GOOGLE'S INITIAL INVALIDITY CONTENTIONS
`
`EXHIBIT A-18
`Prior Art Reference: WordNet System ("WordNet")
`
`The WordNet system' ("WordNet") was publicly known and used at least by 1990 and therefore qualifies as prior art under at least 35
`U.S.C. §§ 102(a), (b), and (g) and/or 103 as to the asserted claims of U.S. Pat. No. 6,366,908 to Chong et al. ("the '908 Patent").
`WordNet, including any material incorporated by reference into WordNet, anticipates claims 6-12 (''the Asserted Claims") of the '908
`Patent under 35 U.S.C. § 102. WordNet also renders obvious the asserted claims under 35 U.S.C. § 103, alone based on the state of
`the art and/or in combination with one or more references identified in Google's Patent Local Rule 3-3 disclosure for the '908 Patent.2
`
`To the extent Plaintiff alleges that the WordNet does not disclose any particular limitation of Asserted Claims of the '908 Patent,
`either expressly or inherently, it would have been obvious to a person of ordinary skill in the art as of the priority date of the '908
`Patent to modify the WordNet and/or to combine the teachings of the WordNet with other prior art references, including but not
`limited to the present prior art references found in Exhibits A-1 to A-23 and the relevant section of charts for other prior art for the
`'908 Patent in a manner that would have rendered the Asserted Claims invalid as obvious.
`
`With respect to the obviousness of the Asserted Claims under 35 U.S.C. § 103, one or more of the principles enumerated by the
`United States Supreme Court in KSR v. Teleflex, 550 U.S. 398 (2007) apply, including: (a) combining various claimed elements
`
`1 WordNet includes all predecessor and subsequent versions of WordNet, and all products (commercial or otherwise) incorporating
`any of the aforementioned technologies, including the SMART system developed at Cornell University and IRENA system developed
`at University ofNijmegen Netherlands.
`2 Google notes that Uniloc appears in many instances to be pursuing overly broad constructions of various limitations of the asserted
`claims of the '908 Patent in an effort to piece together an infringement claim where none exists and to accuse a product that does not
`practice the claims. This claim chart takes into account Uniloc's overly broad construction of the claim limitations. Any assertion
`that a particular limitation is disclosed by a prior art reference or references may be based on Uniloc's apparent constructions and is
`not intended to be, and is not, an admission that such constructions are supportable or proper. Google is investigating this prior art and
`has not yet completed discovery from third parties, who may have relevant information concerning the prior art, including Princeton
`University, their affiliated companies, and/or their employees, and therefore, Google reserves the right to supplement this chart after
`additional discovery is received. To the extent that any of the prior art discloses the same or similar functionality or feature(s) of any
`of the accused products, Google reserves the right to argue that said feature or functionality does not practice any limitation of any of
`the Asserted Claims, and to argue, in the alternative, that if said feature or functionality is found to practice any limitation of any of
`the Asserted Claims of the '908 Patent, then the prior art reference teaches the limitation and that the claim is not patentable.
`
`A-18-1
`
`Google v. Uniloc, IPR2020-00755
`Uniloc's Exhibit 2002, page 1
`
`

`

`known in the prior art according to known methods to yield a predictable result; and/or (b) making a simple substitution of one or
`more known elements for another to obtain a predictable result; and/or ( c) using a known technique to improve a similar device or
`method in the same way; and/or ( d) applying a known technique to a known device or method ready for improvement to yield a
`predictable result; and/or ( e) choosing from a finite number of identified, predictable solutions with a reasonable expectation of
`success or, in other words, the solution was one which was "obvious to try"; and/or (f) a known work in one field of endeavor
`prompting variations of it for use either in the same field or a different field based on given design incentives or other market forces in
`which the variations were predictable to one of ordinary skill in the art; and/or (g) a teaching, suggestion, or motivation in the prior art
`that would have led one of ordinary skill in the art to modify the prior art reference or to combine the teachings of various prior art
`references to arrive at the claimed invention. It therefore would have been obvious to one of ordinary skill in the art to combine the
`disclosures of these references in accordance with the principles and rationales set forth above.
`
`The citations to portions of any reference in this chart are exemplary only. For example, a citation that refers to or discusses a figure
`or figure item should be understood to also incorporate by reference that figure and any additional descriptions of that figure as if set
`forth fully therein. Google reserves the right to rely on the entirety of the references cited in this chart to show that the Asserted
`Claims are invalid. Citations presented for one claim limitation are expressly incorporated by reference into all other limitations for
`that claim as well as all limitations of all claims on which that claim depends. Google also reserves the right to rely on additional
`citations or sources of evidence that also may be applicable, or that may become applicable in light of claim construction, changes in
`Uniloc's infringement contentions, and/or information obtained during discovery as the case progresses.
`
`At least the following documents3 describe the relevant functionality disclosed by WordNet:
`
`•
`
`Julio Gonzalo et al., Indexing with WordNet Synsets Can Improve Text Retrieval (1998) ("WordNet Indexing");
`
`• Sanda M. Harabagiu et al., WordNet 2 -A Morphologically and Semantically Enhanced Resource, in SIGLEX99:
`STANDARDIZING LEXICAL RESOURCES 1 (1999) ("WordNet 2");
`
`• Claudia Leacock et al., Using Corpus Statistics and WordNet Relations for Sense Identification, 24 COMPUTATIONAL
`LINGUISTICS, no. 1, at 147 (1998) ("WordNet Sense Identification");
`
`3 Each of the following documents describing WordNet also qualifies as a printed publication under 35 U.S.C. §§ 102(a), (b), and (g)
`and/or 103 in its own right. These documents, alone or in combination with each other, also anticipate or render obvious the Asserted
`Claims, as set forth in the chart below. One of ordinary skill in the art would have ample motivation to combine these documents
`because they all describe features and functionality of the same prior art system, WordNet.
`
`A-18-2
`
`Google v. Uniloc, IPR2020-00755
`Uniloc's Exhibit 2002, page 2
`
`

`

`• Stan Szpakowicz,A WordNet-basedAlgorithmfor Word Sense Disambiguation, in 95 IJCAI 1368 (1995); ("WordNet Word
`Sense Disambiguation");
`
`• Rila Mandala et al., The Use of WordNet in Information Retrieval, in USAGE OF WORD NET IN NATURAL LANGUAGE
`PROCESSING SYSTEMS (1998) ("WordNet Information Retrieval");
`
`• George A. Miller, Nouns in WordNet: A Lexical Inheritance System, 4 INT'LJ. OF LEXICOGRAPHY, no. 4, at 245 (1990)
`("WordNet Nouns");
`
`• George A. Miller, WordNet: A Lexical Database for English, 38 COMMCN'S OF THE ACM, no. 11, at 39 (1995) ("WordNet
`Lexical Database");
`
`• George A. Miller et al., Introduction to WordNet: An On-line Lexical Database, 3 INT'L J. OF LEXICOGRAPHY, no. 4, at 235
`(1990) ("Introduction to WordNet");
`
`• Philip Resnik, Disambiguating Noun Groupings with Respect to WordNet Senses, in NATURAL LANGUAGE PROCESSING USING
`VERY LARGE CORPORA 77 (1998) ("Disambiguating WordNet Senses");
`
`• R. Richardson et al., Using WordNet as a Knowledge Base for Measuring Semantic Similarity Between Words (1990)
`("WordNet Knowledge Base");
`
`• Sam Scott & Stan Matwin, Text Classification Using WordNet Hypernyms, USAGE OF WORDNET IN NATURAL LANGUAGE
`PROCESSING SYSTEMS (1998) ("WordNet Hypemyms");
`
`• Ellen M. Voorhees, Using WordNet to Disambiguate Word Senses for Text Retrieval, in PROC. OF THE 16THAANNuAL INT'L
`ACM SIG IR CoNF. ON RESEARCH AND DEVELOPMENT IN INFORMATION RETRIEVAL 171 (1993) ("Voorhees article");
`
`• WordNet, WIKIPEDIA, available at htt,ps://en.wikipedia.org/wiki/WordNet (last accessed Aug. 22, 2019) ("WordNet
`Wikipedia").
`
`This chart is based on a limited amount of publicly available information that was located regarding WordNet; other information
`describing WordNet also likely anticipates and/or renders obvious the Asserted Claims. Google is in the process of issuing a subpoena
`for additional information from Princeton University, their affiliated companies and/or their employees and reserve the right to
`supplement this chart after additional discovery is received.
`
`A-18-3
`
`Google v. Uniloc, IPR2020-00755
`Uniloc's Exhibit 2002, page 3
`
`

`

`
`
`pyaBed‘2002Waluxgs,co/1uN
`
`
`
`
`
`
`
`
`
`GSZ00-0Z07udl‘S011UN“AB[B005v-8I-V
`
`