Case 6:20-cv-00592-ADA Document 1-2 Filed 06/29/20 Page 1 of 16
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`Exhibit B
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`Case 6:20-cv-00592-ADA Document 1-2 Filed 06/29/20 Page 2 of 16
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`Gucci.com website (“The accused instrumentality”)
`The accused instrumentality practices a method performed in a system comprising user navigable nodes (e.g.,
`Gucci.com has different product categories (nodes) such as What’s New, Women, Men, Children, etc. for selection
`by a user), documents (e.g., products webpages) attached to the user navigable nodes (e.g., Gucci.com has different
`products categories (nodes) such as What’s New, Women, Men, Children, etc. for selection by a user), keywords
`(e.g., products webpages are tagged using keywords such as boot, etc.) associated with the user navigable nodes (e.g.,
`Gucci.com has different products categories (nodes) such as What’s New, Women, Men, Children, etc. for selection
`by a user), and having search (e.g., search box) and navigation capability that allows users to move from node to
`node via links between the nodes (e.g., from the home page node, users can go to nodes such as “What’s New”,
`“Women”, “Men”, “Children”, etc.; and then within a node, such as Men, Gucci.com contains nodes of particular
`categories such as “Bags”, “Ready to Wear”, “Shoes”, etc. which in turn contain particular products nodes) and make
`selections when at individual nodes (e.g., a desired products node).
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`US7689617
`1. A method
`performed in a system
`comprising user
`navigable nodes,
`documents attached to
`the user navigable
`nodes, keywords
`associated with the
`user navigable nodes
`and having search and
`navigation capability
`that allows users to
`move from node to
`node via links between
`the nodes and make
`selections when at
`individual nodes, the
`method comprising, at
`a user navigable node
`within the system:
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`https://www.gucci.com/us/en/
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`As shown below, the accused instrumentality has different product categories (nodes) for user selection. It provides
`navigation capability that allows users to move from a products category (a node), “Men”, to sub-product categories
`(another node), “Bags”, “Ready to Wear”, “Shoes”, etc. within the “Men” category, via links between the nodes and
`make selections when at individual nodes.
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`Case 6:20-cv-00592-ADA Document 1-2 Filed 06/29/20 Page 3 of 16
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`https://www.gucci.com/us/en/
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`https://www.gucci.com/us/en/
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`https://www.gucci.com/us/en/ca/men/shoes-for-men/boots-for-men-c-men-shoes-boots
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`Case 6:20-cv-00592-ADA Document 1-2 Filed 06/29/20 Page 5 of 16
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`https://www.gucci.com/us/en/pr/men/shoes-for-men/boots-for-men/mens-boot-with-interlocking-g-horsebit-p-
`6143261D0701068
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`As shown below, the accused instrumentality provides a webpage related to an individual node and tags the node
`with keywords.
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`https://www.gucci.com/us/en/st/newsearchpage?searchString=boots&search-cat=header-search
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`Case 6:20-cv-00592-ADA Document 1-2 Filed 06/29/20 Page 7 of 16
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`https://www.gucci.com/us/en/pr/men/shoes-for-men/boots-for-men/mens-boot-with-interlocking-g-horsebit-p-
`6143261D0701068
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`The accused instrumentality practices receiving an input (e.g., a user inputted search query) from a user.
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`receiving an input
`from a user;
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`https://www.gucci.com/us/en/
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`determining that the
`input contains an
`unknown word;
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`https://www.gucci.com/us/en/st/newsearchpage?searchString=boots&search-cat=header-search
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`The accused instrumentality practices determining that the input (e.g., a user inputted search query) contains an
`unknown word (e.g., a word which is not a keyword).
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`https://www.gucci.com/us/en/
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`https://www.gucci.com/us/en/
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`The accused instrumentality practices subsequent to the determining (e.g., determining a new word which is not a
`keyword), navigating through the system to a current node (e.g., a products node desired by the user) from the user
`navigable node (e.g., home page node) based upon at least one additional input (e.g., a user input to select a desired
`products) from the user that was provided while at the user navigable node (e.g., home page node).
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`As shown below, when a user searches for “drsse” which is a misspelled word, the accused instrumentality determines
`that the searched word is an unknown word i.e., neither a keyword nor a synonym of the keywords. It provides results
`to the user and navigates the user to the desired product (e.g., current node), “Wool silk sleeveless dress” based on
`the selection of the desired product by the user.
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`subsequent to the
`determining,
`navigating through the
`system to a current
`node from the user
`navigable node based
`upon at least one
`additional input from
`the user that was
`provided while at the
`user navigable node;
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`https://www.gucci.com/us/en/
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`https://www.gucci.com/us/en/st/newsearchpage?searchString=drsse&search-cat=header-search
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`presenting at least one
`response to the user
`based upon the
`documents attached to
`the current node
`resulting from the
`navigation; and
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`https://www.gucci.com/us/en/pr/women/ready-to-wear-for-women/dresses-for-women/mini-dresses-for-
`women/wool-silk-sleeveless-dress-p-631483ZAD889205
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`The accused instrumentality practices presenting at least one response (e.g., displaying at the user device) to the user
`based upon the documents (e.g., webpage related to a product) attached to the current node (e.g., a product node)
`resulting from the navigation.
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`As shown below, when a user searches for “drsse” which is a misspelled word, the accused instrumentality determines
`that the searched word is an unknown word i.e., neither a keyword nor a synonym of the keywords. It provides results
`to the user and navigates the user to the desired product (e.g., current node), “Wool silk sleeveless dress” based on
`the selection of the desired product by the user.
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`Case 6:20-cv-00592-ADA Document 1-2 Filed 06/29/20 Page 13 of 16
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`https://www.gucci.com/us/en/
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`https://www.gucci.com/us/en/st/newsearchpage?searchString=drsse&search-cat=header-search
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`Case 6:20-cv-00592-ADA Document 1-2 Filed 06/29/20 Page 14 of 16
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`https://www.gucci.com/us/en/pr/women/ready-to-wear-for-women/dresses-for-women/mini-dresses-for-
`women/wool-silk-sleeveless-dress-p-631483ZAD889205
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`The accused instrumentality practices following presentation of the at least one response (e.g., displaying at the user
`device), learning one or more associations between the unknown word (e.g., a word which is not a keyword such as
`“drsse”) and one or more keywords (e.g., keywords related to the product node) from the documents (e.g., webpage
`of a product) attached to the current node (e.g., a products node), such that a direct relationship is formed between
`the unknown word (e.g., a word which is not a keyword such as “drsse”) and the one or more keywords (e.g.,
`keywords related to the products node).
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`As shown below, when a user searches for “drsse”, a misspelled word, the accused instrumentality directs the user
`to a desired product based on the user selection. The accused instrumentality learns the misspelled word and
`associates it with the keywords related to the desired product. Shown page has different results then that are available
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`following presentation
`of the at least one
`response, learning one
`or more associations
`between the unknown
`word and one or more
`keywords from the
`documents attached to
`the current node, such
`that a direct
`relationship is formed
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`between the unknown
`word and the one or
`more keywords.
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`for search for correctly spelled word “drsse”. This indicates that accused instrumentality has associated key word
`“drsse” with the displayed results upon previous selection by users on the website.
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`https://www.gucci.com/us/en/st/newsearchpage?searchString=drsse&search-cat=header-search
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`https://www.gucci.com/us/en/st/newsearchpage?searchString=dress&search-cat=header-search
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