UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLE, LLC,
`Petitioner,
`
`v.
`
`CELLULAR SOUTH INC.,
`Patent Owner.
`
`Case IPR2025-00877
`Patent 11,126,853 B2
`
`DECLARATION OF INGRID HSIEH-YEE, PH.D.
`
`Google Exhibit 1018 - Google v. CSI
`IPR2025-00877 - Page 001
`
`

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`
`
`I.
`
`TABLE OF CONTENTS
`
`II.
`
`Page
`INTRODUCTION AND QUALIFICATIONS ............................................ 4
`A. Qualifications and Professional Experience ....................................... 4
`BACKGROUND OF LIBRARY CATALOGING ....................................... 5
`A. Machine-Readable Cataloging (“MARC”) ......................................... 5
`B.
`Library Online Catalogs ..................................................................... 8
`C.
`Scope of this Declaration ................................................................. 12
`D.
`Evidence Considered in Forming My Opinions ............................... 15
`III. AUTHENTICITY AND PUBLIC AVAILABILITY OF KOUZANI
`(EX1006) ................................................................................................... 15
`A. Authentication ................................................................................. 15
`B.
`Records of Library of Congress ....................................................... 17
`C.
`Records of Princeton University Library .......................................... 21
`D.
`IEEE Record .................................................................................... 24
`E.
`Usage Records ................................................................................. 25
`F.
`Summary of My Opinion on Kouzani .............................................. 25
`IV. AUTHENTICITY AND PUBLIC AVAILABILITY OF YANG
`(EX1007) ................................................................................................... 27
`A. Authentication ................................................................................. 27
`B.
`Records of Library of Congress ....................................................... 28
`C.
`Internet Archive Record ................................................................... 32
`D.
`Copyright Record............................................................................. 33
`E.
`Usage Record ................................................................................... 33
`F.
`Summary of My Opinion on Yang ................................................... 34
`V. AUTHENTICITY AND PUBLIC AVAILABILITY OF ROMDHANI
`(EX1008) ................................................................................................... 35
`A. Authentication ................................................................................. 35
`B.
`Records of the Library of Congress .................................................. 37
`C.
`Usage Records ................................................................................. 40
`D.
`Summary of My Opinion on Romdhani ........................................... 41
`ii
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`VI. AUTHENTICITY AND PUBLIC AVAILABILITY OF LUBBERS
`(EX1011) ................................................................................................... 41
`A. Authentication ................................................................................. 41
`B.
`Records of the University of New Orleans Library .......................... 43
`C.
`Internet Archive Records ................................................................. 46
`D. Usage Records ................................................................................. 48
`E.
`Summary of My Opinion on Lubbers............................................... 48
`VII. AUTHENTICITY AND PUBLIC AVAILABILITY OF VAN VLIET
`(EX1013) ................................................................................................... 49
`A. Authentication ................................................................................. 49
`B.
`Library of Congress Records............................................................ 51
`C.
`Copyright Registration Record ......................................................... 54
`D.
`Internet Archive Record ................................................................... 54
`E.
`Citation Records .............................................................................. 55
`F.
`Summary of My Opinion on Van Vliet ............................................. 55
`VIII. AUTHENTICITY AND PUBLIC AVAILABILITY OF TANG
`(EX1014) ................................................................................................... 57
`A. Authentication ................................................................................. 57
`B.
`Records of Linda Hall Library ......................................................... 59
`C.
`Copyright Registration Record ......................................................... 62
`D.
`Internet Archive Record ................................................................... 62
`E.
`Usage Records ................................................................................. 64
`F.
`Summary of My Opinion on Tang ................................................... 64
`IX. CONCLUSION ......................................................................................... 65
`
`
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`
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`-iii-
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`
`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
`
`US Patent No. 11,126,853 (“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
`
`library, a medical library, and a legislative library. I hold a Ph.D. and a Masters in
`
`
`
`
`
`-4-
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`
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`
`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.
`
`as the “Machine-Readable Cataloging” standard, also known as “MARC,” which
`
`
`
`
`
`-5-
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`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
`
`and access information.
`
`
`
`
`
`-6-
`
`
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`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 WorldShare system (a
`
`system for catalogers to create and share MARC records), and the system will
`
`automatically generate a code for the date of record creation in the yymmdd format,
`
`
`
`
`
`-7-
`
`
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`and the creating library’s OCLC symbol is recorded in subfield “a” of the 040 field.
`
`Once the MARC record is in WorldShare, the record is stored in the OCLC WorldCat
`
`database and becomes available to other OCLC members for adoption to their local
`
`online catalogs (i.e., copy cataloging). “WorldCat is the world’s most comprehensive
`
`database of
`
`information about
`
`library collections”
`
`(source: WorldCat,
`
`https://www.oclc.org/en/worldcat.html).
`
`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
`
`
`
`
`
`-8-
`
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`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
`
`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.
`
`The cataloging of serials and the serial check-in process are discussed
`
`
`
`
`
`-9-
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`here to show how libraries usually provide access to newly received serial issues.
`
`According to the glossary of the RDA: Resource Description and Access cataloging
`
`standard, a serial is “a mode of issuance of a manifestation issued in successive parts,
`
`usually bearing numbering, that has no predetermined conclusion. A serial includes
`
`a periodical, monographic
`
`series, newspaper, etc.”
`
`(RDA Glossary at
`
`https://original.rdatoolkit.org/rdagloss_rdaregistry.info-termList-ModeIssue-
`
`1003_1.html
`
`(subscription
`
`required
`
`for
`
`access);
`
`cited
`
`https://www.ccslib.org/Catalogers/index.php/Category:Serials).
`
`Because
`
`in
`
`the
`
`publisher of a serial makes new issues of the serial available successively, a
`
`customary cataloging practice is to create one bibliographic record for the entire
`
`serial, and the serial record (encoded in MARC) typically provides information on
`
`the beginning date and frequency of the serial, not the dates of individual issues. In
`
`other words, libraries typically do not create MARC records for individual issues of
`
`a serial. Instead, they rely on a serial check-in system to track the receipt of new
`
`issues. A common check-in practice is to date stamp a new issue when it arrives. This
`
`practice has become automated since the late 1990s, and libraries now vary in how
`
`they share the receipt date of a new serial issue with the public. Some libraries use a
`
`date stamp, some affix a label to indicate the receipt date, some pencil in the receipt
`
`date, and some do not provide the information to the public.
`
`16.
`
`The serial check-in process usually takes less than an hour, and one of
`
`
`
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`the steps involves placing a date stamp on the new issue to document the date the
`
`issue is checked in. After that, the holdings information of the serial is updated in the
`
`library’s catalog so that users know which issues are available for request or access.
`
`After serial check-in is completed, the new issue is placed on the shelf with the
`
`previous issues of the serial. Libraries with a public periodical room typically place
`
`new issues in the periodical room for easy user access. Because information presented
`
`in serials often reflects latest discovery, a general practice of libraries is to make new
`
`issues of serials available for user access soon after they are checked in, usually
`
`within a week.
`
`17.
`
`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:
`
`• Google Scholar (https://scholar.google.com/)
`
`• IEEE Xplore (https://ieeexplore.ieee.org/Xplore/home.jsp)
`
`• Internet Archive (https://archive.org/)
`
`• Libraries.org, a directory of
`
`libraries
`
`throughout
`
`the world
`
`(https://librarytechnology.org/libraries/)
`
`• Online catalog of the Library of Congress (https://catalog.loc.gov/)
`
`• Online
`
`catalog
`
`of
`
`the
`
`Linda
`
`Hall
`
`Library
`
`(https://catalog.lindahall.org/discovery/search?vid=01LINDAHALL_I
`
`
`
`
`
`-11-
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`NST:LHL)
`
`• Online catalog of
`
`the University of New Orleans Library
`
`(https://uno.ent.sirsi.net/client/en_US/uno)
`
`• 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.
`18.
`
`Scope of this Declaration
`I have been asked to offer an opinion on the public availability date of
`
`the following documents:
`
`(1) Kouzani, A. Z., He, F., & Sammut, K. (1997, October). Fractal face
`
`representation and recognition, in 1997 IEEE International Conference
`
`on Systems, Man, and Cybernetics. Computational Cybernetics and
`
`Simulation (Vol. 2, pp. 1609-1613), EX1006 (“Kouzani”);
`
`(2) Yang, M. H., Kriegman, D. J., & Ahuja, N. (2002, January). Detecting
`
`faces in images: A survey. IEEE Transactions on Pattern Analysis and
`
`Machine Intelligence, 24(1), 34-58, EX1007 (“Yang”);
`
`(3) Romdhani, S., Blanz, V., & Vetter, T. (2002, May). Face identification
`
`by fitting a 3d morphable model using linear shape and texture error
`
`functions, in Computer Vision—ECCV 2002: 7th European Conference
`
`
`
`
`
`-12-
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`
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`on Computer Vision Copenhagen, Denmark, May 28–31, 2002
`
`Proceedings, Part IV, pp. 3-19. Springer Berlin Heidelberg, EX1008
`
`(“Romdhani”);
`
`(4) Lubbers, P., Albers, B., & Salim, F. (2010). Pro HTML5 Programming:
`
`Powerful APIs for Richer Internet Application Development. New York:
`
`Apress ; Springer, EX1011 (“Lubbers”);
`
`(5) Van Vliet, J., & Paganelli, F. (2011). Programming Amazon EC2. 1st
`
`ed. Sebastopol, Calif. : O'Reilly, EX1013 (“Van Vliet”)
`
`(6) Tang, X., & Qu, C. (2010). Facial image recognition based on fractal
`
`image encoding. Bell Labs Technical Journal, 15(1), 209-214, EX1014
`
`(“Tang”).
`
`19.
`
`I am informed by counsel and. Understand that a given reference is
`
`“published” upon a satisfactory showing that such a document has been disseminated
`
`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.
`
`20.
`
`I have been informed by counsel that the Challenged Patent claims June
`
`
`
`
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`-13-
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`29, 2016, as its earliest priority date. I have assessed public accessibility of the
`
`documents referenced below as of this claimed priority date.
`
`21.
`
`I have been informed by counsel that the subject matter of this
`
`proceeding generally relates to processing and/or analyzing multimedia content, such
`
`as audio, video, or image data.
`
`22.
`
`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.
`
`23.
`
`I have been informed by counsel that a person of ordinary skill in the
`
`art as of June 29, 2016, would have knowledge of the scientific literature and have
`
`skills relating to processing and/or analyzing multimedia content, such as audio,
`
`video, or image data. A person of ordinary skill would have possessed a bachelor’s
`
`degree in electrical engineering, computer science, or similar field, with at least two
`
`years of experience in developing and implementing computer software for
`
`processing and/or analyzing multimedia content, such as audio, video, or image data.
`
`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
`
`
`
`
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`less technical experience, or (2) less formal education and more technical or
`
`professional experience.
`
`24.
`
`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 June 29, 2016, 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 Opinions
`In the preparation of this declaration, I have reviewed EX1006-
`25.
`
`EX1008, EX1011, EX1013, and EX1014 referenced in paragraph 18 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 considered in Appendix C.
`
`III. Authenticity and Public Availability of Kouzani (EX1006)
`
`A. Authentication
`
`26.
`
`EX1006 is a true and correct copy of “Fractal face representation and
`
`recognition,” (“Kouzani”), by A. Z. Kouzani, F. He, K. Sammut, in 1997 IEEE
`
`International Conference on Systems, Man, and Cybernetics. Computational
`
`Cybernetics and Simulation, vol. 2, pp. 1609-1613, that I obtained from the Library
`
`of Congress (“LC”). When I began researching Kouzani, I searched WorldCat for
`
`
`
`
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`-15-
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`
`
`records
`
`and
`
`found
`
`a
`
`record
`
`for
`
`this
`
`article
`
`at
`
`https://search.worldcat.org/title/202959300 that showed LC was one of the holding
`
`libraries. After verifying the holdings information in the online catalog of LC, I
`
`obtained a copy of Kouzani through a document vendor. This copy is presented as
`
`EX1006 in this declaration.
`
`27.
`
`Page 1 of EX1006 is a bound volume identified as “IEEE International
`
`Conference on Systems, Man, and Cybernetics Proceedings” that has a call number
`
`of “Q300 .I485a Vol. 2 1997.” Page 2 is the title page that shows this publication has
`
`a title of “SMC ’97 Conference Proceedings” and is the 1997 IEEE International
`
`Conference on Systems, Man, and Cybernetics that has a conference theme of
`
`“Computational Cybernetics and Simulation.” This page shows the conference dates,
`
`location, and sponsor, and also shows this work is “Volume 2 of 5” and has a number
`
`of “97CH36088-5.” Page 3 is conference organization page that shows a library
`
`stamp of “Copyright Office JUN2 1997 Library of Congress.” Page 4 is the copyright
`
`page that shows this work has a 1997 copyright date and the Institute of Electrical
`
`and Electronics Engineers, Inc. holds the copyright. This page shows the IEEE
`
`catalog number, ISBNs (International Standard Book Numbers) for the softbound,
`
`casebound, and microfiche versions of this work, and an ISSN (International
`
`Standard Serial Number) of “1062-922X” for the conference series. The top of the
`
`page shows a hand-written call number of “Q300 .I485a vol. 2, 1997.” Pages 5 and 6
`
`
`
`
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`
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`are selected pages from the table of content that show Kouzani is included in the
`
`session entitled “TA6: Gestures, Speech, and Face Processing II” and begins on
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`internal page 1609. Page 7 to 11 (internal pages 1609 to 1613) are the full text of
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`Kouzani. Internal page 1609 shows the title, authors, abstract, and “0-7803-4053-1”
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`as the ISBN of the volume that contains Kouzani. EX1006 shows Kouzani has a total
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`of five pages, including one equation, seven figures and 13 references.
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`28.
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`To authenticate EX1006, I obtained a copy of Kouzani from the
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`publisher. EX1006A is a true and correct copy from IEEE. I have closely compared
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`EX1006 with this IEEE copy and found them to contain the same content for
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`Kouzani.
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`29.
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`EX1006 is in a condition that creates no suspicion about its
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`authenticity. Specifically, this copy is not missing any intermediate pages, and there
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`are no visible alterations to the document. Furthermore, EX1006 is scanned from a
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`copy held by the Library of Congress and has the same content as the publisher copy
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`(EX1006A). Based on my review and analysis, it is my opinion that EX1006 is
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`authentic.
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`B. Records of Library of Congress
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`30.
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`Libraries can choose to catalog conference proceedings as books or
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`series. The benefit of a serial treatment is that the newly received conference
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`proceedings will go through the serial check-in process and usually become publicly
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`accessible within a week after serial check-in. To determine the public availability
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`date of Kouzani, I searched the online catalog of LC and discovered the library
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`catalogs conference proceedings of IEEE International Conference on Systems, Man,
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`and Cybernetics (“ICSMC”) as a serial. EX1006B is a true and correct copy of the
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`bibliographic and MARC records for the serial containing Kouzani. I personally
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`located, identified, and obtained these records. They are the type of records experts
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`in my field would reasonably rely upon when forming their opinions.
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`31.
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`Pages 1 to 3 of EX1006B are the bibliographic record that shows the
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`conference name as the corporate author, and “Conference proceedings” as the main
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`title. It includes publisher and the serial starting date (“1989”), current frequency, and
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`ISSN (“1062-922X”). The record also includes a note that proceedings for “1989,
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`1991-1992, 1995, are cataloged as monographs in LC,” subject headings,
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`classification , and other details.
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`32.
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`Pages 4 to 6 are the MARC record. The first six digits of Field 008 show
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`the MARC record was created on “900504” (i.e., May 4, 1990), and the code of
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`“d198919uu” following the record creation date indicates the serial began publication
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`in 1989 and has concluded. Subfield ”a” of Field 040 shows IWA created the original
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`record, and subject “d” shows DLC modified the original record later. According to
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`the Directory of OCLC Members (https://www.oclc.org/en/contacts/libraries.html),
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`IWA is the OCLC library symbol for Iowa State University, and DLC is the OCLC
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`library symbol for the Library of Congress. Field 008 and 040 inform my opinion that
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`the Library of Congress used an original record created by the Iowa State University
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`Library in 1990 to create their copy cataloging record. Since EX1006 shows a date
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`stamp of “JUN 2 1997,” it is my opinion that this serial became discoverable at the
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`online catalog of the Library of Congress by at least June 2 1997. After processing,
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`the 1997 conference proceedings that contains Kouzani would become publicly
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`available by June 9, 1997, at this library.
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`33.
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`Field 022 shows the ISSN of this serial. Field 111 shows “IEEE
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`International Conference on Systems, Man, and Cybernetics” as the author of this
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`serial. Field 245 shows the title, and Field 246 shows a variant title. Field 260 shows
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`IEEE of New York, NY has published this journal since 1989. Field 362 shows the
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`serial began publication in 1989, and Field 310 shows the publication frequency is
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`annual. Field 550 shows the conference sponsor. Field 710 shows the sponsor is
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`included in the MARC record to help users discover this serial.
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`34.
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`The subjects of this journal are represented in Field 050 by a Library of
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`Congress Classification (LCC) number of “Q300” that represents periodicals on
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`“Cybernetics” (source: Library of Congress Classification, Schedule Q, at
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`https://www.loc.gov/aba/publications/FreeLCC/LCC_Q2020TEXT.pdf); in Fields
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`650 by four Library of Congress subject headings with “Cybernetics,” “Systems
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`engineering,” “Human-machine systems,” and “Technology and state” as the main
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`topics, each followed by “Congresses” as a form subheading encoded in subfield “v”
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`(“|v”) to indicate the main topics are treated in at a conference. These subject
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`representations enable users to conduct subject searches to discover the serial that
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`contains Kouzani.
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`35.
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`This MARC record (EX1006B) shows that Conference Proceedings /
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`IEEE International Conference on Systems, Man, and Cybernetics is a long-running
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`serial and the MARC record makes it discoverable. The date stamp of “JUN 2 1997”
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`on EX1006 informs my opinion that this serial was discoverable in the online catalog
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`of the Library of Congress by at least by that date. By June 2, 1997, interested users
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`would be able to discover this serial by its ISSN, title, variant title, and conference
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`sponsor. They would also be able to conduct subject searches to discover this journal.
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`As discussed above, a customary library practice is to place a newly received journal
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`issue through the serial check-in process to document its receipt, and the new issue
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`is usually processed promptly to make it publicly accessible, usually within a week
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`after serial check-in is completed. It is therefore my opinion that the issue containing
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`Kouzani became publicly accessible at the Library of Congress by June 9, 1997.
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`36. As evidence that the Library of Congress had an online catalog in
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`operation in 1997 when the journal issue containing Kouzani was received, I obtained
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`a copy of “LOCIS: Library of Congress Information System” archived by Internet
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`Archive. I personally located, identified, and obtained this profile. This is the type of
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`record experts in my field would reasonably rely upon when forming their opinions.
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`This archived copy is presented as EX1006C in this declaration.
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`37.
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`Page 1 is a screen capture of a Wayback Machine calendar that shows
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`this webpage was a