PTAB

CBM2016-00100

Ford Motor Company v. Versata Development Group, Inc.

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1. Case Identification

2. Patent Overview

  • Title: Attribute Prioritized Configuration Using a Combined Configuration-Attribute Data Model
  • Brief Description: The ’825 patent relates to a computer-implemented system and method for product configuration. The invention uses a single, "combined configuration rules-attributes model" to determine valid product configurations and subsequently prioritizes those configurations for a user based on selected attributes such as price, weight, or specific features.

3. Grounds for Unpatentability

Ground 1: Patent Ineligibility under §101 - Claims 1-20 are unpatentable under 35 U.S.C. §101.

  • Prior Art Relied Upon: Not applicable. This ground asserted that the claims are directed to patent-ineligible subject matter.
  • Core Argument for this Ground:
    • Abstract Idea: Petitioner argued the claims are directed to the abstract idea of organizing data according to human preferences—specifically, sorting potential product configurations based on various attributes. The petition contended this represents a fundamental and longstanding commercial practice, analogous to mental processes that can be performed by a human. The core of the claimed method was characterized as collecting, processing, and organizing information, which is an unpatentable abstract concept.
    • No Inventive Concept: Petitioner asserted that implementing this abstract sorting idea on a generic computer does not supply an inventive concept sufficient to transform the claims into patent-eligible subject matter. The claims recite only conventional computer components (processor, memory) performing their well-understood, routine functions to automate a known business practice. The petition argued that the claims do not improve the functioning of the computer itself but merely use the computer as a tool.
    • Human-Performable Example: A central component of the argument was a detailed example demonstrating that a human could perform every step of the claimed invention using pen and paper. Petitioner illustrated how a car dealer, using a 2002 Lincoln Continental price list and order guide (both predating the patent), could create a "combined rules-attributes model" (a table of options and prices). The dealer could then use this table to answer customer queries about the least or most expensive vehicle configurations, thereby showing the claimed process is fundamentally a mental or manual one.

Ground 2: Indefiniteness under §112 - Claims 16 and 20 are indefinite under 35 U.S.C. §112.

  • Prior Art Relied Upon: Not applicable. This ground asserted that the claim language fails to particularly point out and distinctly claim the invention.
  • Core Argument for this Ground:
    • Means-Plus-Function Claims: Petitioner asserted that claims 16 and 20 are drafted in means-plus-function format under §112, ¶6, as they recite multiple "means for..." limitations, including "means for processing," "means for retrieving," and "means for prioritizing."
    • Failure to Disclose Algorithm: The core of the indefiniteness challenge was the argument that the ’825 patent specification fails to disclose the corresponding structure—specifically, a sufficient algorithm—for performing the recited functions. For a computer-implemented means-plus-function claim to be definite, the specification must disclose the algorithm that transforms the general-purpose computer into a special-purpose machine. Petitioner argued that the ’825 patent only discloses a general-purpose computer and restates the claimed functions in prose or high-level flowcharts. These disclosures were alleged to describe what the system does (an outcome) rather than how it does it, leaving a person of ordinary skill in the art without a clear understanding of the claims' scope.

4. Key Technical Contentions (Beyond Claim Construction)

  • No Improvement to Computer Technology: A key contention underpinning the §101 challenge was that the ’825 patent does not claim a "technological invention," which was a threshold requirement for avoiding a Covered Business Method (CBM) review. Petitioner argued the patent’s purported point of novelty—combining a configuration rules model and an attribute information model into a single data structure—is merely a rearrangement of data organization, not a specific improvement to computer technology. The petition contrasted this with patents that improve how a computer operates (e.g., by enabling faster data retrieval or more efficient memory usage), arguing the ’825 patent merely invokes a computer as a tool to execute an abstract business process.

5. Relief Requested

  • Petitioner requested the institution of a Covered Business Method (CBM) review and the cancellation of claims 1-20 of the ’825 patent as unpatentable.