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1. not dated Brochure Deal Proof 3 0 expertEase Software 14 pgs not dated Website Print Out Deal Proof Tech Requirements expertEase Software 1 pg Aug 3 2001 expertEase Software Technology White Paper expertEase Software 2 pgs Copyright 1999 2001 Website Print Out Legal Citation overview Oberon Development 1 pg Copyright 1998 2001 Website Print Out Legal Citation Introduction to the Basics Oberon Development 8 pgs Copyright 2001 Website Print Out Legal Citation Sales Contacts Pricing Information Oberon Development 2 pgs Copyright 1999 Manual Citation Legal Edition Oberon Development Ltd 80 pgs Copyright 1999 A Swedish Grammar Checker J Carlberger R Domeij V Kann O Knutsson Royal Institute of Technology Stockholm Association for Computational Linguistics Copyright 2000 pp 1 8 Towards a Theory of Textual Errors F R Bustamante T Declerck F Sanchez Leon Laboratorio de Linguistica Informatica University of Madrid Spain 13 pgs not dated GramCheck A Grammar and Style Checker F R Bustamante F Sanchez Leon Escuela Politecnica Superior University Carlos III de Madrid Spain 7 pgs not dated A Chart Based Framework for Grammar Checking Initial Studies A Sagvall Hein Department of Linguistics Uppsala University Sweden 12 pgs not dated Tips amp Techniques for using the award wining suite of legal research products Lexis Nexis Research Software 1
2. menu command 40 If the user has not previously selected the BlueCheck OptionsTM menu command 42 for the present word processor document the program displays the BlueCheck Options dialog box 46 FIG 3B In the BlueCheck Options dialog box 46 the user is requested to set certain options that affect the stylistic tests that will be performed on the legal citations within the word processing document Specifically the user is requested to enter whether the word processing document is to be submitted to a state court and if so which state a federal court or whether it is a non court document e g memorandum or law review article After closing the BlueCheck Options dialog box 46 the BlueCheck Error Form 48 is displayed see FIG 3C When the preferred embodiment identifies a perceived error it highlights the citation 50 in the Microsoft Word docu ment 52 and displays the current citation 50 in the Error Form 48 with the error highlighted and with a message 54 explaining the error In most instances the software utility 20 also makes a specific suggestion if so it displays the citation 56 as it will appear if the user selects the suggested change Upon displaying a suggestion the user is preferably presented with at least four options In this instance the options are indicated by four buttons within the Error Form 48 i e Change 58 Ignore 60 Ignore Rule 62 and Cancel 64 If the user s
3. then suggest either changing it to a place holder or having the user edit the date to correct it Checkeditor If the reporter clause should have an editor but does not have one then suggest inserting an editor parenthetical If the current reporter clause has an editor that is not used for this main reporter and the main reporter should have a different editor then suggest changing the editor to the correct one If the current reporter clause has an editor that is not used for this main reporter and the main reporter should not have an editor then suggest deleting the editor clause 20 30 35 40 45 50 55 60 65 20 If an editor should have a volume number but is missing a volume number then suggest inserting the correct volume number If an editor should not have a volume number but does have one then suggest deleting that volume number If the volume number for an editor does not correspond with the volume number for the main reporter then suggest changing the editor s volume number to the correct volume number If the an editor is not punctuated or spelled correctly then suggest changing it to the correct abbreviation If the citation does not have a designation of an editor s main reporter then suggest changing the editor clause to a parenthetical of the correct main reporter or adding a citation to the main reporter as a parallel citation If the citation has a main reporter clause and a
4. United States Court of Federal claims the United States claims Court and the Court of claims Each of these courts shares the same list of valid 20 25 35 40 45 50 55 60 65 10 reporters The Jurisdictions Object Model represents this list of reporters as a single Court Group Object 98 Each Court Object 96 for these three federal courts shares a single Court Group Object 98 rather than having a redundant list of reporters for each court Specifically the Court Group Object 98 contains a Reporter Collection 100 that represents each of the reporters used by these courts along with data summarizing the rules governing the use of parallel and non parallel citations for these courts Each Reporters Collection 100 is a custom collection that contains the individual Reporter Objects 102 used by a particular group of courts Each Reporter Object 102 con tains several types of data about a particular reporter First it includes the range of valid volume numbers for the reporter the range of valid dates for the reporter and the full name and correct abbreviation for the reporter Second it specifies whether the reporter identifies the court or juris diction of the citation For example the reporter United States Reports identifies the jurisdiction federal and court Supreme Court of a citation while the regional reporter North Western Reporter identifies neither Third it identifies each editor used by the main r
5. as a tool in understanding the basic operation of the software utility 20 the sequence of steps in the operation of the software utility 20 may be utilized in any appropriate order to achieve the desired stylistic review of legal citations without departing from the spirit or scope of the invention For example the sequence of operational steps may occur in an altered order may occur in a manner such that some operational steps are simultaneous with other operational steps or may include additional steps as desired As shown per block 202 the software utility 20 is activated within a running word processing application Then per operations block 204 the software utility 20 scans the word processing document to detect elements of the legal citations within the document If no elements of legal citations are detected per decision block 224 operation of the software utility 20 is terminated per block 226 How ever upon detecting elements of a legal citation the soft ware utility 20 parses the legal citation into possible citation structures and evaluates the structures to determine which legal citation structure is most likely correct The software utility 20 then checks the legal citation to determine if it conforms to established stylistic rules such as those of the Bluebook per decision block 206 It should be noted that the Bluebook is described herein as the chosen standard for stylistic rules however other standards for stylist
6. j E Auou mse uonisodap Zanen 110 me L9 997 797 UOREJOGETIOD eu 4 1L6 Sup 65139 0T8 yueuinoog pag 7 j syueunooq euo 6661 JIO 116 LSTI sefueyo eT lurerdxo uodn spuedxo panogo b uousa uoyrsod p ezueuiung ojT y Le JUNOD POM ebenfue7 Krenuo os v IES suondo yoayQenig oauoen A a ele mt af sod puy p s ve wi a puuea Ayred e u no V pJoM YoSoy ojdurec 75 US 7 028 259 B1 Sheet 4 of 10 Apr 11 2006 U S Patent g 914 ajiye MAIAS ME JO wnpuesowew Aieupio ue e yuaunsop jo ed augo Auy O A noo jesapaj e oj payiuqns eq oj jueunoog O HE Seuof os amp uoumso uonisodop jo skep OM st EZ age V 14 1661 NO m6 L9 997 ZIZ ynoo ejejs e oj peniuqns eq o juawnoog O 198 SLE PZA 146 Cour Teorao org jueunooq jo edit H A SISSON 6661 NO m6 LSTI Fa Luet 10 surejdxo uodn spuedxo jeu JAPPUJE ue Joyo Aem 11 998 peua jo ansst ue amjoejnueui oj uourso UONISOdIP Joud sjorpenuoo fpe uoneuejdxo NOYIM PY NAEPIJE ue 13770 30uueo Ayed e y3now y y HAEptgje WEUS e jou st uorgre oep Suosiopuy IC UOIasse souos 0 Krejuoo ospy V Z Ol aia zi SI B min 1 a BO eg wens EI euo fz El Di 5 MEA vols i t y e m lt den mopu op s i up posu weu WPI au paom gosoy ojduies zx US 7 028 259 B1 Sheet 5 of 10 Apr 11 2006 U S Patent 2 914 aoeds e yesu PJOM yxeu ay
7. of manually editing the citation in the word processor to eliminate the error or of ignoring the error If the user accepts one of the suggestions the module edits the text of the word processing document itself through the Document Interface to incorporate that change BRIEF DESCRIPTION OF THE DRAWINGS FIG 1 is a flowchart depicting the basic overall operation of the legal citation software utility of the present invention FIG 2 is a block diagram of one example of a hardware configuration that may be used to implement the legal citation software utility of the present invention FIG 3A depicts the menu commands that are added by the software utility of the present invention to a word processing application menu FIG 3B depicts a dialog box that may be utilized by the software utility of the present invention to determine the type of legal document that will be reviewed by the software utility FIG 3C depicts an error form dialog box that may be utilized by the software utility of the present invention to display error messages and suggestions for correction to the user of the software utility FIG 3D depicts a drop down box that may be utilized within the error form of FIG 3C to provide a user with a listing of the relevant stylize rule that is applicable to the current error detected FIG 3E depicts the error form dialog box wherein the software utility of the present invention has provided the user with more than one s
8. party s name is simply State Commonwealth or People but the citation has a federal jurisdiction then ask the user to change that party s name to the name of the state If one party s name consists only of the name of a state and that state is the same as the citation s jurisdiction then suggest changing the name of the state to State Commonwealth or People US 7 028 259 B1 19 If the name contains City of Town of Township of Borough of or County of and that phrase is not the first word of a party name then suggest deleting the phrase If a party s name contains of and the word of is not the first or second word in the party s name then suggest deleting it if it is a prepositional phrase of location If the case name contains United States of America suggest deleting of America Ifa party s name has more than one phrase that designates the party as being a business entity then suggest deleting the later phrase If a party s name has a word indicating a union designa tion then suggest that the user consult Rule 10 2 1 1 to ensure that it complies with that rule If a party s name starts with C LR or Commissioner of Internal Revenue then suggest changing the phrase to Commissioner If one party s name contains a full word from Table 6 or 10 or the full name of a jurisdiction and the word is not
9. processing document and thus cannot identify errors US 7 028 259 B1 3 or suggest corrections for citations after they have been entered into the word processing document Rather the program requires users to adapt to a new method for creating citations and works only with citations generated through this method SUMMARY OF THE INVENTION The present invention is a legal citation software utility that preferably integrates with a word processing application as a plug in that is when installed it integrates itself into the menu structure of the word processing application and operates while the word processing document remains open in the word processing application It interacts with the user through dialog boxes that appear to originate from within the word processing application Thus from the user s perspec tive the software utility behaves like a component of the word processing application itself much like a spelling checker or word count utility rather than a stand alone application The user starts the legal citation software utility by selecting a menu command from the word processing appli cation The legal citation software utility then scans a word processing document to identify and parse citations As it identifies each citation it performs a series of tests to determine whether the citation conforms to stylistic rules If it encounters an error it displays the citation with the error highlighted displa
10. score per operations block 130 that represents how closely each citation object comes to a complete and accurate citation Assuming that any of these combinations have a score above a minimum threshold it selects the combination with the highest score as represent ing the best interpretation of the citation per operations block 132 In the above example the Citation Builder begins with the two clauses that it identifies a case name clause and a reporter clause and builds a citation object containing only those two clauses It then builds a citation object that contains additional clauses To illustrate it performs the following initial steps with the name of each clause it identifies in brackets US 7 028 259 B1 13 Test 1 Schlemmer v Farmers Union Cent Exch Case Name 397 N W 2d 903 906 Reporter Test 2 Schlemmer v Farmers Union Cent Exch Case Name 1 00 397 N W 2d 903 906 Reporter Minn Reporter Test 3 Schlemmer v Farmers Union Cent Exch Case Name 397 N W 2d 903 906 Reporter Minn Re porter Ct App Court Test 4 Schlemmer v Farmers Union Cent Exch Case Name 397 N W 2d 903 906 Reporter Minn Re porter Ct App Court 1986 Date Test 5 Schlemmer v Farmers Union Cent Exch Case Name 397 N W 2d 903 906 Reporter Minn Juris diction Test 6 Schlemmer v Farmers Union Cent Exch Case Name 397 N W 2d 903 906 Reporter Minn Juris diction Ct App Cou
11. separate reporter clause with an editor but the editor s pagina tion is the same as the main reporter clause then suggest changing the editor reporter clause to a paren thetical of the main clause Checkjurandcourt If the citation does not have a jurisdiction clause or a reporter clause that identifies the jurisdiction but does have a court clause then suggest adding a jurisdiction clause for each jurisdiction that best matches the report ers date and court clause If the citation does not have a jurisdiction clause or a reporter clause that identifies the jurisdiction and does not have a court clause then suggest adding a juris diction clause for each jurisdiction that best matches the reporters and date If the citation does not have a court clause or reporter clause that identifies the court but does have a juris diction clause or reporter clause that identifies the jurisdiction then suggest adding a court clause for every court that best matches the reporters and date If the citation has a jurisdiction clause that is not com patible with the court clause then suggest either chang ing the jurisdiction clause to one that matches the court or changing the court clause to one that matches the jurisdiction If the citation has a federal jurisdiction clause that is redundant because the jurisdiction is identified a federal court clause then suggest deleting the jurisdiction clause If the citation has a state jurisdict
12. the first word of a party s name then suggest replacing the word with its abbreviation If United States is abbreviated suggest changing it to United States Checkreporter If a reporter abbreviation is not punctuated or spelled correctly then suggest changing it to the correct abbre viation If a reporter clause is missing a volume number and the correct volume number is implicit in the volume num ber of an editor then suggest inserting the correct volume number If a reporter clause is missing a volume number and the correct volume number is not implicit in the volume number of an editor then suggest inserting a place holder for the volume number If the volume number of a reporter is outside of the allowed range of volume numbers for this reporter then suggest changing the volume number to a placeholder If a reporter clause is missing the first page number then suggest inserting a placeholder If there is no punctuation between the first page number and a pinpoint page number then suggest inserting a comma If the punctuation between the first page number and a pinpoint page number is not a single comma then suggest changing the punctuation to a comma If a reporter clause is missing a pinpoint page number is missing then suggest inserting a placeholder for the pinpoint page number If the citation s year is compatible with the designated court but is outside the range of valid years for a reporter
13. to the identified error 45 The legal citation checker of claim 39 wherein said software component further functions to offer a suggestion as to correction of the identified error 46 The legal citation checker of claim 45 wherein said software component further functions to enable a user to accept or ignore said suggestion 47 The legal citation checker of claim 39 wherein said software component further functions to display said legal case citation standard that is relevant to the identified error 48 The legal citation checker of claim 39 wherein said legal case citation standard comprises the Bluebook 49 The legal citation checker of claim 39 wherein said software component adjusts its identification of said error according to a type of said word processing document 50 The legal citation checker of claim 49 wherein said type of word processing document is selected from a group consisting of a state court document a federal court docu ment and a non court document 51 The legal citation checker of claim 39 further com prising a storage medium containing elements selected from a group consisting of said software interface said software component an instruction relevant to said software inter face and an instruction relevant to said software component 52 The legal citation checker of claim 39 wherein said software component functions to locate an ambiguous legal case citation and resolve the ambiguity of said am
14. 0 35 40 45 50 55 60 65 18 diction the check procedure suggests inserting a jurisdiction clause that identifies the jurisdiction If for example the citation is Jones v Smith 100 N W 2d 105 110 Ct App 1990 the check procedure will recognize that the juris diction is missing and suggest inserting Iowa Mich Minn and other jurisdictions that use the reporter N W 2d and have courts of appeals Following is a listing of check procedures that are pref erably implemented within the Check Modules component of the legal citation software utility 20 and the preferred suggestions for correction Checkcasename If the case name s designation of versus is not spelled as v then suggest changing it to v If the case name s v is not followed by a space then suggest inserting a space If the case name has more than one designation of versus then suggest deleting the parties to the second case name If the case name contains the phrase et al or d b a then suggest deleting that phrase and the remaining text in that party s name If the case name contains the phrases on of or for of then suggest changing that phrase to ex rel If the case name contains the phrase by and through then suggest changing that phrase to ex rel If the first word of the case name is in petition or application and
15. 7 pgs Copyright 1997 cited by examiner U S Patent Apr 11 2006 Sheet 1 of 10 US 7 028 259 B1 Start Utility within Word 202 Processing Application and Select Document Type if appropriate 204 Scan Word Processing Document to Identify Parse Build Possible Citation Structures amp Evaluate Structures Citation Errors w in Document Does Legal Citation Conform to Stylistic Rules no Display Legal Citation with Error Highlighted Display Error Message s Display Revel ant Blue Book Rule Display Suggestion s for Corrected Citation 216 User Edits Suggestion for Corrected Citation yes 220 Edit Word Processing Document to Insert Correction Accept Suggestion As Is U S Patent Apr 11 2006 Sheet 2 of 10 US 7 028 259 B1 308 Output Peripherals elt Peripherals FIG 2 US 7 028 259 B1 Sheet 3 of 10 Apr 11 2006 U S Patent ve 914 CB kaaa Leo re lw ob spopua utetp SI WeYs JO skep OM sty UJIM juejsrsuoo JOIIUO st Aug PZA S6 OD Su enm patr A Apouuoy Jm ADOT 15661 TECI LTL PEF C9 ZSIL PEA 861 VOI 0dn D A 31189 995 je WARpIye ue J9JJO eur 3r et erre Joud sjorpenuoo la uoneuejdxo pm y APPLY OS Y jou Sr uonere 2op S uo w H t t 43 eunue1c pue Duued La suondo eziuojsn Sur ppy pue sajejdua oe pJEZIM 10497 siaqe pue sedojonu3 lt
16. 71 Test 5 355 Test 6 385 Test 7 500 US 7 028 259 B1 15 Because Test 7 receives a perfect score of 500 the Citation Builder identifies that interpretation of the clauses as being the correct interpretation Of course other methods of scoring may be used without departing from the spirit or scope of the invention When the Citation Builder does not encounter a citation with a perfect score it tests further combinations by exclud ing earlier clauses to ensure that it has not misinterpreted the citation If for example the citation had been incorrectly formatted as Schlemmer v Farmers Union Cent Exch Minn Ct App 397 N W 2d 903 906 1986 then no possibility would have a perfect score as jurisdic tion clause and court clause are placed in an incorrect position Consequently the Citation Builder performs a deeper search in which some earlier clauses parent nodes are discarded with the following result Test 1 Schlemmer v Farmers Union Cent Exch Case Name 1 00 Minn Reporter 0 29 Jurisdiction Min nesota Court Minnesota Supreme Court Score 186 Test 2 Schlemmer v Farmers Union Cent Exch Case Name 1 00 Minn Reporter 0 37 Ct App Court 0 63 397 Jurisdiction Minnesota Court Minnesota Court of Appeals Score 213 Test 3 Schlemmer v Farmers Union Cent Exch Case Name 1 00 Minn Reporter 0 37 Ct App Court 0 63 397 N W 2d 903 906 Reporter 0 85 Juris dict
17. Appeals contains a property YearStart that represents the year the court began operating Because the citation s year property 1970 is less than the YearStart property for the Minnesota Court of Appeals object 1983 this if then statement would identify the error The Check Modules perform a series of similar tests to identify errors Each check module is subdivided into a number of procedures that each perform one or several specific tests When one of the check procedures identifies an error it calls a subroutine that instructs the Error Form to display an error In most situations the check procedure will also instruct the Error Form to suggest one or more specific changes For example the code associated with the first example instructs the Error Form to suggest changing Nw2d to N W 2d Likewise the code associated with the second example instructs the error form to suggest changing 1970 to a placeholder representing the year C Other check procedures may generate multiple sugges tions For example a citation might not identify the juris diction of the deciding court which can be tested through the code If Citation Jurisdiction is Nothing Then If this error is found the check procedure for this test generates a list of jurisdiction objects that are most compat ible with the citation s court clause reporter clause or clauses and the citation s date For each compatible juris 20 25 3
18. a legal citation checker with an open word processing document that is being edited by a word processing application said method comprising the steps of locating a legal case citation within said open word processing document identifying an error within a legal case citation within said open word processing document as compared against a legal case citation standard displaying said error within a window or dialog box displayed simultaneously with said open word process ing document and automatically correcting said error within said legal case citation within said open document according to said predetermined legal case citation standard 5 The method of claim 4 further comprising highlighting said error 6 The method of claim 4 further comprising offering a selection of a type of said open word processing document wherein said selection of said type is displayed in a window or dialog box displayed simultaneously with said open word processing document 7 The method of claim 4 further comprising displaying a suggestion for correction of said error within a window or dialog box displayed simultaneously with said open word processing document 8 The method of claim 7 further comprising offering an interactive acceptance or denial of said suggestion 9 The method of claim 8 further comprising correcting said error within said legal case citation within said open word processing document upon acceptance of said sugges
19. a2 United States Patent Jacobson US007028259B1 US 7 028 259 B1 Apr 11 2006 a0 Patent No 45 Date of Patent 54 INTERACTIVE LEGAL CITATION CHECKER 76 Inventor Robert L Jacobson 1414 Laurel Ave Apt L301 Minneapolis MN US 55403 Notice Subject to any disclaimer the term of this patent is extended or adjusted under 35 U S C 154 b by 706 days 21 Appl No 09 775 184 22 Filed Feb 1 2001 Related U S Application Data 60 Provisional application No 60 179 572 filed on Feb 1 2000 51 Int CI G06F 17 24 2006 01 52 E e Toe osito EE 715 531 58 Field of Classification Search 715 540 715 530 706 12 See application file for complete search history 56 References Cited U S PATENT DOCUMENTS 5 608 625 A 3 1997 Bailey 715 540 6 502 081 B1 12 2002 Wiltshire et al 706 12 OTHER PUBLICATIONS Supnik Paul D Getting Your Cites in Order Los Angeles Lawyer Magazine Jun 1989 WestCiteLink FAQ at http www westlaw com citelink fag wl 2003 LexisNexis Citation Tools 2003 at http support lexisnexis com CitationTools2003 record asp ArticleID CitationTolls2003 default amp Printl 2005 RA Sample Microsoft Word Brochure CiteRite For Windows Features Benefits Lexis Nexis 2 pgs not dated Website Print Out CiteRite II Lexise Nexis 3 pgs Copyright 1999 Websit
20. auer 10 surejdxa uodn spuedxo le n t 2uelemed det mopu eje SOO up es wei mp3 a PIOM yoso ejduieg Ei eG US 7 028 259 B1 Sheet 7 of 10 Apr 11 2006 U S Patent jeoueg L_J E Ezi eno va at 034 EL eim moys C unos e yasuj unoo Buipioep au eyeoipul jou seop uonejo SIUL JO T VA 9661 LEZL ZZZL ped Z9 ou snpuj UOZUOH XASS aoe JO Tal ennin GADHAL CA VAICCAIA 6661 LEZL ZZZL PEs Z9 OUI snpuj uozuod A AOISSOJA a eyin JO Waa 6661 LEZL Z7ZL ped Z9 OUT Snpu UOZUOH A X9ISSSN uonseBBng er M 6661 LEZE Sc Pe d co OUT snpuj UozuoH A DESEN uorisodop Jo sep omy Vote Van 5 L9 99 TIT PTA S6 WU 2199y99n18 09 SUT MI perry A Apeuuay Z661 NO 416 98 SLE PTA 146 OUT 0918 30d S661 JIO Y6 IEZI LIZI PE A Z9 OUT SNPUT uozuog A ADISSIA 6661 WD 416 STI STI PCA 861 VO Odtun A 9i so7 999 Auowysa Ioud sayer JO surejdxe uodn spuedxo yey JIAPpI ue 130 ABUU JI 998 JELOJBU JO INSSI ue o1njoegnuegur 0 Auouiso uottsodap W 7 Old 3 zi ar a zlz E vewou men sow ewo Eo b O uu u amp t 4 5 amp 2g die mopu ada soo ae posi weu vi ai Dou 40801491W ejdures Ez US 7 028 259 B1 Sheet 8 of 10 Apr 11 2006 U S Patent je 214 EIC Tol palpa eo PA nv VE ES reed o apew a
21. biguous legal case citation
22. cation and a software component operable with said software inter face and executable with said word processing appli cation wherein said software component functions to locate a legal case citation within a word processing document and to identify an error within said legal case citation within said word processing document as com pared against a predetermined legal case citation stan dard wherein said software component functions to automatically correct said error within said legal case citation within said word processing document accord ing to said predetermined legal case citation standard 40 The legal citation checker of claim 39 wherein said software interface and said software component are unitary 41 The legal citation checker of claim 39 wherein said software component functions to locate automatically said legal case citation within said word processing document 42 The legal citation checker of claim 39 wherein said software component further functions to parse said legal case citation into a plurality of constituent elements 43 The legal citation checker of claim 42 wherein said plurality of constituent elements are identified through a procedure selected from a group consisting of a fuzzy logic procedure a fuzzy pattern matching procedure a scoring procedure and a ranking procedure 44 The legal citation checker of claim 39 wherein said software component further functions to provide an error message as
23. d by the citation s court but at least one other reporter clause that is valid for the court then suggest deleting the invalid reporter clause If the citation has a reporter clause that is not used by the citation s court and has no other reporter clauses then suggest replacing the invalid reporter clause with a reporter that is used by the court If the citation has two reporters that are of the same type then suggest deleting either one of them If the citation has parallel reporters but should not use parallel reporters then suggest deleting the unneces sary reporter If there are two or more reporter clauses and they are not in the correct order then suggest moving one to its correct position Tf the citation has a citation to one reporter but it is not the best reporter for this court then suggest replacing the disfavored reporter with a preferred reporter If the citation does not have any reporter clauses then suggest inserting one that is valid for this court Tf the citation should use parallel reporters but is missing a reporter that is necessary for this court then suggest inserting the missing reporter Checkdate If the citation contains a full date in the format of month date year but the month is not spelled with the correct abbreviation then suggest replacing the month with the correct abbreviation If the citation contains a full date but in an incorrect format then suggest replacing it with the
24. e Print Out CiteRiteTMII Product Description Lexis Nexis 2 pgs Copyright 2001 Sample CiteRite Report Lexis Nexis 10 pgs not dated Website Print Out CompareRite Sample Printe Lexis Nexis 12 pgs Jan 18 2001 Website Print Out Citelt Legal Citation Made Simple Sidebar Software Inc 8 pgs Copyright 1997 2001 Cite It Legal Citation Made Simple User Manual Sidebar Software Inc 74 pgs Copyright 1997 2000 Website Print Out WestCiteLink Overview West Group 38 pgs Copyright 2001 Brochure Add New Dimension to Your Documents with WestCiteLink 3 0 West Group 4 pgs Copyright 2001 Continued Primary Examiner Heather R Herndon Assistant Examiner Doug Hutton 74 Attorney Agent or Firm Patterson Thuente Skaar amp Christensen P A 57 ABSTRACT A software utility scans a word processing document to locate citations to court opinions It parses each citation to determine its constituent elements such as the citation s case name the reporters in which it is published its juris diction and court and its date It then compares the citation as it is written against stylistic rules for legal citations If it finds a deviation from one of the stylistic rules it displays a message to inform the user of the error and if possible suggests specific changes to correct the error If the user accepts one of the corrections the utility makes that change to the word processing docu
25. ein said means for operating provides an error message as to the identified error 16 The legal citation checker of claim 11 wherein said means for operating offers a suggestion as to the correction of the identified error 17 The legal citation checker of claim 16 wherein said means for operating enables a user to accept or ignore said suggestion 18 The legal citation checker of claim 11 wherein said means for operating provides said predetermined legal case citation standard that is relevant to the identified error 19 The legal citation checker of claim 11 wherein said predetermined legal case citation standard comprises the Bluebook 20 The legal citation checker of claim 11 wherein said means for operating adjusts said identification of said error according to a type of said open word processing document 21 The legal citation checker of claim 20 wherein said type of said open word processing document is selected from a group consisting of a state court document a federal court document and a non court document 22 The legal citation checker of claim 11 further com prising means for storing an element relevant to said legal citation checker wherein said element is selected from a group consisting of said means for interfacing said means for operating means for instructing on the operation of said means for interfacing and means for instructing on the operation of said means for operating 23 A method of locati
26. elects the Change button 58 the software utility 20 incorporates that change within the word processing document 52 and looks for other errors in that 20 25 30 35 40 45 50 55 60 65 8 citation If the user selects the Ignore button 60 the suggestion is ignored and the software utility continues to review the citation 50 for further errors If the user selects the Ignore Rule button 62 the error cited will be ignored for all subsequent citations containing the same error If the user selects the Cancel button 64 the software utility 20 is stopped from further error checking In some instances it may identify more than one possible change If so the preferred embodiment displays a list of citations 56 each of which contains one change see FIG 3E The user may select the appropriate change by clicking on the preferred suggestion The software utility continues to check for other errors in that citation 50 and subsequent citations When the software utility 20 has checked every citation 50 in the document 52 and can identify no further errors it preferably provides an indication of the number of changes made to the document 52 In this instance the software utility 20 displays a dialog box 70 that specifies the number of changes made see FIG 3F The user is also preferably presented with the option of viewing the relevant stylistic rule In this instance if the user wishes to see m
27. eporter For example the Reporter Object for United States Reports identifies Wal lace Black Howard Peters Wheaton Cranch and Dallas as editors The Jurisdictions Object Model is initialized when it is first used The data about each jurisdiction and court is loaded through subroutines in the Populate Jurisdictions module which creates individual jurisdiction objects court objects and court group objects gets their individual prop erties to the correct values and places them in the appro priate jurisdictions or courts collection The data about each reporter is loaded from a file on the user s hard drive through the Load Reporters module which uses data contained in the file to create individual reporter objects sets their individual properties to the correct values and places them in the correct reporters collection The Jurisdictions Collection Courts Collection and Reporters Collection each uses a similar subroutine the Item method to identify whether a particular phrase is a recog nized jurisdiction court or reporter For example the code Set Jur Jurisdictions Item Phrase True True sets the variable Jur to a Jurisdiction Object that matches the string contained in the variable Phrase if there is such a match If Phrase contains Minn for example it would set the Jur variable to the Jurisdiction Object for Minnesota Likewise the code Set Court Jurisdictions Item Minn Courts Item Phrase True Tr
28. erating platforms may be used without departing from the spirit or scope of the invention When installed utilizing the above identified program ming language and operating platform the legal citation software utility 20 preferably operates as a plug in to the word processing applications encompassed within Microsoft Word 97 and Microsoft Word 2000 collectively Microsoft Word That is the software utility 20 func tions as a component of the word processing application rather than as a separate stand alone application The soft ware utility s code can be run either as uncompiled code directly from the Visual Basic 6 Editor or as a set of compiled DLL type libraries The software utility 20 inte grates with Microsoft Word through Microsoft s Compo nent Object Model or ActiveX technology Data struc tures are created through object oriented techniques using standard and custom object classes When the preferred embodiment of the software utility 20 is installed it preferably displays its operation to the user through menu commands and dialog boxes that appear over the existing word processing document Specifically the software utility preferably adds two menu commands in this instance entitled BlueCheck 40 and BlueCheck OptionsTM 42 to Microsoft Word s menu structure 44 see FIG 3A The user begins the main operation of the preferred embodiment by selecting the BlueCheck
29. f other data structures called clauses that represent each of the elements of a typical citation a case name one or more citations to specific reporters and identifications of the jurisdiction court and date of the case The Citation Model begins by locating each clause in a passage of the word processing document Many phrases are ambiguous in that the same phrase may represent the name of a reporter jurisdiction or court When the component encounters such an ambiguity it considers each possible interpretation and assigns a score representing how close that alternative comes to a correct complete citation It then selects the interpretation with the highest score as being the most likely interpretation of the citation After the Citation Model has identified the best interpretation of a citation it passes a data structure representing this citation to other components 4 Check Modules The Check Modules are a set of components within the legal citation software utility that perform a series of tests on each citation data structure In summary the components perform the following tests One Module checks the case name clause to ensure it conforms to Bluebook rules for the formatting and style of case names One Module checks each reporter clause to ensure that the reporter has the correct abbreviation and other format ting such as a volume number and page number One Module checks whether each reporter clause has a desig
30. he individual clauses it assembles them into a Citation Object a data structure that represents a complete citation A flow chart depicting the basic operation of the Citation Model is shown in FIG 5 Upon start of the Citation Model per block 120 the Citation Model searches for five types of clauses per operations block 122 a case name clause that represents the names of the parties to a case a reporter clause that represents a reporter including a volume number and page numbers a jurisdiction clause and a court clause that rep resents the jurisdiction and court of the deciding court and a date clause that represents the year or date of the opinion A Clause Locator identifies these clauses per operations block 124 and uses somewhat different techniques to iden tify the different types of clauses As an example consider the following citation Schlemmer v Farmers Union Cent Exch 397 N W 2d 903 906 Minn Ct App 1986 The Clause Locator identifies case name clauses by searching for the start and end of underlined phrases in the word processing documents Thus it identifies Schlemmer v Farmers Union Cent Exch as representing the case name in the above citation It identifies reporter clauses jurisdiction clauses and court clauses by searching for text that resembles a known reporter jurisdiction or court clause Specifically it searches for the beginning of any abbreviations associated with these clauses us
31. here is no jurisdiction clause or court clause In Tests 2 and 5 it identifies the citation as being to the Minnesota supreme court because there is a reporter or jurisdiction identifying Minnesota In Tests 3 4 6 and 7 it correctly identifies the citation as being the Minnesota court of appeals based on the court clause that it identifies Second the citation object identifies volume numbers and page numbers that are associated with any reporter clause Thus it recognizes 397 as the volume number for N W 2d and 903 906 as its page numbers Third the citation object locates the ending punctuation that follows the last clause Thus in Test 7 for example it correctly includes the close parenthesis mark to complete the Minn Ct App 1986 parenthetical phrase Fourth the citation object calculates a score that repre sents how closely its constituent clauses come to a complete and accurate citation This consists of several sub processes First each clause is assigned a score between 0 and 1 based on how closely it appears to be complete accurate and in the correct relationship to other clauses In the following example which expands on the earlier example the score for each clause is indicated within the brackets 5 20 25 30 35 45 50 55 60 65 14 Test 1 Schlemmer v Farmers Union Cent Exch Case Name 1 00 397 N W 2d 903 906 Reporter 0 93 Test 2 Schlemmer v Fa
32. ic rules may be implemented within the software utility 20 without departing from the spirit or scope of the invention If the legal citation conforms to the stylistic rules the software utility scans the word processing document for the next occurrence of an element of a legal citation per operations block 204 If the legal citation structure does not conform to stylistic rules the legal citation is displayed to the user with the portion of the citation containing an error highlighted in red per operations block 208 Of course other manners of highlighting an error may be used without departing from the spirit or scope of the invention Addi tionally one or more error messages describing the stylistic error are displayed to the user per operations block 210 as is the relevant stylistic rule per operations block 212 Further typically one or more suggestions as to the correct format of the citation are provided per operations block 214 Upon receiving suggestions for correction the user may input their own correction or edit the suggested correction per input block 216 Alternatively the user may accept the suggestion for correction as is per decision block 218 In the instance the user inputs their own correction edits the suggested correction or accepts the suggestion for correc tion as is the software utility 20 operates to directly edit the word processing document and implements the correction per operations block 220 Up
33. ing the fuzzy matching techniques described above The Clause Locator searches for a reporter jurisdic tion or court at each word that consists of letters or numbers rather than a punctuation mark It tests a range of phrases 20 25 30 35 40 45 50 55 60 65 12 that start at that word and continue up to eleven words beyond that and then words its way through shorter phrases It ignores however phrases that end in a punctuation mark At word number 13 for example it tests the following phrases N W 2d 903 906 Minn Ct N W 2d 903 906 Minn N W 2d 903 906 N W 2d 903 N W 2d N W N It recognizes N W 2d as the abbreviation for North West ern Reporter Second Series and builds a reporter clause for that phrase Although it also recognizes N W as the abbreviation for the original North Western Reporter it does not build a reporter clause representing N W as N W is contained within the larger phrase N W 2d and N W 2d is followed by a page number Finally the Clause Locator searches for years and dates by looking for single numbers between the range of 1600 and 2010 and for placeholders for years represented by four underscores It also searches for full dates such as Aug 3 1970 through Visual Basic s IsDate func tion Because the Clause Locator simply looks to the text of phrases to identify clauses it does not distinguish betwee
34. ion Minnesota Court Minnesota Court of Appeals Score 210 Test 4 Schlemmer v Farmers Union Cent Exch Case Name 1 00 Minn Reporter 0 37 Ct App Court 0 63 397 N W 2d 903 906 Reporter 0 93 1986 Date 1 00 Jurisdiction Minnesota Court Minne sota Court of Appeals Score 315 Test 5 Schlemmer v Farmers Union Cent Exch Case Name 0 75 Minn Jurisdiction 0 48 Jurisdiction Minnesota Court Minnesota Supreme Court Score 146 Test 6 Schlemmer v Farmers Union Cent Exch Case Name 0 75 Minn Jurisdiction 0 78 Ct App Court 0 70 397 Jurisdiction Minnesota Court Min nesota Court of Appeals Score 177 Test 7 Schlemmer v Farmers Union Cent Exch Case Name 0 75 Minn Jurisdiction 0 78 Ct App Court 0 70 397 N W 2d 903 906 Reporter 0 85 Jurisdiction Minnesota Court Minnesota Court of Appeals Score 315 Test 8 Schlemmer v Farmers Union Cent Exch Case Name 0 75 Minn Jurisdiction 0 78 Ct App Court 0 70 397 N W 2d 903 906 Reporter 0 93 1986 Date 1 00 Jurisdiction Minnesota Court Minnesota Court of Appeals Score 426 Test 9 Minn Reporter 0 29 Ct App Court 0 63 397 Jurisdiction Minnesota Court Minnesota Court of Appeals Score 93 Test 10 Minn Jurisdiction 0 70 Ct App Court 0 70 397 Jurisdiction Minnesota Court Minnesota Court of Appeals Score 95 Test 11 Ct App Court 0 40 397 N W 2d 903 906 Reporte
35. ion clause that follows a federal court clause then suggest deleting the juris diction clause If the citation has a state jurisdiction clause that is redundant because that state is identified by a state court clause then suggest deleting the jurisdiction clause If both the jurisdiction clause and court clause are redun dant because the jurisdiction and court are identified by a reporter then suggest deleting them together If the jurisdiction clause is redundant because the juris diction is identified by a reporter but there is no court clause or the court clause is not redundant then suggest deleting only the jurisdiction clause If the court clause is redundant because the court is identified by a reporter but there is no jurisdiction clause then suggest deleting the court clause If a court clause follows a jurisdiction clause and either or both is incorrectly abbreviated then suggest changing them as a single unit to the correct abbreviation US 7 028 259 B1 21 If the jurisdiction clause is incorrectly abbreviated then suggest changing it to the correct abbreviation If the court clause is incorrectly abbreviated then suggest changing it to the correct abbreviation If the citation s year is not within a valid range for the designated court then suggest changing the year to a placeholder or ask the user to correct the year manually Checkparallelreporters If the citation has a reporter clause that is not use
36. is parsing citations and checking citations it displays a blank dialog box i e Error Form box 48 to indicate that the software utility 20 is running When a specific check procedure identifies an error however it instructs the Error Form to display that particular error in the Error Form box 48 see FIGS 3C 3D and 3E Each test performed by the Check Modules has a specific identifier or key When a check procedure finds an error it passes that key to the Error Form plus numbers that represent the words of the citation that contain the error The Error Form uses this information to display the citation 50 in the Current Citation window with the error highlighted in red and to display a message 56 explaining the perceived problem In addition the Error Form can display the appropriate text from the Bluebook relating to this error The user can view this text by selecting the Show Rule checkbox 66 or can hide this text to reduce the size of the dialog box by clicking again to de select the checkbox 66 The Error Form also contains code to display specific suggestions 56 identified by the check procedure If a suggestion 56 is identified the Error Form uses a hidden word processing document one that is not visible to the user to make the edits suggested by the check procedure It then displays this corrected citation in the Suggestion window In some instances several different suggestions 56 are requested by the chec
37. k procedure When this occurs the Error Form displays a list of citations each containing a different suggested change and allows the user to select the correct one by clicking on that citation see FIG 3E After displaying an error the Error Form activates two buttons Ignore 60 and Ignore Rule 62 If one suggestion was generated or if multiple suggestions were generated and the user has selected a specific suggestion it also activates the Change button 58 It then waits for the user to respond Ifthe user presses Ignore 60 the Error Form makes no change to the word processing document and returns control to the Check Modules to perform other tests If the user presses Ignore Rule 62 the Error Form makes no changes and will ignore all other errors that share the same error key If the user presses Change 58 the Error Form changes the text of the citation in the main word processing document 52 to the text of the suggested citation 56 The invention then resumes locating parsing and checking citations The present invention may be embodied in other specific forms without departing from the spirit of the essential attributes thereof therefore the illustrated embodiments should be considered in all respects as illustrative and not restrictive reference being made to the appended claims rather than to the foregoing description to indicate the scope of the invention What is claimed 1 A legal citation checker comprising a co
38. led collectively the Check Modules Each check module per forms a series of related tests on the citation object to attempt to identify Bluebook stylistic errors After a citation has been parsed by the Citation Model the resulting citation object can be used to identify information or properties about each specific clause Because the citation object is built through object oriented techniques which each clause represented as a separate object these properties can be accessed with relative simplicity For example if the citation object has a date clause that identifies the year the year can be accessed through the code Var Citation Year This code sets the variable Var to a number representing the year Likewise the text of the various clauses can be accessed through commands like Var Citation CourtClause Text Var Citation ReporterClauses 2 Text US 7 028 259 B1 17 The first sets Var to the text of the citation object s court clause while the second sets Var to the text of the citation object s second reporter clause The reporter clauses court clauses and jurisdiction clauses also have data representing the reporter object court object and jurisdiction object associated with the clause For example the following code sets Var to the correct abbreviation for the citation object s second reporter clause Var Citation ReporterClauses 2 AssociatedReporter AbrvName The check modules access the
39. ment 52 Claims 10 Drawing Sheets File Edit Ven Insert Format Tools Table Window Help Dengaeleizlupaal e Je toma J nes New Romen Die e 7 u E zu Slo sts El g 1157 9th Cir 1999 Messick v Horizon Indus Inc 62 F 3d 1227 1231 9th Cir 1995 Doe deposition testimony to manufacture an issue of material fact it may offer an affidavit that 0 expands upon explains or clarifies prior testimony See Leslie v Grupo ICA 198 F 3d 1152 v Cutter Biological Ing BlueCheek TM x Current Citation 52 953 F 2d 262 266 67 4 Ses Leslie v Grupo ICA 198 F3 1152 1157 9th Cir 1999 two days of depositio 50 Suggestion See Leslie v Grupo ICA 198 F3d 1152 1157 9th Cir 1999 Federal Reporter should be abbreviated as F 3d_ Change F3d to F 3d 58 60 62 Table T 1 United States Jurisdictions Federal Appeals ofifor the District of Columbia D C Cir Cite to F F2d or F 3d Federal Reporter 1891 date F F 2d F 3d Paget Sect 64 Courts of Appeals e g 2d Cir D C Cir previously Circuit Courts of Appeals e g 2d Cir and Court of owe Co ignore ue Can A US 7 028 259 B1 Page 2 OTHER PUBLICATIONS Website Print Out Getting Your Cites in Order Paul D Supnik 5 pgs Sep 27 2000 Website Prin
40. mputer read able medium encoded with a computer program wherein said computer program comprises a first component that enables the legal citation checker to operate as a plug in to a word processing application and a second component operable with the first component that operates to locate a legal case citation within an open word processing document wherein said second component operates to identify an error within the legal case citation as compared against a legal case citation standard and automatically correct the legal US 7 028 259 B1 23 case citation within said open word processing document in conformance with the legal case citation standard 2 The legal citation checker of claim 1 wherein said first component and said second component are unitary 3 A legal citation checker comprising a computer read able medium encoded with a computer program wherein said computer program operates as a plug in application to a word processing application wherein the legal citation checker operates according to a method comprising locating a legal case citation within an open word processing docu ment identifying an error within the legal case citation within the open word processing document as compared against a legal case citation standard and automatically correcting the error within the legal case citation within the open word processing document according to the legal case citation standard 4 A method of operation of
41. n ambiguous phrases that could represent different types of clauses For example the word Minn could represent either an abbreviation of Minnesota Reporters or the juris diction for the state of Minnesota Rather than attempting to resolve this ambiguity the Clause Locator simply creates two separate clauses for Minn a reporter clause and a jurisdiction clause As the Clause Locator identifies clauses a Citation Builder interprets these clauses to determine whether they actually are part of a larger citation and to resolve any ambiguities per decision block 126 The broad fuzzy search used by the Clause Locator will identify many false posi tives phrases that are not parts of citations For example the word Minnesota or the abbreviation Minn may merely be part of a sentence or an address not a citation Likewise the search process identifies every instance of the word a as a potential abbreviation for the Atlantic Reporter which is abbreviated A To determine whether such phrases are part of a citation and to resolve ambiguities like that caused by the phrase Minn the Citation Builder evaluates the clauses based on their context with other recognized clauses For each pos sible combination of clauses in proximity to one another the Citation Builder creates a data structure per operations block 128 called a citation object that represents a complete citation It then assigns a
42. n other software applications by Reed Elsevier and West Publishing called CheckCiteTM and WestCheck respectively check citations for substan tive rather than stylistic accuracy These applications locate citations in a word processing document and compare them to cases contained in their electronic databases They verify that the citations have the correct case name correct report ers correct page and volume numbers accurate quotations and so on Like CiteRite they operate as stand alone applications and merely generate written reports that list perceived discrepancies Further they do not attempt to check for stylistic accuracy indeed some of their sugges tions are contrary to Bluebook stylistic rules Another program Citelt M by Sidebar Software Inc attempts to enforce stylistic accuracy through a different method it requires a user to enter information about each constituent element of a legal citation such as the case name volume number reporter abbreviation etc into the fields of an electronic form Based on this data it generates a complete citation that it pastes into a word processing document At the time it generates the citation it performs certain tests for Bluebook stylistic accuracy on the constitu ent elements and suggests corrections such as suggesting appropriate abbreviations for case names The program is limited however in that it cannot locate or parse citations in a word
43. nation of the reporter s editor if necessary and whether that designation is formatted correctly One Module checks the jurisdiction clause and court clause to determine whether these clauses are abbrevi ated correctly and whether or not they are necessary One Module checks the date clause to determine whether it is formatted correctly and whether the year is valid for the court One Module checks whether the citation has the necessary reporter or reporters for its court One Module checks whether the citation s clauses are in the correct order and whether the correct punctuation is used between the clauses 5 Error Form When a Check Module identifies an error it calls the Error Form a module within the legal citation software utility that displays the problematic citation and implements sugges tions The Error Form displays a dialog box or window that appears on top of the word processing document That dialog box displays the citation with the error highlighted an error message explaining the error and the options the user has to correct it and the text of the Bluebook rule that applies to this error US 7 028 259 B1 5 In addition the Check Module may instruct the Error Form to display one or more specific suggestions If so the Error Form generates and displays citations that contain the suggestions After displaying the error the Error Form gives the user the option of accepting one of the corrected citations
44. ng and correcting a legal case citation in an open document that is being edited by a word processing application comprising the steps of automatically scanning said open document for said legal case citation locating said legal case citation within said open docu ment identifying an error within said legal case citation as compared against a predetermined legal case citation standard and automatically correcting said error within said legal case citation within said open document according to said predetermined legal case citation standard 24 The method of claim 23 wherein said step of locating includes locating an ambiguous case citation and resolving the ambiguity of said ambiguous case citation 25 The method of claim 23 further comprising the step of parsing said legal case citation into a plurality of con stituent elements 26 The method of claim 25 further comprising the step of identifying said plurality of constituent elements through a procedure selected from a group consisting of a fuzzy logic procedure a fuzzy pattern matching procedure a scoring procedure and a ranking procedure 27 The method of claim 23 further comprising the step of providing an error message as to the identified error 28 The method of claim 23 further comprising the step of providing a suggestion as to a correction for the identified error US 7 028 259 B1 25 29 The method of claim 23 further comprising the step of pr
45. ntly the phrase Wall by itself does not identify whether the phrase is used as parenthetical identification of the editor or as a full reporter The Clause Locator simply identifies it as a reporter clause When a citation object is built where one reporter clause follows another as 1 Wall follows 68 U S the citation object assigns a score to determine how closely the second clause appears like an editor parenthetical If the score is sufficiently high the citation object builds an editor clause that contains the editor phrase The editor clause is then assigned as a part of the main reporter clause Thus in Jones v Smith 68 U S 1 Wall 100 105 1863 the reporter clause consists of the entire 68 U S 1 Wall 100 105 with a subsidiary editor clause that represents 1 Wall Upon identifying or establishing the type of clause within each citation a complete citation object for the citation containing all five types of clauses is created per opera tions block 134 The Citation Model then determines if additional citation clauses are present per decision block 136 and repeats the above described process to identify the types of clauses within each citation Ifno additional citation clauses are present the operation of the citation model is terminated II D Check Modules After the Citation Model identifies each individual cita tion it passes its citation object to a series of modules cal
46. o identify type of clause Case Name Reporter Jurisdiction Court amp Date no Create date structure for each possible combination of clauses Evaluate and Assign Score to Each Combination of Clauses Identify Type of Clause Based on Score Create Complete Citation Objects Data Structure for individual citation including the five types of clauses Additional Citation Clauses End Citation ode a US 7 028 259 B1 1 INTERACTIVE LEGAL CITATION CHECKER CLAIM TO PRIORITY The present application claims priority to U S Provisional Patent Application having Application No 60 179 572 filed Feb 1 2000 and entitled Interactive Legal Citation Checker COPYRIGHT CLAIM A portion of the disclosure of this patent document contains material which is subject to copyright protection The copyright owner has no objection to the facsimile reproduction by anyone of the patent document or the patent disclosure as it appears in the Patent and Trademark Office patent file or records but otherwise reserves all copyright rights whatsoever No copyright is claimed to passages from The Bluebook A Uniform System of Citation FIELD OF THE INVENTION The invention relates to citations to case opinions that are typically found in legal writings and more particularly to an interactive system and method for locating and parsing the legal citations for verifying the stylistic acc
47. on implementing the correction within the word pro cessing document the software utility 20 the software utility 20 reparses the citation and checks it against all stylistic tules following the flow of the flowchart of FIG 1 once again by returning to operations block 204 If no further legal citations are detected within the word processing document per decision block 224 the operation of the software utility 20 is terminated per block 226 The operation as described above is preferably imple mented through a program operating on a personal com puter Specifically the legal citation software utility 20 of the present invention is preferably a program that is created with the Visual Basic 6 0 Professional Edition programming US 7 028 259 B1 7 language It preferably operates on a personal computer running Microsoft Windows 95 98 or 2000 An example hardware configuration that may be used to implement the software utility 20 is shown in FIG 2 As indicated the hardware includes a personal computer 30 having a central processing unit 302 memory 304 for storing the software utility 20 and the word processing application as well as various input peripherals 306 e g keyboard mouse disk drives external memory internet connection etc and vari ous output peripherals 308 e g monitor printer disk drives external memory internet connection etc Of course other hardware implementations programming languages and op
48. ore information about an error message he or she may view the text of the relevant Bluebook rule by selecting the Show Rule checkbox 66 Upon selecting the checkbox 66 a drop down window 68 is provided within the Error Form 48 wherein the relevant rule is displayed see FIG 3D When the software utility 20 has completed checking one citation it then checks subsequent citations It should be noted that while the above described menu commands and dialog boxes are the preferred manner of interacting with a user of the software utility 20 numerous other manners of interacting with a user may be utilized without departing from the spirit or scope of the invention II Detailed Operation The legal citation software utility 20 of the present invention utilizes five primary processes to achieve the operation described by the flowchart menu commands and dialog boxes described above First it contains a component that permits the invention to integrate with a word process ing application i e the Document Interface Second it contains a detailed data structure or object model that represents the various rules for each United States jurisdic tion and court i e the Jurisdictions Object Model Third it has a component that scans a document for the constituent elements of citations and builds a data structure that repre sents each citation i e the Citation Model Fourth it has a component that tests each citation for specific err
49. ors 1 e the Check Modules Fifth it has a component that displays identified errors and suggestions and edits the word pro cessing document if a suggestion is accepted 1 e the Error Form The following describes each of these processes in detail utilizing references to the written code of the software utility 20 as coded in Visual Basic 6 0 Professional Edition I A Document Interface The Document Interface is a set of code that functions as an intermediary between the active Microsoft Word docu ment the document and the other components of the software utility 20 The Document Interface creates a data structure that represents each document being used by the software utility 20 In addition to the active word processing document the document being edited by the user the Document Interface also allows other components to create other word processing documents For example the Error US 7 028 259 B1 9 Form component uses the Document Interface to create a new hidden document invisible to the user that it uses to generate suggestions When the Document Interface creates a document data structure it also creates a text data structure the Words Interface that provides an interface for reading and editing the text in that document The Words Interface reads the text in the document and parses the text into individual constitu ent words As an illustration assume that the word process ing document consist
50. oviding said legal case citation standard that is relevant to the identified error 30 The method of claim 23 wherein said legal case citation standard is established by the Bluebook 31 The method of claim 23 further comprising adjusting the step of identifying an error within said legal case citation according to a type of said open document 32 The method of claim 31 wherein said type of open document is selected from a group consisting of a state court document a federal court document and a non court document 33 A legal citation checker for verifying the stylistic accuracy of a legal case citation within an open word processing document within a word processing application said legal citation checker comprising a computer readable medium encoded with a computer program wherein said computer program includes an integration component wherein said integration component interfaces with said word processing application a data structure component operable with said integra tion component wherein said data structure compo nent provides a plurality of stylistic accuracy rules for a plurality of legal jurisdictions a scanning component operable with said data structure component wherein said scanning component scans said open word processing document to locate a legal case citation a testing component operable with said scanning com ponent wherein said testing component tests said located legal case citation for erro
51. pinion for example the writer must adhere to 15 pages of general rules that potentially apply and must also consult several lengthy tables for rules that are specific to that opinion s jurisdiction Some of these rules differ depending on the context of the citation Further the rules for citations to opinions from one jurisdiction are often inconsistent with similar rules for those of another jurisdiction so the writer must frequently consult the appropriate table to ensure that he or she is using the appropriate style for that jurisdiction Consequently conscientious legal professionals must devote a considerable amount of time to ensuring that they 20 25 30 35 40 45 50 55 60 65 2 have properly followed the Bluebook format Since even the most careful professional however will likely make some errors that violate the Bluebook rules a computer program that locates citations in a word processing document checks those citations for stylistic accuracy and suggests and imple ments corrections can provide a substantial benefit in improving accuracy and saving the user s time In addition a computer program that locates citations in a document and parses their constituent components has other applications For example many legal briefs are required to have a table of authorities an index of each citation contained in a brief Presently word processing applications like Microsoft Word have components
52. pue A usamjeq eoeds ou SI eJau 6661 419 416 SLL 701 PC 861 WO OdNID ese eas uoysebing 6661 49 W6 244 SL PEs 861 VOI OdNID 811597 88S yonisodap Jo sep omy uoneyg uaung nI paggena t 9 997 TOT PTA S6 09 SUL MJ Paty a Apauuay T661 NO 436 98 SLE PTA 1L6 SUT Teordo org 13M9 A 307 661 NO T16 IEZI LZZI PEA 29 OUT snpup TOZTIOT HSS 6661 HO 416 LSTI STI PEA 861 VOI odp A 31597 eas Auownsa o d sa J rejo Jo sure dxo uodn spuedxo yey NABPIIJE ue Jogo ABUU JI 399 JELIOJBU JO INSSI ue 9INJIB NUBUI oj Auouinso uonisodop PP Dai less 87 Era a OE bi EAS ro amp e Ro 4 X je m lt det mopuM of ii wo eil we WPI a POM 105012 ejdures 53s US 7 028 259 B1 Sheet 6 of 10 Apr 11 2006 U S Patent 208 y abed PE A PZ4 8ep L6gl Jepoday Spe PE Y JO pZ4 4 0 9110 115 O Q erqwnjog Jo 3913810 94 104 0 sjeeddy Jo uno pue 19 pz Dal sjeaddy jo sunog ynos jsnoroud 119 ya 110 pz Dei sjeaddy jo sunog e10p83 suopoipsunf sayzis P8JUN LL 9IGEL any MOUS e AE O BEI SBUEYO TPE Hu se pajenalgge aq pinoys Jeyodey e19pay J onisodop Jo sKep omy 666 10 416 LSL ZOLL PES BEL WOE ou eise ees 6 19 992 ZOZ PT A 56 UODEICH Juano aa TO Jano 30d 5661 1O 436 I cI LTTI PEA c9 OUT supu uoziog A YOISSPI 6661 HO 416 LSH STI PEA 861 VOI 0drug 7 alse 335 Auourysay Jord s
53. r 0 85 Jurisdiction none Court none Score 168 Test 12 Ct App Court 0 40 397 N W 2d 903 906 Reporter 0 93 1986 Date 1 00 Jurisdiction none Court none Score 279 Test 13 N W 2d 903 906 Reporter 0 93 1986 Date 1 00 Jurisdiction none Court none Score 239 20 25 30 35 40 45 50 55 60 65 16 After each test is complete it recognizes Test 8 as being the citation with the highest score and thus the best interpreta tion of the citation If an imperfect citation is followed by another citation the Citation Builder performs an even more thorough test Consider the following example Schlemmer v Farmers Union Cent Exch Minn Ct App 397 N W 2d 903 906 1986 Khalifa v State Minn Ct App 397 N W 2d 383 387 1986 The Citation Builder tests 32 different interpretations of the Schlemmer citation including interpretations that include elements of the Khalifa citation to ensure that it has considered every possibility However it concludes that the interpretation described in Test 8 above remains the best interpretation Certain citations like the hypothetical citation Jones v Smith 68 U S 1 Wall 100 105 1863 contain paren thetical identifications of the reporter s editor here to Wallace These citations can also be written incorrectly as Jones v Smith 68 U S 100 105 1863 or Jones v Smith 1 Wall 100 105 1863 Conseque
54. re is no open parenthesis mark between it and the preceding reporter clause In Tests 2 3 5 and 6 the trailing jurisdiction and court clauses have lower scores because they are not followed by a date clause or a close parenthesis mark After each clause is assigned its own score the citation object assigns a total score for the citation based on the completeness of the citation and the individual scores of the clauses The score is assigned as follows If a case name clause is present add 100 points times the score of that clause If one or more reporter clauses are present add 150 points times the average score of those clauses If a date clause is present add 100 points times the score of that clause Ifa jurisdiction could be determined add 100 points times the score of the clause jurisdiction clause court clause or reporter clause that identifies it If a court could be determined add 50 points times the score of the clause jurisdiction clause court clause or reporter clause that identifies it Subtract 50 points if there is more than one case name clause court clause or jurisdiction clause Subtract 50 points if there is more than one reporter clause and the clauses are not contiguous to each other Subtract 10 points for each word that is not recognized excluding punctuation Based on these calculations the citation objects assigns the following total scores Test 1 239 Test 2 224 Test 3 256 Test 4 3
55. rmers Union Cent Exch Case Name 1 00 397 N W 2d 903 906 Reporter 1 00 Minn Reporter 0 22 Test 3 Schlemmer v Farmers Union Cent Exch Case Name 1 00 397 N W 2d 903 906 Reporter 1 00 Minn Reporter 0 29 Ct App Court 0 63 Test 4 Schlemmer v Farmers Union Cent Exch Case Name 1 00 397 N W 2d 903 906 Reporter 1 00 Minn Reporter 0 29 Ct App Court 0 93 1986 Date 1 00 Test 5 Schlemmer v Farmers Union Cent Exch Case Name 1 00 397 N W 2d 903 906 Reporter 1 00 Minn Jurisdiction 0 70 Test 6 Schlemmer v Farmers Union Cent Exch Case Name 1 00 397 N W 2d 903 906 Reporter 1 00 Minn Jurisdiction 1 00 Ct App Court 0 70 Test 7 Schlemmer v Farmers Union Cent Exch Case Name 1 00 397 N W 2d 903 906 Reporter 1 00 Minn Jurisdiction 1 00 Ct App Court 1 00 1986 Date 1 00 In Test 1 the reporter clause has a lower score because it is not followed by a jurisdiction clause court clause or date clause as would be expected In Tests 2 4 the Minn reporter clause receives a low score because it does not have a volume number or page numbers and because there is no comma between it and the preceding reporter clause and no open parenthesis mark between it and the following court clause the punctuation that would be expected if Minn were actually a reporter In Test 3 the court clause receives a lower score in part because the
56. rocessing document including each word in the document Other components of the legal citation software utility use the Document Interface to read the contents of and make changes to the word processing document 2 Jurisdictions Object Model The Jurisdictions Object Model is a hierarchical data structure that contains a representation of the specific Blue book rules for each of the United States jurisdictions At the highest level of the hierarchy it contains a representation of each of the 59 United States jurisdictions representing the federal court system and the court system for each state and territory Each jurisdiction in turn contains a representation 0 20 30 40 45 50 60 65 4 of each particular court used in that jurisdiction Each court contains a representation of information specific to that court such as the reporters used by the court and the valid dates for cases from that court Other components use the Jurisdictions Object Model to identify courts jurisdictions and reporters in the document to assess how they relate to one another and to apply specific tests to determine whether the citation is formatted correctly 3 Citation Model The Citation Model is the component of the legal citation software utility that scans a document for elements of a citation and then parses the elements by building a data structure that represents each citation The citation data structure consists o
57. rs in stylistic accuracy as compared against said rules and an error component operable with said testing compo nent wherein said error component automatically corrects said error in stylistic accuracy within said open word processing document 34 The legal citation checker of claim 33 wherein said integration component said data structure component said scanning component said testing component and said error component are of a configuration selected from a group consisting of a unitary component configuration a partial unitary component configuration and an individual compo nent configuration 35 The legal citation checker of claim 33 wherein said scanning component parses the located legal citation into a plurality of constituent elements 36 The legal citation checker of claim 33 wherein said error component displays said detected error in stylistic accuracy 37 The legal citation checker of claim 33 wherein said error component provides a suggestion for a correction of said detected error in stylistic accuracy 38 The legal citation checker of claim 37 wherein said error component enables a user to accept or ignore said suggestion 39 A legal citation checker comprising a computer readable medium encoded with a computer program wherein said computer program includes an 5 20 25 30 35 40 45 50 55 26 a software interface that interfaces with an existing word processing appli
58. rt Test 7 Schlemmer v Farmers Union Cent Exch Case Name 397 N W 2d 903 906 Reporter Minn Juris diction Ct App Court 1986 Date When the Citation Builder encounters an ambiguous phrase like Minn it considers alternatives based on each possible interpretation Thus in Tests 2 4 it interprets Minn as a reporter while in Tests 5 7 it interprets Minn as a jurisdiction The Citation Builder determines which tests to perform through an algorithm that treats the individual clauses as nodes of a tree data structure In the above example for example it interprets the case name clause as the top node of the tree the N W 2d reporter clause as a child node and the ambiguous Minn jurisdiction clause and reporter clause as children of the N W 2d reporter clause The Citation Builder recursively visits each node of the tree and builds a citation object that composed of the present node and all parent nodes As each citation object is constructed the citation object performs a number of further steps to interpret the citation First it identifies the most reasonable interpretation of the citation s jurisdiction and court based on the citation object s reporter clauses jurisdiction clauses and court clauses In the above example it cannot identify a jurisdic tion or court for Test 1 because North Western Reporter does not identify any particular jurisdiction or court and because t
59. s of the following passage Once a plaintiff establishes a prima facie case of Title VII discrimination through a disparate impact the defen dant must articulate a reasonable business justification for the practice See Wards Cove Packing Co v Atonio 490 U S 642 659 60 1989 The Words Interface parses this text into a series of indi vidual words Once a plaintiff establishes etc The Words Component parses this text according to non stan dard rules for example punctuation marks are treated as separate words Thus the phrase U S consists of four words the two letters and the two periods Other software utility components use the Words Inter face to read and write to the individual words of the document For example the code Text ActiveDoc Words 1 3 will set the variable Text to the first three words of the document Once a plaintiff Likewise a component may use the Words Interface to change the text in the word processing document For example the code ActiveDoc Words 1 1 After changes the first word in the word processing document Once to After The Words Interface allows other components to access and set other information about individual words or phrases such as how the text is formatted whether it is bold italicized or underlined and the text s Rich Text Format formatting codes It also allows other components to delete or insert ranges of tex
60. sam seDueuo Inoy yuauunoop siu Buneyo peysiuy sey eeng O IX yoeygenig SNONUABUISIP SI LUBUS SE JI 9QEI O Jdwoye Sau0t os Auou n sa uonisodap Jo sAep om St YIM juajsisuoo Aporuo st XUOUI1 S9 suosiepuy IC 1661 JIO 416 19 997 Z9Z PC 56 09 su INA perry Apouusy 7661 HO 16 98 SLE PTA 146 OUT 7215301019 19019 A 307 6661 JIO Y6 TETI LIZI PEA c9 OUT snpup WOZTIOH A Hossa 6661 O 6 LSI Ch ZST PEA 861 VO odnir A 91159 395 Auou n So Joud so j rejo JO suiejdxo uodn spuedxo 184 JIAepITITe ue J3JJO eut JI 98J euojeur Jo anssi ue amjoepnueui oj Auouinsa uonrsodop 7 7 Old d E BERERE sean El ten D I 0 b OF PMA roles Ro Y 4 e m e dja opui age soor euni p s ve yp3 eny DIOM YOSOIS W ejQUue Scr US 7 028 259 B1 Sheet 9 of 10 Apr 11 2006 U S Patent u 92190 T algo pafqo Ja4 oda u palo J2J0d2 j 201 Ja440d23 J2440d23 u0122 02 uo1422 02 J2 J0d2 j Jajuoday A u 492190 u 492190 pafqo 86 dnoug uno dnoug juno3 dnosg punog u j23fqO 96 Lo A LG uo1422 02 82 u01422 02 401499109 Juno Juno Juno 92 pafqo 1 pafqo OTTEN uolpoipsiun p 46 pafqo TEE Vv 914 u01422 09 uoijorpsiun p 06 U S Patent Apr 11 2006 Sheet 10 of 10 US 7 028 259 B1 Start Citation Model Search for Citation Clauses Attempt t
61. same date in the proper month date year format Ifthe citation does not contain a date clause then suggest that inserting a placeholder Checkclauseorder Ifthe reporter clauses do not follow the case name clause then suggest moving the reporter clauses to the position following the case name Ifthe jurisdiction clause and court clause are adjacent and they do not follow the last reporter clause then suggest moving them together to the position following the last reporter clause If the jurisdiction clause does not follow the last reporter clause then suggest moving it to the position following the last reporter clause If the court clause and date clause are adjacent and do not follow the jurisdiction clause or the last reporter clause then suggest moving them to the position following the jurisdiction clause or the last reporter clause If the court clause does not follow the jurisdiction clause or last reporter clause then suggest moving it to the position following the jurisdiction clause or last reporter clause If the date clause does not follow the court clause jurisdiction clause or last reporter clause then suggest moving it to the position following the court clause jurisdiction clause or last reporter clause 20 25 30 35 40 45 50 55 60 65 22 ILE Error Form The Error Form is a set of code that displays errors and suggestions identified by the Check Modules While the invention
62. se properties of the citation to look for anticipated errors For example the following code checks whether a reporter clause s abbreviation is the correct abbreviation for that clause If Citation ReporterClause 1 AbrvText lt gt Citation AssociatedReporter AbrvName Then Translated this code asks a question Is the abbreviation used by the first reporter clause different from the correct abbreviation for the reporter object associated with this clause If the reporter clause consisted of 100 Nw2d 105 110 the abbreviation would be Nw2d However the correct abbreviation for the associated reporter object rep resenting North Western Reporter Second Series would be N W 2d Since the two phrases are not identical the if then statement would identify an error Likewise the following code tests whether the date appears to be correct If Citation Year lt Citation Court YearStart or Citation Year Citation Court YearEnd Then Translated this code asks Is the year in the date clause earlier than first valid year for the citation s court or later than the last valid year if any for this court If the citation were Jones v Smith 100 N W 2d 105 110 Minn Ct App 1970 this question would identify an error The Minnesota Court of Appeals did not begin operating until 1983 as represented by Table T 1 of the Bluebook so 1970 is an invalid year The court object for the Minnesota Court of
63. t II B Jurisdictions Object Model The Jurisdictions Object Model represents the Bluebook rules that are unique to each United States jurisdiction such as the name and abbreviation of each jurisdiction and court and the reporters used by each court The Jurisdictions Object Model represents this information through a hierar chical object oriented data structure as shown in FIG 4 The top level of the Jurisdictions Object Model is the Jurisdictions Collection 90 a custom collection class The Jurisdictions Collection 90 contains 57 individual Jurisdic tion Objects 92 one for each of the United States jurisdic tions listed in Table T 1 of the Bluebook Each Jurisdiction Object 92 contains specific information about that jurisdic tion such as its full name its abbreviated name and the courts and reporters used by that jurisdiction Each Jurisdiction Object 92 contains a Courts Collection 94 a custom collection class The Courts Collection 94 contains the individual Court Objects 96 for that jurisdic tion Each Court Object 96 contains specific information about one court such as the full name of the court the correct abbreviation for that court the range of valid years for that court and the Court Group Object 98 associated with that court The Court Group Objects 98 summarize data about reporters This data is often common to several related courts For example Table T 1 of the Bluebook lists three related federal courts the
64. t Out Buyer s Guide to Corel WordPerfect Legal Suite Thomas L Rowe 4 pgs Copyright 1998 Website Print Out CiteRite 5 5 and 7 0 review Law Office Computing Magazine 1 pg Aug 31 2000 Website Print Out Law Office Software BlumbergExcelsior Inc 2 pgs Copyright 2000 Manual Using WestCheck Version 3 2 for Windows West Group 18 pgs Copyright 1999 Brochure CheckCite 2000 Quick Reference Lexis Nexis pg Copyright 1999 Website Print Out expertEaseTM Software overview 33 pgs Aug 3 2001 Website Print Out Complex Document Proofing LexTech Inc 2 pgs Aug 3 2001 Website Print Out Entrepreneurs Invading Israel to Find Fortunes Jessica Steinberg Forward 3 pgs Copyright 1998 Website Print Out Three Products to Watch Summer 1998 Mark Rambler Law Office Technology Review 2 pgs Copyright 1998 Website Print Out Beyond Spell Check Aug Sep 1998 Richard Belthoff Law Office Computing Magazine 2 pgs Copyright 1998 Website Print Out The Electronic Lawyer Alan Pearlman Legal Tech Newsletter 2 pgs Copyright 1998 Website Print Out Avoiding Silly Drafting Errors with Deal Proof Barry Bayer Benjamin H Cohen Law Office Technology Review 3 pgs Copyright 1998 Website Print Out Across Our Desk Bruce Brumberg National Association of Stock Plan Professionals vol 6 No 1 Mar 1998 complete Brochure Drafting with Deal Proof Team expertEase Software 2 pgs
65. that generate tables of authorities however these components require the user to mark each citation manually in the word processing document A program that automatically locates and marks each citation in a document such as the invention described herein would help to improve the speed and accuracy of building tables of authorities DESCRIPTION OF THE PRIOR ART At least one other software application called CiteR ite and marketed by Reed Elsevier plc checks word processing documents for Bluebook stylistic errors This program has several limitations however First the program operates as a separate stand alone application Unlike the present invention which operates as a plug in that works from within a word processing application a user of Cit eRite must first close the word processing document and then launch the separate CiteRiteTM application to check the document Second the program merely generates a written report that lists potential errors Unlike the present inven tion it does not suggest specific corrections and cannot edit the word processing document to implement those correc tions Rather the user must review the report and manually make any corrections According to Reed Elsevier market ing literature CiteRiteTM improved upon prior unnamed cite checking applications that were even more limited as they required the user to mark each citation before the software could check it In additio
66. that word is followed by of then suggest changing the phrase to In re If the case name begins with In re or Ex parte but also contains a designation of versus then suggest deleting the In re or Ex parte procedural phrase If ex rel follows a designation of In re or Ex parte then suggest deleting ex rel and the remainder of the case name If In re or Ex parte is incorrectly punctuated or capitalized then suggest correcting it If ex rel is incorrectly punctuated or capitalized then suggest cor recting it If the first word of a party name is abbreviated then suggest changing it to its unabbreviated phrase If the first word of a party name is The and it is not part of the phrases The King The Queen or The case s then suggest deleting it If the name of a party ends in a word that describes a party like administrator appellee or executor then suggest deleting that word If the case name contains State of State Common wealth of State or People of State and state is the jurisdiction of the citation then suggest deleting of state If the case name contains State of State Common wealth of State or People of State and state is the jurisdiction of the citation then suggest deleting State of Commonwealth or People of If one
67. tion 10 The method of claim 4 further comprising displaying a legal case citation standard that is relevant to said error in a window or dialog box displayed simultaneously with said open word processing document 11 A legal citation checker comprising a computer readable medium encoded with a computer program wherein said computer program includes means for interfacing with an existing word processing application and means for operating with said means for interfacing said means for operating also for locating a legal case citation within an open word processing document that is being edited and for identifying an error within said legal case citation as compared against a predetermined case citation standard and wherein said means for operating also for automatically correcting said error within said legal case citation within said open word processing document according to said predetermined legal case citation standard 20 25 30 35 40 45 50 55 60 65 24 12 The legal citation checker of claim 11 wherein said means for interfacing and said means for operating are unitary 13 The legal citation checker of claim 11 wherein said means for operating locates automatically said legal case citation 14 The legal citation checker of claim 11 wherein said means for operating parses said legal case citation into 2 plurality of constituent elements 15 The legal citation checker of claim 11 wher
68. ue True True sets the variable Court to the Minnesota court that matches the string contained in the variable Phrase if any If Phrase contains Ct App it will set Court to the Court Object for the Minnesota Court of Appeals One problem with identifying and parsing citations in a document is that a program must be able to correctly interpret a citation even if the citation contains errors including typographical errors For example the Bluebook instructs that Minnesota should be abbreviated as Minn but users may omit punctuation e g Minn may use incorrect capitalization e g MInn may incorrectly use the postal abbreviation MN or the unabbreviated name or may misspell it altogether eg Mnn Likewise although the Bluebook instructs that users should refer to the Minnesota Court of Appeals as Ct App writers often misspell it as App Ct or simply App Thus if a program merely searches a word processing document for US 7 028 259 B1 11 the correct abbreviations it would overlook many phrases that incorrectly identify a jurisdiction court or reporter To overcome this problem the Jurisdictions Model uses fuzzy pattern matching technigues to be more fault tolerant The Item method of the Jurisdictions Collection Courts Collection and Reporters Collection each use a custom class called the Fuzzy Collection that uses a variety of techniques to identify close but ine
69. uggestion for correction FIG 3F is a summary dialog box that may be utilized by the software utility of the present invention to notify the user of the number of changes that were made to legal citations within a word processing document FIG 4 depicts the hierarchical data structure utilized by the Jurisdictions Object Model component of the legal citation software utility of the present invention FIG 5 is flowchart showing the basic operation of the Citation Model component of the legal citation software utility of the present invention APPENDIX An appendix containing a printed program listing of the present invention is provided following the claims and abstract of the application DETAILED DESCRIPTION OF THE PREFERRED EMBODIMENTS A legal citation software utility of the present invention when implemented within an existing word processing application operates to locate legal citations within a word processing document The software utility then proceeds to verify the stylistic accuracy of those legal citations accord ing to established standards while providing the user the opportunity to correct stylistic errors within the word pro cessing document 20 25 30 35 40 45 50 55 60 65 6 1 Basic Operation Referring to FIG 1 a flowchart depicting the basic operation of the legal citation software utility 20 of the present invention is provided It should be noted that the flowchart is provided
70. uracy of the legal citations and for displaying and implementing correc tions of the legal citations BACKGROUND OF THE INVENTION Legal citations to case opinions are typically found in legal writings When attorneys write legal briefs and memo randa when judges write legal opinions and when law students and law professors write academic papers the writings typically contain citations to legal sources such as case opinions statutes and administrative regulations When writing these citations members of the United States legal profession must follow particular stylistic guidelines Most are expected to follow the stylistic rules that are promulgated in a handbook called the Bluebook A Uniform System of Citation the Bluebook According to the Bluebook stylistic rules a typical case citation has the form United States v McDonald 531 F 2d 196 199 200 4th Cir 1976 In this citation United States v McDonald represents the name of the case 531 F 2d 196 represents volume 531 page 196 of the reporter Federal Reporter Second Series 199 200 represents the pinpoint page number to a specific passage 4th Cir represents the court that decided the opinion the Federal Fourth Circuit Court of Appeals and 1976 represents the year the opinion was decided Case names are often under lined or italicized The Bluebook s rules are quite specific and complex When adding a citation to a single court o
71. xact matches First the Fuzzy Collection ignores punctuation and capi talization of the phrase Thus the above examples would return the Minnesota Jurisdictions Object for MINN and would return the Minnesota Court of Appeals Court Object for ctapp Second the Fuzzy Collection not only looks for the correct abbreviation like Ct App or Minn but also for aliases phrases like App App Ct MN or Minnesota that are common misspellings of an expected phrase Third the Fuzzy Collection uses an edit distance algo rithm to identify other typographical errors The edit dis tance algorithm will identify one string as being equivalent if it begins with the same character as the correct abbrevia tion or the alias and has no more than one character in difference Thus it will identify Ct Ap or Ct Appp as representing the Court of Appeals The Fuzzy Collection combines all of these techniques when searching for a jurisdiction court or reporter that matches a phrase Thus it will return Minnesota as a jurisdiction from the phrase min even though the punc tuation is wrong the capitalization is wrong and the phrase is misspelled and will return the Court of Appeals for Ap Ct even though the phrase is a misspelling of an alias ILC Citation Model The Citation Model locates individual clauses of a citation by searching for key terms As it identifies t
72. ys an error message displays the relevant Bluebook rule and typically displays one or more citations that incorporate a recommended suggested correction The user may then edit the citation manually may reject the recommended correction or may accept the recommended correction If the user selects a suggestion the invention automatically edits the word processing document to incor porate the change selected by the user The invention then continues to check that citation and other citations in the document until no further errors are encountered The legal citation software utility has five primary pro cesses First it contains a component that permits the invention to integrate with a word processing application Second it contains a detailed data structure or object model that represents the various rules for each United States jurisdiction and court Third it has a component that scans a document for the constituent elements of citations and builds a data structure that represents each citation Fourth it has a component that tests each citation for specific errors Fifth it has a component that displays identified errors and suggestions and edits the word processing document if a suggestion is accepted The following briefly describes each of these processes 1 Document Interface The Document Interface integrates the invention with a word processing application This component creates a data structure that represents the word p

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