`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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`In the Inter Partes Review of U.S. Patent No. 8,156,096
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`Trial No.: Not Yet Assigned
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`Issued: April 10, 2012
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`Filed: September 23, 2011
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`Inventor: Meiresonne
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`Title: SUPPLIER IDENTIFICATION AND LOCATOR SYSTEM AND
`METHOD
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`
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`DECLARATION OF DR. BEN BEDERSON
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`Qualifications
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`I, Dr. Ben Bederson, hereby declare under penalty of perjury:
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`1.
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`I have since 1998 been a Professor of Computer Science at the
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`University of Maryland (“UMD”), where I have joint appointments at the Institute
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`for Advanced Computer Studies and the College of Information Studies
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`(Maryland’s “iSchool”). I am also Associate Provost of Learning Initiatives and
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`Executive Director of the Teaching and Learning Transformation Center. I am a
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`member and previous director of the Human-Computer Interaction Lab (“HCIL”),
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`the oldest and one of the best known Human-Computer Interaction research groups
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`in the country. I am also co-founder and Chief Scientist of Zumobi, Inc., a Seattle-
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`based startup that is a publisher of content applications for high end mobile
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`phones. I am also co-founder and co-director of the International Children’s
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`Digital Library (“ICDL”), a web site providing the world’s largest collection of
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`freely available online children’s books from around the world with an interface
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`aimed to make it easy for children and adults to search and read children’s books
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`online. In addition, I have for more than 15 years consulted for numerous
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`companies in the area of user interfaces, including Microsoft, the Palo Alto
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`Research Center, Sony, Lockheed Martin, and NASA Goddard Space Flight
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`Center.
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`2.
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`For more than 25 years, I have studied, designed, and worked in the
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`field of computer science and human-computer interaction. My experience
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`includes 25 years of teaching and research, with research interests in human-
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`computer interaction and the software and technology underlying today’s mobile
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`computing world. This includes web browsing, including the use of interaction
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`strategies such as rollover (or mouseover) to increase simplicity and
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`discoverability of information systems, just to name a few.
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`3.
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`At UMD, my research is in the area of Human-Computer Interaction
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`(“HCI”), a field that relates to the development and understanding of computing
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`systems to serve users’ needs. Researchers in this field are focused on making
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`universally usable, useful, efficient, and appealing systems to support people in
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`their wide range of activities. My approach is to balance the development of
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`innovative technology that serves people’s practical needs. Example systems
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`following this approach that I have built include PhotoMesa (software for end
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`users to browse personal photos), DateLens (software for end users to use their
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`mobile devices to efficiently access their calendar information), SpaceTree
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`(software for end users to efficiently browse very large hierarchies), ICDL (as
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`described above), and StoryKit (an iPhone app for children to create stories).
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`4.
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`At Zumobi, I am responsible for investigating new software platforms
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`and developing new user interface designs that provide efficient and engaging
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`interfaces to permit end users to access a wide range of content on mobile
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`platforms (including the iPhone and Android-based devices). For example, I
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`designed and implemented software called “Ziibii,” a “river” of news for iPhone,
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`software called “ZoomCanvas,” a zoomable user interface for several iPhone apps,
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`and iPhone apps including “Inside Xbox” for Microsoft and Snow Report for REI.
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`5.
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`At the International Children’s Digital Library (ICDL), I have since
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`2002 been the technical director responsible for the design and implementation of
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`the web site, www.childrenslibrary.org (originally at www.icdlbooks.org). In
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`particular, I have been closely involved in designing the user interface as well as
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`the software architecture for the web site since its inception in 2002. I hired and
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`worked closely with two software engineers to build and maintain the web site
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`from its launch in 2002 to the present. I have helped with the software code on
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`both the client and server. The goal of this web site is to support children and
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`adults from around the world to efficiently and easily search for and read books
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`online. By 2003, the ICDL web site included a text input area for entering
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`keywords and a search engine to permit users to run keyword searches to find
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`books. The search results were presented to the user as a web page listing of
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`books, each of which included descriptive information about the book.
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`Furthermore, by 2003 the results web page returned after performing a search
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`included a list of small images of each book page. Javascript coding was
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`implemented at that time to allow a user to move his mouse cursor over those
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`images in order to show larger versions of each image. Javascript was used in
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`coding other pages as well at that time to support rollover to provide additional
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`information. On the home page, rollovers/mouseovers (the terms are
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`interchangeable) were used to provide menu options, and descriptions of the
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`“basic” and “enhanced” versions of the web site. In both cases, the Javascript
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`“onmouseover” event was used to provide this functionality.
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`6.
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`Screenshots showing parts of the ICDL web site dating from
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`November, 2003 are set forth below. These screenshots accurately depict features
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`of the ICDL web site as of November 30, 2003 and were retrieved by me using the
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`“Wayback Machine.” The screen shot below shows the ICDL homepage on
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`November 30, 2003:
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`(https://web.archive.org/web/20031130022500/http://www.icdlbooks.org/). After
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`moving the mouse over the “Basic” flag shown in the screen shot above, a rollover
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`action would result in additional information being displayed, as shown below:
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`(https://web.archive.org/web/20031130022500/http://www.icdlbooks.org/).
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`7.
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`The Wayback Machine is a service of the Internet Archive that
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`archives old versions of publicly available web pages. It works in a similar way to
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`search engines in that it uses a “spider” to follow links on the web to visit many
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`web pages. But instead of creating an index to the most recent version of each web
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`page it visits, the Wayback Machine stores a copy of each version of each page it
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`visits. It then makes these stored copies of the web pages available at
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`http://web.archive.org using a well specified structure for the URLs that indicate
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`what time and date the copy of the web page was copied from the live World Wide
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`Web. The structure of the stored URLs is described by the Internet Archive as
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`follows: “The Internet Archive assigns a URL to each archived page on its site in
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`the format http://web.archive.org/web/[Year in yyyy][Month in mm][Day in
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`dd][Time code in hh:mm:ss]/[Archived URL]. (http://archive.org/legal/faq.php)
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`Thus, the Internet Archive URL
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`http://web.archive.org/web/19970126045828/http://www.archive.org/ would be the
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`URL for the record of the Internet Archive home page (http://www.archive.org/)
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`archived on January 26, 1997, at 4:58 a.m. and 28 seconds (1997/01/26 at
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`04:58:28).” (https://archive.org/legal/faq.php)
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`8.
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`I know that the Wayback Machine works in this way not only from
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`the Internet Archive’s description, but also from personal experience. I
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`collaborated with Brewster Kahle, the founder and director of the Internet Archive,
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`on my International Children’s Digital Library project. I visited him in October
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`2001 and he gave me a personal tour of the servers that run the Wayback Machine
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`and explained to me how it worked. I have also used the Wayback Machine
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`myself for various reasons over the 13 years since I visited the Internet Archive,
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`and have found it to work consistently and reliably as described above.
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`9.
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`Beginning in the mid-1990’s, I have been responsible for the design
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`and implementation of numerous other web sites in addition to the ICDL. For
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`example, I designed and built my own professional web site when I was an
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`Assistant Professor of Computer Science at the University of New Mexico in 1995
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`and have continued to design, write the code for, and update both that site (which I
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`moved to the University of Maryland in 1998, currently at
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`http://www.cs.umd.edu/~bederson/) as well as numerous project web sites, such as
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`Pad++, http://www.cs.umd.edu/hcil/pad++/. Pad++ included a custom web
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`browser which I built from scratch in 1996 and distributed as open source software
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`at the Pad++ web site. That web browser was described in numerous publications
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`including “Pad++: A Zoomable Graphical Sketchpad for Exploring Alternate
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`Interface Physics” (Ex. 1014, Bederson et al., 1996a) and “A Zooming Web
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`Browser” (Ex. 1015, Bederson et al., 1996b). It supported the version of HTML
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`available at the time (HTML 1.0) as well as an embedded scripting language. The
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`following images are from Figure 5 in Bederson et al., 1996a (Ex. 1014 at p. 11), a
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`custom web browser that I built that used a “zoomable user interface” to show a
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`visual representation of which pages a user visited:
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`.
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`10. More recently, I have worked on complex web “apps,” some of which
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`include search results and Javascript-based mouseover interaction. These include
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`my current publications page, a system called “Q&A” which supports real-time
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`support for classroom interactive response by students with collaborative
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`annotation of each other’s responses, and “CT Arcade”, a site that allows children
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`to learn computational thinking by programming a “bot” to play a game against
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`them. The following screen shot shows my current publications page, which
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`includes a search engine and Javascript-based rollover interaction to show
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`additional information about each search result. It shows the result of searching
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`for the word “web.” The mouse has been rolled over the second-to-last search
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`result, and the corresponding item on the timeline is highlighted.
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`(http://www.cs.umd.edu/~bederson/papers/index.html)
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`11. The following shows the “Q&A” interactive student response web
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`site. This screenshot shows the results of 50 students simultaneously answering a
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`question and then annotating each other’s annotations.
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`(http://qa-umd.appspot.com/results/73849)
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`12. The following shows the “CT Arcade” web site. This screenshot
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`shows a game in progress where the human player is teaching the “bot” player how
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`to improve its strategy.
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`10
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`(http://ctarcade.appspot.com/trainer)
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`13.
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`I hold a B.S., M.S., and Ph.D. in computer science. I also earned an
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`undergraduate minor in electrical engineering. I received the Janet Fabri Memorial
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`Award for Outstanding Doctoral Dissertation for my Ph.D. work in robotics and
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`computer vision. I have combined my hardware and software skills throughout my
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`career in Human-Computer Interaction research, building various interactive
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`electrical and mechanical systems that couple with software to provide an
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`innovative user experience.
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`14. My work has been published extensively in more than 140 technical
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`publications, and I have given about 100 invited talks, including 7 keynote
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`lectures. I have won a number of awards including the Brian Shackel Award for
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`“outstanding contribution with international impact in the field of HCI” in 2007,
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`and the Social Impact Award in 2010 from Association for Computing
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`Machinery’s (“ACM”) Special Interest Group on Computer Human Interaction
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`(“SIGCHI”). ACM is the primary international professional community of
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`computer scientists, and SIGCHI is the primary international professional HCI
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`community. I have been honored by both professional organizations. I am an
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`“ACM Distinguished Scientist,” which “recognizes those ACM members with at
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`least 15 years of professional experience and 5 years of continuous Professional
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`Membership who have achieved significant accomplishments or have made a
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`significant impact on the computing field.” I am a member of the “CHI
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`Academy,” which is described as follows: “The CHI Academy is an honorary
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`group of individuals who have made substantial contributions to the field of
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`human-computer interaction. These are the principal leaders of the field, whose
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`efforts have shaped the disciplines and/or industry, and led the research and/or
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`innovation in human-computer interaction.” The criteria for election to the CHI
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`Academy are: (1) cumulative contributions to the field; (2) impact on the field
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`through development of new research directions and/or innovations; and (3)
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`influence on the work of others.”
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`15.
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`I have appeared on radio shows numerous times to discuss issues
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`relating to user interface design and people’s use and frustration with common
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`technologies, web sites, and mobile devices. My work has been discussed and I
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`have been quoted by mainstream media around the world over 120 times, including
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`by the New York Times, the Wall Street Journal, the Washington Post, Newsweek,
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`the Seattle Post-Intelligencer, the Independent, Le Monde, NPR’s All Things
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`Considered, New Scientist Magazine, and MIT’s Technology Review.
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`16.
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`I have designed, programmed and publicly deployed dozens of user-
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`facing software products that have cumulatively had millions of users. My work is
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`cited in significant patents that are central to several major companies’ user
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`interfaces, including Sony and Apple.
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`17.
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`I am the co-inventor of 7 U.S. patents, listed below. The patents are
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`generally directed to user interfaces/experience.
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` Pahud, M., Murillo, O. E., Karlson, A. K., & Bederson, B. B. Monitoring
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`Pointer Trajectory and Modifying Display Interface. US Patent # 8,261,211.
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` Good, L.E., Bederson, B. B., & Stefik, M.J. (Inventors). Methods and
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`Systems for Supporting Presentation Tools Using Zoomable User Interfaces.
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`US Patent # 7,707,503.
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` Bederson, B. B., Good, L. E., & Stefik, M.J. (Inventors). Methods and
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`Systems for Incrementally Changing Text Representation. US Patent #
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`7,650,562.
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` Bederson, B. B., Good, L. E., & Stefik, M. J. (Inventors). Methods and
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`Systems for Incrementally Changing Text Representation. US Patent #
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`7,549,114.
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` Wallace, R. S., Bederson, B. B., & Schwartz, E. L. (Inventors). TV Picture
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`Compression and Expansion. US Patent # 5,642,167.
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` Bederson, B. B., Wallace, R. S., & Schwartz, E. L. (Inventors). Two-
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`Dimensional Pointing Motor. US Patent # 5,204,573.
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` Wallace, R. S., Bederson, B. B., & Schwartz, E. L. Telephone Line Picture
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`Transmission. US Patent # 5,175,617.
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`18.
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`I have worked as an expert in several legal matters as a consulting
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`expert, a fact witness, and an expert witness. I have written expert reports, have
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`had my deposition taken, and have provided trial testimony.
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`19. Exhibit 1012 is my curriculum vitae which includes a complete list of
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`my qualifications. Exhibit 1013 is a list of matters in which I have provided expert
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`testimony, either at deposition or at trial in the last 5 years.
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`20.
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`I have been retained on behalf of Google, Inc. to offer statements and
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`expert opinions regarding the understanding of a person of ordinary skill in the art
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`(discussed below) as it relates to U.S. Patent No. 8,156,096 and other references
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`presented to me by counsel for Google.
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`21.
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`I am being compensated at a rate of $600 per hour for my services.
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`My compensation does not depend on the outcome of this review proceeding or of
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`the litigation pending against Google in the U.S. District Court for the Western
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`District of Michigan.
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`Materials Considered
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`22.
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`In developing my opinions set forth in this declaration, I have
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`considered the following materials:
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` U.S. Patent No. 8,156,096 (“the ’096 patent”) (Ex. 1001).
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` U.S. Patent No. 6,271,840 (“Finseth”) (Ex. 1007) and the exhibits filed with
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`the corresponding U.S. Application No. 09/160,633 (Ex. 1019).
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` U.S. Patent Pub. App. No. 2002/0042750 (“Morrison”) (Ex. 1008).
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` U.S. Patent Pub. App. No. 2003/0146939 (“Petropoulos”) (Ex. 1009).
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` Bederson, B. B., Hollan, J. D., Perlin, K., Meyer, J., Bacon, D., & Furnas, G.
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`(1996a). Pad++: A Zoomable Graphical Sketchpad For Exploring
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`Alternate Interface Physics. Journal of Visual Languages &
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`Computing, 7(1), 3-32 (Ex. 1014).
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` Bederson, B. B., Hollan, J. D., Stewart, J. B., Rogers, D., Druin, A., & Vick,
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`D. (1996b). A Zooming Web Browser. In Electronic Imaging: Science &
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`Technology (pp. 260-271). International Society for Optics and Photonics
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`(Ex. 1015).
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` Berners-Lee, T., et al., The World-Wide Web. Communications of the
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`ACM, Vol. 37, No. 8, 76-82 (August 1994) (Ex. 1016).
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` Hill, B. (1997) World Wide Web Searching for Dummies, Second
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`Edition, Hungry Minds, Inc. (Excerpts at Ex.1006).
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` Kasten, E., HTML, A Gentle Introduction, Linux Journal, 15 Ed., Article
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`3, p. 35 (July 1995) (Ex. 1017).
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` Wagner, R. (1997) JavaScript Unleashed, Second Edition, sams.net
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`(Excerpts at Ex. 1018).
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`Level of Ordinary Skill For the ’096 Patent
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`23.
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`I have read the ’096 patent and understand it issued on an application
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`filed on September 23, 2011, and claims priority to earlier-filed applications.
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`24. The ’096 patent relates to a “supplier identification and locator system
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`that allows a user to identify a supplier of goods or services over the Internet.”
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`(Ex. 1001, Abstract.) I understand that the disclosed system of the patent includes,
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`at least, one directory web site which has links to other web sites, a descriptive
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`portion located substantially adjacent to each link, a rollover viewing area that
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`displays information about the other web sites, and an input receiving area where a
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`user inputs a keyword.
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`25.
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`I have been advised that the factors that may be considered in
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`determining the level of ordinary skill in the art include: (1) the levels of education
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`and experience of persons working in the field; (2) the types of problems
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`encountered in the art; and (3) the sophistication of the technology involved. I
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`understand that a person of ordinary skill in the art (“POSITA”) is not a specific
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`real individual, but rather a hypothetical individual having the qualities reflected
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`by the above factors.
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`26.
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`In my opinion, the field of art relevant to the ’096 patent is web site
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`design and web site software development. The field includes web site design
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`because the patent describes web site design issues such as keyword searching,
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`input receiving areas, vertical listing layouts, rollover interaction techniques, etc.
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`The field includes web site software development because the patent describes
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`software features such as keyword results and interaction techniques.
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`27.
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`In my opinion, a POSITA relevant to the ’096 patent at the time of the
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`alleged invention would have at least a bachelor’s degree in computer science or
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`related field, and approximately one year of experience in web site design. This is
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`based on my understanding of the field at the time, and is supported by my own
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`experience. The more junior of the two developers that I hired in 2003 to help
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`create the International Children’s Digital Library wrote the Javascript code that
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`implemented the mouseover effect described above, and at that time, she had
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`finished her bachelor’s degree in mathematics about two years earlier. The
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`techniques described in the patent could be implemented with standard,
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`commercial, off-the-shelf technology by July 2000, and a POSITA would be
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`readily able to apply those standard techniques to implement the patent’s
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`disclosures.
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`State Of The Art As Of July 2000
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`28. Tim Berners-Lee initially developed the World Wide Web (WWW) in
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`1990. While Internet-based communications had been around for some time at this
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`point, the WWW simplified things by combining a few basic technologies
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`including web servers, web browsers, and HTML. The Internet was an enabling
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`technology – allowing computers to communicate arbitrary information between
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`any locations in the world (Ex. 1016, Berners-Lee, 1994).
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`29. While the term “Web servers” has a variety of definitions, in general
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`Web servers are computers on the Internet that run a special program to listen to
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`web “requests” and respond to those requests – typically by returning a document
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`that was requested. Subject to hardware resource limitations, a Web server may
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`serve any number of web pages. Static web pages may be stored on a server’s hard
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`drives and processed in memory. Dynamic web pages, such as those generated in
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`response to a user’s search request, are generated and processed in memory. Any
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`collection of web pages may constitute a web site, and a Web server may host
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`more than one web site.
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`30. Web browsers are client programs that display data fetched from web
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`servers. Somewhat like a word processing program that can open a document and
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`display it, a web browser can open a special kind of document (called HTML) and
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`display it. However, web browsers have the additional feature that they can fetch
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`those documents across the internet from web servers. They also can interpret the
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`HTML documents they display to recognize hyperlinks that when clicked on by a
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`user, fetch the document referenced by the hyperlink’s Uniform Resource Locator
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`(“URL”) and display them (typically replacing the previously displayed
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`document). As Berners-Lee described in 1994, these URLs offered a “Universal”
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`way of locating and accessing any network communications protocol including
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`HTTP. (Ex. 1016 at p. 1.)
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`31. HTML is a textual document format for describing the visual
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`presentation of documents, including embedded objects such as images and forms
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`as well as links to other documents. It consists of plain text that will be displayed
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`as such along with “tags” which surround portions of text and are used to modify
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`how that text is displayed. Tags are formed by a word surrounded by a pair of
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`angle brackets with a matching closing tag that is prefixed with a forward slash.
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`For example, the following is a simple HTML snippet “Here is some <B>bold
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`text</B>.” (Ex. 1017 at p. 1, Kasten, 1995.) When this HTML is interpreted by a
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`web browser, it would be displayed as following:
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`Here is some bold text.
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`32. HTML can include links to other documents. It specifies those links
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`with an “anchor” tag (i.e., <A …> and a closing </A> tag) along with URLs to
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`indicate the location of the other document. URLs are created in text with a
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`specific structured format including several elements such as the address (often
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`represented by a domain name) of a web server the other document is on, and the
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`location (or “path”) of that document on the web server. An example of an anchor
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`tag follows where the “HREF” parameter specifies the URL of the document to be
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`fetched and displayed when the link is clicked (id. at p. 3):
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`<A HREF="http://remote.host.name/docs/foo.html">Foodocument</A>
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`33.
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`In general, web sites are collections of HTML-based web pages that
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`are stored or generated on a web server that is typically accessed by a single
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`domain address. In order for a user to view those web sites, they would direct their
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`web browser to load the web page located at a specific URL. At that point, the
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`web browser would communicate with the web server specified by the URL via the
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`Internet to fetch the desired web page and would then display it. (Ex. 1016 at pp.
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`1-3.)
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`34. One way to navigate the web in 2000 was to follow links from one
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`page to another. However, that was only effective if you already had access to a
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`web page with a link to the page you were looking for. From the earliest days of
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`the web, people built web pages that were directory lists of other web pages,
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`including links to those pages. In fact, as early as 1991, Tim Berners-Lee, the
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`inventor of the World Wide Web, built a directory himself. This directory became
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`the WWW Virtual Library (“VL”). As described in a history of the VL maintained
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`at http://vlib.org/admin/history, people setting up servers would let Berners-Lee
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`know about those new servers, and he (and later others) would add them to the
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`directory listing manually.
`
`35. As the number of web servers and web pages grew, people started
`
`looking for automated alternatives to manually constructed directory listings, and
`
`that effort led to the idea of a search engine. Search engines and their operation
`
`were well known to a POSITA. They are made available via web sites that include
`
`web pages that provided a search box into which a user could enter keywords.
`
`Typically, the entered keywords are then matched against the content of indexed
`
`web pages to find those that are relevant. Since the number of matching results
`
`could be in the thousands, search engines needed to decide on an order in which to
`
`present their search results. This was typically done by analyzing the content of
`
`the pages in question to determine how many times the search keywords appeared
`
`in the document. Extra weight was often given to documents where the keywords
`
`were found in more meaningful parts of the web page such as a title or URL
`
`domain. This resulted in a ranking that controlled the order in which search results
`
`21
`
`Google Exhibit 1011
`Page 21
`
`
`
`were displayed to users. Typically, the more relevant search results are displayed
`
`higher up in a list of results. Some of the most common ones in the late 1990s
`
`were Altavista, Excite, Hotbot, Lycos and Yahoo. (Ex. 1006 at p. 71.)
`
`36. A POSITA would have known by 2000 that search engines commonly
`
`work by initially creating an index of many millions of web pages (or more),
`
`typically by running a “crawler” that automatically follow links from one page to
`
`another, thus creating that index on the server (Id. at p. 73). The search engine
`
`then generates a web page with a standard HTML form that enables a user to enter
`
`keywords to search the index. The keywords are transmitted via HTTP to the web
`
`server, which in turn runs algorithms to search the index to find web pages that are
`
`relevant to the entered keywords and to order the resulting web pages. Based on
`
`the results, the server generates a search results web page, typically including a list
`
`of links to those web pages with additional descriptive information about the web
`
`pages associated with each link (see e.g. id. at pp. 95, 101), and transmits the
`
`search results web page via HTTP to the user’s web browser for display. During
`
`the process of generating the search results web page, the page is constructed and
`
`therefore at least temporarily stored1 in the server’s memory (RAM). A user could
`
`1 I have been instructed that the meaning of “web site stored on the server” means
`
`“one or more web pages in memory on the server(s),” under the broadest
`
`reasonable construction standard.
`
`22
`
`Google Exhibit 1011
`Page 22
`
`
`
`then click on one of the resulting links, and the web browser would display the
`
`linked web page. The following figures show the search engine feature provided
`
`on the home pages of Yahoo!, Excite and Lycos, and/or resulting search results
`
`pages from the late 1990s, as depicted in Hill 1997 (Ex. 1006):
`
`(Ex. 1006 at p. 70).
`
`
`
`23
`
`Google Exhibit 1011
`Page 23
`
`
`
`
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`
`24
`
`24
`
`Google Exhibit 1011
`Page 24
`
`Google Exhibit 1011
`Page 24
`
`
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`Hating at match accuracy
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`25
`
`25
`
`Google Exhibit 1011
`Page 25
`
`Google Exhibit 1011
`Page 25
`
`
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`26
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`26
`
`Google Exhibit 1011
`Page 26
`
`Google Exhibit 1011
`Page 26
`
`
`
`
`(Id. at p. 81).
`
`
`
`
`37. There were also commercial solutions that combined directory web
`
`sites with search engines. Two examples of this kind of site which would have
`
`been particularly well known to a POSITA by 2000 are Craigslist and Amazon.
`
`The screenshot below shows the Craigslist directory search web site dating from
`
`June 20, 2000, which I obtained from the Wayback Machine. Categories are
`
`shown in the main part of the page (“community & events”, “personals”,
`
`“housing”, etc.), and users could enter search terms in the box just below “search
`
`craigslist” in the left column.
`
`27
`
`Google Exhibit 1011
`Page 27
`
`
`
`
`
`(https://web.archive.org/web/20000620031910/http://www.craigslist.org/)
`
`
`38. The screenshot below is of Amazon’s home page dating from October
`
`13, 1999, which I obtained from the Wayback Machine. It includes a list of
`
`categories in the left column (“Books”, “Music”, “Video”, etc.) with search box
`
`just above it.
`
`28
`
`Google Exhibit 1011
`Page 28
`
`
`
`(https://web.archive.org/web/19991013091817/http://amazon.com/)
`
`
`Javascript and Rollover
`
`
`
`39. Web pages at least as early as 1997 included Javascript scripts that
`
`were used to define dynamic characteristics of the web page, including how a user
`
`could interact with it. As described in the 1997 W3C working draft of the HTML
`
`4.0 Specification (http://www.w3.org/TR/WD-html40-970917/), scripts, including
`
`well before 2000 Javascript could be embedded in web pages with the “script” tag.
`
`The following is an example from the “Scripts” sub-page of the 1997 W3C HTML
`
`4.0 specification:
`
`29
`
`Google Exhibit 1011
`Page 29
`
`
`
`
`(http://www.w3.org/TR/WD-html40-970917/interact/scripts.html, highlights
`added.)
`
`
`40. As is further described in the “Scripts” sub-page of the 1997 W3C
`
`HTML 4.0 specification, it was possible before 2000 to attach scripts to web pages
`
`so they would be executed
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