Академический Документы
Профессиональный Документы
Культура Документы
Jonathan Stroud, Reg. No. 72,518 Roshan Mansinghani, Reg. No. 62,429
jonathan@unifiedpatents.com roshan@unifiedpatents.com
Unified Patents Inc. Unified Patents Inc.
1875 Connecticut Ave. NW, Floor 10 13355 Noel Road, Suite 1100
Washington, D.C., 20009 Dallas, TX, 75240
Telephone: (202) 805-8931 Telephone: (214) 945-0200
v.
IPR2017-01039
Patent 7,231,379
____________
TABLE OF CONTENTS
I. INTRODUCTION ............................................................................................ 1
42.104........................................................................................................................ 6
13
V. CONCLUSION............................................................................................... 68
i
IPR2017-01039
U.S. Patent No. 7,231,379
A. Real Party-In-Interest ................................................................................... 69
ii
IPR2017-01039
U.S. Patent No. 7,231,379
I. INTRODUCTION
U.S. Patent 7,231,379 (the 379 Patent). The 379 Patent broadly claims the use
vertices. Put simply, there are only two concepts related to navigation of
hierarchical systems in the claims, and they are both obvious in view of the prior
art.
First, when a user inputs a given keyword, the claimed method causes the
system to jump to the node or vertex associated with that keyword, without
requiring the user to traverse through each intervening step in the hierarchical
network. The allowance of the 379 Patent was largely based on this jumping
concept. However, as shown by the Wesemann and Fratkina prior art references,
arranged systems before the filing of the 379 Patent in 2002. See, e.g. Wesemann
(EX1004) at Abstract; see also, e.g., Smyth Decl. (EX1007) at 36-40, 49, 55-56,
84. Neither Wesemann nor Fratkina was cited during prosecution of the 379
Patent.
1
IPR2017-01039
U.S. Patent No. 7,231,379
Second, the 379 Patent includes four claims related to using a thesaurus to
search synonyms of user inputs and updating that thesaurus to understand new
synonyms. However, such thesaurus searching and updating had already been
significantly developed by the 1990s, and these thesaurus limitations fail to add
anything new over the prior art. Smyth Decl. (EX1007) at 41-45, 69-76.
Navigating hierarchical trees was not novel in 2002, and the claims of the
379 Patent fail to include any limitations that would make it a non-obvious
improvement over what had already been practiced for years before the filing of
the patent. See infra Section IV; see also Smyth Decl. (EX1007) generally at 31-
The 379 Patent relates to methods for searching a hierarchical menu tree
allegedly novel take on this concept is a search system that jumps to different
hierarchical tree. See, e.g., 379 Patent File History (EX1002) at 47 (Response to
solves the inadequacies of prior art systems, by allowing the system to cause the
2
IPR2017-01039
U.S. Patent No. 7,231,379
user to jump from one node in the hierarchy to another node that is not directly
connected to that node, without having to traverse through every intervening node
in the path . . . .); see also Patent Owners Opposition to Motion to Dismiss
(EX1003) at 18-19 (As discussed extensively during the prosecution history, the
jumping term, as defined above, was a point of novelty that distinguished the
claimed invention from the prior art.). In prosecution and litigation, Patent Owner
(PO) has construed jumping, used in both independent claims 1 and 7, to mean
a direct traversal from one node or vertex to another node or vertex that is not
vertices or to a node or vertex whose only least common ancestor with that node or
18; 379 Patent File History (EX1002) at 89 (Appeal Brief (May 31, 2005)). The
379 Patent asserts that jumping may occur laterally (i.e., across branches of the
branch). See, e.g., 379 Patent (EX1001) at 12:49-56, 14:54-63. A simple example
Figure 2:
1
For the purposes of this Petition, Petitioner does not contest this construction of
jumping as the broadest reasonable interpretation of this term. See Sec. III.D, infra.
3
IPR2017-01039
U.S. Patent No. 7,231,379
possible keywords are identified in the response and used to search
the index and identify any node to which the response may be
directed, irrespective of the hierarchy. Thus, a user response of an
orange to a verbal description located above the fruit node 202 in
the hierarchy, for example, What would you like to buy today?
would cause the system to identify orange as a key word from the
response, search the index, and directly identify node [](206) as the
node whose verbal description should be presented next, thereby
avoiding the need to traverse intervening nodes, for example, through
the fruit node (202)[], at all. This illustrates an example of a simple
jump according to the invention.
hierarchical tree without traversing through intervening nodes or vertices was well-
known prior to the filing of the 379 Patent. For example, Wesemann, cited below,
4
IPR2017-01039
U.S. Patent No. 7,231,379
discloses both lateral and vertical jumping through a hierarchical network, and
Fratkina, also cited below, teaches that users may skip over parts of a hierarchical
menu.
Claims 3-6 of the 379 Patent further recite a method for using a thesaurus
Additional synonyms for keywords may be added to the thesaurus and associated
with nodes as users input new words into the system and navigate the system. See
id. at 9:65-10:2, 10:41-43. As discussed herein, these concepts were also known
prior to the filing of the 379 Patent. See Smyth Decl. (EX1007) at 41-45, 69-76.
For example, Rajaraman, cited below, teaches each of these limitations in the
The application that resulted in the 379 Patent was filed on November 19,
2002. See 379 Patent (EX1001). For purposes of this proceeding, Petitioner
assumes that the priority date for the Challenged Claims is November 19, 2002.
The original application included 26 claims, but was reduced to seven claims due
seven claims were not amended from their original application during prosecution,
5
IPR2017-01039
U.S. Patent No. 7,231,379
claims 1 and 7, insisting that jumping required a system (as opposed to a user) to
traverse from one node to a second, non-adjacent node based on an input from a
user, without traversing through intervening nodes in the path. See id. at 62-64; see
also, e.g., id. at 89-90, 127-30, 133, 156. The applicant took issue with cited prior
art that applicant contended graphically presented the user with the matching node
and required the user to select the node to cause the jump. See id. at 64
(distinguishing Pooser). The applicant made only general and conclusory remarks
of independent claims 1 and 7. But, as discussed below, this concept was already
through in-between menu states. Unlike the cited prior art distinguished by
applicant, Wesemann (as well as Fratkina) uses interactive voice response systems
(like those disclosed in the 379 Patent) that automatically perform the
Petitioner certifies that the 379 Patent is available for IPR and that the
6
IPR2017-01039
U.S. Patent No. 7,231,379
Petitioner is not barred or estopped from requesting IPR challenging the claims of
In view of the prior art and evidence, claims 1-7 of the 379 Patent are
art references identified below, IPR of the Challenged Claims should be granted.
37 C.F.R. 42.104(b)(2).
Ground 4: Claims 3-6 are obvious under 103(a) over U.S. Pat.
No. 7,539,656 to Fratkina et al. (Fratkina) in view of U.S. Pat. EX1006,
EX1005
No. 6,366,910 to Rajaraman et al. (Rajaraman)
Section IV identifies where each element of the Challenged Claims is found in the
prior art. 37 C.F.R. 42.104(b)(4). The exhibit numbers of the supporting evidence
relied upon to support the challenges are provided above and the relevance of the
7
IPR2017-01039
U.S. Patent No. 7,231,379
evidence to the challenges raised are provided in Section IV. 37 C.F.R.
skill in the art (PHOSITA) at the time of the 379 Patent would have been a
education substituting for experience and vice versa. Smyth Decl. (EX1007) at
28-30.
The 379 Patent has not expired. As such, the claim terms should be given
42.100(b). Petitioner proposes the following constructions. All claim terms not
i. node
All seven claims use the term node. Referring to Figure 1, the 379 Patent states,
8
IPR2017-01039
U.S. Patent No. 7,231,379
[t]he individual boxes 102-120 are referred to as nodes and each represents a
specific choice or option in the hierarchy. 379 Patent (EX1001) at 4:22-26. Thus,
ii. vertex
Only claim 7 uses the term vertex (and its plural form, vertices). Node
and vertex are used interchangeably throughout both the patent specification and
its prosecution history. See, e.g., 379 Patent (EX1001) at 2:5-9 (In general, there
will also be a combination of vertices or nodes in the graph that best represent or
are closest to the goal the user is trying to accomplish. We call these vertices the
direct traversal from one node or vertex to another node or vertex). The only
9
IPR2017-01039
U.S. Patent No. 7,231,379
according to a connected graph that contains no circuits. We call such a
graph a tree. . . . Informally, a menu tree can be regarded as a
series of vertices in a hierarchy or ordered pattern, arranged in
rows of increasing numbers of vertices. More precisely, a menu
tree can be represented as a tree in which (i) the vertices are all the
options provided anywhere in the menu tree, plus a first vertex,
(ii) every vertex except the first vertex, i.e., every option vertex, is
associated with the verbal description (or such other means) by which a
menu presents that option, (iii) an edge connects the first vertex to
each vertex that the first menu presents to the user as an option,
and (iv) each other vertex is similarly connected by edges to every
other vertex that the corresponding menu presents to the user as an
option.
379 Patent (EX1001) at 3:5-27 (emphasis added); see also id. at 3:59-63 (It
iii. keyword
The 379 Patent teaches that each node in the hierarchy is associated with a
verbal description (whether audible or written) and that [e]ach such description
contains key words that are deemed to be of importance and other words that can
10
IPR2017-01039
U.S. Patent No. 7,231,379
node may have the associated verbal description Would you like to make a
deemed important, so all of the other words in the description can be ignored. Id.
at 4:37-41. Other nodes may have verbal descriptions with multiple keywords. For
at 4:44-51. And the word flight could be a keyword if the system includes non-
air travel options, such as train, but it could also be an ignored term if, for example,
The 379 Patent describes an index that associates keywords with nodes. Id.
at 4:62-5:7. This index allows the menu tree of nodes to be searched by keyword
regardless of where in the hierarchy the user is currently located by allowing them
to jump to a node matching the keyword. Id. at 5:7-12. The patent teaches that the
specific format described for the index is only for illustration and that other
techniques for interrelating data, such as hash tables, direct or indirect indexing,
keywords are identified from the users speech. Id. at 6:63-7:9. Importantly, the
11
IPR2017-01039
U.S. Patent No. 7,231,379
379 Patent explicitly teaches that a keyword can be more than just a single word
and can also include other forms of information, such as specific data patterns:
information, such as a data pattern, that is associated with at least one node or
vertex.
iv. jumping
As discussed above in the Summary of the 379 Patent, the applicant during
traversal from one node or vertex to another node or vertex that is not
or vertices or to a node or vertex whose only least common ancestor with that
node or vertex is the root node or vertex). See supra Sec. II.A (detailing Patent
(EX1003)). Petitioner notes that this jumping may occur laterally (i.e., across
branch). See, e.g., 379 Patent (EX1001) at 12:49-56, 14:54-63. Given Applicants
12
IPR2017-01039
U.S. Patent No. 7,231,379
repeated assertions regarding this term during prosecution and its subsequent
allowance, the BRI of jumping at least includes POs above quoted construction.
v. verbal description
The 379 Patent teaches that each node in the hierarchy is associated with a
verbal description that describes the subject matter of the particular node. Id. at
3:37-43, 4:32-41. The 379 Patent expressly defines a verbal description as a set
form.
June 22, 2001 and is prior art to the 379 Patent under 35 U.S.C. 102(e) (pre-
AIA). Wesemann (EX1004). Wesemann was not cited during prosecution of the
Wesemann is in the same field of endeavor as, and reasonably pertinent to,
the 379 Patent. As mentioned above, the 379 Patent relates to methods for
13
IPR2017-01039
U.S. Patent No. 7,231,379
type automated telephone voice response system. See 379 Patent (EX1001) at
3:49-58, see also id. at 3:5-14. The 379 Patent purports to solve problems related
Abstract, 2:22-30. Like the 379 Patent, Wesemann relates to improving the
user already knows what the final menu state will be as a problem in the art). And
Wesemann teaches solving this problem in the same manner as the 379 Patent
purports to do, by teaching a system which enables users to jump from one menu
state to another menu state of the telephone service system without having to enter
input for each menu state between the first and the second menus states.
Wesemann (EX1004) at Abstract (emphasis added); see also id. at 3:54-56 ([T]he
invention enables a user to jump over in between menu states, from a first menu
state to a second menu state with only a single user input. (emphasis added)), 3:6-
Wesemann is analogous prior art to the claimed invention of the 379 Patent. See
14
IPR2017-01039
U.S. Patent No. 7,231,379
i. Claim 1
in a hierarchical arrangement:
Wesemann (EX1004) at 3:33-46 (emphasis added); see also id. at Abstract, 10:40-
64, Figs. 5-6. The user may navigate the menu hierarchy by systematically moving
between nodes as prompted by the system, or the user may jump to different nodes
without transitioning through in-between menu states. See id. at 9:66-10:20; see
also id. at 1:13-19, 11:65-12:12, Fig. 5. A PHOSITA would understand that the
15
IPR2017-01039
U.S. Patent No. 7,231,379
Wesemann describes its teachings in an exemplary embodiment of a
such as support, sales, and a personnel directory. Id. at 10:40-45. These menus may
have their own submenus. For example, the sales menu has different submenus for
home, business, and refurbished computers, and each of these menus has a
submenu for laptops and desktops. Id. at Fig. 6. The menu and submenus constitute
(Main menu 610 and each of the submenus 620-674 comprise discrete menu
similar in structure to the flight system menu example described in the 379 Patent:
Wesemann:
Id. at Fig. 6.
16
IPR2017-01039
U.S. Patent No. 7,231,379
379 Patent:
[1(a)] at a first node, receiving an input from a user of the system, the input
containing at least one word identifiable with at least one keyword from among
multiple keywords,
Wesemann teaches a system that receives a user input, such as spoken words
64, 11:47-12:6. For example, the system may receive at a main menu state 610
spoken words from a user, such as refurbished laptop sales. Id. at 11:65-12:6. A
(keywords) with each of the menu states (nodes) in the hierarchy. Id. at 7:15-17
17
IPR2017-01039
U.S. Patent No. 7,231,379
(A template, such as template 232, maps all of the menu states of a telephone
menu system and all of the corresponding prompts and acceptable responses and
inputs.), 8:56-63, 12:13-16. The users spoken input (at least one word) is
responses and inputs (keywords) stored in the template to determine the node with
the accepted response that is most similar to the input. Id. at 6:56-64, 7:6-14,
12:13-21. This mapping of inputs to nodes allows the ability for user input to cause
Id. at 3:28-43 (emphasis added); see also id. at 10:65-11:16, 4:51-54 (Users
device that can be recognized and processed by the voicemail system.), 12:13-16
(The voice enabled user interface is able to determine what menu prompts are
most similar to the input entered by the user because all of the menu prompts and
18
IPR2017-01039
U.S. Patent No. 7,231,379
acceptable inputs and requests are mapped in a template). For example, when
user input in the form of the spoken words refurbished laptop sales is received at
a main menu node 610, the system identifies this as an accepted response
(keyword) for node 672 (refurbished laptop sales) and jump[s] directly to that
inputs (keywords) associated with each of the menu states (nodes) in the hierarchy,
is just like the 379 Patents index, which maps keyword associations with
different nodes. See 379 Patent (EX1001) at 5:2-4 (An index . . . associating
these keywords with the nodes containing them is then created.); 6:7-11 ([W]hen
19
IPR2017-01039
U.S. Patent No. 7,231,379
identified in the response and used to search the index and identify any node to
which the response may be directed .); see also Smyth Decl., (EX1007) at 51.
A PHOSITA, would understand that the acceptable inputs and requests mapped
in the template to associated menu states are keywords (e.g., one or more words or
patterns of data associated with nodes) to which the spoken words in the users
Wesemann compares the users spoken words to the acceptable inputs and
requests stored in the template for an IVR telephone system just like the 379
Patent compares a users spoken words to keywords stored in an index for an IVR
PHOSITA to be patterns of data (consistent with the 379 Patent) against which the
users spoken words are compared so as to determine whether those words are
sufficiently similar to any node to be an accepted input and to identify the most
exceedingly obvious for the acceptable inputs and requests mapped in the
2
The BRI of keyword at least includes one or more words or pieces of information,
such as a data pattern, that is associated with at least one node or vertex. See Sec.
III.D.iii, supra.
20
IPR2017-01039
U.S. Patent No. 7,231,379
PHOSITA would have been motivated to use keywords, because using keywords
to search directory trees had long been well known, including in most conventional
computer operating systems file storage systemsso it would have been natural
for a PHOSITA to use keywords, and a PHOSITA could have obtained predictable
been highly suggestive to a PHOSITA of keywords and would have also motivated
Wesemann also teaches that its keywords are identifiable from among
Wesemanns system that are mapped to user inputs via the template and the system
identifies the nodes that are most similar to the user input. Wesemann (EX1004) at
7:15-17, 8:56-63, 12:13-16, Fig. 6; see also Smyth Decl., (EX1007) at 49-52. To
the extent Patent Owner improperly contends that the first node must itself be
3
Claim 1 merely recites from among multiple keywords and does not recite that the
first node must itself be associated with multiple keywords from among which the
keyword identifiable with the word in the users input is identified. Such an interpretation
would be contrary to the 379 specification, which provides numerous examples of nodes
21
IPR2017-01039
U.S. Patent No. 7,231,379
correlating inputs with the acceptable inputs and requests, thus allowing multiple
disclosure that Wesemann teaches that nodes can store multiple acceptable
responses (keywords), i.e., multiple pieces of information or data patterns, that can
be compared to the users spoken words. Smyth Decl. (EX1007) at 54. Thus,
that each only have only one associated keyword. See, e.g., 379 Patent (EX1001) at
4:37-41 (For example, one node may have the associated verbal description Would you
like to make a reservation? In this description, there is only one key word
reservation deemed important, so all other words in the description can be ignored.),
7:12-17 (with each node 1-7 having only one associated keyword, even though multiple
22
IPR2017-01039
U.S. Patent No. 7,231,379
Wesemann, nonetheless teaches this interpretation of from among multiple
[1(b)] identifying at least one node, other than the first node, that is not directly
connected to the first node but is associated with the at least one keyword, and
jumping to the at least one node.
distinguishing the 379 Patent over the prior art. See Patent Owners Opposition to
includes a direct traversal from one node or vertex to another node or vertex that
is not directly connected to it (i.e., without traversal through any intervening nodes
or vertices or to a node or vertex whose only least common ancestor with that node
or vertex is the root node or vertex). See supra Sec. III.D.iv,., Wesemann teaches
this precise concept of allowing a user to jump over in between menu states:
23
IPR2017-01039
U.S. Patent No. 7,231,379
Wesemann (EX1004) at 3:47-56 (emphasis added); see also id. at Abstract, 3:10-
Specifically, Wesemann teaches identifying at least one node, other than the
first node, that is not directly connected to the first node but that is associated with
the acceptable response/input, i.e., keyword. This can be accomplished because all
menu states (nodes) in the hierarchy are mapped in template 232 to acceptable
232, maps all of the menu states of a telephone menu system and all of the
24
IPR2017-01039
U.S. Patent No. 7,231,379
over the prior art. This advantage should be appreciated even more
fully when considering that, according to the present embodiment, the
telephone service system of menu hierarchy 600 cannot recognize
audio or vocal commands, but instead is only responsive to DTMF
signals.
Id. at 12:25-42 (emphasis added), Fig. 6 (annotated). In the above example, a user
can jump vertically from main menu 610 to extension 123 without traversing
Alternatively, the user may jump laterally between nodes, such as jumping from
home laptop sales to home computer support without traversing up and down
the parent nodes sales, main menu, and computer support. Unlike the prior
art cited during prosecution of the 379 Patent, Wesemann teaches that this
25
IPR2017-01039
U.S. Patent No. 7,231,379
commands, or keywords, without requiring the user to select different menu items
from a display or navigate through the hierarchical menu. See, e.g., id. at 12:30-32
(For example, from main menu 610 a user can state 123 and the user will
associated with jumping from one menu state to another menu state are conducted
without the knowledge and efforts of the user . . . .). As discussed above for
user inputs (keywords) to menu states (nodes) to allow the user to jump to the
menu state that is most similar to the user input. See Wesemann as applied to
limitation [1(a)], supra; see also Wesemann (EX1001) at 12:12-36; see also Smyth
ii. Claim 2
least one node to the user. The 379 Patent defines a verbal description as a set
26
IPR2017-01039
U.S. Patent No. 7,231,379
form, and this is the BRI of this term. Id. at 1:50-52; see also supra Sec. III.D.v.
A verbal description may consist of message prompts, such as Would you like to
of menu prompts corresponding to each of the particular menu states (nodes), and
these menu prompts are verbally presented to a user over a telephone device when
Voicemail system 140 comprises voicemail data 150 that can include
any type of data that can be transmitted to a user over a telephone
device. In one preferred embodiment, voicemail data 150 comprises a
prerecorded message, such as, for example, a menu prompt, a
telephone phone message, a greeting, etc.
Id. at 5:62-67 (emphasis added); see also id. at 3:28-20 (The user responds to
prompts generated by the telephone service system by speaking into the telephone
device.); 7:15-17 (A template, such as template 232, maps all of the menu states
acceptable responses and inputs.) (emphasis added), 8:56-59 (In one presently
preferred embodiment, template 232 contains a map of all the menu states of a
telephone service system and all the prompts corresponding to each of the
menu states.) (emphasis added). For example, these verbal menu prompts may
27
IPR2017-01039
U.S. Patent No. 7,231,379
support, or press 3 followed by # for a directory of personnel. Id. at 11:33-38.
As other examples, these prompts may also include prompts for home computer
understand that after a user jumps to a node, the user will be presented with the
menu prompt (verbal description) for that node. See Smyth Decl. (EX1007) at 57.
provides a verbal description of multiple potential nodes in the event that a user
If a user enters the main menu 610 of the telephone service system of
the computer sales organization with the desire to purchase a
refurbished laptop computer, the user can systematically enter input in
response to menu prompts to reach refurbished laptop sales 672 by
navigating through sales 630 and refurbished computer sales 670 to
arrive at refurbished laptop sales 672. Alternatively, according to the
invention, a user can jump directly to refurbished laptop sales 672 by
28
IPR2017-01039
U.S. Patent No. 7,231,379
speaking the words refurbished laptop sales. If the user mistakenly
says, refurbished laptop computers, or refurbished notebook
sales, the voice-enabled user interface prompts the user with a
clarifying prompt, such as Would you like refurbished laptop
sales or refurbished desktop sales? The user can then enter the
appropriate input refurbished laptop sales.
teaches providing a verbal description associated with the at least one node to the
user, and, thus, teaches the limitation of claim 2. See Smyth Decl. (EX1007) at 57,
63.
iii. Claim 7
claims 1 and 2. Claim 7 refers to vertices, but as discussed above, the 379
patent uses vertices and nodes interchangeably, and the BRI of a vertex is
graph. See Sec. III.D.i, supra. Wesemann teaches a hierarchical menu tree that can
be represented as a graph containing vertices and edges, where the edges connect
at least two of the vertices. For example, in Figure 6 of Wesemann, the menu tree
29
IPR2017-01039
U.S. Patent No. 7,231,379
displays the vertices for Sales connected by edges to each of Home Computer
which provides verbal descriptions (a set of words relating to the subject matter
30
IPR2017-01039
U.S. Patent No. 7,231,379
corresponding to a particular menu state, or vertex, and users provide inputs to the
Wesemann (EX1004) at 3:28-35 (emphasis added); see also id. at 5:62-67, 7:15-17,
menu prompts. . . .); see Wesemann as applied to claim 2, supra. The menu
menu state (vertex). Id. For example, the system provides the prompt of asking the
at the main menu node 610. Id. at 11:33-55, Fig. 6. A PHOSITA, therefore, would
a verbal description associated with a first vertex. Smyth Decl. (EX1007) at 58-
60, 63.
[7(b)] analyzing the input to identify a meaningful term that can be associated
with at least one keyword
above for claim 1, Wesemann teaches using speech recognition software to analyze
31
IPR2017-01039
U.S. Patent No. 7,231,379
(keywords) stored in the template, which maps those keywords to each of the menu
states. See supra Sec. IV.A.i, Wesemann as applied to claim [1(a)] & [1(b)].
Wesemann teaches that the speech recognition software 230 interprets audio or
voice data received from a user and a comparison is made to determine if the input
PHOSITA would understand that this process identifies one or more meaningful
terms from the users spoken input that can be associated/compared with a
51-53. For example, the user can speak the words refurbished laptop sales to
jump to the node for refurbished laptop sales (i.e., node 672) or the user can speak
the words home laptop sales to jump to the node for home laptop sales (i.e., node
652) in Wesemanns menu tree. Id.; see also Wesemann (EX1001) at 12:4-6,
12:58-65; see also supra Section IV.A.i, limitation [1(a)]. Figure 5 demonstrates
the flow chart for analyzing an input received from a user in the Wesemann
system:
32
IPR2017-01039
U.S. Patent No. 7,231,379
Id. at Fig. 5.
Second, Wesemann also teaches that additional data may be stored in the
the acceptable inputs and requests to allow the system to better determine what a
user is attempting to input. Id. at 12:13-24. A PHOSITA would understand that this
process allows additional meaningful terms from the users spoken input to be
33
IPR2017-01039
U.S. Patent No. 7,231,379
Third, Wesemann teaches providing a user with a clarifying prompt when
voice inputs may be attributable to more than one menu state stored in the
template:
Id. at 12:7-12. In this example, a PHOSITA would understand that the system has
refurbished laptop sales, and that the system has requested an additional
meaningful term associated with a keyword for one of these nodes. Smyth Decl.
(EX1007) 61.
Finally, for the same reasons as discussed for claim 1, to the extent PO
argues that Wesemann somehow does not teach identifying a word/term with a
keyword per se, it would have nonetheless been obvious to do so. See supra Sec.
IV.A.i, limitation [1(a)]; see also Smyth Decl. (EX1007) at 61, 53.
[7(c)] selecting a vertex in the graph structure that is not connected by an edge to
the first vertex, based upon an association between the meaningful term and the
at least one keyword and a correlation between the at least one keyword and the
vertex; and jumping to the vertex.
34
IPR2017-01039
U.S. Patent No. 7,231,379
limitation [7(c)]. See supra Wesemann as applied to limitation [1(b)], Sec. IV.A.i.
to jump to;
(b) the vertex selected to jump to (e.g., 123 or home computer support)
is not connected by an edge to the first vertex (e.g., the first vertex is main menu
node 610 for the vertical jump to extension 123; alternatively, the first vertex is
home computer sales 650 for the lateral jump to home computer support 646);
and
in the input (e.g., a voice command containing terms such as 123 or home
(d) the system jumps to the vertex without requiring the user to traverse
35
IPR2017-01039
U.S. Patent No. 7,231,379
See Wesemann (EX1004) at Fig. 6 (annotated); see also id. at 12:25-42; see also id.
Thus, Wesemann teaches each limitation of claim 7. See also Smyth Decl.
(EX1007) at 58-63.
December 7, 1998, and, therefore, constitutes prior art to the 379 Patent under 35
(GPS) method and system that generates search results for items that are
hierarchically classified. See Rajaraman (EX1005) at 2:9-22; see also id. at 1:66-
36
IPR2017-01039
U.S. Patent No. 7,231,379
querying hierarchically classified data.), Abstract. Like the 379 Patent,
Rajaraman (EX1005) at Fig. 4; see also id. at 6:25-35. As discussed above, the
379 Patent also relates to methods for navigating a hierarchical system of nodes,
See 379 Patent (EX1001) at 3:49-58, see also id. at 3:5-14, Fig. 1. Therefore,
Rajaraman is within the field of endeavor of the 379 Patent and constitutes
problems addressed by the 379 Patent. First, the 379 Patent seeks, in part, to
37
IPR2017-01039
U.S. Patent No. 7,231,379
address the problem of users becoming discouraged or frustrated in having to
navigate a hierarchy of nodes or choices to find a goal of interest, and the 379
Patent uses keyword searching across nodes to address this issue. 379 Patent
claims 3-6 of the 379 Patent, which relate to the use of a thesaurus. The 379
described in more detail below, Rajaraman also teaches a special terms file that
relating to the womens shirts classification when a user queries for a blouse
and vice versa. See Rajaraman (EX1005) at 7:22-8:25. Rajaraman also teaches a
log analyzer that assists with learning users meanings for previously unknown
38
IPR2017-01039
U.S. Patent No. 7,231,379
Rajaraman, therefore, is also analogous art because it is reasonably pertinent to
i. Claims 3-4
depends from claim 3 and requires the searching further comprise identifying the at
least one word from the users input as synonymous with the at least one keyword.
As the claim itself makes clear, a thesaurus correlates keywords with synonyms.
keywords so that a synonym can also cause the system to jump to the desired node.
See 379 Patent (EX1001) at 8:3-32. The specification further describes that the
words, correlating synonyms to nodes, etc.), but that such details are irrelevant to
teaches a general purpose searching system for searching data grouped into
39
IPR2017-01039
U.S. Patent No. 7,231,379
lists various words (i.e., Good Terms) that are synonymous with the
special term file word for the classification womens shirts) (emphasis added);
see also id. at Fig. 7. During a search, Rajaramans index builder accesses the
special terms file (thesaurus) and assigns synonymous terms (so-called Good
classifications having synonymous terms in the search results. Id. at 8:26-30 and
Fig. 9; see also id. at 9:7-45 and Fig. 11. This addition of synonyms to the index is
40
IPR2017-01039
U.S. Patent No. 7,231,379
41
IPR2017-01039
U.S. Patent No. 7,231,379
Further, with regard to claim 4, Rajaramans searching comprises
identifying at least one word input by the user, such as blouse, as synonymous
42
IPR2017-01039
U.S. Patent No. 7,231,379
an index of classifications that includes a special terms file that assigns good
addition to keywords was well known by that time, and a PHOSITA would have
appreciated that such functionality would beneficially provide users unaware of the
navigating the hierarchical menu system in Wesemann. Id. Both Rajaraman and
Wesemann relate to hierarchical menu systems that allow keyword searching, and
recognizes that additional data stored in the template to expand the scope/reach of
43
IPR2017-01039
U.S. Patent No. 7,231,379
at 76. Further, a PHOSITA would have recognized that the application of known
yield predictable results when applied in the system of Wesemann and would not
render any features of Wesemann, such as the ability to jump between nodes,
inoperable. Id. Therefore, claims 3-4 are obvious over Wesemann in view of
Rajaraman.
[5(a)] The method of claim 1 further comprising determining that the at least
one word is neither a keyword nor a synonym of any keyword; and
In one embodiment, the GPS system logs search requests along with
the search results and may also log which search results (i.e.,
classifications) are selected by the user. Periodically, these logs can be
analyzed to determine whether synonyms should be added for a search
term. For example, users may enter the search term aparel, rather
than apparel. Because the term aparel is not in the product
database and not in the classification hierarchy, the search result
will be empty. Therefore, it would be useful to add the term aparel as
a synonym of apparel. The GPS system provides a log analyzer to
help determine when to add synonyms. In one embodiment, the log
analyzer identifies the search requests that resulted in no search
44
IPR2017-01039
U.S. Patent No. 7,231,379
results or in very few classifications in the search results and
displays the identified search requests to an analyst responsible for
deciding on synonyms.
[5(b)] learning a meaning for the word so that the word will be treated as a
learned synonym for at least one particular keyword of the multiple keywords.
Rajaraman teaches that its search system includes a log analyzer to allow
In one embodiment, the GPS system logs search requests along with
the search results and may also log which search results (i.e.,
classifications) are selected by the user. Periodically, these logs can be
analyzed to determine whether synonyms should be added for a
search term. For example, users may enter the search term aparel,
rather than apparel. Because the term aparel is not in the product
database and not in the classification hierarchy, the search result will be
empty. Therefore, it would be useful to add the term aparel as a
synonym of apparel. The GPS system provides a log analyzer to
help determine when to add synonyms. In one embodiment, the log
analyzer identifies the search requests that resulted in no search results
or in very few classifications in the search results and displays the
identified search requests to an analyst responsible for deciding on
45
IPR2017-01039
U.S. Patent No. 7,231,379
synonyms. For example, the terms of the identified search requests
can be displayed along with a field so that the analyst can enter the
word(s) with which the displayed search term is synonymous. The
log analyzer may also display statistical information as to how
many times the displayed search term was entered by a user. Also,
the log analyzer may display additional information such as a
subsequent search request entered by the same user that does
return search results.
taught by Rajaraman. Smyth Decl. (EX1007) at 76. As discussed for claims 3-4, it
Wesemanns system; and, it would have further been obvious to allow the
functionality was already well known in the art. Id. A PHOSITA would have
would have improved the system by making it even more user-friendly and by
further enhancing the efficiency with which a user can navigate the hierarchy of
nodes. Id. A PHOSITA would have further recognized that such an application in
4
See the discussion immediately below within this section for discussion regarding the
46
IPR2017-01039
U.S. Patent No. 7,231,379
the system of Wesemann would have required minor modifications at most and
yielded predictable results. Id. A PHOSITA would have also been motivated to
correlating inputs could be added to its template. See id.; see also Wesemann, at
Id.
Petitioner notes that claim 5 merely recites learning a meaning for the word
so that the word will be treated as a learned synonym for at least one particular
keyword and does not expressly recite automatically learning such a synonym
with no user involvement. Thus, a learning step that may involve some human
input to cause the learning to occur is still within the ambit of claim 5.
5 that no human involvement can be involved in the claimed learning and that
the analyst mentioned in the paragraph cited above is a human, not part of the
system of Rajaraman. Such arguments are inapposite. First, it is well settled that
manual activity which has accomplished the same result. In Re Venner, 262 F.2d
91, 95 (C.C.P.A. 1958); see also, e.g., Ex Parte Brent Bursey, Appeal 2014-
(Rendering automatic by computer that which is done by hand per se would have
47
IPR2017-01039
U.S. Patent No. 7,231,379
been obvious to one of ordinary skill in the art.); Western Union Co. v.
MoneyGram Payment Systems, Inc., 626 F.3d 1361, 1370-71 (Fed. Cir. 2010)
(finding that the use of electronic transaction device where prior art employed fax
machine was obvious, rejecting argument that the patentee's effort invested in
software implementation of its commercial system tended to show that the patent
was inventive.). Merely replacing the manual activity of a human with software
logic that would allow the log analyzer to perform the broadly-recited learning step
the 379 Patent would have found it obvious to automate the learning step in
such algorithms were already well known. See Smyth Decl. (EX1007) at 74, see
also id. at 70-75, 41-45. A PHOSITA would have appreciated the benefit in
system and does not expressly recite that this subsequent user must be different
from the first user of the system. Further, the 379 specification indicates that a
48
IPR2017-01039
U.S. Patent No. 7,231,379
subsequent user that benefits from the updated thesaurus may be either the same
[I]t tracks what the user did, what node of the tree the user went to, and
on this basis, it learns a new response to coach class. The next time a
caller (either the same person or a different person) uses the words
coach class the system does not offer the traditional path as it did the
first time, but instead it offers a new set of nodes based on what it
learned the first time.
379 Patent (EX1001) at 14:32-38 (emphasis added). In the event PO argues that
not limit its thesaurus functionality to applying to only a specific user, but instead
bases it on the behavior of multiple users and even on homonyms and alternate
spellings:
For example, users may enter the search term aparel, rather than
apparel. Because the term aparel is not in the product database and
not in the classification hierarchy, the search result will be empty.
Therefore, it would be useful to add the term aparel as a synonym of
apparel.
Id. at 7:67-8:5 (emphasis added); see also id. at 8:22-25 (For example, if users
enter the search request sole and the search results relate only to shoes, the
analyst may want to indicate that sole is a synonym for soul, as in music.
(emphasis added)). Further, Rajarman, teaches that its thesaurus (i.e., the special
49
IPR2017-01039
U.S. Patent No. 7,231,379
terms file) is a component of its overall system, which is used by all users of the
limiting its thesaurus to only a particular user, and, instead, subsequent users also
benefit from the thesaurus of synonyms, which is based on multiple users search
behvaiors. Id. at 4:55-5:9, Fig. 2, 7:22-42, Fig. 7; see also Smyth Decl. (EX1007) at
75. It also would have been obvious to a PHOSITA to have the thesaurus apply to
other subsequent users because it was well known in the art that thesauruses of
synonyms are improved when they are based on the learned search behaviors of
multiple users, which yields a more robust thesaurus functionality. Smyth Decl.
(EX1007) at 75; see also id. at 44. Thus, Wesemann in view of Rajaraman
Therefore, claims 5-6 are obvious over Wesemann in view of Rajaraman. Id.
at 70-76.
U.S. Patent No. 7,539,656 to Fratkina et al. (Fratkina) was filed on March
6, 2001, and therefore is prior art to the 379 Patent under 35 U.S.C. 102(e) (pre-
AIA). Fratkina (EX1006). Fratkina was not cited during prosecution of the 379
50
IPR2017-01039
U.S. Patent No. 7,231,379
automated telephone response system. See 379 Patent (EX1001) at 3:49-58, see
also id. at 3:5-14. The 379 Patent purports to solve problems related to
Abstract, 2:22-30. Like the 379 Patent, Fratkina teaches improving the efficiency
different subgoals. See Fratkina (EX1006) at 34:32-53; see also id. at 27:25-43;
see also id. at 37:54-63 and Fig. 15 (pointing dialog to a correct subgoal focus if a
user inputs a known menu item). Also like the 379 Patents IVR system
voice response (IVR) and/or speech recognition system that recognizes spoken
words input by the user. See 379 Patent (EX1001) at 6:66-67; Fratkina (EX1006)
reasonably pertinent to the 379 Patent. See also Smyth Decl. (EX1007) at 77-79.
Therefore, Fratkina qualifies as analogous prior art to the claimed invention of the
379 Patent.
51
IPR2017-01039
U.S. Patent No. 7,231,379
i. Claim 1
nodes:
52
IPR2017-01039
U.S. Patent No. 7,231,379
taxonomys area of concern at an appropriate level for distinguishing
among the correct knowledge containers to return: neither too coarse a
representation which fails to differentiate among many knowledge
containers, nor too granular a representation which models more
distinctions than really exist among available knowledge containers.
Fratkina (EX1006) at Fig. 10; see also id. at 22:9-29 (describing navigating
through the menu through the use of concept triggers), 22:55-23:2 (describing
53
IPR2017-01039
U.S. Patent No. 7,231,379
navigating through focus nodes), Figs. 11-12, 20. Thus, to the extent the
[1(a)] at a first node, receiving an input from a user of the system, the input
containing at least one word identifiable with at least one keyword from among
multiple keywords,
Fratkina teaches a system whereby the system receives input from a user
containing words at a first node (such as, for example, at a Meal Type node,
Fratkina (EX1006) at 13:15-24 (emphasis added); see also id. at 13:25-39, 22:19-
29 ([A] user states that they want breakfast . . .), Fig. 10, 26:36-57 (Breakfast
node), Fig. 11, 34:9-53 (Diet node and Menu node); Fig. 12. Fratkina also
teaches that these inputs contain at least one word identifiable with at least one
keyword from among multiple keywords. For example, a user may use keyword
54
IPR2017-01039
U.S. Patent No. 7,231,379
or natural language queries to request actions or make choices, and a dialog
engine converts the users input into tags to be processed by the system using an
query types), 14:27-31. The system uses the inputs to traverse the taxonomy:
See id. at 26:26-45 (emphasis added); see also id. at 14:27-31 (Each taxonomy tag
55
IPR2017-01039
U.S. Patent No. 7,231,379
indicates the knowledge container's strength of association with that concept
more keywords for navigating the taxonomies. See Smyth Decl., (EX1007) at 80-
83.
US. Patent May 26, 2009 Sheet 10 6f 19 US 7,539,656 B2
The teachings of Fratkina can be further understood by way of its examples.
Figures 10-11 of Fratkina depict a menu hierarchy where a user states that they
want breakfast:
1030 10540
1010 creoteGool
@@ node=breokf0st;
@ ;
SCRAMBLED
@ POACHED
BENEDICT
BREAKFAST
WITH SYRUP
1020 PANCAKES
CE}
@@ FIG. 10
SYRUP
56
IPR2017-01039
Unified EX1006 Page 13
IPR2017-01039
U.S. Patent No. 7,231,379
57
IPR2017-01039
U.S. Patent No. 7,231,379
the goal of the dialog proceeds from the eggs node to the
scrambled node 1130.
Id. at 26:50-57; see also id. at Fig. 10, 22:19-29.
through the menu hierarchy, providing input, where the input includes at least one
word (e.g., eggs) associated with a keyword (e.g., eggs) from among multiple
[1(b)] identifying at least one node, other than the first node, that is not directly
connected to the first node but is associated with the at least one keyword, and
jumping to the at least one node.
Fratkina teaches jumping directly from one node to another that is not
autocontextualization:
58
IPR2017-01039
U.S. Patent No. 7,231,379
232 from the focus node(s) to the target node(s) heavily depends on
user responses to system questions.
Fratkina (EX1006) at 34:32-53 (emphasis added); see also id. at 27:25-43 (In the
process of goal resolution, the focus is typically advanced along the edges of the
taxonomy graph, but may jump to a node (or set of nodes) more than one edge
Therefore, using the menu example, a user may move through the menu
described above. However, Fratkinas system may also jump to a specific place
depending on the users response to the systems questions. Thus, if a user was at
the breakfast node (first node) and desired scrambled eggs, he may simply say he
wants scrambled eggs after being asked what he wanted for breakfast, which
would be associated with a node not directly connected to the breakfast node;
and a PHOSITA would have found it obvious that, using autocontextualization, the
dialog designer would be able to identify the scrambled node as the place the
user desired to go based on his response and jump directly to that node, without
requiring the user to first traverse through the eggs node. Id.; see also id. at 34:9-
53, Fig. 12; Smyth Decl. (EX1007) at 84. Fratkinas express teachings regarding
59
IPR2017-01039
U.S. Patent No. 7,231,379
provide for a more natural/conversational and efficient flow in Fratkinas system.
Id.
minimum, suggest, the use of the one or more keywords to jump directly to a node
within the taxonomy that is associated with the keyword without traversing
ii. Claim 2
the subject matter whether presented audibly or in written form, and this is the
BRI of this term. 379 Patent (EX1001) at 1:50-52; see also Sec. III.D.v, supra. A
verbal description may consist of message prompts, such as Would you like to
make a reservation? Id. at 4:32-45. Fratkina teaches that its system may provide a
60
IPR2017-01039
U.S. Patent No. 7,231,379
Similarly, in 1120 when the user answers scrambled in response
to the question How would you like your eggs prepared, the goal
of the dialog proceeds from the eggs node to the scrambled
node 1130. In this example, the nodes selected are confirmed nodes
since they represent nodes whose relevance to the user's information
need has been established.
Id. at 26:46-60. (emphasis added), Fig. 11, Fig. 21; see also id. at 13:15-24 (The
dialog engine 232 response is passed to a text-to-speech system that turns it into a
iii. Claim 7
claims 1 and 2. Claim 7 refers to vertices, but as discussed above, the 379
patent uses vertices and nodes interchangeably, and the BRI of a vertex is
graph. See Sec. III.D.i, supra. Fratkina relates to a hierarchical network that can
be represented as a graphical menu tree containing vertices and edges, where the
edges connect at least two of the vertices. For example, in Figures 10-12 of
61
IPR2017-01039
U.S. Patent No. 7,231,379
graphical arrangement. Referring to Figure 10, depicted below, the vertices
Fratkina (EX1006) at Fig. 10 (annotated); see also id. at Figs 4, 11, 12; see also
62
IPR2017-01039
U.S. Patent No. 7,231,379
Dialog engine 232 improves its understanding of the users initial
question by conducting a multi-step dialog with the user. Based on the
users responses to follow-up questions, the dialog engine is further
able to focus its analysis of the users response (i.e., limit the remaining
sets of concepts by creating constraints) .
Id. at 26:34-60. (emphasis added); see also id. at 13:15-24; 37:12-30; see also
[7(b)] analyzing the input to identify a meaningful term that can be associated
with at least one keyword;
Fratkina teaches that its system analyzes user inputs to identify meaningful
terms that can be associated with one or more keywords associated with different
Once dialog engine 232 creates an initial set of goals (target nodes and
focus nodes) based on the subject matter of the users inquiry, it begins
63
IPR2017-01039
U.S. Patent No. 7,231,379
to resolve the goals. The process of goal resolution is one of taxonomy
traversal, going from more general concepts at the root to more specific
concepts closer to the leaves of the taxonomy graph. . . . When dialog
engine 232 receives an answer from a user, it identifies one or more
goals for the dialog, based on the dialog engine's current
understanding of the user's response. Dialog engine 232 improves
its understanding of the users initial question by conducting a
multi-step dialog with the user. Based on the users responses to
follow-up questions, the dialog engine is further able to focus its
analysis of the users response (i.e., limit the remaining sets of concepts
by creating constraints). In other words, dialog engine 232 seeks to
describe the user's information request in more and more detail by
mapping user responses to concept nodes in the goal taxonomy.
(keywords), 13:15-24, 34:32-53; see also Fratkina applied to claim [1(a)] and
[1(b0] supra. For example, the user speaking/inputting a meaningful term (e.g.,
eggs) can be associated with a keyword (e.g., eggs). Id. at 26:50-57; see also
id. at Fig. 10, 22:19-29. A PHOSITA would understand that Fratkina teaches a
system in which a user may input a command containing one or more words that
may identifiable with at least one or more keywords for navigating the taxonomies.
[7(c)] selecting a vertex in the graph structure that is not connected by an edge to
the first vertex, based upon an association between the meaningful term and the
at least one keyword and a correlation between the at least one keyword and the
vertex; and jumping to the vertex.
64
IPR2017-01039
U.S. Patent No. 7,231,379
jumping limitation as it has been claimed in the 379 Patent, and, at a minimum,
it would have been obvious to implement such jumping in the context of the meal
menu example. See supra Sec. IV.C.i. As discussed, Fratkina teaches that
depending on the users responses, the system may autocontextualize the users
taxonomy and the dialog designer can explicitly specify a place to jump to.); see
also id. at 27:25-43 (In the process of goal resolution, the focus is typically
advanced along the edges of the taxonomy graph, but may jump to a node (or set of
nodes) more than one edge away from the previous focus.); see also id. at 37:54-
63. Using the meal hierarchy example, a PHOSITA would have understood
with this limitation and it would have been obvious to do so (as discussed above
(b) the vertex selected to jump to is not connected by an edge to the first
65
IPR2017-01039
U.S. Patent No. 7,231,379
(c) the vertex to jump to is selected based on analysis of a meaningful term
(e.g., a user input of scrambled eggs) associated with a keyword associated with
See, e.g., id. at 26:34-60, Fig. 11; Smyth Decl., (EX1007) at 89.
Given the above, claims 1, 2 and 7 are obvious over Fratkina. Smyth Decl.,
(EX1007) at 77-90.
claims 3, 4, 5, and 6, which each relate to the use of thesaurus functionality. See
searching system that uses a special terms file (thesaurus) for good terms,
which are designated as being synonymous to classification terms, and the system
includes a log analyzer that facilitates addition of new synonyms. See Rajaraman
(EX1005) at 7:22-8:53, 9:7-20; see also id. at Figs. 7, 9, and 11. Rajaraman
teaches and renders obvious each of the limitations of claims 3-6, and Petitioner
66
IPR2017-01039
U.S. Patent No. 7,231,379
Fratkina expressly teaches that user inputs can be processed using a
thesaurus:
Fratkina (EX100X) at 7:47-52. And Fratkina expressly teaches that [its] dialog
engine is designed to work with any prior art search/retrieval engines to produce a
search space. Id. at 8:51-60. These express teachings would have motivated a
search engine provided by the special terms file that assigns good terms to
different classifications, as well as its log analyzer for adding new synonyms. See
Smyth Decl. (EX1007) at 91-92. A PHOSITA would have appreciated that such
in Fratkina. Id. Both Rajaraman and Fratkina relate to hierarchical menu systems
that allow keyword searching, and modifying Fratkina to include this functionality
PHOSITA would have recognized that the application of known methods related to
67
IPR2017-01039
U.S. Patent No. 7,231,379
functionality) would yield predictable results when applied in the system of
Fratkina and would not render any features of Fratkina, such as the ability to jump
Therefore, claims 3-6 are obvious over Fratkina in view of Rajaraman. Id.
V. CONCLUSION
For the forgoing reasons, Petitioner respectfully requests inter partes review
Respectfully submitted,
68
IPR2017-01039
U.S. Patent No. 7,231,379
A. Real Party-In-Interest
this proceeding, the filing of this petition, or the conduct of any ensuing trial. In
B. Related Matters
(E.D. Tex.).
(E.D. Tex.).
69
IPR2017-01039
U.S. Patent No. 7,231,379
01149 (E.D. Tex.).
(E.D. Tex.).
(E.D. Tex.).
lead and back-up counsel. 37 C.F.R. 42.8(b)(3) and (b)(4). Please direct all
70
IPR2017-01039
U.S. Patent No. 7,231,379
jonathan@unifiedpatents.com, and roshan@unifiedpatents.com. 37 C.F.R.
42.8(b)(4).
71
IPR2017-01039
U.S. Patent No. 7,231,379
APPENDIX OF EXHIBITS
72
IPR2017-01039
U.S. Patent No. 7,231,379
Development in Information Retrieval, pp. 13-29, ACM Press,
1988
Exhibit 1020 Gerard Salton, Anita Wong, and Chung-Shu Yang, A vector space
model for automatic indexing, Communications of the ACM,
18(11): 613-620, 1975
Exhibit 1021 Jinxi Xu, W. Bruce Croft, Query expansion using local and global
document analysis, Proceedings of the 19th ACM SIGIR
International Conference on Research and Development in
Information Retrieval, pp. 4-11, ACM, 1996
Exhibit 1022 Carolyn J. Crouch, A cluster-based approach to thesaurus
construction, Proceedings of the 11th ACM SIGIR International
Conference on Research and Development in Information
Retrieval pp. 309-320. ACM, 1988
Exhibit 1023 Hinrich Schtze and Jan O. Pedersen, A cooccurrence-based
thesaurus and two applications to information retrieval, 1
Intelligent Multimedia Information Retrieval Systems and
Management, pp. 266-274, 1994
Exhibit 1024 Gntzer et al., Automatic Thesaurus Construction by Machine
Learning from Retrieval Sessions, 25 Information Processing &
Management No. 3 pp. 265-273, 1998
Exhibit 1025 Mostafa et al., A Multilevel Approach to Intelligent Information
Filtering: Model, System, and Evaluation, 15 ACM Transactions
on Information Systems No. 4, pp. 368-399, 1997
Exhibit 1026 U.S. Patent No. 6,006,225 to Bowman et al.
73
IPR2017-01039
U.S. Patent No. 7,231,379
2
IPR2017-01039
U.S. Patent No. 7,231,379
A courtesy copy of this Petition for Inter Partes Review was also provided via
e-mail to the Patent Owners litigation counsel of record at the below e-mail address:
David R. Bennett
Direction IP Law
P.O. Box 14184
Chicago, IL 60614
dbennett@directionip.com