EXHIBIT 3

Case 6:20-cv-00309-ADA Document 41-3 Filed 08/26/21 Page 1 of 43
IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

CORRINO HOLDINGS LLC, 

Plaintiff, 

v. 

EXPEDIA, INC. AND TRIVAGO N.V., 

Defendant. 

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Civil Action No. 6:20-cv-309- ADA 

JURY TRIAL DEMANDED 

AMENDED INFRINGEMENT CONTENTIONS 

Pursuant to Paragraph 2 of the Court’s ORDER GOVERNING PROCEEDINGS – 

PATENT CASE (Dkt. 14), Plaintiff Corrino Holdings LLC (“Corrino”), hereby makes the 

following Preliminary Disclosure of Infringement Contentions (“PICs”) to Expedia, Inc. and 

trivago N.V. (collectively “Expedia”). 

Corrino’s PICs are based on Corrino’s current interpretation of the asserted patents and 

on publicly available information describing Expedia’s proprietary products, systems, and 

relationships. Corrino reserves the right to amend its PICs and asserted claims based on 

information Corrino obtains through discovery and otherwise as this case progresses. Corrino 

reserves the right to amend its infringement contentions responsive to claim construction 

proceedings and the Court’s claim construction rulings or any other relevant rulings. Corrino 

reserves the right to amend its infringement contentions and asserted claims based on any 

proceedings before the United States Patent and Trademark Office regarding Corrino’s patents, 

including the patents-in-suit. 

Case 6:20-cv-00309-ADA Document 41-3 Filed 08/26/21 Page 2 of 43
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Moreover, the charts and Accused Instrumentalities attached hereto are not intended to 

cover duplicative instrumentalities or products, i.e., those Expedia instrumentalities and products 

that have the same structure, function and operation as the charts and Accused Instrumentalities 

identified herein. Corrino will supplement its PICs as to such duplicative instrumentalities or 

products to the extent required by the Court. 

Asserted Patents and Infringement Charts 

Corrino provides the attached claim charts which identify where to find each element of 

each asserted claim within the Accused Instrumentalities. (Exhibits A-G). Corrino identifies 

these asserted claims based on its current and preliminary understanding and reserves the right to 

supplement its identification as discovery proceeds, including identifying additional claims. 

These charts serve a notice function and are not required to and therefore do not present every 

possible permutation or theory of Corrino’s case. Corrino’s PICs focus on notice of the 

underlying direct infringement and are not provided to and should not be read to explain such 

issues as joint liability, mastermind, or indirect infringement, for example. 

Corrino presently contends that Expedia’s Accused Instrumentalities literally infringe the 

Asserted Patents as more specifically explained in the attached charts. Corrino may further 

assert infringement under the doctrine of equivalents as identified in the attached charts, to the 

extent that the difference between any component of any product and any step of any service or 

any claim element is insubstantial. 

x U.S. Patent No. 6,741,188 (“the ’188 Patent”), see Ex. A. 

x U.S. Patent No. 7,716,149 (“the ’149 Patent”), see Ex. B. 

x U.S. Patent No. 7,843,332 (“the ’332 Patent”), see Ex. C. 

x U.S. Patent No. 7,847,685 (“the ’685 Patent”), see Ex. D. 

Case 6:20-cv-00309-ADA Document 41-3 Filed 08/26/21 Page 3 of 43
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x U.S. Patent No. 7,958,104 (“the ’104 Patent”), see Ex. E. 

x U.S. Patent No. 9,152,734 (“the ’734 Patent”), see Ex. F. 

x U.S. Patent No. 9,262,533 (“the ’533 Patent”), see Ex. G. 

Accused Instrumentalities 

Based on the information currently available, Corrino identifies the following 

instrumentalities, including all reasonably similar variants or improvements, as the accused 

instrumentalities: Expedia’s websites and mobile apps for each of the Expedia Brands and 

Subsidiaries, specifically, the www.expedia.com website and related mobile application, the 

www.cheaptickets.com website and related mobile application, the www.hotels.com website and 

related mobile application, the www.orbitz.com website and related mobile application, the 

www.travelocity.com website and related mobile application, the www.trivago.com website and 

related mobile application, the www.HomeAway.com website and related mobile application, 

the www.Vrbo.com website and related mobile application, and all other substantially similar 

products and services (collectively the “Accused Products”). The term “Accused Products” 

includes the associated computer system, software, hardware, processes, and methods related 

thereto. As used herein, each website and related mobile application is a “Platform,” each 

Platform is an “Accused Product,” and the Accused Products are referred to collectively as 

“Accused Instrumentalities.” 

Corrino identifies these Accused Instrumentalities based on its preliminary understanding 

of information currently available to Corrino. Expedia has not to date provided any relevant 

technical discovery, and Corrino reserves the right to supplement its identification as discovery 

proceeds, including identifying additional instrumentalities. 

Case 6:20-cv-00309-ADA Document 41-3 Filed 08/26/21 Page 4 of 43
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Document Production Accompanying Disclosure 

Corrino has provided a copy of the file history of each Asserted Patent. Based on the 

information currently available, Corrino is currently relying on the earliest filing date of an 

application, including any provisional application, from which the Asserted Patents issued. As a 

result, Corrino is not producing documents concerning the conception, reduction to practice, 

design, and development of each claimed invention which were created on or before the earliest 

application date for each respective Asserted Patent. Corrino will supplement its response to the 

extent it subsequently alleges a priority date other than that of the earliest application of each 

Asserted Patent. 

File Histories 

Corrino has produced the file history for each Asserted Patent.

Respectfully submitted, 

Date: 3 August 2021 \s\ Henning Schmidt 

Henning Schmidt 

Texas State Bar Number 24060569 

HSchmidt@dimuro.com

Cecil E. Key 

Ckey@dimuro.com

Jay P. Kesan 

JKesan@dimuro.com

DIMURO GINSBERG, P.C. 

1101 King St., Suite 610 

Alexandria, Virginia 22314 

Phone: (703) 684-4333 

Fax: (703) 548-3181 

Attorneys for Plaintiff 

Corrino Holdings, LLC. 

Case 6:20-cv-00309-ADA Document 41-3 Filed 08/26/21 Page 5 of 43
EXHIBIT F 

Preliminary Infringement Contentions for U.S. Patent 9,152,734 

Title: SYSTEMS AND METHODS FOR IDENTIFYING INTERSECTIONS USING CONTENT METPriority Date: at least May 24, 2010, filing date of Provisional Appl. No. 61/347,815 

Filing Date: May 24, 2011 Inventors: Peter Rinearson, Kristofor Selden, Michael Flashman Abstract: User-submitted content (e.g., stories) may be associated with descriptive metadata (intersection m

timeframe, location, tags, and so on. The user-submitted content may be browsed and/or searched 

metadata. Intersection criteria comprising a prevailing timeframe, a location, and/or other metadaused to identify an intersection space comprising one or more stories. The stories may be ordered importance, which may be determined (at least in part) by comparing story metadata to the interse

All allegations of Plaintiff’s operative Complaint, including those filed hereafter, are incorporated herein 

Plaintiff reserves the right to revise these contentions, including as discovery in the case progresses and in view oclaim construction in this action or any other relevant rulings or information becomes available. The contentions required to provide general notice of the asserted claims and infringing features of the accused instrumentalities, exhaustive list of all proof thereof to be marshalled at trial.Accused Instrumentalities: Based on the information currently available, Corrino identifies the following instr

including all reasonably similar variants or improvements, as the accused instrumentalities: Expedia’s websites aeach of the Expedia Brands and Subsidiaries, specifically, the www.expedia.com website and related mobile appwww.cheaptickets.com website and related mobile application, the www.hotels.com website and related mobile www.orbitz.com website and related mobile application, the www.travelocity.com website and related mobile apwww.trivago.com website and related mobile application, the www.HomeAway.com website and related mobile www.Vrbo.com website and related mobile application, and all other substantially similar products and services. exemplary accused instrumentalities charted below are Expedia, CheapTickets, and Travelocity, the remaining AInstrumentalities have substantially the same if not identical structure, function and operation as the Accused Insbelow and therefore also infringe for the same reasons demonstrated in the charts below.

Case 6:20-cv-00309-ADA Document 41-3 Filed 08/26/21 Page 6 of 43
Contents 

Exemplary Accused Instrumentality: Expedia .....................................................................................................Exemplary Accused Instrumentality: CheapTickets ............................................................................................Exemplary Accused Instrumentality: Travelocity ................................................................................................

Case 6:20-cv-00309-ADA Document 41-3 Filed 08/26/21 Page 7 of 43
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U.S. 9,152,734 

Exemplary Accused Instrumentality: Expedia 

Claim Language Exemplary Accused Instrumentality 

1. A method for presenting story content relating to a timeframe and location of interest, the method performed by a computing system having one or more hardware computer processors, the method comprising:

Expedia allows users to search flights from the preferred departure airpdestination airports. This search comprises options for preferred depart(“location of interest”) and preferred departure or arrival time (“timeframea story and story content relating to a timeframe and location of interest. https://www.expedia.com/. 

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Claim Language Exemplary Accused Instrumentality 

Screenshots taken from hands on testing of Expedia website. 

receiving a query comprising an intersection criteria, the intersection criteria comprising a 

Expedia enables users to enter search query for available flight optiondeparture airports to destination airports. Further, the search query coarrival airport (“location of interest”) and departure or arrival time (“timefr

A 

Location of 

interest 

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Claim Language Exemplary Accused Instrumentality 

location and a timeframe of interest; 

shown in the exemplary case below, the user searches for flights from Washtimeframe of Morning 5 AM to Morning 11.59 AM. 

Screenshots taken from hands on testing of Expedia website. 

generating an intersection space comprising one or more stories matching the location and the 

Based on the applied search query with specified intersection criterias, Expconsisting of desired flights (“an intersection space”).

“Intersection 

criteria” 

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Claim Language Exemplary Accused Instrumentality 

timeframe of the query, said generating comprising: 

Screenshots taken from hands on experience of Expedia website. 

accessing a plurality of stories stored on a non-transitory computer-readable storage 

Expedia creates a search result page (“intersection space”) for displayinrecords (such as flights from the preferred airport within selected timeframExpedia looks for desired search results (“stories”) with information tha

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Claim Language Exemplary Accused Instrumentality 

medium, each story submitted by a user and comprising one or more content items and having respective intersection metadata, the intersection metadata of each story comprising a location and a timeframe pertaining to the story; 

query (“intersection metadata”) in its database (“stored on a computer-reshown in the exemplary case below, the search results are displayed to th

user query i.e. search term, location and timeframe. 

Screenshots taken from hands on experience of Expedia website 

selecting stories for inclusion in the intersection space that have 

The flights departure location and time as mentioned in the filters are sele

the user. In the exemplary case below, the flight departing from location ‘W

di

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Claim Language Exemplary Accused Instrumentality 

intersection metadata corresponding to the location and the timeframe of the intersection criteria; and 

time between Morning 5 AM to Morning 11.59 AM (“intersection criteselected for displaying as desired results. Selecting these criterias displaresults that are similar or have matching metadata (such as time and locati

Screenshots taken from hands on testing of Expedia website. 

The intersection 

criteria 

Intersection 

metadata 

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Claim Language Exemplary Accused Instrumentality 

filtering the stories selected for inclusion in the intersection space so that each remaining story is associated with an indication provided by one or more users that the remaining story is associated with a same one or more participants; 

Expedia filters the stories selected for inclusion in the intersection space so 

story is associated with an indication provided by one or more users. Sfilters the results associated with the different airlines (“more participan

indicating user preferences, such as airline choice like for example Delta, to display in the intersection space based on the selected criteria. 

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Claim Language Exemplary Accused Instrumentality 

Screenshots taken from hands on testing of Expedia website. 

https://www.expedia.com/service/#/myTrips/19367. 

calculating a relative importance of each story in the intersection space, wherein the relative importance of respective stories indicates a relative overlap between the timeframe of interest and a timeframe of the respective story; and 

Expedia provides search result based on the different sort orders such as by arrival, earliest departure etc., that can be selected by the user. In the exemsorting based on earliest departure, JetBlue Airways has been given a hcompared to Delta airlines. All the stories in the results have overlappinthe timeframe selected by the user and departure time of each airline story Expedia calculates a relative importance of each story in the intersection criteria provided by the user, such as price, earliest arrival, earliest depardisplayed based on the calculated relative importance. 

https://www.expedia.com/service/#/myTrips/19367

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Claim Language Exemplary Accused Instrumentality 

Screenshots taken from hands on testing of Expedia website. 

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Claim Language Exemplary Accused Instrumentality 

providing, for presentation on a display, the intersection space comprising indicators of one or more of the stories included in the intersection space in an order based on the relative importance of each respective story in the intersection space. 

The identified search results (flights) are displayed to the user on the searc“indicators”. As mentioned in the description of the patent, an indicator cdescription about the contributor of the story (indicating the contributor of this case, the names of the airlines or airways listed in the search results arScreenshots taken from hands on testing of Expedia website. 

Intersection 

space 

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Claim Language Exemplary Accused Instrumentality 

2. The method of claim 1, wherein selecting a particular story for inclusion in the intersection space comprises: matching the location of the intersection criteria to a location of the particular story; andmatching the timeframe of the intersection criteria to a timeframe of the particular story. 

The Expedia provides flight details on the display using a matching criteria 

departure time and location (“intersection criteria”) to the flight departure 

Screenshots taken from hands on experience of Expedia website. 

Intersection 

space

Intersection 

Criteria 

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U.S. 9,152,734 

Exemplary Accused Instrumentality: CheapTickets 

Claim Language Exemplary Accused Instrumentality 

1. A method for presenting story content relating to a timeframe and location of interest, the method performed by a computing system having one or more hardware computer processors, the method comprising:

CheapTickets users to plan and book travel from the wide range of options packages and flights. It enables travelers to search flights from the preferrto the preferred destination airports. This search comprises options for parrival airport (“location of interest”) and preferred departure or arrival tim

https://www.cheaptickets.com/. 

Case 6:20-cv-00309-ADA Document 41-3 Filed 08/26/21 Page 20 of 43
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Claim Language Exemplary Accused Instrumentality 

Screenshots taken from hands on experience of CheapTickets website. 

Location 

of interest 

Timeframe 

Case 6:20-cv-00309-ADA Document 41-3 Filed 08/26/21 Page 21 of 43
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Claim Language Exemplary Accused Instrumentality 

receiving a query comprising an intersection criteria, the intersection criteria comprising a location and a timeframe of interest; 

CheapTickets enables users to enter search query for available flight optio

departure airports to destination airports. Further, the search query compriseairport (“location of interest”) and departure or arrival time (“timeframe of in the exemplary case below, the user searches for departure flights frowithin timeframe of Morning (5.00 AM to 11.59 AM). 

 “Intersection 

criteria” 

Case 6:20-cv-00309-ADA Document 41-3 Filed 08/26/21 Page 22 of 43
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Claim Language Exemplary Accused Instrumentality 

 Screenshots taken from hands on experience of Cwebsite 

generating an intersection space comprising one or more stories matching the location and the timeframe of the query, said generating comprising: accessing a plurality of stories stored on a non-transitory computer-readable storage medium, each story submitted by a user and comprising one or more content items and having respective intersection metadata, the intersection metadata of each story comprising a location and a timeframe pertaining to the story; 

CheapTickets creates a search result page (“intersection space”) for displayrecords (such as flights from the preferred airport within selected timefram

CheapTickets looks for desired search results (“stories”) with informatsearch query (“intersection metadata”) in its database (“stored on a computeAs shown in the exemplary case below, the search results are displayed tthe user query i.e. search term, location and timeframe. 

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Claim Language Exemplary Accused Instrumentality 

Screenshots taken from hands on testing of Cheaptickets website

selecting stories for inclusion in the intersection space that have intersection metadata corresponding to the location and the timeframe of the intersection criteria; and 

The flights departure location and time as mentioned in the filters are seresults. In the exemplary case below, the flight departing from locati

departure time between Morning 5.00 AM to 11.59 AM are selected as “for displaying the desired results. 

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Claim Language Exemplary Accused Instrumentality 

Screenshots taken from hands on testing of CheapTickets website

filtering the stories selected for inclusion in the intersection space so that each remaining story is associated with an indication 

CheapTickets filters the stories selected for inclusion in the intersectio

remaining story is associated with an indication provided by one or more 

CheapTickets filters the results associated with the different airlines (“mor

In

“Intersectio

n criteria” 

Case 6:20-cv-00309-ADA Document 41-3 Filed 08/26/21 Page 25 of 43
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Claim Language Exemplary Accused Instrumentality 

provided by one or more users that the remaining story is associated with a same one or more participants; 

on criteria indicating user preferences, such as airline choice like for ex

Airway etc., to display in the intersection space based on the selected crite

Screenshots taken from hands on testing of CheapTickets website.

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Claim Language Exemplary Accused Instrumentality 

https://www.cheaptickets.com/p/info-other/legal.htm. 

calculating a relative importance of each story in the intersection space, wherein the relative importance of respective stories indicates a relative overlap between the timeframe of interest and a timeframe of the respective story; and 

CheapTickets provides search result based on the different sort orders sucearliest arrival, earliest departure etc., that can be selected by the user. In below, in sorting based on earliest departure, American Airlines has 

importance as compared to Delta airlines and JetBlue Airways. All the storoverlapping timeframe between the timeframe selected by the user and dairline story in the search result. https://www.cheaptickets.com/p/info-other/legal.htm. 

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Claim Language Exemplary Accused Instrumentality 

Screenshots taken from hands on testing of CheapTickets website.

providing, for presentation on a display, the intersection space comprising indicators of one or 

The identified search results (flights) are displayed to the user on the searc“indicators”. As mentioned in the description of the patent, an indicator c

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Claim Language Exemplary Accused Instrumentality 

more of the stories included in the intersection space in an order based on the relative importance of each respective story in the intersection space. 

description about the contributor of the story (indicating the contributor of this case, the names of the airlines or airways listed in the search results arScreenshots taken from hands on testing of CheapTickets website.

2. The method of claim 1, wherein selecting a particular story for 

CheapTickets provides flight details on the display using a matching criteri

departure time and location (“intersection criteria”) to the flight departure 

Intersectio

n space 

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Claim Language Exemplary Accused Instrumentality 

inclusion in the intersection space comprises: matching the location of the intersection criteria to a location of the particular story; andmatching the timeframe of the intersection criteria to a timeframe of the particular story. 

Screenshots taken from hands on testing of CheapTickets website.

“Intersection 

Intersection space 

“A P

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U.S. 9,152,734 

Exemplary Accused Instrumentality: Travelocity 

Claim Language Exemplary Accused Instrumentality 

1. A method for presenting story content relating to a timeframe and location of interest, the method performed by a computing system having one or more hardware computer processors, the method comprising:

Travelocity allows users to search flights from the preferred departure air

destination airports. This search comprises options for preferred depart(“location of interest”) and preferred departure or arrival time (“timeframe

https://www.travelocity.com/. 

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Claim Language Exemplary Accused Instrumentality 

Screenshots taken from hands on testing of Travelocity website.

Location 

of interest 

A 

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Claim Language Exemplary Accused Instrumentality 

receiving a query comprising an intersection criteria, the intersection criteria comprising a location and a timeframe of interest; 

Travelocity enables users to enter search query for available flight optiondeparture airports to destination airports. Further, the search query coarrival airport (“location of interest”) and departure or arrival time (“timefr

shown in the exemplary case below, the user searches for flights from New timeframe of Afternoon 12 PM to 5:59 PM. Screenshots taken from hands on testing of Travelocity website 

“Intersectio

n criteria” 

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Claim Language Exemplary Accused Instrumentality 

generating an intersection space comprising one or more stories matching the location and the timeframe of the query, said generating comprising: 

Based on the applied search query with specified intersection criterias, Trpage consisting of desired flights (“an intersection space”). Screenshots taken from hands on testing of Travelocity website.

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Claim Language Exemplary Accused Instrumentality 

accessing a plurality of stories stored on a non-transitory computer-readable storage medium, each story submitted by a user and comprising one or more content items and having respective intersection metadata, the intersection metadata of each story comprising a location and a timeframe pertaining to the story; 

Travelocity creates a search result page (“intersection space”) for displayirecords (such as flights from the preferred airport within selected timeframTravelocity looks for desired search results (“stories”) with information thquery (“intersection metadata”) in its database (“stored on a computer-reshown in the exemplary case below, the search results are displayed to th

user query i.e. search term, location and timeframe. 

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Claim Language Exemplary Accused Instrumentality 

 Screenshots taken from hands on testing of Travelocity website. 

selecting stories for inclusion in the intersection space that have intersection metadata corresponding to the location and 

The flights departure location and time as mentioned in the filters are sele

the user. In the exemplary case below, the flight departing from location ‘Ntime between Afternoon 12 PM to 5:59 PM (“intersection criteria”) for the 

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Claim Language Exemplary Accused Instrumentality 

the timeframe of the intersection criteria; and 

displaying as desired results. Selecting these criterias display only those ssimilar or have matching metadata (such as time and location). 

Screenshots taken from hands on testing of Travelocity website.

filtering the stories selected for inclusion in the intersection space so that each remaining story is associated with an indication 

Travelocity filters the stories selected for inclusion in the intersection remaining story is associated with an indication provided by one or more Travelocity filters the results associated with the different airlines (“more 

In

The 

intersection 

criteria 

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Claim Language Exemplary Accused Instrumentality 

provided by one or more users that the remaining story is associated with a same one or more participants; 

on criteria indicating user preferences, such as airline choice like for ex

Airway etc., to display in the intersection space based on the selected crite

 Screenshots taken from hands on testing of Travelocity website 

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Claim Language Exemplary Accused Instrumentality 

https://www.travelocity.com/p/info-other/legal.htm.

calculating a relative importance of each story in the intersection space, wherein the relative importance of respective stories indicates a relative overlap between the timeframe of interest and a timeframe of the respective story; and 

Travelocity provides search result based on the different sort orders such earliest arrival, earliest departure etc., that can be selected by the user. In below, in sorting based on earliest departure, American Airlines has 

importance as compared to JetBlue Airways. All the stories in the resutimeframe between the timeframe selected by the user and departure time 

in the search result. https://www.travelocity.com/p/info-other/legal.htm.

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Claim Language Exemplary Accused Instrumentality 

Screenshots taken from hands on testing of Travelocity website.

providing, for presentation on a display, the intersection space comprising indicators of one or more of the stories included in the intersection space in an order based on the relative importance of each 

The identified search results (flights) are displayed to the user on the searc“indicators”. As mentioned in the description of the patent, an indicator cdescription about the contributor of the story (indicating the contributor of this case, the names of the airlines or airways listed in the search results ar

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Claim Language Exemplary Accused Instrumentality 

respective story in the intersection space. 

Screenshots taken from hands on testing of Travelocity website.

2. The method of claim 1, wherein selecting a particular story for 

Travelocity provides flight details on the display using a matching criteria departure time and location (“intersection criteria”) to the flight departure 

Indicato

more o

Intersection 

space 

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Claim Language Exemplary Accused Instrumentality 

inclusion in the intersection space comprises: matching the location of the intersection criteria to a location of the particular story; andmatching the timeframe of the intersection criteria to a timeframe of the particular story. 

Screenshots taken from hands on testing of Travelocity website.

“Intersection 

criteria” 

Intersection 

space 

“A Par

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