in the art at the making of the
`
`invention; and the patentee having proceeded contrary to the accepted wisdom of
`
`the prior art. I also understand that any of this evidence must be specifically
`
`connected to the invention rather than associated with the prior art or with
`
`marketing or other efforts to promote an invention.
`
`39.
`
`I understand that the teachings of two or more prior art references may
`
`be combined in the manner disclosed in the claim if such a combination would
`
`have been obvious to one having ordinary skill in the art at the effective filing date.
`
`In determining whether a combination would have been obvious, I understand that
`
`the following exemplary rationales may support a conclusion of obviousness:
`
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`U.S. Patent No. 6,366,908
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`• Combining prior art elements according to known methods to yield
`
`predictable results;
`
`• Simple substitution of one known element for another to obtain
`
`predictable results;
`
`• Use of a known technique to improve similar devices (methods, or
`
`products) in the same way;
`
`• Applying a known technique to a known device (method, or product)
`
`ready for improvement to yield predictable results;
`
`• “Obvious to try”—choosing from a finite number of identified,
`
`predictable solutions, with a reasonable expectation of success;
`
`• Known work in one field of endeavor may prompt variations of it for
`
`use in either the same field or a different one based on design
`
`incentives or other market forces if the variations are predictable to a
`
`person of ordinary skill in the art; and
`
`• Some teaching, suggestion, or motivation in the prior art that would
`
`have led a person of ordinary skill to modify the prior art reference or
`
`to combine prior art reference teachings to arrive at the claimed
`
`invention.
`
`40.
`
`I understand that the obviousness analysis need not seek out precise
`
`teachings directed to the specific subject matter of the challenged claim, but
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`instead can take account of the ordinary innovation and experimentation in the
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`U.S. Patent No. 6,366,908
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`relevant field that does no more than yield predictable results.
`
`41.
`
`I understand that, in assessing whether there was an apparent reason to
`
`modify or combine known elements as claimed, it may be necessary to look to
`
`interrelated teachings of multiple patents or prior art references, the effects of
`
`commercial demands, and the background knowledge of a person of ordinary skill
`
`in the art. I further understand that any motivation that would have applied to a
`
`person of ordinary skill in the art, including motivation from common sense or
`
`derived from the problem to be solved, is sufficient to explain why references
`
`would have been combined.
`
`42.
`
`I understand that modifications and combinations suggested by
`
`common sense are important and should be considered. Common sense suggests
`
`that familiar items can have obvious uses beyond the particular application being
`
`described in a prior art reference, that if something can be done once it would be
`
`obvious to do it multiple times, and that in many cases a person of ordinary skill in
`
`the art can fit the teachings of multiple patents together in an obvious manner to
`
`address a particular problem. The prior art does not need to be directed to solving
`
`the same problem that is addressed in the patent.
`
`43.
`
`I understand that a person of ordinary skill in the art is also a person
`
`of ordinary creativity. In many fields, it may be that there is little discussion of
`
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`obvious techniques, modifications, and combinations, and it may be the case that
`
`U.S. Patent No. 6,366,908
`
`market demand will drive a new design, rather than scientific research or literature.
`
`When there is market pressure or design need to solve a particular problem, and
`
`there are a finite number of identified, predictable solutions, a person of ordinary
`
`skill has a good reason to employ the known options. If this leads to the expected
`
`success, then it is likely the product of ordinary skill and common sense as
`
`opposed to patentable innovation. I understand that if a combination was obvious
`
`to try, that may show that it was obvious and therefore unpatentable. That a
`
`particular combination of prior art elements was obvious to try suggests that the
`
`combination was obvious even if no one made the combination.
`
`C. Step-Plus-Function Claims: 35 U.S.C. § 112, paragraph 6
`44. Counsel for Petitioner has informed me that for step-plus-function
`
`limitations, a prior art reference or combination of references must disclose the
`
`identical function in the claim limitation and must disclose a structure that
`
`performs the function that is either identical to or the equivalent of the structure in
`
`the specification of the challenged patent that performs the claimed function. I
`
`understand that a structure is equivalent if it performs the identical function in
`
`substantially the same way to achieve substantially the same result as the claim
`
`limitation at issue.
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`VI. State of the Art Prior to the ’908 Patent
`45. Natural language processing (NLP) is a subfield of linguistics,
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`U.S. Patent No. 6,366,908
`
`computer science, information engineering, and artificial intelligence, concerned
`
`with enabling computers to understand and process human (i.e., natural) languages.
`
`46. The history of NLP generally started in the late 1940s. During this
`
`early phase, the work mainly focused on machine translation (MT). Ex. 1031,
`
`Jones, 2. As early as 1958, language processing was already linked with
`
`information retrieval, and work was done in many aspects of NLP, including
`
`morphology, syntax, and semantics. Ex. 1031, Jones, 2. Due to the need to resolve
`
`syntactic and semantic ambiguity, much of the NLP research done in this period
`
`was focused on syntax or semantic processing.
`
`47. Beginning in the late 1960s to late 1970s, much of the NLP work was
`
`influenced by artificial intelligence with “much more emphasis on world
`
`knowledge and on its role in the construction and manipulation of meaning
`
`representations.” Ex. 1031, Jones, 4.
`
`48. Then from the late 1970s to late 1980s, the NLP work, moved towards
`
`the use of logic for knowledge representation and reasoning, stimulated by the
`
`development of grammatical theory. This phase of NLP can be described as the
`
`grammatico-logical phase, and the NLP work was oriented towards the
`
`development of grammatical theories and parsing algorithms. The processing
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`paradigm was syntax-driven to process language into logical forms. Ex. 1031,
`
`U.S. Patent No. 6,366,908
`
`Jones, 6. It was also during this period that various practical tools, were developed,
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`such as parsers and database systems. Ex. 1031, Jones, 7. Other NLP researches
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`include word sense disambiguation, statistical NLP, machine-readable dictionaries
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`and lexicons, etc. Ex. 1031, Jones, 7.
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`49. By the 1990s, the lexicalist approach to grammar in the 1980s became
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`the main trend. The use of lexicon was almost standard practice, as well as the use
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`of parsers with semantic rules for delivering logical forms. Ex. 1031, Jones, 7.
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`During this phase of NLP, there was also much progress with using statistical
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`methods to NLP and the development of processing tools, such as taggers. Ex.
`
`1031, Jones, 7.
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`50. All these advancements enable NLP with the ability to process various
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`ambiguities inherent in natural languages. Three types of ambiguities are relevant
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`to the understanding of prior art: lexical ambiguity, syntactic ambiguity, and
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`semantic ambiguity.
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`51. Lexical ambiguity is the ambiguity of a single word. With any
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`language, a word may have multiple meanings and, thus, multiple parts of speech.
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`For example, the word back may be treated as a noun, an adjective, or a verb.
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`52. Syntactic ambiguity refers to when a sentence may be parsed in
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`different ways. A classic example is: “Time flies like an arrow,” which may be
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`parsed in at least three possible meanings, as shown below:
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`
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`Divya Godayal, An introduction to part-of-speech tagging and the Hidden Markov
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`Model, (June 8, 2018), https://www.freecodecamp.org/news/an-introduction-to-
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`part-of-speech-tagging-and-the-hidden-markov-model-953d45338f24/; see also
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`Heidorn, 1:63-2:10.
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`53. Semantic ambiguity occurs when the meaning of the words
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`themselves can be misinterpreted. For example, the sentence “The car hit the pole
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`while it was moving” has semantic ambiguity because the word “it” is ambiguous
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`and, thus, the sentence can be interpreted either as “The car, while moving, hit the
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`pole” or as “The car hit the pole while the pole was moving.”
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`54. To resolve these ambiguities, NLP typically involves the following
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`phases or steps:
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`55. During the first morphological phase of NLP, the input text is broken
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`down into sets of tokens corresponding to paragraphs, sentences, and words. Often
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`the words are lemmatized into a single form for easy analysis and may be stemmed
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`to their root form. During this first phase, the words may also be identified by their
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`part of speech (i.e., part-of-speech tagging).
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`56. During the second syntax phase of NLP, the sentence is defined into a
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`structure that shows the syntactic relationships between the different words using a
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`syntax analyzer or parser. The purpose of this second phase is to conform the text
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`to the rules of formal grammar and to give the input text a structural representation.
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`57. Syntactic parsing also often includes part-of-speech tagging. The
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`oldest technique of tagging is rule-based part-of-speech tagging, which uses a
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`dictionary or lexicon for obtaining possible tags for tagging each word. Rule-based
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`part-of-speech tagging generally has two steps: in the first step, each word is
`
`assigned a list of potential parts-of-speech using a dictionary or lexicon; in the
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`second step, a set of disambiguation rules is used to resolve any lexical ambiguities
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`to obtain a single part-of-speech for each word. Other techniques of tagging, such
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`as stochastic part-of-speech tagging techniques, incorporate the use of frequency or
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`probability. These techniques were also well known by 1999. The output of the
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`syntax phase is a data structure generally in the form of a parse tree or other
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`hierarchical structure.
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`58. During the third semantic phase of NLP, the text is checked for
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`meaningfulness, and the various relationships between words (lexical items) are
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`analyzed. Often the output of this phase is a context-free representation of the input
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`sentence that translates the input sentence to logic (e.g., logical form).
`
`59. While NLP, as I explained above, deals with information processing,
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`information retrieval (IR) is concerned with retrieving information from document
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`repositories. In particular, IR deals with the organization, storage, and retrieval of
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`information, and assists users in finding the information they require.
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`60.
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`In every information retrieval system, the ability to identify a set of
`
`tokens to represent a body of text is an essential feature. At the most basic
`
`approach, IR systems use simple single token (keywords) to search documents. Ex.
`
`1010, Grossman, 125. But as early as 1960s, research has been undertaken to
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`employ NLP to understand user query. Ex. 1010, Grossman, 127. By 1999, more
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`“sophisticated approaches” to IR are based on NLP algorithms and include “part-
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`of-speech taggers, syntax parsers, and information extraction heuristics.” Ex. 1010,
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`Grossman, 125, 128.
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`VII. Overview of Prior Art
`A. Overview of Braden-Harder
`61. Braden-Harder is titled “Apparatus and Methods for an Information
`
`Retrieval System that Employs Natural Language Processing of Search Results to
`
`Improve Overall Precision.” Ex. 1020, Braden-Harder, Cover.
`
`62. Braden-Harder’s Abstract states:
`
`Apparatus and accompanying methods for an information
`retrieval system that utilizes natural language processing to
`process results retrieved by, for example, an information retrieval
`engine such as a conventional statistical-based search engine, in
`order to improve overal