paul allen patent complaint (interval licensing, llc v. aol, inc., et al.)

8/9/2019 Paul Allen Patent Complaint (Interval Licensing, LLC v. AOL, Inc., et al.)

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COMPLAINT FOR PATENT INFRINGEMENT S U S M A N G O D F R E Y L . L . P .

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UNITED STATES DISTRICT COURTWESTERN DISTRICT OF WASHINGTON

AT SEATTLE

INTERVAL LICENSING LLC,

Plaintiff,

v.

AOL, INC.; APPLE, INC.; eBAY, INC.;

FACEBOOK, INC.; GOOGLE INC.;NETFLIX, INC.; OFFICE DEPOT, INC.;

OFFICEMAX INC.; STAPLES, INC.;

YAHOO! INC.; AND YOUTUBE, LLC,

Defendants.

Case No.

COMPLAINT FOR PATENT

INFRINGEMENT

JURY DEMAND

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff Interval Licensing LLC, files this complaint for patent infringement against

Defendants AOL, Inc., Apple, Inc., eBay, Inc., Facebook, Inc., Google Inc., Netflix, Inc.,

Office Depot, Inc., OfficeMax Inc., Staples, Inc., Yahoo! Inc., and YouTube, LLC. Plaintiff

Interval Licensing LLC alleges:

Page 1 of 15 1201 Third Avenue, Suite 3800

Seattle, WA 98101-3000

Tel: (206) 516-3880; Fax: (206) 516-3883

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Case 2:10-cv-01385 Document 1 Filed 08/27/10 Page 1 of 15


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THE PARTIES

1. Interval Licensing LLC (Interval) is a limited liability company dulyorganized under the laws of the state of Washington, with its principal place of business at

505 Fifth Avenue South, Suite 900, Seattle, WA 98104.

2. Interval is informed and believes, and on that basis alleges, that DefendantAOL, Inc. (AOL) is a corporation duly organized and existing under the laws of the state

of Delaware, with its principal place of business at 770 Broadway, New York, NY 10003.

3. Interval is informed and believes, and on that basis alleges, that DefendantApple, Inc. (Apple) is a corporation duly organized and existing under the laws of the

state of California, with its principal place of business at 1 Infinite Loop, Cupertino, CA

95014.

4. Interval is informed and believes, and on that basis alleges, that DefendanteBay, Inc. (eBay) is a corporation duly organized and existing under the laws of the state

of Delaware, with its principal place of business at 2145 Hamilton Avenue, San Jose, CA

95125.

5. Interval is informed and believes, and on that basis alleges, that DefendantFacebook, Inc. (Facebook) is a corporation duly organized and existing under the laws of

the state of Delaware, with its principal place of business at 1601 S. California Avenue, Palo

Alto, CA 94304.

6. Interval is informed and believes, and on that basis alleges, that DefendantGoogle Inc. (Google) is a corporation duly organized and existing under the laws of the

state of Delaware, with its principal place of business at 1600 Amphitheatre Parkway,

Mountain View, CA 94043.



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7. Interval is informed and believes, and on that basis alleges, that DefendantNetflix, Inc. (Netflix) is a corporation duly organized and existing under the laws of the

state of Delaware, with its principal place of business at 100 Winchester Circle, Los Gatos,

CA 95032.

8. Interval is informed and believes, and on that basis alleges, that DefendantOffice Depot, Inc. (Office Depot) is a corporation duly organized and existing under the

laws of the state of Delaware, with its principal place of business at 6600 North Military

Trail, Boca Raton, FL 33496.

9.

Interval is informed and believes, and on that basis alleges, that Defendant

OfficeMax Inc. (OfficeMax) is a corporation duly organized and existing under the laws

of the state of Delaware, with its principal place of business at 263 Shuman Boulevard,

Naperville, IL 60563.

10. Interval is informed and believes, and on that basis alleges, that DefendantStaples, Inc. (Staples) is a corporation duly organized and existing under the laws of the

state of Delaware, with its principal place of business at 500 Staples Drive, Framingham,

MA 01702.

11. Interval is informed and believes, and on that basis alleges, that DefendantYahoo! Inc. (Yahoo) is a corporation duly organized and existing under the laws of the

state of Delaware, with its principal place of business at 701 First Avenue, Sunnyvale, CA

94089.

12. Interval is informed and believes, and on that basis alleges, that DefendantYouTube, LLC (YouTube) is a limited liability company duly organized and existing



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under the laws of the state of California, with its principal place of business at 901 Cherry

Avenue, San Bruno, CA 94066.

JURISDICTION AND VENUE

13. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1338(a)because this action arises under the patent laws of the United States, 35 U.S.C. 1 et seq.

Venue is proper in this Federal Circuit pursuant to 28 U.S.C. 1391(b)-(c) and 1400(b) in

that a substantial part of the events giving rise to the claims occurred in this district and the

defendants have a regular and established practice of business in this district and have

committed acts of infringement in this district.

INTERVAL RESEARCH CORPORATION WAS A PIONEER IN THE

TECHNOLOGY INDUSTRY

14. Interval Research Corporation (Interval Research) was founded in 1992 byPaul Allen and David Liddle to perform advanced research and development in the areas of

information systems, communications, and computer science. Mr. Allen, who served as

Interval Researchs chairman, was one of the earliest pioneers of personal computer

software. He co-founded Microsoft with Bill Gates in 1975 and later founded Vulcan

Ventures in 1986. Mr. Liddle served as Interval Researchs president and chief executive

officer. He was instrumental in developing fundamental technologies starting in the early

1970s when he worked at Xerox at the Palo Alto Research Center.

15. Starting with Mr. Allen, Mr. Liddle, and a handful of scientists and inventors,Interval Research evolved into one of the preeminent technology firms. It employed over

110 of the worlds leading scientists, physicists, and engineers, and was at the forefront in

designing next-generation science and technology.



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16. In addition to the research that Interval Research conducted, it also providedfunding and assistance for other projects. For example, Interval Research served as an

outside collaborator to and provided research funding for Sergey Brin and Lawrence Pages

research that resulted in Google. Indeed, a Google screenshot dated September 27, 1998

entitled About Google! identifies Interval Research in the Credits section as one of two

Outside Collaborators and one of four sources of Research Funding for Google. See

Sept. 27, 1998 Website About Google! attached as Exhibit 1.

17. Mr. Brin and Mr. Page also recognized Interval Researchs funding in theAcknowledgements section of their 1998 research article entitled Anatomy of a Large-

Scale Hypertextual Web Search Engine in which they present Google.

18. As a testament to Interval Researchs innovation, it was issued approximately300 patents in less than a decade. Four of those patents are the patents-in-suit.

19. Interval Licensing LLC owns the patents-in-suit. The company is owned andcontrolled by Mr. Allen.

INFRINGEMENT OF U.S. PATENT NO. 6,263,507

20. On July 17, 2001, United States Patent No. 6,263,507 (the 507 patent) wasduly and legally issued for an invention entitled Browser for Use in Navigating a Body of

Information, With Particular Application to Browsing Information Represented By

Audiovisual Data. Interval was assigned the 507 patent and continues to hold all rights

and interest in the 507 patent. A true and correct copy of the 507 patent is attached hereto

as Exhibit 2.

21. Defendant AOL has infringed and continues to infringe one or more claimsof the 507 patent. AOL is liable for infringing the 507 patent under 35 U.S.C. 271 by



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making and using websites, hardware, and software to categorize, compare, and display

segments of a body of information as claimed in the patent.

22. Defendant Apple has infringed and continues to infringe one or more claimsof the 507 patent. Apple is liable for infringing the 507 patent under 35 U.S.C. 271 by



23. Defendant eBay has infringed and continues to infringe one or more claimsof the 507 patent. eBay is liable for infringing the 507 patent under 35 U.S.C. 271 by



24. Defendant Google has infringed and continues to infringe one or more claimsof the 507 patent. Google is liable for infringing the 507 patent under 35 U.S.C. 271 by



25. Defendant Netflix has infringed and continues to infringe one or more claimsof the 507 patent. Netflix is liable for infringing the 507 patent under 35 U.S.C. 271 by



26. Defendant Office Depot has infringed and continues to infringe one or moreclaims of the 507 patent. Office Depot is liable for infringing the 507 patent under 35

U.S.C. 271 by making and using websites, hardware, and software to categorize, compare,

and display segments of a body of information as claimed in the patent.



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27. Defendant OfficeMax has infringed and continues to infringe one or moreclaims of the 507 patent. OfficeMax is liable for infringing the 507 patent under 35 U.S.C.

271 by making and using websites, hardware, and software to categorize, compare, and

display segments of a body of information as claimed in the patent.

28. Defendant Staples has infringed and continues to infringe one or more claimsof the 507 patent. Staples is liable for infringing the 507 patent under 35 U.S.C. 271 by



29.

Defendant Yahoo has infringed and continues to infringe one or more claims

of the 507 patent. Yahoo is liable for infringing the 507 patent under 35 U.S.C. 271 by



30. Defendant YouTube has infringed and continues to infringe one or moreclaims of the 507 patent. YouTube is liable for infringing the 507 patent under 35 U.S.C.

271 by making and using websites, hardware, and software to categorize, compare, and

display segments of a body of information as claimed in the patent.

31. Defendants AOL, Apple, eBay, Google, Netflix, Office Depot, OfficeMax,Staples, Yahoo, and YouTubes acts of infringement have caused damage to Interval, and

Interval is entitled to recover from Defendants the damages sustained by Interval as a result

of Defendants wrongful acts in an amount subject to proof at trial. Defendants

infringement of Intervals exclusive rights under the 507 patent will continue to damage

Interval, causing irreparable harm for which there is no adequate remedy at law, unless

enjoined by this Court. Interval reserves the right to allege, after discovery, that Defendants



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infringement is willful and deliberate, entitling Interval to increased damages under 35

U.S.C. 284 and to attorneys fees and costs incurred in prosecuting this action under 35

U.S.C. 285.


32. On March 7, 2000, United States Patent No. 6,034,652 (the 652 patent)was duly and legally issued for an invention entitled Attention Manager for Occupying the

Peripheral Attention of a Person in the Vicinity of a Display Device. Interval was assigned

the 652 patent and continues to hold all rights and interest in the 652 patent. A true and

correct copy of the 652 patent is attached hereto as Exhibit 3.


making, using, offering, providing, and encouraging customers to use products that display

information in a way that occupies the peripheral attention of the user as claimed in the

patent.




patents.





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patent.

36. Defendant Yahoo has infringed and continues to infringe one or more claimsof the 652 patent. Yahoo is liable for infringing the 652 patent under 35 U.S.C. 271 by



patent.

37. Defendants AOL, Apple, Google, and Yahoos acts of infringement havecaused damage to Interval, and Interval is entitled to recover from Defendants the damages

sustained by Interval as a result of Defendants wrongful acts in an amount subject to proof

at trial. Defendants infringement of Intervals exclusive rights under the 652 patent will

continue to damage Interval, causing irreparable harm for which there is no adequate

remedy at law, unless enjoined by this Court. Interval reserves the right to allege, after

discovery, that Defendants infringement is willful and deliberate, entitling Interval to

increased damages under 35 U.S.C. 284 and to attorneys fees and costs incurred in

prosecuting this action under 35 U.S.C. 285.


38. On September 7, 2004, United States Patent No. 6,788,314 (the 314patent) was duly and legally issued for an invention entitled Attention Manager for

Occupying the Peripheral Attention of a Person in the Vicinity of a Display Device.

Interval was assigned the 314 patent and continues to hold all rights and interest in the 314

patent. A true and correct copy of the 314 patent is attached hereto as Exhibit 4.



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patent.




patent.




patent.




patent.

43. Defendants AOL, Apple, Google, and Yahoos acts of infringement havecaused damage to Interval, and Interval is entitled to recover from Defendants the damages

sustained by Interval as a result of Defendants wrongful acts in an amount subject to proof



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at trial. Defendants infringement of Intervals exclusive rights under the 314 patent will

continue to damage Interval, causing irreparable harm for which there is no adequate

remedy at law, unless enjoined by this Court. Interval reserves the right to allege, after

discovery, that Defendants infringement is willful and deliberate, entitling Interval to

increased damages under 35 U.S.C. 284 and to attorneys fees and costs incurred in

prosecuting this action under 35 U.S.C. 285.


44. On June 29, 2004, United States Patent No. 6,757,682 (the 682 patent)was duly and legally issued for an invention entitled Alerting Users to Items of Current

Interest. Interval was assigned the 682 patent and continues to hold all rights and interest

in the 682 patent. A true and correct copy of the 682 patent is attached hereto as Exhibit 5.


making and using websites and associated hardware and software to provide alerts that

information is of current interest to a user as claimed in the patent.




47. Defendant eBay has infringed and continues to infringe one or more claimsof the 682 patent. eBay is liable for infringing the 682 patent under 35 U.S.C. 271 by





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48. Defendant Facebook has infringed and continues to infringe one or moreclaims of the 682 patent. Facebook is liable for infringing the 682 patent under 35 U.S.C.

271 by making and using websites and associated hardware and software to provide alerts

that information is of current interest to a user as claimed in the patent.




50.

Defendant Netflix has infringed and continues to infringe one or more claims

of the 682 patent. Netflix is liable for infringing the 682 patent under 35 U.S.C. 271 by



51. Defendant Office Depot has infringed and continues to infringe one or moreclaims of the 682 patent. Office Depot is liable for infringing the 682 patent under 35

U.S.C. 271 by making and using websites and associated hardware and software to

provide alerts that information is of current interest to a user as claimed in the patent.

52. Defendant OfficeMax has infringed and continues to infringe one or moreclaims of the 682 patent. OfficeMax is liable for infringing the 682 patent under 35 U.S.C.



53. Defendant Staples has infringed and continues to infringe one or more claimsof the 682 patent. Staples is liable for infringing the 682 patent under 35 U.S.C. 271 by



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55. Defendant YouTube has infringed and continues to infringe one or moreclaims of the 682 patent. YouTube is liable for infringing the 682 patent under 35 U.S.C.



56. Defendants AOL, Apple, eBay, Facebook, Google, Netflix, Office Depot,OfficeMax, Staples, Yahoo, and YouTubes acts of infringement have caused damage to

Interval, and Interval is entitled to recover from Defendants the damages sustained by

Interval as a result of Defendants wrongful acts in an amount subject to proof at trial.

Defendants infringement of Intervals exclusive rights under the 682 patent will continue

to damage Interval, causing irreparable harm for which there is no adequate remedy at law,

unless enjoined by this Court. Interval reserves the right to allege, after discovery, that

Defendants infringement is willful and deliberate, entitling Interval to increased damages

under 35 U.S.C. 284 and to attorneys fees and costs incurred in prosecuting this action

under 35 U.S.C. 285.

JURY DEMAND

57. Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Intervalrespectfully requests a trial by jury on all issues properly triable by jury.



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PRAYER FOR RELIEF

WHEREFORE, Plaintiff Interval Licensing LLC requests entry of judgment in its

favor and against Defendants as follows:

a) Declaration that (1) Defendants AOL, Apple, eBay, Google, Netflix, OfficeDepot, OfficeMax, Staples, Yahoo, and YouTube have infringed U.S. Patent No. 6,263,507;

(2) Defendants AOL, Apple, eBay, Facebook, Google, Netflix, Office Depot, OfficeMax,

Staples, Yahoo, and YouTube have infringed U.S. Patent No. 6,757,682; and (3) Defendants

AOL, Apple, Google, and Yahoo have infringed U.S. Patent Nos. 6,034,652 and 6,788,314.

b)

Awarding the damages arising out of (1) Defendants AOL, Apple, eBay,

Google, Netflix, Office Depot, OfficeMax, Staples, Yahoo, and YouTubes infringement of

U.S. Patent No. 6,263,507; (2) Defendants AOL, Apple, eBay, Facebook, Google, Netflix,

Office Depot, OfficeMax, Staples, Yahoo, and YouTubes infringement of U.S. Patent No.

6,757,682; and (3) Defendants AOL, Apple, Google, and Yahoos infringement of U.S.

Patent Nos. 6,034,652 and 6,788,314, to Interval, together with prejudgment and post-

judgment interest, in an amount according to proof;

c) Permanently enjoining Defendants and their respective officers, agents,employees, and those acting in privity with them, from further infringement, including

contributory infringement and/or inducing infringement, of U.S. Patent Nos. 6,263,507,

6,034,652, 6,788,314, and 6,757,682, or in the alternative, awarding a royalty for post-

judgment infringement;

d) Awarding attorneys fees pursuant to 35 U.S.C. 285 or as otherwisepermitted by law; and



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COMPLAINT FOR PATENT INFRINGEMENT

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S U S M A N G O D F R E Y L . L . P .

1201 Third Avenue, Suite 3800


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e) Awarding such other costs and further relief as the Court may deem just andproper.

Dated: August 27, 2010 /s/Justin A. NelsonJustin A. NelsonWA Bar No. 31864

E-Mail: [email protected]

Matthew R. BerryWA Bar No. 37364

E-Mail: [email protected]

SUSMAN GODFREY L.L.P.

1201 Third Ave, Suite 3800Seattle, WA 98101

Telephone: (206) 516-3880Facsimile: (206) 516-3883

Max L. Tribble, Jr.

E-Mail: [email protected] GODFREY L.L.P.

1000 Louisiana Street, Suite 5100

Houston, Texas 77002

Telephone: (713) 651-9366Facsimile: (713) 654-6666

Michael F. HeimE-mail: [email protected]

Eric J. Enger

E-mail: [email protected] J. Davis

E-mail: [email protected]

HEIM, PAYNE & CHORUSH, L.L.P.600 Travis, Suite 6710

Houston, Texas 77002

Telephone: (713) 221-2000

Facsimile: (713) 221-2021

Attorneys for INTERVAL LICENSING LLC



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EXHIBIT 1

Case 2:10-cv-01385 Document 1-1 Filed 08/27/10 Page 1 of 2


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ut Google!

//web.archive.org/web/19991013102702/google.stanford.edu/about.html[7/8/2010 8:32:32 AM]

About

Links

Research Papers about Google and the WebBasePictures and stats for the Stanford Google Hardware

Credi ts

Current Development: Sergey Brin, Larry Page, and Craig Silverstein

Design and Implementation Assistance: Scott Hassan and Alan SterembergFaculty Guidance: Hector Garcia-Molina, Rajeev Motwani, Jeffrey D. Ullman, and Terry Winograd

Research Funding: NSF,NASA, DARPA and Interval Research

Equipment Donations: IBM, Intel, and SunEquipment Consulting: Penguin ComputingSoftware: GNU, Linux, Python,Parasoft (debugging), and Gimp (logo design)

Collaborating Groups in the Computer Science Departmentat Stanford University: The Digital Libraries ProThe Project on People Computers and Design, The Database Group, The Stanford InfoLab, The MIDAS Dat

Mining Group, and The Theory DivisionOutside Collaborators: Interval Research Corporation and the IBM Almaden Research Center

Technical Assistance: The Computer Science Department's Computer Facilities Group, Stanford's DistributedComputing and Intra-Networking Systems Group

ast modified: Sun Sep 27 20:26:46 PDT 1998

http://web.archive.org/web/19991013102702/http://google.stanford.edu/google_papers.htmlhttp://web.archive.org/web/19991013102702/http://google.stanford.edu/googlehardware.htmlhttp://web.archive.org/web/19991013102702/http://www-db.stanford.edu/~sergey/http://web.archive.org/web/19991013102702/http://hci.stanford.edu/~page/http://web.archive.org/web/19991013102702/http://www-cs-students.stanford.edu/~csilvers/mailto:[email protected]://web.archive.org/web/19991013102702/http://www-cs-students.stanford.edu/~alans/http://web.archive.org/web/19991013102702/http://www-db.stanford.edu/people/hector.htmlhttp://web.archive.org/web/19991013102702/http://theory.stanford.edu/people/rajeev/motwani.htmlhttp://web.archive.org/web/19991013102702/http://www-db.stanford.edu/~ullman/http://web.archive.org/web/19991013102702/http://www-pcd.stanford.edu/~winograd/http://web.archive.org/web/19991013102702/http://www.nsf.gov/http://web.archive.org/web/19991013102702/http://www.nsf.gov/http://web.archive.org/web/19991013102702/http://www.nasa.gov/http://web.archive.org/web/19991013102702/http://www.darpa.mil/http://web.archive.org/web/19991013102702/http://www.interval.com/http://web.archive.org/web/19991013102702/http://www.ibm.com/http://web.archive.org/web/19991013102702/http://www.intel.com/http://web.archive.org/web/19991013102702/http://www.intel.com/http://web.archive.org/web/19991013102702/http://www.sun.com/http://web.archive.org/web/19991013102702/http://www.penguincomputing.com/http://web.archive.org/web/19991013102702/http://www.gnu.org/http://web.archive.org/web/19991013102702/http://www.linux.org/http://web.archive.org/web/19991013102702/http://www.python.org/http://web.archive.org/web/19991013102702/http://www.python.org/mailto:[email protected]://web.archive.org/web/19991013102702/http://www.gimp.org/http://web.archive.org/web/19991013102702/http://www-cs.stanford.edu/http://web.archive.org/web/19991013102702/http://www-cs.stanford.edu/http://web.archive.org/web/19991013102702/http://www.stanford.edu/http://web.archive.org/web/19991013102702/http://www-diglib.stanford.edu/http://web.archive.org/web/19991013102702/http://hci.stanford.edu/http://web.archive.org/web/19991013102702/http://www-db.stanford.edu/http://web.archive.org/web/19991013102702/http://infolab.stanford.edu/http://web.archive.org/web/19991013102702/http://www-db.stanford.edu/midas/midas.htmlhttp://web.archive.org/web/19991013102702/http://www-db.stanford.edu/midas/midas.htmlhttp://web.archive.org/web/19991013102702/http://theory.stanford.edu/index.htmlhttp://web.archive.org/web/19991013102702/http://www.interval.com/http://web.archive.org/web/19991013102702/http://www.almaden.ibm.com/http://web.archive.org/web/19991013102702/http://csdcf.stanford.edu/http://web.archive.org/web/19991013102702/http://www-leland.stanford.edu/group/dcg/http://web.archive.org/web/19991013102702/http://www-leland.stanford.edu/group/dcg/http://web.archive.org/web/19991013102702/http://www-leland.stanford.edu/group/networking/http://web.archive.org/web/19991013102702/http://www-leland.stanford.edu/group/networking/http://web.archive.org/web/19991013102702/http://www-leland.stanford.edu/group/dcg/http://web.archive.org/web/19991013102702/http://www-leland.stanford.edu/group/dcg/http://web.archive.org/web/19991013102702/http://csdcf.stanford.edu/http://web.archive.org/web/19991013102702/http://www.almaden.ibm.com/http://web.archive.org/web/19991013102702/http://www.interval.com/http://web.archive.org/web/19991013102702/http://theory.stanford.edu/index.htmlhttp://web.archive.org/web/19991013102702/http://www-db.stanford.edu/midas/midas.htmlhttp://web.archive.org/web/19991013102702/http://www-db.stanford.edu/midas/midas.htmlhttp://web.archive.org/web/19991013102702/http://infolab.stanford.edu/http://web.archive.org/web/19991013102702/http://www-db.stanford.edu/http://web.archive.org/web/19991013102702/http://hci.stanford.edu/http://web.archive.org/web/19991013102702/http://www-diglib.stanford.edu/http://web.archive.org/web/19991013102702/http://www.stanford.edu/http://web.archive.org/web/19991013102702/http://www-cs.stanford.edu/http://web.archive.org/web/19991013102702/http://www.gimp.org/mailto:[email protected]://web.archive.org/web/19991013102702/http://www.python.org/http://web.archive.org/web/19991013102702/http://www.linux.org/http://web.archive.org/web/19991013102702/http://www.gnu.org/http://web.archive.org/web/19991013102702/http://www.penguincomputing.com/http://web.archive.org/web/19991013102702/http://www.sun.com/http://web.archive.org/web/19991013102702/http://www.intel.com/http://web.archive.org/web/19991013102702/http://www.ibm.com/http://web.archive.org/web/19991013102702/http://www.interval.com/http://web.archive.org/web/19991013102702/http://www.darpa.mil/http://web.archive.org/web/19991013102702/http://www.nasa.gov/http://web.archive.org/web/19991013102702/http://www.nsf.gov/http://web.archive.org/web/19991013102702/http://www-pcd.stanford.edu/~winograd/http://web.archive.org/web/19991013102702/http://www-db.stanford.edu/~ullman/http://web.archive.org/web/19991013102702/http://theory.stanford.edu/people/rajeev/motwani.htmlhttp://web.archive.org/web/19991013102702/http://www-db.stanford.edu/people/hector.htmlhttp://web.archive.org/web/19991013102702/http://www-cs-students.stanford.edu/~alans/mailto:[email protected]://web.archive.org/web/19991013102702/http://www-cs-students.stanford.edu/~csilvers/http://web.archive.org/web/19991013102702/http://hci.stanford.edu/~page/http://web.archive.org/web/19991013102702/http://www-db.stanford.edu/~sergey/http://web.archive.org/web/19991013102702/http://google.stanford.edu/googlehardware.htmlhttp://web.archive.org/web/19991013102702/http://google.stanford.edu/google_papers.htmlhttp://web.archive.org/web/19991013102702/http://google.stanford.edu/


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EXHIBIT 3



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EXHIBIT 4



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paul allen patent complaint (interval licensing, llc v. aol, inc., et al.)

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