`
`INTRODUCTION
`I.
`I, H. V. Jagadish, declare as follows:
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`1.
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`I am a Professor of Electrical Engineering and Computer Science at the
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`University of Michigan. Unless otherwise noted, I have personal knowledge of the matters
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`stated below, and, if called to testify, I could and would testify competently thereto.
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`2.
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`I have been retained by the Patent Owner (“PO”), Enfish, LLC in this matter.
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`This Declaration sets forth my opinions and the bases for those opinions regarding the
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`validity of the instituted claims of U.S. Patent No. 6,151,604 (the “ʼ604 Patent”).
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`II.
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`QUALIFICATIONS
`3.
`I am an independent consultant. All of my opinions stated in this report are
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`based on my own personal knowledge and professional judgment. In forming my opinions, I
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`have relied on my knowledge and experience in databases and software development
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`practices, and on the documents and information referenced in this Report. I am over 18
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`years of age and, if I am called upon to do so, I would be competent to testify as to the
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`matters set forth herein.
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`4.
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`I am the Bernard A. Galler Collegiate Professor of Electrical Engineering and
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`Computer Science at the University of Michigan. I am part of the database group and
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`director of the software systems laboratory at the University. As a professor, I teach
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`courses related to database management, the web, and data structures and algorithms.
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`5.
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`Attached hereto as Appendix A is a true and correct copy of my C.V.
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`6.
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`I obtained my Ph. D. from Stanford in 1985, and worked many years for
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`AT&T, where I eventually headed the database department. I began my work at the
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`University of Michigan in the fall of 1999, and also performed work at the University of
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`Illinois.
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`7.
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`I have published extensively, and am recognized as a leading researcher in
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`the area of databases. Certain academic search systems include me in the top (15) authors
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`in the database area
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`(http://academic.research.microsoft.com/?SearchDomain=2&SubDomain=18&entitytype=2).
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`Appendix B, attached. In particular, I am the most published author
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`(http://academic.research.microsoft.com/Conference/458/vldb-very-large-data-bases) in
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`VLDB (Very Large Databases), a leading forum for database research. Appendix C,
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`attached.
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`8.
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`9.
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`I am a Fellow of the ACM, and named inventor on 37 United States Patents.
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`I have testified as an expert at trial or by deposition within the preceding four
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`years, as set forth in Appendix D, attached. I have additionally worked as a consulting
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`expert in a number of cases.
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`III.
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`COMPENSATION
`10.
`I am being compensated at the rate of $520 per hour for my work as an
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`expert in this case. My compensation is not dependent on the content of my opinions or the
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`outcome of this case.
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`IV.
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`BACKGROUND ON THE INVENTION DESCRIBED AND CLAIMED IN THE ʼ604 PATENT
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`11.
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`A database is a structured collection of related data that describes some part
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`of the world. For example, databases can store all of the operational data needed to
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`describe a commercial market (e.g. Amazon.com) or scientific phenomena (e.g.
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`meteorological data).
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`12.
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`The information that describes and defines the organization of a database,
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`which is called metadata, must itself be expressly defined and stored. Such metadata might
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`include, for example, the minimum value permitted in a particular data field or the
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`relationship among two data fields.
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`13.
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`The stored data and the stored metadata are both used to meet a user’s
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`request for information, but these were typically stored separately, since they are used in
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`different ways: parts of the data, possibly combined and manipulated, are what are provide
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`to the user; the metadata provides important information about the data, and in particular is
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`central to determining how the system works with the data.
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`14. Different approaches exist to database design. In the mid-1990s, the
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`dominant database model enabled programmers and software users to perceive the data in
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`a database as existing in a collection of interrelated tables, even though the physical
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`storage of the data was far different.
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`15.
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`In this “relational” model, the overall database can consist of many different
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`tables, each table representing related types of data objects, and these tables are linked
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`together by matching data values in specified fields. Each table, in turn, consists of simple
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`rows and columns of data. However, the collection of tables in a database can be quite
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`large and the relationships between tables quite complex.
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`V.
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`PRIOR ART DATABASE TECHNOLOGIES LEFT UNMET MARKET NEEDS
`A.
`They required extensive up-front design and redesign efforts.
`16.
`Then-existing database technologies required a large, up-front investment in
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`design. To implement a database, designers would first need to analyze the properties of
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`and inter-relationships between real-world entities about which information is to be stored in
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`the database. Based on this analysis, they would have to develop a logical design for the
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`structure of the database. The database would then capture this design as metadata for the
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`database to be created.
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`17.
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`All of the steps described above requires a great deal of effort, which may be
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`affordable in situations where there is a great deal of structure that remains relatively
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`constant so that the one-time cost of design can provide benefits for an extended period.
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`All too often, such structure and stability are not available. In consequence, researchers of
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`the time faced the “problems” of managing “[d]ata whose schema is unclear, changes
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`without notice, or whose structure is irregular.” See Silberschatz et al, Database Research:
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`Achievements and Opportunities Into the 21st Century, Report of an NSF Workshop on the
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`Future of Database Systems Research, May 26-27, 1995, at p. 13.
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`18. Databases of this time also were not easy to redesign. Changes might need
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`to be made when, for example, relationships changed among the data being stored, or new
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`sources or types of data needed to be integrated. To make these changes, the system’s
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`data model would need to be analyzed and modified accordingly, possibly necessitating
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`modifications to the application programs relying on that data. The impacts of such
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`changes were often high costs, significant downtime, and major inconvenience.
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`They could not readily integrate multiple types and sources of data.
`B.
`19. Database technologies of the mid-1990s could not effectively manage new
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`and varied data types. As an illustration, a database system might store date information,
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`which is highly-structured, and also email, free-text information, and images.
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`20.
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`In describing this “problem” with data type management, researchers wrote,
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`“There must be a way for the programmer to construct the types appropriate for his or her
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`application.” Ex. 2008, p. 115.
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`21.
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`As new data types continued to evolve, then-existing systems were ill-
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`equipped to accommodate them, as most systems were focused on a fixed, non-extensible
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`set of supported data types.
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`22. Nor did the then-existing technologies support efficient integration and
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`management of many different data sources, as data at diverse locations might exist in
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`different formats, languages, and systems of measure. Numerous strategies to integrate
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`data sources were being developed, but these nascent efforts could not yet meet the
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`business need.
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`23.
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`Indeed, in 1995, researchers declared the need for “tools to integrate
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`heterogeneous information.” Ex. 2026, p. 13.
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`C.
`24.
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`They failed to help users overcome information overload.
`Then-existing
`technologies
`lacked an
`intuitive way
`to readily access
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`information of interest in a growing sea of data. Even years later, researchers were still
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`trying to cope with the “enormous quantity of data” that was becoming available. Ex. 2009,
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`p. 7. At the desktop level, for example, individual users were accumulating massive
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`numbers of electronic files, and this problem was exacerbated by the increasing flood of
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`email communications.
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`25.
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`Presenting this voluminous data to end-users in a quantity and format that
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`they could comprehend became increasingly challenging. A major problem was that
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`technologies of the time did not provide meaningful, user-editable linkages between related
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`pieces of information. Nor did those technologies allow users to effectively search across
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`the many different types of data.
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`VI.
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`INVENTIVE FEATURES THAT ENABLED ENFISH TO MEET MARKET NEEDS
`26.
`In my opinion, the Enfish patents claim at least four novel features that,
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`present a novel database design.
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`Single-table database
`2.
`In the claimed inventions, all of the database information is in one table,
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`27.
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`including indexes of the stored data that facilitate rapid searches, while rows in the table are
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`explicitly allowed to differ in their type (and hence structure). For example, all of the claims
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`require “a logical table, said logical table including…” (emphasis added).
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`28. Where the prior art required creation of a new table for new information
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`objects, the single table of Enfish merely requires a new record type. That single table is
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`sufficient because it can flexibly store any type of data defined by users. Maintenance and
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`searching are also easier across only a single table.
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`Metadata
`3.
`29. Metadata describes and defines a database, ensuring that the data, once
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`stored, can be used effectively. For example, in a traditional relational database, metadata
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`defines the logical structure such as the table names and column names and types. There,
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`metadata is stored in a separate set of system tables that are managed by the database,
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`not by the user.
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`30.
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`The big separation between data and metadata in traditional systems limits
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`their use, particularly in terms of flexibility. These limitations led many to propose ways of
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`integrating metadata, even years later. See, e.g., Ex. 2012, p. 625. Yet despite “numerous
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`proposals . . . in order to facilitate metadata management,” “a simple, elegant approach to
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`uniformly model and query both the data and the metadata [were] elusive.” Ex. 2013, pp. 1-
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`2.
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`31.
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`In contrast, Enfish metadata records are in the same table as the data
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`records. For example, claim 1 recites “at least one of said logical rows includes logical
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`column information defining each of said logical columns.” ‘604 patent cl. 1. These
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`metadata records allow users to introduce new types of rows and define new columns when
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`required. Users can freely add and manipulate them, making it very easy to introduce new
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`record types into the database.
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`Self-referentiality
`4.
`It is standard practice in relational databases for records to link related
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`32.
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`records (by using a common attribute value in specified fields). Usually, a record in one
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`table is linked to a record in a different table.
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`33.
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`In the Enfish design, all records are in a single table, so all links between
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`records are also within a single table. For example, to help link a row of metadata about a
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`column, claim 1 recites “at least one of said logical rows has an OlD equal to the OlD of a
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`corresponding one of said logical columns.” Ex. 1101, cl. 1.
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`34.
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`This design simplifies the maintenance of reciprocal references, which can be
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`challenging. More generally, the ability to define an unlimited number of links between data
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`items to model complex relationships among data closely emulates the way that humans
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`associate pieces of information.
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`35.
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`In traditional database systems, links are only to data records, not to
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`metadata records. But the Enfish design allows reference to metadata records, which
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`leads to great flexibility in handling new types of data records, and in making changes to the
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`design of the database as needs evolve. Cf. Ex. 2026, p. 13 (identifying challenges in
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`handling data schemas and structure). As an example, a column may be added or changed
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`simply by changing data in a metadata row that references that column.
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`Object identifiers
`5.
`The Enfish inventors provided object identifiers (OIDs) to allow users to freely
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`36.
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`represent relationships between any sets of data in the database. For example, claim 1
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`recites “each said logical row having an object identification number (OlD) to identify each
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`said logical row.” Ex. 1101, cl. 1.
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`37.
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`To this end, Enfish designed each row to represent an object, and used an
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`object identifier to reference the row. Since column definitions are also rows in the table,
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`column definitions also get object identifiers, making it easy to treat both rows and columns
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`as objects. This minimizes the user’s burden in using the database and in translating data
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`to and from external applications.
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`38.
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`Further, object identifiers enable a user to manipulate stored data without
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`having to rely on some unique field in the data itself (e.g., social security number). These
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`object identifiers associated with rows and columns are also natural means for one record to
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`reference another. Indeed, any relation can be represented using object-identifier links.
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`VII. MARKET SUCCESS OF ENFISH DUE TO ITS INVENTIVE FEATURES
`39.
`The Enfish products’ ability to support juggling large amounts of information,
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`handle new and varied types of data, and support efficient indexing and searching were a
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`direct result of Enfish’s patented inventions that put all data into a single table. They also
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`resulted from the including of metadata records that allowed users to introduce new types of
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`rows and define new columns when required.
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`40.
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`And both of these design features were made possible by the use of a self-
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`referential table using object identifiers that tied the metadata to the data by linking rows
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`and columns.
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`41.
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`Enfish’s flexible and efficient search capabilities were the direct result of its
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`novel, single-table design as well as its ability to support new data types through the use of
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`metadata – that was accessible in the self-referential database through the use of object
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`identifiers.
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`42.
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`The organizational and analytical
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`flexibility of Enfish (e.g. automatic
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`organization of content across data sources and ability to determine what info is important
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`to each user) was again attributable to the four novel features implemented in DEXIS and
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`disclosed and claimed in the ‘604 patent.
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`VIII. CLAIM CONSTRUCTION
`A.
`The Standard for Claim Construction in Inter Partes Review
`43.
`I understand that, in Inter Partes Review, the claims are to be given their
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`broadest reasonable interpretation (BRI) in light of the specification. See 37 C.F.R.
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`§ 42.100(b). In performing my analysis and rendering my opinions, I have interpreted claim
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`terms for which PO has not proposed a construction by giving them the ordinary meaning
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`they would have to a person having ordinary skill in the art (“POSITA”), reading the ʼ604
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`Patent with its relevant priority filing date (March 28, 1995) in mind and in light of its
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`specification and file history.
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`Opinion Regarding a POSITA
`B.
`44. Counsel has advised me that to determine the appropriate level of one of
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`ordinary skill in the art, the following factors may be considered: (a) the types of problems
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`encountered by those working in the field and prior art solutions thereto; (b) the
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`sophistication of the technology in question, and the rapidity with which innovations occur in
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`the field; (c) the educational level of active workers in the field; and (d) the educational level
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`of the inventor.
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`45.
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`The relevant technology field for the ʼ604 Patent is data management and
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`information retrieval. Based on this, and the four factors above, it is my opinion that
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`POSITA would have been someone with at least a BS degree in Electrical Engineering or
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`Computer Science, and with at least three years of additional experience in use of relational
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`database systems.
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`C.
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`46.
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`Constructions of Specific Claim Terms
`1.
`OID
`The terms “OID” and/or “object identification number” are recited in claims 1,
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`2, 10, 11, 12, 16, 17, 20, 24, 31, 32, 40, 41, 42, 46, 47, 50, and 54. “OID” and “object
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`identification number” are well-known terms of art. Their broadest reasonable interpretation
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`is the well-understood meaning to one of ordinary skill in the art. An “OID” is a system-
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`generated number that uniquely identifies an object of interest and is immutable.
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`An “OID” Is Unique
`(1)
`The description in the specification is consistent with the above reading.
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`47.
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`First, as the patent specification describes in the background, those of skill in the art
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`understand that in any object-oriented model, the OIDs are unique: “Key features of the
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`object-oriented model are: 1) each item has a unique system generated object identification
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`number that can be used for exact retrieval.” Ex. 1101, 1:65-2:1.
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`48.
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`The specification goes on to describe how the system must use unique OIDs:
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`“As previously described, the system must generate a unique OID when columns and rows
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`are formed.” Ex. 1101, 8:7-8. And every row and every column is assigned such a unique
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`OID: “Each row is assigned a unique object identification number (OID) stored in column
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`120 and each column also is assigned a unique OID, indicated in brackets and stored in row
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`108.” Ex. 1101, 6:43-45.
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`49.
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`In one particular embodiment, the specification describes using a session
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`identification to ensure uniqueness: “In the preferred embodiment, the session identification
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`is derived from the unique serial number of the application installed on the users machine.”
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`Ex. 1101, 8:22-24. Figure 4 of the specification illustrates an embodiment of a method
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`whereby unique OIDs are ensured by combining a session identification and a timestamp.
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`Ex. 1101, Figure 4. Even with a session ID and timestamp, the embodiment includes
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`additional tiebreaking steps to ensure uniqueness. Id.
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`’604 Patent, Figure 4
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`50.
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`I agree with Dr. Hosking that the OIDs are unique. See Ex. 1002, ¶ 51; Ex.
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`2003, 27:18-29:15 (“Q So do OIDs need to be unique from object to object to be able to
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`identify an object? A Indeed, they would have to be unique otherwise they cannot be
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`compared for [e]quality. . . . Q If you want to provide OIDs for a certain group of objects, do
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`the OIDs for those objects need to be unique at least within that group of OIDs? . . . THE
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`WITNESS: If I have a group of objects that I want to distinguish, then within that group of
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`objects the OIDs must be unique.”)
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`51.
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`To effectively identify an object, it should never be the case that the same
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`OID is attached to two or more objects in a database. As the specification describes, OIDs
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`are known in the art and used in the invention for retrieval: “each item has a unique system
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`generated object identification number that can be used for exact retrieval.” Ex. 1001, 1:60-
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`64. Without uniqueness, retrieval of an object with an OID will result in more than one
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`object and, thus, a non-functional database.
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`52.
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`The literature further supports an interpretation of OID that requires
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`uniqueness. Introduction to Database and Knowledge-Base Systems, published in 1992,
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`states that an OID “uniquely identifies an object.” Ex. 2070, p. 307. I agree with Dr.
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`Hosking that Introduction to Database and Knowledge-Base Systems is an authoritative
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`book.
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`53.
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`Fundamentals of Database Systems, another authoritative text, also states
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`that OIDs are unique:
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`20.2.1 Object Identity
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`An OO database system provides a unique identity to each
`independent object stored in the database. The unique identity is
`typically implemented via a unique, system-generated object
`identifier (OID). The value of an OID is not visible to the external
`user, but is used internally by the system to identify each object
`uniquely and to create and manage inter-object references. The OID
`can be assigned to program variables for the appropriate type when
`needed.
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`The main property required of an OID is that it be immutable; that is,
`the OID value of a particular object should not change. . . . It is also
`desirable that each OID be used only once; that is, even if an
`object is removed from the database, its OID should not be
`assigned to another object.
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`Ex. 2068, p. 644.
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`54.
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`Another authoritative text, Database Systems: An Application Oriented
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`Approach, also describes the commonly-known OID as unique:
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`
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`[E]very object has a unique and immutable identity, called the
`object ID (OID), which is independent of the actual value of the object.
`The OID is assigned by the system when the object is created and
`does not change during the object’s lifetime. Note the distinction
`between OIDs and primary keys of relations. Like an OID, a primary
`key uniquely identifies the object. However, unlike an OID, the value
`of a primary key might change . . .
`
`Ex. 2069, pp. 543-44 (emphasis added).
`
`55.
`
`Finally, Microsoft also considers OIDs to be unique identifiers:
`
`Object identifiers are unique numeric values that are granted by
`various issuing authorities to identify data elements, syntaxes, and
`other parts of distributed applications. Because they are globally
`unique, object identifiers ensure that the objects that are defined by
`these issuing authorities do not conflict with one another when
`different directories, such as Active Directory and Novell Directory
`Services, are brought together in a global directory namespace.
`
`Ex. 2067(emphasis added).
`
`56.
`
`Second,
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`An “OID” Is Immutable
`(1)
`the broadest reasonable
`interpretation of OID must
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`include
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`immutability. Persons of ordinary skill in the art understand that a functional system must
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`assign an identifier to an object that does not change: if an object identifier could be
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`changed, the object could no longer be retrieved unambiguously or referenced with
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`confidence and, thus, the system would be non-functional.
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`57.
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`Again, the inclusion of immutability in the broadest reasonable interpretation
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`of OID is supported by both the specification and the literature. For example, OIDs are
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`shared across systems:
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`Important date records are assigned special predetermined OIDS
`since they always have the same identity in any system. Assigning
`predetermined OID’s to dates allows Important Dates to be shared
`across systems. The predetermined OID is generated by using a
`special session identification number that signifies that the OID is an
`Important Date. In this case, the timestamp represents the value of
`the Important Date itself, not the time that it was created.
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`Ex. 1101, 14:1-4. If an OID were to change, the change could not be propagated to other
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`systems.
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`58.
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`Introduction to Database and Knowledge-Base Systems, published in 1992,
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`states that an OID does not change even if other properties of the object change: “The
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`main property required of an OID is that it be immutable; that is, the OID value of a
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`particular object should not change.” Ex. 2068, p. 644 (emphasis added).
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`59. Database Systems: An Application Oriented Approach, also describes OIDs
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`as non-changing:
`
`[E]very object has a unique and immutable identity, called the object
`ID (OID), which is independent of the actual value of the object. The
`
`16
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`Enfish, LLC; IPR2014-00575
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`Page 16 of 126
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`
`
`
`
`OID is assigned by the system when the object is created and
`does not change during the object’s lifetime. Note the distinction
`between OIDs and primary keys of relations. Like an OID, a primary
`key uniquely identifies the object. However, unlike an OID, the value
`of a primary key might change . . .
`
`Ex. 2069, pp. 543-44 (emphasis added).
`
`An “OID” Is System Generated
`(1)
`Third, the broadest reasonable interpretation of “OID” includes an OID that is
`
`60.
`
`system generated. This is true at least because, in order to ensure that an OID is unique
`
`and that it is immutable, it must be system-generated rather than user-generated. Again,
`
`this interpretation is supported by the specification and the literature.
`
`61.
`
`The specification describes a “key feature” that OIDs are system generated:
`
`Key features of the object-oriented model are: 1) each item has a unique system generated
`
`object identification number that can be used for exact retrieval.” Ex. 1101, 1:65-2:1.
`
`62.
`
`Particular embodiments described in the specification also define an OID as
`
`system generated:
`
`Important date records are assigned special predetermined OIDS
`since they always have the same identity in any system. Assigning
`predetermined OID’s to dates allows Important Dates to be shared
`across systems. The predetermined OID is generated by using a
`special session identification number that signifies that the OID is
`an Important Date. In this case, the timestamp represents the value of
`the Important Date itself, not the time that it was created.
`
`17
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`Page 17 of 126 | Hosagrahar (H.V.) Jagadish, Ph.D.
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`Enfish, LLC; IPR2014-00575
`Exhibit 2407
`Page 17 of 126
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`
`
`
`
`Ex. 1101, 14:1-8 (emphasis added).
`
`63.
`
`Introduction to Database and Knowledge-Base Systems, published in 1992,
`
`states that an OID is “system-generated” Ex. 2070, p. 307.
`
`64.
`
`Fundamentals of Database Systems, states that the main feature of an OID is
`
`that it is system generated:
`
`20.2.1 Object Identity
`
`to each
`identity
`An OO database system provides a unique
`independent object stored in the database. The unique identity is
`typically implemented via a unique, system-generated object
`identifier (OID). The value of an OID is not visible to the external
`user, but is used internally by the system to identify each object
`uniquely and to create and manage inter-object references. The
`OID can be assigned to program variables for the appropriate type
`when needed.
`
`Ex. 2068, p. 644 (emphasis added).
`
`65.
`
`Finally, Microsoft also considers OIDs to be system generated:
`
`Object identifiers are unique numeric values that are granted by
`various issuing authorities to identify data elements, syntaxes,
`and other parts of distributed applications. Because they are globally
`unique, object identifiers ensure that the objects that are defined by
`these issuing authorities do not conflict with one another when
`different directories, such as Active Directory and Novell Directory
`Services, are brought together in a global directory namespace.
`
`18
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`Page 18 of 126 | Hosagrahar (H.V.) Jagadish, Ph.D.
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`Enfish, LLC; IPR2014-00575
`Exhibit 2407
`Page 18 of 126
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`
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`
`
`Ex. 2067 (emphasis added).
`
`“anchor”
`2.
`The term “anchor” is recited in claims 21 and 51 of the ʼ604 Patent. In light of
`
`66.
`
`the specification, this term should be construed as “a set of values stored within a logical
`
`cell that specify the location of a key word or phrase within the logical cell and identify the
`
`key word or phrase.” Ex. 1101, 12:37-34, FIG. 12.
`
`“external documents”
`3.
`The term “external documents” is recited in claims 30 and 60 of the ʼ604
`
`67.
`
`Patent. In light of the specification, this term should be construed as “documents that are
`
`not directly stored in the database.” Ex. 1101, 16:1-9, FIG. 2.
`
`D.
`
`68.
`
`Algorithmic Support for Means-Plus-Function Limitations
`1.
`Structure Generally for Means-Plus-Function Limitations
`At least the following portions of the specification of the ʼ604 Patent disclose
`
`the structure generally to support the functions recited in the means-plus-function limitations
`
`found in the instituted claims:
`
` “Useful machines for performing the operations of the present
`invention include general purpose digital computers or other similar
`digital devices.” Ex. 1101, 4:49-52.
`
` “The present invention relates to method steps for operating a
`computer in processing electrical or other (e.g., mechanical, chemical)
`physical signals to generate other desired physical signals. The
`present invention also relates to apparatus for performing these
`
`19
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`Page 19 of 126 | Hosagrahar (H.V.) Jagadish, Ph.D.
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`Enfish, LLC; IPR2014-00575
`Exhibit 2407
`Page 19 of 126
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`
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`
`
`operations. This apparatus may be specially constructed for the
`required purposes or it may comprise a general purpose computer as
`selectively activated or reconfigured by a computer program stored in
`the computer. The algorithms presented herein are not inherently
`related to a particular computer or other apparatus. In particular,
`various general purpose machines may be used with programs written
`in accordance with the teachings herein, or it may prove more
`convenient to construct more specialized apparatus to perform the
`required method steps. The required structure for a variety of these
`machines will appear from the description given below.” Ex. 1101,
`4:55-5:4.
`
` “As illustrated [in FIG. 1], the information storage and retrieval system
`includes a computer 23 which comprises . . . a central processing unit
`(CPU) 24 . . . and a memory 26.” Ex. 1101, 5:22-25, FIG. 1.
`
`“means for configuring said memory according to a logical table”
`2.
`69. Claims 1, 11, 15-17, and 24 recite “means for configuring said memory
`
`according to a logical table.” Having reviewed the specification of the ʼ604 Patent, it is my
`
`opinion that, to one of ordinary skill in the art, certain portions of the specification and
`
`drawings would link the recited function to a series of algorithm steps. It is also my opinion
`
`that one of ordinary skill in the art would understand how to implement those algorithm
`
`steps using techniques and resources that were available at the time the ʼ604 Patent was
`
`filed.
`
`70.
`
`First Algorithm Step: The specification describes creating, in a computer
`
`memory, a logical table that need not be stored contiguously in the computer memory, the
`
`20
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`Page 20 of 126 | Hosagrahar (H.V.) Jagadish, Ph.D.
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`Enfish, LLC; IPR2014-00575
`Exhibit 2407
`Page 20 of 126
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`
`
`logical table being comprised of rows and columns, the rows corresponding to records, the
`
`columns corresponding to fields or attributes, the logical table being capable of storing
`
`different kinds of records:
`
`
`
` “The table of the present invention comprises a plurality of rows and
`columns.” Ex. 1101, Abstract, Lines 5-7.
`
` “A row corresponds to a record and a column corresponds to a field . .
`. .” Id., Abstract, Lines 8-9.
`
` “The table of the present invention comprises a plurality of rows and
`columns.” Id., 2:53-54.
`
` “A row corresponds to a record and a column corresponds to an
`attribute . . . .” Id., 2:55-57
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