PTAB

CBM2013-00024

Salesforcecom Inc v. VirtualAGILity Inc

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1. Case Identification

2. Patent Overview

  • Title: Processing Management Information
  • Brief Description: The ’413 patent discloses a computer-implemented system for managing a collaborative activity. The system uses a data model where information is organized into multiple, different types of hierarchies, and individual model entities can simultaneously belong to more than one hierarchy.

3. Grounds for Unpatentability

Ground 1: Anticipation under §102 - Claims 1-21 are anticipated by Lowery

  • Prior Art Relied Upon: Lowery ("Managing Projects with Microsoft Project 4.0," 1994).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lowery, a comprehensive user manual for Microsoft Project 4.0 software, taught every limitation of the challenged claims. Lowery was said to disclose a computer-implemented system for supporting the management of a collaborative activity (a project) by persons who are not IT specialists. The reference allegedly described organizing project data—referred to as model entities like tasks and resources—into multiple, distinct types of hierarchies. For example, Lowery depicted a task hierarchy (with tasks and subtasks) and a separate resource hierarchy (with resource groups and individual resources). Petitioner asserted Lowery explicitly showed a given model entity could simultaneously belong to more than one hierarchy, pointing to examples where a resource from the resource hierarchy is assigned to a specific task in the task hierarchy. Furthermore, Lowery was said to extensively disclose a graphical user interface (GUI) that permits users to access, create, modify, delete, and view the model entities and their associated information.

Ground 2: Anticipation under §102 - Claims 1-21 are anticipated by Ito

  • Prior Art Relied Upon: Ito (Patent 5,761,674).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Ito, which described an "integrated construction project information management system," also anticipated all claims. Ito was argued to disclose a project model comprising a product model and a process model, with constituent objects arranged in a hierarchical structure. Petitioner highlighted figures in Ito that illustrate multiple, distinct hierarchical views, such as "Project view," "Object view," and "Management view." The argument was made that model entities subordinate to one view (e.g., entities within the "Management View") are also subordinate to the broader "Project View" hierarchy, and therefore belong to multiple hierarchies. Ito was also said to teach a GUI that allows different users (e.g., sales persons, designers) to access and manipulate the project data according to their specific roles and permissions.

Ground 3: Obviousness under §103 - Claims 1-21 are obvious over Lowery in view of Ito

  • Prior Art Relied Upon: Lowery ("Managing Projects with Microsoft Project 4.0," 1994) and Ito (Patent 5,761,674).
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative to anticipation, Petitioner argued that the claims would have been obvious over the combination of Lowery and Ito. The petition asserted that all claimed features were present across the two references. Lowery was presented as providing a detailed, practical guide to a commercially available product with a well-developed GUI for managing information in a multi-hierarchical system. Ito was presented as teaching the underlying system architecture and relational data model for organizing such information.
    • Motivation to Combine: Petitioner asserted a POSITA, tasked with creating a collaborative management tool, would have been motivated to combine the teachings because both references were directed to the same field of information management and modeling. A POSITA would naturally look to Lowery’s successful, user-friendly GUI implementation and Ito’s robust underlying data structure design as complementary, common-sense elements to include in a comprehensive system. The known industry practice of ensuring software compatibility and data exchange, as described in Lowery, was cited as further evidence of this motivation.
    • Expectation of Success: The combination was portrayed as predictable. Applying the known user interface principles from the Lowery manual to a system with an underlying data organization taught by Ito would have yielded the claimed system with a high expectation of success.
  • Additional Grounds: Petitioner also asserted that claims 1-21 are invalid under 35 U.S.C. §101 as being directed to the abstract idea of managing a "collaborative activity" using generic computer components, which add no patent-eligible inventive concept.

4. Key Claim Construction Positions

  • "System" (Claim 1): Petitioner argued that while claim 1 recites a system "implemented using a processor and a storage device," the plain language does not make these hardware elements components of the claimed system itself. This construction was central to Petitioner's §101 argument, framing the claim as being directed to an abstract "representation of a model," rather than a tangible machine or apparatus.
  • "Model of a collaborative activity" and "model entities": Petitioner asserted that because the patent failed to define these key terms, they should be given their broadest reasonable interpretation consistent with their plain and ordinary meaning. This broad construction was used to argue that the claims encompassed any abstract method of organizing information for a group project, thereby ensuring the claims read on the conventional project management systems disclosed in the prior art.
  • "Belonging to": Petitioner contended that the specification used the terms "associated with" and "belonging to" interchangeably when describing the relationship between a model entity and a hierarchy. This construction allowed for a broad interpretation where any link, assignment, or logical association between an entity and a hierarchy would satisfy the claim limitation, a feature Petitioner argued was common in the prior art.

5. Relief Requested

  • Petitioner requested institution of a Covered Business Method Patent Review and cancellation of claims 1-21 of the ’413 patent as unpatentable.