PTAB

CBM2014-00162

Salesforcecom Inc v. Applications In Internet Time LLC

Key Events

Petition

petition

Title: Integrated Change Management Unit
Brief Description: The ’111 patent specification describes a system for managing business activities in response to changes in regulatory and non-regulatory requirements. The disclosed system uses "intelligent agents" to monitor databases for changes and automatically update related documents, reports, and user interfaces. However, the challenged claims are broadly directed to a generic method of dynamically generating a user interface based on separate sets of unique and common application information, and then modifying that information in response to detected changes, without reciting the specific regulatory or "intelligent agent" features from the specification.

Prior Art Relied Upon: N/A
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that claims 1-12 are directed to the abstract idea of "change management"—the concept of monitoring an information source and updating other stored information in response to detected changes. The claims do not add an inventive concept to this abstract idea. Instead, they recite only generic and conventional computer components and functions, such as receiving information, establishing a communication connection, generating a user interface, and modifying data. Petitioner asserted these are the most basic functions of a computer and are insufficient to transform the abstract idea into a patent-eligible invention. The petition further contended that the claims fail the machine-or-transformation test, as the steps can be performed mentally or with pen and paper, and the claimed method does not transform any article into a different state or thing.

Prior Art Relied Upon: Peters ("The Design of A Change Notification Server for Clients Of a Passive Object-Oriented Database Management System," July 1992).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Peters, which was not cited during prosecution, discloses every limitation of the challenged claims. Peters describes a client/server architecture with a "change notification server" that aids database clients in detecting changes to shared data. For claim 1, Petitioner mapped Peters’ disclosure of collaborative "groupware" applications as teaching the "first information about unique aspects." It mapped Peters’ description of a railway network management system with graphical user interfaces (GUIs) for different users (train and station operators) as teaching the "second information about user interface elements." Peters’ system dynamically generates these GUIs for managing the railway network and, crucially, modifies displayed data in response to changes detected by the change management server, thus teaching the final limitation of claim 1. Petitioner argued Peters’ disclosure of client processes and GUIs for train scheduling and collaborative work systems met all limitations of the independent and dependent claims.

Prior Art Relied Upon: Gordon (Patent 6,243,717).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Gordon discloses a collaborative client/server system for revision management of linked data entities. Gordon’s application server, which encapsulates business rules and application logic, was argued to teach the "first information." Its disclosure of standardized toolsets and user applications met the "second information" limitation. Gordon explicitly teaches generating a GUI that allows a user to select different versions of data, and its core novelty is a method to automatically update referencing data records when a source record is revised, thereby teaching the "modifying" step of claim 1. Petitioner contended that Gordon’s system for revision management of manufacturing data anticipated the claims. For any elements of dependent claims not explicitly disclosed, Petitioner argued they would have been obvious to a POSITA based on Gordon's teachings.
Additional Grounds: Petitioner asserted additional anticipation challenges based on Haverstock (Patent 6,064,977) and the Pad++ publications (Bederson I and II). Petitioner also asserted multiple obviousness grounds combining Peters, Gordon, Haverstock, and/or Pad++.

"application": Petitioner proposed this term be construed as "a program designed to assist in the performance of a specific task, such as data entry." This construction was argued to be consistent with the specification and the ordinary meaning in the art at the time of filing.
"dynamically generating" / "dynamically generate": Petitioner proposed this phrase be construed as "automatically generating or updating." This construction was based on dictionary definitions of "dynamic" as an event that occurs as needed while a program is running.
Other Terms: Petitioner argued that terms like "physical designs," "physical structures," and "logical designs" may be indefinite but proposed constructions based on the specification if they were to be construed (e.g., "designs related to physical products").

Eligibility for CBM Review: A central contention of the petition was that the ’111 patent qualifies as a "covered business method" patent and is not exempt as a "technological invention." Petitioner argued the patent fails both prongs of the test for a technological invention: (1) it does not recite a technological feature that is novel and unobvious, instead relying on generic computer components; and (2) it does not solve a technical problem with a technical solution. The petition asserted that the problem solved by the patent, as described by the patent owner, was a commercial one (i.e., the time, effort, and money required to respond to regulatory changes), not a technical one.

Petitioner requested institution of a Covered Business Method (CBM) review and cancellation of claims 1-18 of the ’111 patent as unpatentable under 35 U.S.C. §§ 101, 102, and/or 103.