UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`
`INTERNATIONAL BUSINESS MACHINES CORPORATION,
`
`Petitioner
`
`
`
`v.
`
`
`
`INTELLECTUAL VENTURES I LLC,
`
`Patent Owner
`
`_________________________________________
`
`Case Number: IPR2015-01481
`
`Patent 6,510,434
`
`______________________________
`
`Declaration of Dr. Yannis Papakonstantinou
`
`
`
`
`
`
`
`
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, Cover
`
`
`________________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`
`INTERNATIONAL BUSINESS MACHINES CORPORATION,
`
`Petitioner
`
`
`
`v.
`
`
`
`INTELLECTUAL VENTURES I LLC,
`
`Patent Owner
`
`_________________________________________
`
`Case Number: IPR2015-01481
`
`Patent 6,510,434
`
`______________________________
`
`Declaration of Dr. Yannis Papakonstantinou
`
`
`
`
`
`
`
`
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, Cover
`
`
`
`TABLE OF CONTENTS
`
`
`
`I.
`
`Introduction............................................................................................... 1
`
`II. Qualifications ............................................................................................. 2
`
`III. My Understanding of the Obviousness Standard in Determining
`Patentability .......................................................................................................... 6
`
`IV. Basis of Opinion ......................................................................................... 7
`
`V. Overview of the ‘434 Patent ...................................................................... 8
`
`VI. Wical in view of Lassila ............................................................................ 10
`
`VII. Morita in view of Lassila .......................................................................... 13
`
`VIII. Perjury Statement ................................................................................ 16
`
`
`
`
`
`
`
`
`
`ii
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. ii
`
`
`
`I, Dr. Yannis Papakonstantinou, declare as follows:
`
`I.
`
`Introduction
`
`1.
`
`I am over 18 years of age. I have personal knowledge of the facts
`
`stated in this declaration and could testify competently to them if asked to do so.
`
`2.
`
`I have been retained on behalf of Patent Owner, Intellectual Ventures
`
`I LLC (IV), to provide this declaration in connection with the inter partes review
`
`(IPR) of U.S. Patent No. 6,510,434 (“the ’434 patent”) assigned Case Number
`
`IPR2015-01481. Specifically, I have been asked to provide my opinion relating to
`
`an inquiry into the patentability of claims 1-3, 5 and 6 from the ’434 patent relative
`
`to Wical,1 Morita,2 and Lassila.3
`
`3.
`
`I am being compensated for my time spent on this matter by
`
`Intellectual Ventures I LLC, including independent study, document review,
`
`analysis, and writing, at my standard hourly consulting rates. My compensation is
`
`not dependent upon my testimony or the outcome of this or any other proceeding. I
`
`have no financial interest in Intellectual Ventures I LLC.
`
`
`
`
`1 U.S. Patent No. 6,038,560 to Wical (“Wical” or “Exhibit 1006”).
`
` U.S. Patent No. 5,168,565 to Morita (“Morita” or “Exhibit 1007”).
`
` 2
`
` 3
`
` Ora Lassila, Web Metadata: A Matter of Semantics, IEEE Internet Computing,
`Vol. 2, Issue 4 (“Lassila” or “Exhibit 1008”).
`
`
`
`1
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 1
`
`
`
`II. Qualifications
`
`4.
`
`I am an expert in the field of database systems including information
`
`retrieval and databases that utilize Extensible Markup Language (XML). I have
`
`decades of experience in the field of database systems that began in the early
`
`1990’s and continues to the present day. In particular I have written a substantial
`
`number of papers as well as given numerous conference talks related to querying
`
`and searching for information in XML databases. I have given counsel for Patent
`
`Owner a true and correct copy of my curriculum vitae (CV) which I understand
`
`will be submitted as an exhibit in this proceeding. A summary of some of my
`
`qualifications is presented below.
`
`5.
`
`I received a Diploma of Electrical and Computer Engineering from
`
`the National Technical University of Athens in Athens, Greece in 1990. In 1994, I
`
`received a M.S. in Computer Science from Stanford University, and in 1997, I
`
`received a Ph.D. in Computer Science from Stanford University. The title of my
`
`thesis was “Query Processing in Heterogeneous Information Systems.”
`
`6.
`
`I am currently a Full Professor of Computer Science and Engineering
`
`at University of California, San Diego (UCSD). I have been a professor of
`
`Computer Science and Engineering at UCSD since 1996. Courses I have taught
`
`while a professor at UCSD relevant to this IPR proceeding include “Database
`
`Application Programming” and “Database Systems: Advanced Topics and
`
`
`
`2
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 2
`
`
`
`Implementation” both of which I designed and introduced into the UCSD
`
`curriculum in 1998.
`
`7.
`
`In addition to my tenure as a professor at UCSD I have provided
`
`technical consulting services to companies such as BEA Corp., Skyler Technology
`
`and Ferring Pharmaceuticals in relation to intellectual property matters, data
`
`integration and data processing. In addition, as indicated in my CV, I have
`
`provided consulting services in connection with many intellectual property
`
`disputes. I have testified in court, provided declarations or expert reports and been
`
`deposed in connection with various patent related legal proceedings in which I was
`
`involved as an expert. In one of these disputes I was retained on behalf of IV in
`
`connection with IPR2014-01385 filed by IBM on U.S. Patent No. 7,984,081.
`
`None of these matters are related to the present proceeding as far as I am aware.
`
`8. My research spans database and Internet-related technologies. I have
`
`published over eighty-five research articles in scientific conferences and journals,
`
`given tutorials at major conferences, and served on journal editorial boards and
`
`program committees for numerous international conferences and symposiums. I
`
`was the co-Chair of WebDB 2002, the General Chair of ACM SIGMOD 2003, the
`
`co-Chair of XIME-P 2004 and the Vice PC Chair for the “XML, Metadata and
`
`Semistructured Data” track of IEEE ICDE 2004. I have also received an invitation
`
`to be a Program Chair of IEEE ICDE 2017. In 1998, I received the NSF CAREER
`
`
`
`3
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 3
`
`
`
`award for my work on integrating heterogeneous data.
`
`9.
`
`In 2000, I founded Enosys Software, which built one of the first two
`
`generally available distributed XML/XQuery processor for information integration
`
`(EII), was subsequently acquired by BEA in 2003, and its product was sold under
`
`the BEA Liquid Data brand name.
`
`10.
`
`I have published the following articles in the fields of information
`
`retrieval and XML-related databases that span from before the filing date of the
`
`‘434 patent and continue to the present. A full list appears in my CV but my
`
`publications include the following: L. Gravano and Y. Papakonstantinou.
`
`“Mediating and Metasearching on the Internet”; In IEEE Data Engineering
`
`Bulletin, 21(2), pp. 28-36, 1998; Y. Papakonstantinou and V. Vassalos
`
`“Architecture and Implementation of an XQuery-based Information Integration
`
`Platform” In IEEE Data Engineering Bulletin, 25(1), pp. 18-26, March 2002; V.
`
`Hristidis, Y. Papakonstantinou “DISCOVER: Keyword Search in Relational
`
`Databases”; in VLDB 2002: 670-681; Y. Papakonstantinou et.al., “XML Views,
`
`Queries and Algebra in the Enosys Integration Platform”; Data and Knowledge
`
`Engineering Journal, 44(3): 299-322 (2003); V. Hristidis, L. Gravano, Y.
`
`Papakonstantinou “Efficient IR-Style Keyword Search over Relational Databases”;
`
`in VLDB 2003: 850-861; A. Balmin, Y. Papakonstantinou, “Storing and Querying
`
`XML Data Using Denormalized Relational Databases”; in VLDB Journal 14(1):
`
`
`
`4
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 4
`
`
`
`30-49 (2005); Yu Xu, Yannis Papakonstantinou “Efficient LCA-based keyword
`
`search in XML data”; in EDBT Conf 2008: 535-546; V. Hristidis, N. Koudas, Y.
`
`Papakonstantinou, D. Srivastava, “Keyword Proximity Search in XML Trees”;
`
`IEEE Transactions on Knowledge and Data Engineering 18(4): 525-539 (2006).
`
`11.
`
`I have been actively involved as a member in conference program
`
`committees, a member of technical working groups, and an editor of technical
`
`journals related to databases and information retrieval from before the filing date
`
`of the ‘434 patent and continue to the present. A full list appears in my CV but my
`
`memberships include the following: multiple times Program Committee member of
`
`the ACM SIGMOD and VLDB conferences; Associate Editor of IEEE
`
`Transactions on Knowledge and Data Engineering (2008). Member of the W3C
`
`XML Query working group, 2000-2002; Vice Program Chair of IEEE Data
`
`Engineering Conf. (ICDE), 2006, in charge of “Semi-structured data, metadata,
`
`and XML”.
`
`12.
`
`I have been involved in research regarding information integration,
`
`XML, query processing and retrieval projects that have combined received over
`
`$10,000,000 in grant money from the National Science Foundation and others,
`
`most of which research I was the primary investigator of.
`
`13.
`
`I believe my education, research, conference presence, teaching and
`
`other work experiences adequately well qualify me to testify as to what the
`
`
`
`5
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 5
`
`
`
`understanding of one of ordinary skill in the art would have been at the time the
`
`‘434 patent was filed on Dec. 29, 1999.
`
`III. My Understanding of the Obviousness Standard in Determining
`
`Patentability
`
`14.
`
`I understand that a patent claim is not patentable if the claimed
`
`invention would have been obvious to a person of ordinary skill in the art at the
`
`time the application was filed. This means that even if all of the requirements of
`
`the claim cannot be found in a single prior art reference so as to anticipate the
`
`claim, the claim might still be not patentable if the claimed invention would have
`
`been obvious.
`
`15. To obtain a patent, a claimed invention must have been nonobvious in
`
`view of the prior art in the field. I understand that an invention is obvious when the
`
`differences between the subject matter sought to be patented and the prior art are
`
`such that the subject matter as a whole would have been obvious at the time the
`
`invention was made to a person having ordinary skill in the art.
`
`16.
`
`I understand that to prove that a prior art reference or a combination
`
`of prior art references renders a patent obvious, it is necessary to: (1) identify the
`
`particular references that either alone, or in combination, render the patent obvious;
`
`(2) specifically identify which elements of the patent claim appear in each of the
`
`asserted references; and (3) explain how the prior art references could have been
`
`
`
`6
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 6
`
`
`
`combined in order to create the inventions claimed in the particular claim at issue.
`
`IV. Basis of Opinion
`
`17.
`
`In forming my opinions expressed in this declaration, I have
`
`considered and relied upon my education, background, and experience. I reviewed
`
`the Petition filed by Petitioner along with relevant exhibits to the Petition. A list of
`
`reviewed materials that is most relevant to my opinion is presented below. I
`
`understand these documents have been or will be submitted as exhibits in this IPR
`
`proceeding with the following exhibit numbers:
`
`Exhibit/Paper
`Number
`
`Document Description
`
`Ex. 1001
`Ex. 1004
`Ex. 1006
`Ex. 1007
`
`Ex. 1008
`
`Ex. 1014
`
`Declaration of Dr. H.V. Jagadish
`U.S. Patent No. 6,510,434
`U.S. Patent No. 6,038,560 to Wical
`U.S. Patent No. 5,168,565 to Morita
`Ora Lassila, Web Metadata: A Matter of Semantics, IEEE
`Internet Computing, Vol. 2, Issue 4
`The ‘434 Patent File History - Notice of Allowance
`
`
`
`18.
`
`In addition, I understand the time of the invention for claims 1-3, 5
`
`and 6 of the ‘434 Patent is the filing date, December 29, 1999.
`
`19.
`
`I have been instructed by Patent Owner’s counsel that for the purposes
`
`of this declaration, I should use the definition of a person of ordinary skill in the art
`
`at the time of the invention as set forth in Dr. Jagadish’s declaration. Ex. 1001,
`
`Jagadish Decl. at ¶¶ 37-40.
`
`
`
`7
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 7
`
`
`
`20. As such, unless otherwise stated, all the opinions I provide in this
`
`declaration are based on the knowledge of “a person with a Bachelor of Science
`
`degree in Computer Science, Computer Engineering, or other similar degree and
`
`one (1) year of work experience related to the field of the ’434 Patent” as of
`
`December 29, 1999.
`
`V. Overview of the ‘434 Patent
`
`21. The ‘434 Patent describes a primary goal is “to locate the requested
`
`information as quickly as possible” and it identifies a variety of problems suffered
`
`in prior art that impede this goal. Id. at 1:39-2:24. Problems in the prior art at the
`
`time of the invention to be solved include “eliminate ambiguity in the search
`
`request, focus the search on the most relevant information, perform the search in
`
`the most efficient manner and support searching multiple databases.” Id. at 2:25-
`
`33.
`
`22. The ‘434 solves the problems that existed in the prior art by “using an
`
`index that includes tags and metafiles to locate the desired information.” Id. at
`
`2:36-39; 4:11-14. Because the index “includes” tags and metafiles one of skill in
`
`the art understands that tags and metafiles are distinct components different from
`
`the index itself. Id. at 7:19-20.
`
`23. An exemplary index of the ‘434 patent includes three different types
`
`of groupings: domains, categories and terms. Id. at 4:17-33. The index may be
`
`
`
`8
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 8
`
`
`
`created so that an extensible markup language (XML) tag “is associated with each
`
`domain (a domain tag) and with each term associated with a category (a category
`
`tag).” Id. at 4:34-39.
`
`24. As stated in the ‘434 patent a “tag is generally associated with data or
`
`text and conveys information about the data or text.” Id. at 7:20-22. In the context
`
`for the ‘434 patent the tags are associated with domains, categories, terms and
`
`hierarchies. Id. at 4:34-43 and 7:32-33.
`
`25. Category tags are generally used to describe information that is
`
`common to many domains, such as business hours and type of payment accepted.
`
`Id. at 7:40-43. Conversely domain tags are used to describe information that is not
`
`generally considered related. For example, domain tags can be associated with
`
`different lines of business such as Restaurant and Automobile. Id. at 7:57-60.
`
`26. The ‘434 patent also describes a hierarchy among the list of related
`
`tags in a metafile, which can be established by a hierarchy tag. Id. at 4:42-43 and
`
`8:1-12. I understand Dr. Jagadish’s opinion is that the hierarchy discussed in the
`
`‘434 patent would encompass a data graph where nodes are included under other
`
`nodes, such as Dr. Jagadish’s example provided of the YAHOO! Search engine or
`
`through “IS-A” or “IS-PART-OF” relationships. See e.g., Ex. 1001 at ¶26, ¶115,
`
`¶146, ¶246. However, it is my opinion that one of ordinary skill in the art
`
`understands hierarchy as used in the ‘434 patent does not refer to a hierarchy
`
`
`
`9
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 9
`
`
`
`between nodes and sub-nodes of a data graph but rather it uses the term hierarchy
`
`to exclusively refer to a hierarchy of priority between tags in a metafile. This is
`
`understood based on the ‘434 patent’s repeated and consistent usage of the term
`
`“hierarchy” as establishing the order of priority among the related tags in a
`
`metafile to search for the most relevant information and never referring to a
`
`hierarchy established by having domains being groups of categories. Id. at 2:31-33,
`
`4:42, 8:55-57, 9:42-47, 9:54-56, 11:64-12:8, 8:1-7, 8:55-57, 9:43-47.
`
`27. Claims 5 and 6 of the ‘434 patent require a “creating a hierarchy
`
`between the tags” in the metafile. In light of the teachings of the ‘434 patent
`
`discussed above and the claim language, the only reasonable understanding of a
`
`“creating a hierarchy between the tags” in the metafile as recited in claims 5 and 6
`
`of the ‘434 patent to one of skill in the art would be establishing a priority between
`
`the tags in the metafile.
`
`VI. Wical in view of Lassila
`
`28.
`
`I understand the Petitioner has asserted that Wical's “knowledge base”
`
`discloses the index recited in claim 1 while Wical’s “directed graph” discloses the
`
`metafile recited in claim 1 of the '434 patent.
`
`29. A directed graph is a term of art that refers to a graph consisting a set
`
`of nodes that are connected together by lines called edges. A graph is directed
`
`when the edges have a particular direction from one node to another node. Thus, a
`
`
`
`10
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 10
`
`
`
`directed graph merely refers to a way one can structure the relationships between a
`
`set of data objects.
`
`30. Wical uses the term “directed graph” as a short-hand way to
`
`characterize to those of skill in the art how the categories of the knowledge base
`
`are related. Ex. 1006 at 11:56-57. To one of skill in the art reading Wical, the
`
`directed graph is the knowledge base, which is reflected in Wical’s interchangeable
`
`usage of the two terms. Id. at 11: 17-20, 11:59-65, 12:58-61. As such, the directed
`
`graph is not a stand-alone data structure that can be created separately from the
`
`knowledge base.
`
`31.
`
`I understand the Petition also alleges that the top level categories, such
`
`as the categories of “Leisure and Recreation” and “Geography” shown in Figure 4
`
`of Wical represent domain tags and that these categories may be related. My
`
`opinion is that one of skill in the art would not consider “Leisure and Recreation”
`
`and “Geography” to be related because those two categories are, at a minimum,
`
`described as "independent static ontologies" by Wical. Id. at 11:24-28. One of
`
`skill in the art would not consider the top level categories of independent
`
`ontologies to be related since that would in effect eliminate the independence of
`
`those ontologies.
`
`32.
`
`In addition, there is neither a direct relationship shown between
`
`“Leisure and Recreation” and “Geography” in Figure 4 nor a discussion in Wical
`
`
`
`11
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 11
`
`
`
`that the two categories are indirectly related. Any semantic, linguistic or usage
`
`connection between the high level categories of “Leisure and Recreation” and
`
`“Geography” is too remote for the two to be considered related by one of ordinary
`
`skill in the art.
`
`33. Furthermore, in light of teaching of Wical, it is my opinion that one of
`
`ordinary skill in the art would have no reasonable basis to create a relationship
`
`between two top level categories in Wical in separate ontologies. The purpose of
`
`establishing ontologies in a system like Wical’s is to create linguistic and semantic
`
`separation between certain groups of categories so that the categories can be
`
`organized in a logical fashion. If a relationship were made between top level
`
`categories of different ontologies it would greatly diminish this purposeful
`
`separation and undercut the benefit of relying on relationship information to
`
`identify additional categories in Wical.
`
`34. Finally, if there was a direct connection between two top level
`
`categories of Wical it would create a loop in Wical’s directed graph so that the
`
`same categories may be traversed multiple times in response to a search request
`
`creating inefficiencies and possibly preventing the identification of other relevant
`
`categories outside the loop.
`
`35.
`
`I understand the Petition has relied on the relationship of categories to
`
`subcategories, as illustrated in Figure 4 of Wical, to disclose the claimed hierarchy
`
`
`
`12
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 12
`
`
`
`between the tags in the metafile. Yet, as discussed above, the ‘434 Patent does not
`
`use the term hierarchy to describe domains being above categories, but rather to
`
`describe a priority of tags in a metafile to assist further searching. Ex. 1004 at 2:31-
`
`33, 4:42, 8:55-57, 9:42-47, 9:54-56, 11:64-12:8, 8:1-7, 8:55-57, 9:43-47.
`
`36. One of ordinary skill in the art would not understand Figure 4 or any
`
`other disclosure in Wical to teach a hierarchical priority of tags in a metafile.
`
`While Figure 4 indicates “distance weights” between categories, Wical uses these
`
`distance weights to calculate which categories exceed a predetermined distance
`
`threshold to determine expanded query terms. Ex. 1004 at 14:1-29. However, the
`
`priority of related categories is a different concept than semantic distance between
`
`categories. For example, if a user searches for “car” one might want to prioritize
`
`the additional category of “insurance” over “truck” despite a lesser semantic
`
`distance of “car” and “truck” than “car” and “insurance.”
`
`37. Lastly, there is also no teaching in Lassila alone or in combination
`
`with Wical that would lead one of skill in the art to consider the top level
`
`categories in Wical to be related. There is also no teaching in Lassila alone or in
`
`combination with Wical to establish a priority among tags in a metafile.
`
`VII. Morita in view of Lassila
`
`38.
`
`I understand the Petitioner has asserted that Morita’s “inverted file”
`
`discloses the index recited in claim 1 while Morita’s “keyword connection table”
`
`
`
`13
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 13
`
`
`
`discloses the metafile recited in claim 1 of the '434 patent.
`
`39. An inverted file is a term of art that refers to a file that maps text to
`
`the documents that the text is located in. Thus, in Morita, the inverted file would
`
`contain the keywords and the documents those keywords are located in. Ex. 1007
`
`at 5:20-24. The inverted file is generated by inverted file generator 40 and the
`
`inverted file is stored as file 41. Id.
`
`40. Morita’s keyword connection
`
`table
`
`is a diagonal
`
`table with
`
`relationship information between keywords in the table. Id at 2:1-5 and 4:49-5:4.
`
`The keyword connection table is updated with new keywords and relationships as
`
`new documents are registered with the system. Id. The keyword connection table
`
`is generated by keyword connection table processor 30 and the keyword
`
`connection table is stored in file 31. Id. at 4:49-56. With regards to the “IS-A”
`
`and “IS-PART-OF” connections, Morita’s keyword connection table can be
`
`depicted as a directed graph, much like Wical’s Figure 4.
`
`41.
`
`I understand the Petition alleges a keyword, such as the keyword
`
`“ENTERPRISE” shown in Figure 5 of Morita corresponds to a domain because of
`
`the “IS-A” relationship between it and other keywords. Figure 5 does not show
`
`any other keywords at the end of an “IS-A” or “IS-PART-OF” relationship. Id. at
`
`Fig. 5. Assuming a keyword connection table did contain more than one keyword
`
`at the end of an “IS-A” or “IS-PART-OF” relationship, one of skill in the art would
`
`
`
`14
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 14
`
`
`
`not reasonably conclude that those two keywords should be related based on
`
`Morita’s teachings that its “graph is normally not a complete graph” where all
`
`keywords are related, as shown in Figure 9. Id. at 7:14-42.
`
`42.
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`I understand the Petition has relied on the “IS-A” or “IS-PART-OF”
`
`relationship of keywords to disclose the claimed hierarchy between the tags in the
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`metafile in Morita. Yet, as discussed above, the ‘434 Patent does not use the term
`
`hierarchy to describe domains being above categories, but rather to describe a
`
`priority of tags in a metafile to assist further searching. Ex. 1004 at 2:31-33, 4:42,
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`8:55-57, 9:42-47, 9:54-56, 11:64-12:8, 8:1-7, 8:55-57, 9:43-47.
`
`43. One of ordinary skill in the art would not understand Figure 5 or any
`
`other disclosure in Morita to teach a priority of tags in a metafile. While Figures 5-
`
`8 indicates “relationship values” between keywords, Morita uses these values to
`
`determine the “amplitude of the relation” and to determine which keywords exceed
`
`a certain threshold and are thus considered relevant to the search request. Ex. 1007
`
`at 13:23-26 and 15:7-10. However, the priority of related categories is a different
`
`concept than amplitude of relation between keywords. For example, if a user
`
`searches for “car” one might want to prioritize the additional keyword of
`
`“insurance” over “truck” despite a lesser amplitude of relationship between “car”
`
`and “truck” than between “car” and “insurance.”
`
`44. Lastly, there is also no teaching in Lassila alone or in combination
`
`
`
`15
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 15
`
`
`
`with Morita that would lead one of skill in the art to consider different keywords at
`
`the end of an “IS-A” or “IS-PART-OF” relationship in Morita to be related. There
`
`is also no teaching in Lassila alone or in combination with Morita to establish a
`
`priority among tags in a metafile.
`
`
`
`VIII. Perjury Statement
`
`I declare that all statements made herein of my knowledge are true, and that
`
`all statements made on information and belief are believed to be true, and that
`
`these statements were made with the knowledge that willful false statements and
`
`the like so made are punishable by fine or imprisonment, or both, under Section
`
`1001 of Title 18 of the United States Code.
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`
`
`Executed on March 27, 2016 in Paris, France.
`
`
`
`__________________
`Dr. Yannis Papakonstantinou
`
`
`
`16
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 16
`
`
`
`IV I LLC
`Exhibit 2001
`
`IPR2016-00020
`Petitioners Old Republic General Ins. Group, Inc., et al. Ex. 1035, p. 17
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