PTAB

CBM2014-00168

Salesforcecom Inc v. Applications In Internet Time LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Integrated Change Management Unit
  • Brief Description: The ’482 patent describes a system for managing changes in business requirements, particularly regulatory changes, and automatically generating an updated software application user interface to reflect those changes. The system uses a multi-layered server architecture to separate application-specific data from common user interface functions to facilitate dynamic generation.

3. Grounds for Unpatentability

Ground 1: Indefiniteness under 35 U.S.C. §112 - Claims 1-59

  • Prior Art Relied Upon: Not applicable. Argument is based on the patent’s intrinsic record.
  • Core Argument for this Ground:
    • Petitioner argued that claims 1-59 are unpatentable as indefinite because they fail to inform a person of ordinary skill in the art (POSITA) about the scope of the invention with reasonable certainty. The claims were characterized as "extremely generic and broad" with only a "tenuous connection" to the specification, which is focused on managing regulatory changes.
    • Key Aspects: The primary contention focused on the terms "layer" and "change management layer." Petitioner asserted that the specification fails to provide a clear definition or structure for the claimed "first layer," "second layer," and "third layer," leading to ambiguity about their boundaries and functions. The use of these terms was argued to be inconsistent within the claims and misaligned with their standard technical meaning, making it impossible to discern the claimed architecture. Similarly, the "change management layer" was described as indefinite because the claims do not limit it to the "intelligent agents" detailed in the specification, leaving its scope and mechanism of action unclear.

Ground 2: Anticipation over Peters - Claims 1, 3, 5-6, 10, 20-21, 23-26, 30, 40-41, 43, 45-46, and 49 are anticipated under 35 U.S.C. §102 by Peters.

  • 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 describes a client/server system for coordinating changes to shared data, discloses every element of the challenged claims. The "change notification server" in Peters was mapped directly to the claimed server computer with a "change management layer." Peters’ system aids "database clients in detecting change to shared data" and generates updated user interfaces, which Petitioner argued meets the limitation of dynamically generating an application. The architecture in Peters was alleged to inherently use separate layers of data: a "first layer" containing application-specific logic (e.g., for a train scheduling system) and a "second layer" with common UI functions, which are retrieved by a "third layer" to generate the final UI for the client.

Ground 3: Obviousness over Peters in view of Haverstock - Claims 1, 3, 5-6, 10, 20-21, 23-26, 30, 40-41, 43, 45-46, and 49 are obvious over Peters in view of Haverstock.

  • Prior Art Relied Upon: Peters ("The Design of A Change Notification Server for Clients Of a Passive Object-Oriented Database Management System" (July 1992)) and Haverstock (Patent 6,064,977).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that to the extent Peters does not explicitly disclose the use of a "browser application" as recited in limitations [h] and [i] of claim 1, Haverstock provides this teaching. Haverstock discloses a web server that provides "direct scheduling and calendaring from a web browser" and teaches the dynamic generation of content in the browser when underlying data changes. Peters teaches the core client/server architecture for managing and propagating data changes.
    • Motivation to Combine: A POSITA would combine Peters’ change management architecture with Haverstock’s web-based interface to create a more efficient and widely accessible system. Leveraging ubiquitous web browsers as the client interface was a well-known and desirable design choice to simplify software distribution and maintenance, providing a clear motivation to implement Peters' server-side logic with a browser-based front end as taught by Haverstock.
    • Expectation of Success: The integration of server-side application logic with a browser-based client was a conventional and well-understood approach in the art at the time. A POSITA would have had a reasonable expectation of success in combining these known elements to achieve a system that dynamically updates browser-based applications in response to server-side data changes.

  • Additional Grounds: Petitioner asserted numerous additional anticipation challenges against the same set of claims based on Gordon (Patent 6,243,717) and Pad++ (a 1996 journal article). Further obviousness grounds were asserted based on various combinations of Peters, Gordon, Haverstock, and Pad++.

4. Key Claim Construction Positions

  • "application": Petitioner proposed construing this term 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 computing context at the time of the invention.
  • "dynamically generating" / "dynamically generate": While asserting these terms may be indefinite, Petitioner proposed a construction of "automatically generating or updating." This was based on dictionary definitions of "dynamic" as something occurring "when and as needed" while a program is running.
  • "Layer" terms ("first layer," "second layer," etc.): Petitioner did not offer a specific construction but argued the terms are indefinite for failing to provide any structural or functional clarity, as noted in Ground 1.

5. Key Technical Contentions (Beyond Claim Construction)

  • The petition’s central technical contention was that the "layered" architecture recited in the claims is fundamentally ambiguous and technically unsound as claimed. Petitioner argued that the claims require separate "first" and "second" layers, yet dependent claims suggest both layers could map to the same "business content layer" described in the specification. This internal contradiction, combined with a disconnect from the standard meaning of "layer" in network or software architecture, was presented as a core technical flaw rendering the claims invalid.

6. Relief Requested

  • Petitioner requests institution of Covered Business Method (CBM) review and cancellation of claims 1-59 of the ’482 patent as ineligible for patenting, indefinite, and unpatentable under 35 U.S.C. §§ 102 and 103.