Raging Bull # 339539:
McAuley - Case3:10-cv-04645-RS Document134-4 Filed11/05/12
(4 pages)
I, Aubrey McAuley, hereby declare:
l. I am the inventor of U.S. PatentNos.6,826,744 and7,7l6,629,the patents-in-suit in the lawsuit identified above.
2. I am also very familiar with the WebOS software system identified in the "Other Publications" section of U. S. Patent No. 7,716,629.
3. The prior WebOS system does not include the elements of the claimed inventions of the patents-in-suit. With the prior WebOS technology, if a company had multiple newspapers, for example, it would have to have a separate object library and database for each newspaper it owned. This is an absolute requirement because each object in the object library for each paper was hardcoded to specify details for that paper. The objects were not re-usable on the other papers; they were not interchangeable with each other; and they could not separately service multiple papers. Each object library was only able to function with the database and format templates for the specific paper for which it was coded during the initial installation. If a new object was created for one paper, and any other paper wanted to make use of that object, the second paper would have to copy the code from the first one, and a programmer would have to change the hardcoded details in that object before it could function in the second paper. This manual process would have to be repeated for each paper.
4. Between 1999 and 2001, Adhesive introduced Version 7 of WebOS, which by now had changed names to SiteFlash. It implemented arbitrary objects and the inventions of the patents-in-suit, while any version of WebOS smaller than 7 did not implement arbitrary objects. This new Version 7 also used an object library which supported a vastly more efficient technology in arbitrary objects, With the invention of arbitrary objects, SiteFlash could have used a single object library to support all of the newspapers of the multi-newspaper customer in the above example. A programmer would only need to create a single object, which could then be syndicated to each paper without any further effort by the programmer. The specification of the U.S. Patent No. 6,826,744 in column 2, lines 43-49, and column 6, lines 30-45 explains how the use of arbitrary objects solved the problems described above.
I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct and based upon my personal knowledge, and if called upon as a witness, I could and would testify thereto.
Executed this (5th) day of November, 2012
