throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`META PLATFORMS, INC.,
`Petitioner,
`
`v.
`
`MULLEN INDUSTRIES LLC,
`Patent Owner.
`
`Case IPR2025-00741
`U.S. Patent No. 11,376,493 B2
`Issue Date: July 5, 2022
`
`Title: LOCATION-BASED GAMES AND
`AUGMENTED REALITY SYSTEMS
`
`DECLARATION OF INGRID HSIEH-YEE, PH.D.
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 001
`
`

`

`I.
`
`II.
`
`INTRODUCTION AND QUALIFICATIONS ............................................ 3
`A. Qualifications and Professional Experience ....................................... 3
`BACKGROUND OF LIBRARY CATALOGING ....................................... 4
`A. Machine-Readable Cataloging (“MARC”) ......................................... 4
`B.
`Library Online Catalogs ..................................................................... 7
`C.
`Scope of this Declaration ................................................................... 9
`D.
`Evidence Considered in Forming My Opinion ................................. 11
`III. AUTHENTICATION AND PUBLIC AVAILABILITY OF
`ROLLAND (EX1013) ................................................................................. 12
`A. Authentication ................................................................................. 12
`B.
`Records of Linda Hall Library ......................................................... 14
`C.
`Copyright Registration Record ......................................................... 18
`D. Usage Records ................................................................................. 18
`E.
`Summary of My Opinion on Rolland ............................................... 19
`IV. CONCLUSION ......................................................................................... 19
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 002
`
`

`

`I, Ingrid Hsieh-Yee, declare as follows:
`
`I.
`
`INTRODUCTION AND QUALIFICATIONS
`I am over the age of eighteen and otherwise competent to make this
`1.
`
`declaration.
`
`2.
`
`I have been retained by counsel for Petitioner to provide my expert
`
`opinion in connection with the above-captioned proceeding (“IPR”) regarding the
`
`public availability of a certain prior art references in relation to U.S. Patent No.
`
`11,376,493 B2 (“Challenged Patent”).
`
`3.
`
`I am being compensated for my time in connection with this IPR at my
`
`current consulting rate. I am also being reimbursed for any reasonable expenses
`
`associated with my work and testimony in this investigation. My compensation is
`
`not contingent on the results of my study, the substance of my opinions, or the
`
`outcome of this matter.
`
`A. Qualifications and Professional Experience
`4. My complete qualifications and professional experience are described
`
`in my academic curriculum vitae (Appendix A). The following is a brief summary
`
`of my relevant qualifications and professional experience.
`
`5.
`
`I was a professor in the Department of Library and Information Science
`
`at the Catholic University of America for 32 years and was conferred the title of
`
`Professor Emerita in December 2022. I have experience working in an academic
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 003
`
`

`

`library, a medical library, and a legislative library. I hold a Ph.D. and a Masters in
`
`Library and Information Studies from the University of Wisconsin-Madison.
`
`6.
`
`I am an expert on library cataloging and classification and have
`
`published two editions on this subject, Organizing Audiovisual and Electronic
`
`Resources for Access: A Cataloging Guide (2000 and 2006). I taught a variety of
`
`courses, including Cataloging and Classification, Advanced Cataloging and
`
`Classification, Organization of Internet Resources, Organization of Information,
`
`Metadata, Digital Content Creation and Management, Internet Searches and Web
`
`Design, Information Literacy Instruction, Advanced Information Retrieval and
`
`Analysis Strategies, and The Information Professions in Society. I am familiar with
`
`metadata schema design and implementation. In my teaching, I covered the design
`
`and implementation of metadata in databases, search engines, digital repositories,
`
`digital libraries, and digital archives. I also covered how information organization
`
`affects the discovery and access to digital resources on the Internet. My research
`
`interests cover cataloging and classification, information organization, metadata,
`
`information retrieval,
`
`information architecture, digital collections, scholarly
`
`communication, social media, user interaction with information systems, and others
`
`II. BACKGROUND OF LIBRARY CATALOGING
`A. Machine-Readable Cataloging (“MARC”)
`I am very familiar with a library cataloging encoding standard known
`7.
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 004
`
`

`

`as the “Machine-Readable Cataloging” standard, also known as “MARC,” which
`
`became the national standard for sharing bibliographic data in the United States by
`
`1971 and the international standard by 1973. MARC is the primary communications
`
`protocol for the transfer and storage of bibliographic metadata in libraries. Experts in
`
`my field reasonably rely upon MARC records when forming their opinions.
`
`8.
`
`A MARC record consists of several fields, each of which contains
`
`specific data about the work. Each field is identified by a standardized, unique, three-
`
`digit code corresponding to the type of data that follows. Appendix B is a true and
`
`correct copy of Parts VII to X of “Understanding MARC Bibliographic: Machine-
`
`Readable Cataloging” (https://www.loc.gov/marc/umb/um07to10.html), a brief
`
`description and tutorial published by the Library of Congress in 2009 that explains
`
`commonly used MARC fields. For example, the personal author of a work is recorded
`
`in Field 100, the title is recorded in Field 245, publisher information is recorded in
`
`Field 260, the physical volume and characteristics of a publication are recorded in
`
`Field 300, and topical subjects are recorded in Fields 650. More details of MARC21
`
`format for Bibliographic Data are available on the Library of Congress website at
`
`https://www.loc.gov/marc/bibliographic/.
`
`9.
`
`I am very familiar with library cataloging and processing practices and
`
`the relationships between OCLC (Online Computer Library Center) and library
`
`catalogs, and how libraries create and share their records to help the public discover
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 005
`
`

`

`and access information.
`
`10. OCLC is the largest bibliographic network of the world, and its
`
`WorldCat database contains more than 559 million records from thousands of
`
`member institutions (many of which are libraries of some type) in more than 100
`
`countries. OCLC was founded in 1967 to promote and support library cooperation.
`
`According to the third article of the “Amended Articles of Incorporation of OCLC
`
`[Online Computer Library Center], Inc.,” OCLC was created “to establish, maintain,
`
`and operate a computerized library network and to promote the evolution of library
`
`use, of libraries themselves, and of librarianship, and to provide processes and
`
`products for the benefit of library users and libraries, including such objectives as
`
`increasing availability of library resources to individual library patrons and reducing
`
`the rate of rise of library per-unit costs, all for the fundamental public purpose of
`
`furthering ease of access to and use of the ever-expanding body of worldwide
`
`scientific,
`
`literary, and educational knowledge and
`
`information”
`
`(source:
`
`https://www.oclc.org/content/dam/oclc/membership/articles-of-incorporation.pdf).
`
`11. OCLC members can contribute original cataloging records in MARC
`
`to the system or derive cataloging records from existing records, an activity referred
`
`to as “copy cataloging.” When an OCLC participating institution acquires a work, it
`
`can create an original MARC record for the work in OCLC’s Connexion system (a
`
`system for catalogers to create and share MARC records), and the system will
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 006
`
`

`

`automatically generate a code for the date of record creation in the yymmdd format,
`
`and the creating library’s OCLC symbol is recorded in subfield “a” of the 040 field.
`
`Once the MARC record is in Connexion, it becomes available to other OCLC
`
`members for adoption to their local online catalogs (i.e., copy cataloging).
`
`12. After a MARC record is created in Connexion, it also becomes
`
`searchable and viewable on WorldCat.org, which is a free web portal for users to
`
`explore more than 10,000 libraries worldwide. Records in WorldCat.org, however,
`
`are not presented in MARC fields. Instead, the data elements are labeled to help users
`
`interpret the records. Thus, the information stored in MARC records in Connexion is
`
`available to the interested public through the user-friendly WorldCat web portal.
`
`B.
`13.
`
`Library Online Catalogs
`Library online catalogs gained acceptance in the early 1980s and many
`
`libraries migrated their systems to the World Wide Web in the mid-1990s. Library
`
`online catalogs are based on MARC records that represent their collections in order
`
`to help the public understand what materials are publicly accessible in those libraries.
`
`Most libraries with online catalogs have made their catalogs freely available on the
`
`Web. These online catalogs offer user-friendly search interfaces. Strong user interest
`
`in keyword searches and the popularity of Google have led to the “googlization” of
`
`library search systems. As a result, many library catalogs nowadays provide a single
`
`search box for users to conduct keyword searches, with additional support for
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 007
`
`

`

`searches by author, title, subject terms, and other data elements such as ISBN
`
`(International Standard Book Number). Library catalogs these days also offer
`
`features for users to narrow their search results by language, year, format, and other
`
`elements. Many libraries display MARC records on their online catalogs with labels
`
`for the data elements to help the public interpret MARC records. Many libraries also
`
`offer the option to display MARC records in MARC fields.
`
`14.
`
`Libraries create MARC records for works they acquire, including
`
`books, serials, motion pictures, and publications in other formats. Monograph
`
`cataloging is fairly common in libraries, and most libraries make a newly cataloged
`
`monograph available to the public soon after the cataloging work is completed,
`
`usually within a week. Libraries can create original cataloging records or use an
`
`existing record in the OCLC WorldCat database to create a copy cataloging record.
`
`As soon as the cataloging record is completed, it is added to the library’s online
`
`catalog for users. If the record is an original record, it is also entered into the OCLC
`
`system. If it is a copy cataloging record, the library’s holding symbol is attached to
`
`the existing original record in the OCLC system to facilitate searching and
`
`interlibrary loan.
`
`15.
`
`I am personally familiar with many online catalogs, databases, and
`
`search engines. In preparing for this declaration, I used the following authoritative
`
`information systems to search for records:
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 008
`
`

`

`• Google Scholar (https://scholar.google.com/)
`
`• Libraries.org, a directory of
`
`libraries
`
`throughout
`
`the world
`
`(https://librarytechnology.org/libraries/)
`
`• Online
`
`catalog
`
`of
`
`the
`
`Linda
`
`Hall
`
`Library
`
`(https://catalog.lindahall.org/discovery/search?vid=01LINDAHALL_I
`
`NST:LHL)
`
`• Public
`
`catalog
`
`of
`
`the
`
`US
`
`Copyright
`
`Office
`
`(https://cocatalog.loc.gov/cgi-
`
`bin/Pwebrecon.cgi?DB=local&PAGE=First)
`
`• WorldCat.org (https://search.worldcat.org/)
`
`C.
`16.
`
`Scope of this Declaration
`I have been asked to offer an opinion on the public availability dateS of
`
`the following documents:
`
`• Rolland, J. P., Holloway, R. L., & Fuchs, H. (1995, December).
`
`Comparison of optical and video see-through, head-mounted displays,
`
`in Telemanipulator and Telepresence Technologies : 31 October-1
`
`November 1994, Boston, Massachusetts, Proceedings of SPIE vol. 2351,
`
`pp. 293-307, EX1013 (“Rolland”).
`
`17.
`
`I am informed by counsel and. Understand that a given reference is
`
`“published” upon a satisfactory showing that such a document has been disseminated
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 009
`
`

`

`or otherwise made publicly available to the extent that persons interested and
`
`ordinarily skilled in the subject matter or art could locate it exercising reasonable
`
`diligence and obtain the document. I have also been informed by counsel and
`
`understand that materials available in a library constitute “printed publications” if
`
`they are catalogued and indexed according to general library practices and protocols
`
`that make the references available and accessible to members of the interested public.
`
`18.
`
`I have been informed by counsel that the Challenged Patent claims
`
`November 16, 2004, as its earliest priority date. I have assessed public accessibility
`
`of the documents referenced below as of this claimed priority date.
`
`19.
`
`I have been informed by counsel that the subject matter of this
`
`proceeding generally relates to virtual and augmented reality computing systems.
`
`20.
`
`I have been informed by counsel that a “person of ordinary skill in the
`
`art at the time of the invention” (POSA) is a hypothetical person who is presumed to
`
`be familiar with the relevant field and its literature at the time of the inventions. I
`
`have been informed by counsel that this hypothetical person is also a person of
`
`ordinary creativity, capable of understanding the scientific principles and literature
`
`applicable to the pertinent field.
`
`21.
`
`I have been informed by counsel that a person of ordinary skill in the
`
`art as of November 16, 2004, would have knowledge of the scientific literature and
`
`have skills relating to virtual and augmented reality computing systems. A person of
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0010
`
`

`

`ordinary skill would have possessed a bachelor’s degree in electrical engineering,
`
`computer science, or similar field, with two years combined experience in designing
`
`and/or developing interactive location-based computer systems/software, such as
`
`video games or other simulations incorporating location information (such as GPS
`
`information associated with a user’s physical location), and in designing and/or
`
`developing computer systems/software involving graphical virtual and/or augmented
`
`reality. A person could also have qualified as a person of ordinary skill in the art with
`
`some combination of (1) more formal education (such as a master’s of science
`
`degree) and less technical experience, or (2) less formal education and more technical
`
`or professional experience.
`
`22.
`
`It is my opinion that such a person would have been actively engaged
`
`in learning about the field, possibly through formal instruction and through
`
`bibliographic resources. By at least November 16, 2004, such a person would have
`
`had access to a vast array of print and electronic resources, including at least the
`
`documents referenced below.
`
`D. Evidence Considered in Forming My Opinion
`In the preparation of this declaration, I have reviewed EX1013
`23.
`
`referenced in paragraph 16 above, and any other documents I reference herein. Each
`
`of these is a type of material that experts in my field would reasonably rely upon
`
`when forming their opinions. I provided a further description of materials I
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0011
`
`

`

`considered in Appendix C.
`
`III. Authentication and Public Availability of Rolland (EX1013)
`
`A. Authentication
`
`24.
`
`Exhibit 1013 is a true and correct copy of “Comparison of optical and
`
`video see-through, head-mounted displays,” (“Rolland”), by Rolland, Holloway, and
`
`Fuchs, in Telemanipulator and Telepresence Technologies : 31 October-1 November
`
`1994, Boston, Massachusetts, Proceedings of SPIE vol. 2351, pp. 293-307, that I
`
`obtained from the Linda Hall Library. This copy is presented as EX1013 in this
`
`declaration.
`
`25.
`
`Page 1 is the cover that shows the conference name, conference chair
`
`and editor, and the date and location of the conference. The top of the page indicates
`
`this work is the proceedings of “SPIE – The International Society for Optical
`
`Engineering” and the page identifies this work as “Volume 2351.” Page 2 shows the
`
`same information as the cover, and indicates “SPIE – The International Society for
`
`Optical Engineering” sponsored and published this work, and “IEEE NCC – Virtual
`
`Reality Technical Committee” is a cooperating organization. Page 3 is the copyright
`
`page that shows this work has a “1994” copyright date and SPIE holds the copyright.
`
`It also shows the ISBN (International Standard Book Number) of this work is “0-
`
`8194-1686-X” and the Library of Congress Catalog Card No. for this work is “94-
`
`67548.” The top of the page shows a hand-written call number of “TJ210.3 .T442
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0012
`
`

`

`1994.” Pages 4 to 6 (internal pages iii to v) are the table of contents, and the left side
`
`of page 4 shows an annotation of “3-14-95” (i.e., March 14, 1995), indicating the
`
`Linda Hall Library added this work to their collections on this date. The knowledge
`
`of this date annotation practice is based on my personal experience with the library
`
`and its collections. This page also shows a library stamp of the Linda Hall Library.
`
`Page 6 (internal page v) shows Rolland begins on page 293.
`
`26.
`
`Pages 7 to 21 are the full text of Rolland. Page 7 (internal page 293)
`
`shows the title, authors, abstract, and keywords of this article. The bottom of the page
`
`shows this article appears in “SPIE Vol. 2315 Telemanipulator and Telepresence
`
`Technologies (1994)” whose ISBN is “0-8194-1686-X.” EX1013 shows Rolland has
`
`a total of 15 pages, including seven figures and 29 references.
`
`27.
`
`To authenticate EX1013, I obtained a copy of Rolland from the
`
`webpage
`
`for
`
`this
`
`article
`
`at https://www.spiedigitallibrary.org/conference-
`
`proceedings-of-spie/2351/0000/Comparison-of-optical-and-video-see-through-
`
`head-mounted-displays/10.1117/12.197322.short from the SPIE Digital Library.
`
`This SPIE copy is presented as EX1013A in this declaration. EX1013A shows this
`
`article has a total of 15 pages, including seven figures and 29 references. I have
`
`closely compared the library copy (EX1013) with the publisher copy (EX1013A),
`
`and found them to contain the same content for Rolland.
`
`28.
`
`EX1013 is in a condition that raises no suspicion about its authenticity.
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0013
`
`

`

`Specifically, this copy is not missing any intermediate pages, and there are no visible
`
`alterations to the document. Furthermore, this library copy has the same content as
`
`the publisher copy (EX1013A) and is held by a well-known public research library.
`
`Based on my review and analysis, it is my opinion that EX1013 is authentic.
`
`B. Records of Linda Hall Library
`
`29.
`
`To determine the public availability date of Telemanipulator and
`
`Telepresence Technologies (Proceedings of SPIE Vol. 2351) that contains Rolland in
`
`libraries, I obtained records for this work from the online catalog of the Linda Hall
`
`Library. EX1013B is a true and correct copy of the bibliographic and MARC records
`
`for this work. I personally located, identified, and obtained these records. They are
`
`the type of records experts in my field would reasonably rely upon when forming
`
`their opinions.
`
`30.
`
`Pages 1 to 3 of EX1013B are the bibliographic record and Page 4 is a
`
`copy of the MARC record. Page 1 shows ”conference proceedings” is the format of
`
`this work, and it is cataloged as a book and is available at “Linda Hall Library Books
`
`– 2nd Floor (TJ210.3.T442 1994).” The record details includes the title, series title,
`
`personal and corporate contributors, subjects, ISBNs, series details, publisher,
`
`creation date (“c1994”), physical details, and a general note. The title, editor,
`
`associated organizations, publisher, the 10-digit ISBN, and series information match
`
`the
`
`information presented
`
`in EX1013, confirming
`
`this record represents
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0014
`
`

`

`Telemanipulator and Telepresence Technologies that contains Rolland.
`
`31.
`
`Page 4 is a copy of the MARC record. The first six digits of Field 008
`
`show the record was created on “950214” (i.e., February 14, 1995), and the code of
`
`“s1994” following the record creation date shows this work has a single publication
`
`date of 1994. Subfields ‘a” and “c” of Field 040 show “RVE” created the original
`
`record and entered it into the OCLC WorldCat database, and subfield “d” shows
`
`“LHL” modified the original record later. According to the Directory of OCLC
`
`Members (https://www.oclc.org/en/contacts/libraries.html), “RVE” is the OCLC
`
`library symbol for the Rochester Institute of Technology Library, and “LHL” is the
`
`OCLC library symbol for Linda Hall Library. Based on the data in Fields 008 and
`
`040, it is my opinion that the Rochester Institute of Technology Library created the
`
`original record for the conference proceedings containing Rolland on February 14,
`
`1995, and Linda Hall Library used the original record to create their copy cataloging
`
`record. The date annotation in EX1013 shows the library added the conference
`
`proceedings to their collections on March 14, 1995. It is therefore my opinion that
`
`the copy cataloging record for Telemanipulator and Telepresence Technologies that
`
`contains Rolland became discoverable in their online catalog on March 14, 1995. A
`
`customary library practice is to process a newly cataloged monograph promptly for
`
`public access, usually within a week after the cataloging work is completed. It is
`
`therefore my opinion that, after processing, the physical copy of Telemanipulator and
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0015
`
`

`

`Telepresence Technologies that contains Rolland became publicly accessible at the
`
`Linda Hall Library by March 21, 1995.
`
`32.
`
`Field 010 shows the Library of Congress card number, Field 020 shows
`
`the 13-digit and 10-digit ISBNs, Field 245 shows the title, subtitle, and statement of
`
`responsibility, and Field 260 shows the publisher and copyright date. Field 490 shows
`
`the series information presented in the publication and Field 830 shows the authorized
`
`form of the series title and numbering. The editor is presented in Fields 700, and two
`
`sponsoring organizations are included in Fields 710. These fields show interested
`
`users could use these data elements to discover the conference proceedings
`
`containing Rolland.
`
`33.
`
`Interested users could also conduct subject searches to discover this
`
`conference proceedings, because the MARC record contains subject representations.
`
`Field 090 shows a Library of Congress Classification number (“TJ210.3”) that
`
`represents “Congresses” on “Mechanical devices and figures. Automata. Ingenious
`
`mechanism. Robots (General)” (source: Library of Congress Classification Schedule
`
`T at https://www.loc.gov/aba/publications/FreeLCC/LCC_T2019TEXT.pdf), and
`
`Fields 650 show four Library of Congress subject headings, with “Manipulators
`
`(Mechanism),” “Robotics,” “Remote control,” and “Virtual reality” representing the
`
`main topics, each followed by “Congresses” as a form subheading encoded in
`
`subfield “v” to indicate the main topics are treated at a conference.
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0016
`
`

`

`34.
`
`The date annotation in EX1013 and the MARC record (EX1013B)
`
`show that the Linda Hall Library completed their copy cataloging record for
`
`Telemanipulator and Telepresence Technologies that contains Rolland on March 14,
`
`1995, making this work discoverable in their online catalog from that date on. As of
`
`that date, interested users could discover this work by title, series, editor, and two
`
`sponsoring organizations. They could also conduct subject searches to discover this
`
`conference proceedings.
`
`35. As evidence that the Linda Hall Library had an online catalog in
`
`operation in 1995 when the library added Telemanipulator and Telepresence
`
`Technologies that contains Rolland on March 14, 1995 to their collections, I obtained
`
`a profile of
`
`the
`
`library at https://librarytechnology.org/library/2294
`
`from
`
`libraries.org, a directory of libraries throughout the world. I personally located,
`
`identified, and obtained this profile. This is the type of record experts in my field
`
`would reasonably rely upon when forming their opinions. This profile is presented as
`
`EX1013C in this declaration.
`
`36.
`
`The Technology Profile on page 2 of EX1013C shows the Linda Hall
`
`Library began using Horizon as their online catalog in 1994, and changed to Voyager
`
`in 2010. These dates mean that in 1995 interested users were able to use the Horizon
`
`system to search for the conference proceedings containing Rolland and access this
`
`article at the Linda Hall Library.
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0017
`
`

`

`C. Copyright Registration Record
`
`37.
`
`Ex. 1013D is a true and correct copy of the copyright registration record
`
`for Telemanipulator and Telepresence Technologies that contains Rolland. I
`
`personally located, identified, and obtained this record from the public catalog of the
`
`US Copyright Office. This is the type of record experts in my field would reasonably
`
`rely upon when forming their opinions.
`
`38.
`
`The title, subtitle, editor, imprint, series title, and series numbering
`
`match the information presented in EX1013, confirming this record represents
`
`Telemanipulator and Telepresence Technologies that contains Rolland. The “Date of
`
`Publication” field shows this work was published on “1994-12-30” (i.e., December
`
`30, 1994), and the “Registration Number / Date” field shows this work was registered
`
`with the US Copyright Office on “1995-04-05” (i.e., April 5, 1995). These dates align
`
`well with the “3-14-95” date annotation in EX1013 that shows the Linda hall Library
`
`added this work to their collections on that date.
`
`D. Usage Records
`
`39. Actual usage of a publication is reflected by other publications that
`
`make reference to it. I have reviewed citations to Rolland on Google Scholar to
`
`compile a list of early citations. EX1013E presents six citations published from 1996
`
`to 2000 to show early usage of Rolland. This list shows the earliest citation appeared
`
`in 1997.
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0018
`
`

`

`E.
`
`40.
`
`Summary of My Opinion on Rolland
`
`The copyright
`
`registration
`
`record
`
`for Telemanipulator and
`
`Telepresence Technologies that contains Rolland (EX1013D) shows this work was
`
`published on December 30, 1994. The date annotation on EX1013 shows Linda Hall
`
`Library added this work to their collections on March 14, 1995, and the MARC record
`
`(EX1013B) shows their copy cataloging record was based on a record created by the
`
`Rochester Institute of Technology Library. The MARC record has made this work
`
`discoverable in the online catalog of the Linda Hall Library since March 14, 1995.
`
`The physical copy, after processing, would become publicly accessible by March 21,
`
`1995.
`
`IV. Conclusion
`
`41.
`
`In signing this Declaration, I recognize that the Declaration will be filed
`
`as evidence in a contested case before the Patent Trial and Appeal Board of the United
`
`States Patent and Trademark Office. I also recognize that I may be subject to cross-
`
`examination in this proceeding. If required, I will appear for cross-examination at the
`
`appropriate time.
`
`42.
`
`I hereby declare that all statements made herein of my own knowledge
`
`are true and that all statements are made on information and belief are believed to be
`
`true, and further that these statements were made with the knowledge that willful
`
`false statements and the like so made are punishable by fine or imprisonment, or both,
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0019
`
`

`

`under 18 U.S.C. § 1001.
`
`Dated: March 25, 2025
`
`Respectfully submitted,
`
`agitee
`
`Ingrid Hsieh-Yee, Ph.D.
`Annapolis, Maryland
`
`6.
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0020
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0020
`
`

`

`APPENDIX A
`APPENDIX A
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0021
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0021
`
`

`

`
`
`Ingrid Hsieh-Yee
`Professor Emerita
`Dept. of Library and Information Science
`Catholic University of America
`Washington, D.C. 20064
`E-mail: hsiehyee@cua.edu
`
`
`Education
`
`Ph.D. 1990. Library and Information Studies, University of Wisconsin-Madison
`
`Minors: Sociology and Psychology
`
`M.A. 1984. Library and Information Studies, University of Wisconsin-Madison.
`
`M.A. 1983. Comparative Literature, University of Wisconsin-Madison.
`
`B.A. 1980. Foreign Languages and Literature, National Taiwan University.
`
`
`Work Experience
`
`Professor, School/Dept. of Library and Information Science, Catholic University of America,
`1990-2022 (Assistant Professor, 1990-1996; Associate Professor, 1997-2004; Professor
`2004-2022; Professor Emerita 2022)
`
`
`Co-Chair, Dept. of Library and Information Science, Catholic University of America, June 2015-
`August 2016.
`
`
`Acting Dean, School of Library and Information Science, Catholic University of America,
`January 2010-June 2012.
`
`
`Cataloger, Dept. of Legislative Reference Library, Annapolis, Maryland, 1989-1990.
`
`Lecturer, School of Library and Information Studies, University of Wisconsin-Madison, 1988.
`
`Teaching Assistant, School of Library and Information Studies, University of Wisconsin-
`Madison, 1986-1988.
`
`
`Cataloger, Health Sciences Library, University of Wisconsin-Madison, 1984-1986.
`
`
`Areas of Teaching and Research Interests
`
`Information Organization and Access; Metadata; Cataloging & Classification; Information
`Architecture; Information Retrieval; Digital Collections; Social Media; Scholarly
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0022
`
`

`

`
`Communication; Information Behavior; Health Informatics; Human Computer Interaction;
`Usability Studies
`
`Grants & Honors
`
`Cultural Heritage Information Management Project. IMLS grant. Amount: $498,741. Period:
`Aug. 2012 to July 2015. Co-PI with Dr. Youngok Choi.
`
`2
`
`
`D.C. Health Information Technology (HIT4): Building Capacity & Providing Access in Our
`Nation’s Capital. Dept. of Labor H2B Training Grant. Grant amount: $4,175,500. Grant
`period: Nov. 2011 to Dec. 2015. Partner with the Metropolitan School of Professional
`Studies of the Catholic University of America, Children’s National Medical Center, D.C.
`Department of Employment Services, Holy Cross Hospital, Howard University, Center
`for Urban Progress, Providence Hospital, and Sibley Memorial Hospital.
`
`
`Capital Health Careers Project. Department of Labor Healthcare Sector and Other High Growth
`and Emerging Industries Grant. Grant amount: $4,953,999. Grant period: March 2010 –
`February 2013. Awarded to a group of healthcare organizations and educational
`institutions in Washington, D.C. Providence Health Foundation of Providence Hospital
`(Lead institution). Part of the grant supported the development of a Master’s degree
`program in Information Technology with a concentration in Health Information
`Technology offered by the School of Library and Information Science.
`
`
`The Washington D.C. School Librarians Project. IMLS grant. Grant amount: $412,660. Grant
`period: Aug. 2007 – June 2011. The School partnered with the District of Columbia
`Public Schools (DCPS) and the District of Columbia Library Association to educate and
`mentor school media specialists for the DCPS system. PI, Jan. 2010 to June 2011.
`
`
`SIG Member of the Year, American Society for Information Science and Technology (2009).
`
`Most Outstanding Paper of OCLC Systems & Services (2001).
`
`ALISE Research Grant (2001).
`
`Most Outstanding Paper of OCLC Systems & Services (2000).
`
`Research Grant from ERIC (1999-2000).
`
`Best Research Paper Award; Association for Library and Information Science Education (1998).
`
`Research Grants, Catholic University of America. 1991, 1992, 1993, 1996, 1998, 1999, 2004,
`2005, 2006, 2007, 2013-14.
`
`
`Cooperative Faculty Research Grant, Consortium of Universities in the Washington
`Metropolitan Area (1993-1994).
`
`Meta Exhibit 1017
`Meta v. Mullen - Page 0023
`
`

`

`3
`
`
`
`
`Cooperative Research Grant, Council on Library Resources (1993-1994).
`
`Journal of the American S

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