UNITED STATES PATENT AND TRADEMARK OFFICE
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`MINDGEEK USA INC., MINDGEEK S.À.R.L.,
`MINDGEEK USA INC., MINDGEEK S.A.R.L.,
`MG FREESITES LTD., MG FREESITES II LTD.,
`MG FREESITES LTD., MG FREESITES II LTD.,
`MG CONTENT RK LTD., MG CONTENT DP LTD.,
`MG CONTENT RK LTD., MG CONTENT DP LTD.,
`MG CONTENT RT LTD., MG PREMIUM LTD.,
`MG CONTENT RT LTD., MG PREMIUM LTD.,
`MG CONTENT SC LTD., MG CYPRUS LTD.,
`MG CONTENT SC LTD., MG CYPRUS LTD.,
`LICENSING IP INTERNATIONAL S.À.R.L.,
`LICENSING IP INTERNATIONAL S.A.R.L.,
`9219-1568 QUÉBEC INC. d/b/a ENTREPRISE MINDGEEK CANADA, and
`9219-1568 QUEBEC INC. d/b/a ENTREPRISE MINDGEEK CANADA, and
`COLBETTE II LTD.,
`COLBETTE II LTD.,
`
`Petitioners
`Petitioners
`
`v.
`v.
`
`UNIVERSITY OF SOUTHERN CALIFORNIA
`UNIVERSITY OF SOUTHERN CALIFORNIA
`
`PRESERVATION TECHNOLOGIES LLC
`PRESERVATION TECHNOLOGIES LLC
`
`Patent No. 6,199,060
`Patent No. 6,199,060
`
`Issue Date: March 6, 2001
`Issue Date: March 6, 2001
`
`Title: Method and Apparatus Management of Multimedia Assets
`Title: Method and Apparatus Management of Multimedia Assets
`
`____________________________________________________________
`
`DECLARATION OF H V JAGADISH, PH.D.
`DECLARATION OF H V JAGADISH, PH.D.
`
`Page 1 of 17
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`TABLE OF CONTENTS
`TABLE OF CONTENTS
`
`I.
`Introduction and Qualifications .......................................................................... 1
` 1
`I. Introduction and Qualifications (cid:9)
`II. Understanding of the Governing Law ................................................................ 4
`4
`II. Understanding of the Governing Law (cid:9)
`A.
`Types of Claims – Independent and Dependent........................................... 4
`4
`A. Types of Claims — Independent and Dependent (cid:9)
`B.
`Invalidity by Anticipation or Obviousness................................................... 4
`B.
`4
`Invalidity by Anticipation or Obviousness (cid:9)
`C.
`Secondary or Objective Evidence of Nonobviousness ................................ 6
`C.
`Secondary or Objective Evidence of Nonobviousness (cid:9)
`6
`D. Relevant Time Period for the Anticipation and Obviousness Analyses.......... 7
`D. Relevant Time Period for the Anticipation and Obviousness Analyses (cid:9)
`7
`E.
`Basis For My Opinion .................................................................................. 7
`E. Basis For My Opinion (cid:9)
`7
`F. Level of Ordinary Skill in the Art in the Relevant Timeframe ........................ 7
`F. Level of Ordinary Skill in the Art in the Relevant Timeframe (cid:9)
`7
`III. State of the Art at the Claimed Priority Date .................................................. 8
`III. State of the Art at the Claimed Priority Date (cid:9)
`8
`A.
`Indexing and Catalogs .................................................................................. 8
`A. (cid:9)
`Indexing and Catalogs (cid:9)
`8
`IV. Discussion of the ’060 Patent ........................................................................ 11
`11
`IV. (cid:9) Discussion of the '060 Patent (cid:9)
`A. Overview ........................................................................................................ 11
`11
`A. Overview (cid:9)
`B.
`Claim Terms of the ’060 Patent ................................................................. 13
`B. Claim Terms of the '060 Patent (cid:9)
`13
`V. The Prior Art References .................................................................................. 13
`V. The Prior Art References (cid:9)
`13
`VI. Conclusion ..................................................................................................... 15
`VI. Conclusion (cid:9)
` 15
`
`ii ii
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`I, H V Jagadish, hereby declare the following:
`I, H V Jagadish, hereby declare the following:
`
`1.
`1.
`
`I have been asked to provide my opinions concerning claims 1-18 of
`I have been asked to provide my opinions concerning claims 1-18 of
`
`U.S. Patent No. 6,199,060 (“’060 Patent”). I am being compensated for my time in
`U.S. Patent No. 6,199,060 ("'060 Patent"). I am being compensated for my time in
`
`preparing this declaration, but my compensation is not tied to the outcome of this
`preparing this declaration, but my compensation is not tied to the outcome of this
`
`matter and my compensation is not based on the substance of the opinions rendered
`matter and my compensation is not based on the substance of the opinions rendered
`
`here.
`here.
`
`I.
`I. (cid:9)
`
`Introduction and Qualifications
`Introduction and Qualifications
`2.
`All of my opinions stated in this declaration are based on my own
`2. All of my opinions stated in this declaration are based on my own
`
`personal knowledge and professional judgment. In forming my opinions, I have
`personal knowledge and professional judgment. In forming my opinions, I have
`
`relied on my knowledge and experience in software development practices, and on
`relied on my knowledge and experience in software development practices, and on
`
`the documents and information referenced in this report. I am competent to testify
`the documents and information referenced in this report. I am competent to testify
`
`as to the matters set forth herein.
`as to the matters set forth herein.
`
`3.
`3.
`
`I am the Bernard A. Galler Collegiate Professor of Electrical
`I am the Bernard A. Galler Collegiate Professor of Electrical
`
`Engineering and Computer Science at the University of Michigan. I am part of the
`Engineering and Computer Science at the University of Michigan. I am part of the
`
`database group and the software systems laboratory at the University. As a professor,
`database group and the software systems laboratory at the University. As a professor,
`
`I teach courses related to database management, the web, and data structures and
`I teach courses related to database management, the web, and data structures and
`
`algorithms.
`algorithms.
`
`4.
`My research focuses on how to build database systems and query
`4. My research focuses on how to build database systems and query
`
`models so that they are truly usable and how to design analytics processes so that
`models so that they are truly usable and how to design analytics processes so that
`
`they can deliver real insights to non-technical decision makers. My research is
`they can deliver real insights to non-technical decision makers. My research is
`
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`focused on building computing and data systems that have the “right” end-to-end
`focused on building computing and data systems that have the "right" end-to-end
`
`capability, in terms of meeting the users’ needs effectively, with minimum effort on
`capability, in terms of meeting the users' needs effectively, with minimum effort on
`
`their part.
`their part.
`
`5.
`Attached hereto as Exhibit 1007 is a true and correct copy of my
`5. Attached hereto as Exhibit 1007 is a true and correct copy of my
`
`Curriculum Vitae.
`Curriculum Vitae.
`
`6.
`6.
`
`I obtained my Ph.D. from Stanford University in 1985, and worked
`I obtained my Ph.D. from Stanford University in 1985, and worked
`
`many years for AT&T where I eventually headed the database department. I began
`many years for AT&T where I eventually headed the database department. I began
`
`my work at the University of Michigan in the fall of 1999, and also performed work
`my work at the University of Michigan in the fall of 1999, and also performed work
`
`at the University of Illinois.
`at the University of Illinois.
`
`7.
`7.
`
`I have published extensively, and am recognized as a leading
`I have published extensively, and am recognized as a leading
`
`researcher in the area of databases.
`researcher in the area of databases.
`
`8.
`8.
`
`I am a Fellow of the ACM, a Fellow of AAAS, and named inventor
`I am a Fellow of the ACM, a Fellow of AAAS, and named inventor
`
`on 37 United States patents.
`on 37 United States patents.
`
`9.
`9.
`
`I am being compensated at the rate of $670 per hour for my work as
`I am being compensated at the rate of $670 per hour for my work as
`
`an expert in this case. My compensation is not dependent on the content of my
`an expert in this case. My compensation is not dependent on the content of my
`
`opinions or the outcome of this case.
`opinions or the outcome of this case.
`
`10.
`The references I considered in preparing this declaration are listed
`10. The references I considered in preparing this declaration are listed
`
`below.
`below.
`
`•
`•
`
`•
`•
`
`U.S Patent No. 6,092,080.
`U.S Patent No. 6,092,080.
`
`File history for U.S Patent No. 6,092,080.
`File history for U.S Patent No. 6,092,080.
`
`2 2
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`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`•
`•
`
`U.S. Patent No. 6,181,336 to Chiu.
`U.S. Patent No. 6,181,336 to Chiu.
`
`U.S. Patent No. 5,907,837 to Ferrel.
`U.S. Patent No. 5,907,837 to Ferrel.
`
`U.S. Patent No. 6,199,060.
`U.S. Patent No. 6,199,060.
`
`File history for U.S. Patent No. 6,199,060.
`File history for U.S. Patent No. 6,199,060.
`
`U.S. Patent No. 6,212,527.
`U.S. Patent No. 6,212,527.
`
`File History for U.S. Patent No. 6,212,527.
`File History for U.S. Patent No. 6,212,527.
`
`Canadian Patent Application No. 2,128,667 to Jones-Lee.
`Canadian Patent Application No. 2,128,667 to Jones-Lee.
`
`Objective video quality assessment system based on human perception
`Objective video quality assessment system based on human perception
`
`to Webster et al.
`to Webster et al.
`
`U.S. Patent No. 5,630,121 to Braden-Harder et al.
`U.S. Patent No. 5,630,121 to Braden-Harder et al.
`
`European Patent Application Pub. No. 0 609 517 to Braden-Harder et
`European Patent Application Pub. No. 0 609 517 to Braden-Harder et
`
`al.
`al.
`
`U.S. Patent No. 5,668,897 to Stolfo.
`U.S. Patent No. 5,668,897 to Stolfo.
`
`U.S. Patent No. 5,307,266 to Hayashi et al.
`U.S. Patent No. 5,307,266 to Hayashi et al.
`
`U.S. Patent No. 6,574,638 to Gustman
`U.S. Patent No. 6,574,638 to Gustman
`
`File History for U.S. Patent No. 6,574,638.
`File History for U.S. Patent No. 6,574,638.
`
`U.S. Patent No. 5,832,495 to Gustman.
`U.S. Patent No. 5,832,495 to Gustman.
`
`Any references cited herein.
`Any references cited herein.
`
`3 3
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`II.
`II. (cid:9)
`
`Understanding of the Governing Law
`Understanding of the Governing Law
`
`A.
`A. (cid:9)
`
`Types of Claims – Independent and Dependent
`Types of Claims — Independent and Dependent
`
`11.
`11.
`
`I understand that
`there are two types of U.S. patent claims: 1)
`I understand that there are two types of U.S. patent claims: 1)
`
`independent claims and 2) dependent claims. I understand that independent claims
`independent claims and 2) dependent claims. I understand that independent claims
`
`only include the aspects stated in the independent claim. I further understand that
`only include the aspects stated in the independent claim. I further understand that
`
`dependent claims include the aspects stated in that dependent claim, plus all the
`dependent claims include the aspects stated in that dependent claim, plus all the
`
`aspects stated in the other claim(s) from which that dependent claim depends.
`aspects stated in the other claim(s) from which that dependent claim depends.
`
`B.
`B. (cid:9)
`12.
`12.
`
`Invalidity by Anticipation or Obviousness
`Invalidity by Anticipation or Obviousness
`I understand that a claim is invalid if it is anticipated or obvious.
`I
`I understand that a claim is invalid if it is anticipated or obvious. I
`
`understand that anticipation of a claim requires that every element of a claim is
`understand that anticipation of a claim requires that every element of a claim is
`
`disclosed expressly or inherently in a single prior art reference, arranged as in the
`disclosed expressly or inherently in a single prior art reference, arranged as in the
`
`claim. With regard to inherency, I understand that anticipation by inherency requires
`claim. With regard to inherency, I understand that anticipation by inherency requires
`
`that one of ordinary skill in the relevant art would have recognized that the missing
`that one of ordinary skill in the relevant art would have recognized that the missing
`
`descriptive matter is necessarily present in the subject matter described in the
`descriptive matter is necessarily present in the subject matter described in the
`
`reference.
`reference.
`
`13.
`13.
`
`I further understand that obviousness of a claim requires that the claim
`I further understand that obviousness of a claim requires that the claim
`
`be obvious from the perspective of a person of ordinary skill in the relevant art, at
`be obvious from the perspective of a person of ordinary skill in the relevant art, at
`
`the time the invention was made. In analyzing obviousness, I understand that it is
`the time the invention was made. In analyzing obviousness, I understand that it is
`
`important to understand the scope of the claims, the level of skill in the relevant art,
`important to understand the scope of the claims, the level of skill in the relevant art,
`
`the scope and content of the prior art, the differences between the prior art and the
`the scope and content of the prior art, the differences between the prior art and the
`
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`claims, and any secondary considerations.
`claims, and any secondary considerations.
`
`14.
`14.
`
`I also understand that if a technique has been used to improve one
`I also understand that if a technique has been used to improve one
`
`device, and a person of ordinary skill in the art would recognize that it would
`device, and a person of ordinary skill in the art would recognize that it would
`
`improve similar devices in the same way, using the technique is obvious unless its
`improve similar devices in the same way, using the technique is obvious unless its
`
`actual application is beyond his or her skill. For instance, I understand that the
`actual application is beyond his or her skill. For instance, I understand that the
`
`simple substitution of one known element for another or the mere application of a
`simple substitution of one known element for another or the mere application of a
`
`known technique to a piece of prior art ready for the improvement is obvious.
`known technique to a piece of prior art ready for the improvement is obvious.
`
`15.
`15.
`
`In addition, I understand that the United States Supreme Court has said
`In addition, I understand that the United States Supreme Court has said
`
`that “[t]he use of one material instead of another in constructing a known machine is,
`that "[t]he use of one material instead of another in constructing a known machine is,
`
`in most cases, so obviously a matter of mere mechanical judgment, and not of
`in most cases, so obviously a matter of mere mechanical judgment, and not of
`
`invention, unless some new and useful result, an increase of efficiency, or a decided
`invention, unless some new and useful result, an increase of efficiency, or a decided
`
`saving in the operation, is clearly attained.” Hicks v. Kelsey, 85 U.S. 670, 673 (1873).
`saving in the operation, is clearly attained." Hicks v. Kelsey, 85 U.S. 670, 673 (1873).
`
`Moreover, to avoid obviousness, I understand that such a new and useful result,
`Moreover, to avoid obviousness, I understand that such a new and useful result,
`
`increase of efficiency, or decided saving in the operation must be unpredictable. KSR
`increase of efficiency, or decided saving in the operation must be unpredictable. KSR
`
`Int’l Co. v. Teleflex Inc., 550 U.S. 398, 416 (U.S. 2007) (“when a patent claims a
`Int'l Co. v. Teleflex Inc., 550 U.S. 398, 416 (U.S. 2007) ("when a patent claims a
`
`structure already known in the prior art that is altered by the mere substitution of one
`structure already known in the prior art that is altered by the mere substitution of one
`
`element for another known in the field, the combination must do more than yield a
`element for another known in the field, the combination must do more than yield a
`
`predictable result.”).
`predictable result.").
`
`16.
`There may also be a specific “teaching, suggestion or motivation” to
`16. There may also be a specific "teaching, suggestion or motivation" to
`
`combine any first prior art reference with a second prior art reference. Such a
`combine any first prior art reference with a second prior art reference. Such a
`
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`“teaching, suggestion, or motivation” to combine the first prior art reference with
`"teaching, suggestion, or motivation" to combine the first prior art reference with
`
`the second prior art reference can be explicit or implicit.
`the second prior art reference can be explicit or implicit.
`
`17.
`17.
`
`I understand that there are several sources for a “teaching, suggestion
`I understand that there are several sources for a "teaching, suggestion
`
`or motivation” to combine references: the nature of the problem to be solved, the
`or motivation" to combine references: the nature of the problem to be solved, the
`
`teachings of the prior art, and the knowledge of the persons of ordinary skill in the
`teachings of the prior art, and the knowledge of the persons of ordinary skill in the
`
`art. In addition, market forces or other design incentives may be what produced a
`art. In addition, market forces or other design incentives may be what produced a
`
`change, rather than true inventiveness. I also know that the application of common
`change, rather than true inventiveness. I also know that the application of common
`
`sense and ordinary skill to solve a problem is not patentable.
`sense and ordinary skill to solve a problem is not patentable.
`
`18.
`18.
`
`I understand that when considering invalidity, each claim must be
`I understand that when considering invalidity, each claim must be
`
`considered individually.
`considered individually.
`
`C.
`C. (cid:9)
`
`Secondary or Objective Evidence of Nonobviousness
`Secondary or Objective Evidence of Nonobviousness
`
`19.
`19.
`
`I understand that secondary considerations are relevant
`to the
`I understand that secondary considerations are relevant to the
`
`determination of whether a claim is obvious. Such secondary considerations can
`determination of whether a claim is obvious. Such secondary considerations can
`
`include evidence of commercial success caused by an invention, evidence of a long-
`include evidence of commercial success caused by an invention, evidence of a long-
`
`felt need that was solved by an invention, evidence that others copied an invention,
`felt need that was solved by an invention, evidence that others copied an invention,
`
`or evidence that an invention achieved a surprising result. I understand that such
`or evidence that an invention achieved a surprising result. I understand that such
`
`evidence must have a nexus, or causal relationship to the elements of a claim, in
`evidence must have a nexus, or causal relationship to the elements of a claim, in
`
`order to be relevant to the obviousness or non-obviousness of the claim. I have not
`order to be relevant to the obviousness or non-obviousness of the claim. I have not
`
`been provided any such secondary considerations in relation to the claims of the ’060
`been provided any such secondary considerations in relation to the claims of the '060
`
`Patent.
`Patent.
`
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`D. Relevant Time Period for the Anticipation and Obviousness
`D. Relevant Time Period for the Anticipation and Obviousness
`
`Analyses
`Analyses
`
`20.
`20. (cid:9)
`
`I also understand that the earliest U.S. application that eventually led to
`I also understand that the earliest U.S. application that eventually led to
`
`the ’060 Patent was filed on July 8, 1996. Therefore, for the purposes of this
`the '060 Patent was filed on July 8, 1996. Therefore, for the purposes of this
`
`declaration, I have analyzed anticipation and obviousness as of July 8, 1996.
`declaration, I have analyzed anticipation and obviousness as of July 8, 1996.
`
`E.
`E. (cid:9)
`
`Basis For My Opinion
`Basis For My Opinion
`
`21.
`In forming my opinion, I have relied on the ’060 Patent claims and
`21. In forming my opinion, I have relied on the '060 Patent claims and
`
`disclosure and the materials listed above, along with my belief as to the knowledge
`disclosure and the materials listed above, along with my belief as to the knowledge
`
`of the person of ordinary skill in the relevant art in the July 1996 timeframe.
`of the person of ordinary skill in the relevant art in the July 1996 timeframe.
`
`F. Level of Ordinary Skill in the Art in the Relevant Timeframe
`F. Level of Ordinary Skill in the Art in the Relevant Timeframe
`
`22.
`22.
`
`In ’060 Patent, I believe that a relevant person of ordinary skill in the art
`In '060 Patent, I believe that a relevant person of ordinary skill in the art
`
`(“POSITA”) would have had a B.S. degree in computer science or electrical
`("POSITA") would have had a B.S. degree in computer science or electrical
`
`engineering (or comparable degree) and two years of experience in databases or
`engineering (or comparable degree) and two years of experience in databases or
`
`networking.
`networking.
`
`23.
`These descriptions are approximate, and a higher level of education or
`23. These descriptions are approximate, and a higher level of education or
`
`specific skill might make up for less experience, and vice-versa.
`specific skill might make up for less experience, and vice-versa.
`
`24.
`24.
`
`I believe I have a sufficient level of knowledge, experience and
`I believe I have a sufficient level of knowledge, experience and
`
`education to provide an expert opinion, including what one of ordinary skill in the
`education to provide an expert opinion, including what one of ordinary skill in the
`
`art would have understood from the prior art in this field at that time.
`art would have understood from the prior art in this field at that time.
`
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`III.
`State of the Art at the Claimed Priority Date
`III. State of the Art at the Claimed Priority Date
`
`A.
`A. (cid:9)
`
`Indexing and Catalogs
`Indexing and Catalogs
`
`25.
`Even before computers were in widespread use, humanity had felt a
`25. Even before computers were in widespread use, humanity had felt a
`
`need to organize information and facilitate retrieval of items relevant to a query.
`need to organize information and facilitate retrieval of items relevant to a query.
`
`Libraries developed catalog systems for this purpose.
`Libraries developed catalog systems for this purpose.
`
`26. With the rise of digital information, the field of information retrieval
`26. With the rise of digital information, the field of information retrieval
`
`was born, with the central purpose of presenting a user with repository items most
`was born, with the central purpose of presenting a user with repository items most
`
`relevant to an expressed query. These repository items were initially restricted to
`relevant to an expressed query. These repository items were initially restricted to
`
`text documents, and indeed, these remain of central importance even today.
`text documents, and indeed, these remain of central importance even today.
`
`27.
`27.
`
`In the 1960s and 70s, computers did not typically have the capacity to
`In the 1960s and 70s, computers did not typically have the capacity to
`
`analyze and index every word in the full text of a document. As such, it was typical
`analyze and index every word in the full text of a document. As such, it was typical
`
`practice to associate a set of keywords or index terms with a document, and to index
`practice to associate a set of keywords or index terms with a document, and to index
`
`only these in a catalog. Over time, as computers became more powerful, it became
`only these in a catalog. Over time, as computers became more powerful, it became
`
`possible to index every word in the full text of a document.
`possible to index every word in the full text of a document.
`
`28.
`28.
`
`In addition to text, other types of objects were also stored in
`In addition to text, other types of objects were also stored in
`
`repositories, including videos, photographs, and audio recordings. The simplest way
`repositories, including videos, photographs, and audio recordings. The simplest way
`
`to access such objects was by name. However, it was recognized that many users
`to access such objects was by name. However, it was recognized that many users
`
`would be interested in accessing such data by “content”. This was accomplished by
`would be interested in accessing such data by "content". This was accomplished by
`
`reusing an old idea of having a catalog distinct from the stored object, as had been
`reusing an old idea of having a catalog distinct from the stored object, as had been
`
`the case with text documents. Attributes or descriptions of the stored multimedia
`the case with text documents. Attributes or descriptions of the stored multimedia
`
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`object, whether derived by the computer in an automated fashion or specified
`object, whether derived by the computer in an automated fashion or specified
`
`explicitly by a human, could be stored and indexed in a catalog separate from the
`explicitly by a human, could be stored and indexed in a catalog separate from the
`
`object itself.
`In fact, these attributes or descriptions would often be stored in a
`object itself. In fact, these attributes or descriptions would often be stored in a
`
`relational database while the objects themselves were stored in separate files.
`relational database while the objects themselves were stored in separate files.
`
`Exhibit 1008, Query by image and video content: the QBIC system by Flickner et
`Exhibit 1008, Query by image and video content: the QBIC system by Flickner et
`
`al,
`IEEE Computer, Volume: 28 Issue: 9 pp. 23 – 32, Sep 1995, DOI:
`al, IEEE Computer, Volume: 28 Issue: 9 pp. 23 — 32, Sep 1995, DOI:
`
`10.1109/2.410146.
`10.1109/2.410146.
`
`29. This technology was in widespread use in the 1980s. Archive servers,
`29. This technology was in widespread use in the 1980s. Archive servers,
`
`and index servers distinct from them, were introduced. Storage managers had
`and index servers distinct from them, were introduced. Storage managers had
`
`already been in widespread use for many years by then.
`already been in widespread use for many years by then.
`
`30. By the early 1990s, computers had become powerful enough and digital
`30. By the early 1990s, computers had become powerful enough and digital
`
`storage capacities had increased enough that it became feasible to digitize and store
`storage capacities had increased enough that it became feasible to digitize and store
`
`videos: not just short clips but even entire movies. There was tremendous interest
`videos: not just short clips but even entire movies. There was tremendous interest
`
`in so-called “video-on-demand”. There was a great deal of progress made on the
`in so-called "video-on-demand". There was a great deal of progress made on the
`
`storage and retrieval of videos.
`storage and retrieval of videos.
`
`31. There was also work reported on building these servers with tertiary
`31. There was also work reported on building these servers with tertiary
`
`storage. Exhibit 1009, Efficient organization and access of multi-dimensional
`storage. Exhibit 1009, Efficient organization and access of multi-dimensional
`
`datasets on tertiary storage systems by L.T. Chen et al. in Information Systems
`datasets on tertiary storage systems by L.T. Chen et al. in Information Systems
`
`Volume 20, Issue 2, April 1995, Pages 155-183. And also in a distributed
`Volume 20, Issue 2, April 1995, Pages 155-183. And also in a distributed
`
`environment. Exhibit 1010, A Distributed Hierarchical Storage Manager for a
`environment. Exhibit 1010, A Distributed Hierarchical Storage Manager for a
`
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`Video-on-Demand System by Craig Federighi and Lawrence A. Rowe, Technical
`Video-on-Demand System by Craig Federighi and Lawrence A. Rowe, Technical
`
`Report
`Report (cid:9)
`
`No.
`No. (cid:9)
`
`UCB/CSD-94-795,
`UCB/CSD-94-795, (cid:9)
`
`February
`February (cid:9)
`
`1994,
`1994,
`
`http://www2.eecs.berkeley.edu/Pubs/TechRpts/1994/CSD-94-795.pdf.
`http ://www2. eecs .b erkeley. edu/Pub s/TechRpts/1994/C SD-94-795 .pdf.
`
`32. When a user specifies some search terms to retrieve a text document, it
`32. When a user specifies some search terms to retrieve a text document, it
`
`is often useful for the system to point the user to specific portions of the document
`is often useful for the system to point the user to specific portions of the document
`
`that are relevant, particularly if the document is long. Technology for such
`that are relevant, particularly if the document is long. Technology for such
`
`identification of “segments” or “snippets” of a text document has long been known.
`identification of "segments" or "snippets" of a text document has long been known.
`
`33. Similarly, given a long video, it is helpful for a user to be pointed to
`33. Similarly, given a long video, it is helpful for a user to be pointed to
`
`specific portions of it that are relevant to a particular search request. Fortunately,
`specific portions of it that are relevant to a particular search request. Fortunately,
`
`standard methods for video storage already segment videos into scenes. So it was
`standard methods for video storage already segment videos into scenes. So it was
`
`straightforward to adopt ideas from text document indexing for this purpose. See,
`straightforward to adopt ideas from text document indexing for this purpose. See,
`
`for example, Exhibit 1011, Content based video indexing and retrieval, by S.W.
`for example, Exhibit 1011, Content based video indexing and retrieval, by S.W.
`
`Smoliar and HongJiang Zhang, IEEE MultiMedia, Volume: 1 Issue: 2, Summer
`Smoliar and HongJiang Zhang, IEEE MultiMedia, Volume: 1 Issue: 2, Summer
`
`1994, pp. 62-72, DOI: 10.1109/93.311653. For another example, a paper from 1993
`1994, pp. 62-72, DOI: 10.1109/93.311653. For another example, a paper from 1993
`
`describes a system that had been constructed and says: “Our prototype system,
`describes a system that had been constructed and says: "Our prototype system,
`
`Media Streams, enables users to create multi-layered, iconic annotations of streams
`Media Streams, enables users to create multi-layered, iconic annotations of streams
`
`video data … by means of a cascading hierarchical structure . . . .” Exhibit 1012,
`video data ... by means of a cascading hierarchical structure . . . ." Exhibit 1012,
`
`Media Streams: an iconic visual language for video annotation, by M. Davis,
`Media Streams: an iconic visual language for video annotation, by M. Davis,
`
`Proceedings 1993 IEEE Symposium on Visual Languages, 24-27 Aug. 1993Print
`Proceedings 1993 IEEE Symposium on Visual Languages, 24-27 Aug. 1993Print
`
`ISBN: 0-8186-3970-9 DOI: 10.1109/VL.1993.269596.
`ISBN: 0-8186-3970-9 DOI: 10.1109NL.1993.269596.
`
`10 10
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`

`34. These technologies had in fact progressed enough by the mid-1990s
`34. These technologies had in fact progressed enough by the mid-1990s
`
`that people were beginning to build other facilities on the infrastructure. For
`that people were beginning to build other facilities on the infrastructure. For
`
`example, quality assessments could be used to annotate videos in Exhibit 1013,
`example, quality assessments could be used to annotate videos in Exhibit 1013,
`
`Objective video quality assessment system based on human perception by Arthur
`Objective video quality assessment system based on human perception by Arthur
`
`A. Webster et al, Proceedings Volume 1913, Human Vision, Visual Processing, and
`A. Webster et al, Proceedings Volume 1913, Human Vision, Visual Processing, and
`
`Digital Display IV; (1993) https://doi.org/10.1117/12.152700, 8 September 1993.
`Digital Display IV; (1993) https://doi.org/10.1117/12.152700, 8 September 1993.
`
`Similarly, video segments could be selectively retrieved and combined into a
`Similarly, video segments could be selectively retrieved and combined into a
`
`storyboard as described in Exhibit 1014, IDIC: assembling video sequences from
`storyboard as described in Exhibit 1014, IDIC: assembling video sequences from
`
`story plans and content annotations, by Sack and Davis, Proceedings of IEEE
`story plans and content annotations, by Sack and Davis, Proceedings of IEEE
`
`International Conference on Multimedia Computing and Systems, 14-19, May
`International Conference on Multimedia Computing and Systems, 14-19, May
`
`1994. Print ISBN: 0-8186-5530-5 DOI: 10.1109/MMCS.1994.292