PTAB

IPR2013-00079

IBM Corp v. Financial Systems Technology Intellectual Property Pty Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Easily Expandable Data Processing System and Method
  • Brief Description: The ’520 patent describes a relational database framework that makes relationships between different data entities explicit. The system uses a set of definition tables (Entity Definition Table, Relation Definition Table) to define entity and relation types, which in turn point to corresponding instance tables (Entity Instance Tables, Relation Instance Tables) that store the actual data records.

3. Grounds for Unpatentability

Ground 1: Obviousness over Davis - Claims 10-13 and 15-16 are obvious over a 1988 publication by Davis.

  • Prior Art Relied Upon: Davis ("EDICT – An Enhanced Relational Data Dictionary: Architecture and Example," a 1988 publication) and Khoyi (Patent 5,206,951).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Davis discloses a multi-layered architecture for a relational database management system that teaches every element of the challenged claims. Davis’s “ENTITY_SETS” table was alleged to be an entity definition table containing entity type records, and its “SUPPLIERS” table was an associated entity instance table. Similarly, Davis’s “BINARY_RELATIONSHIP” table was argued to be a relation definition table, and its “DELIVER” table was a corresponding relation instance table. Petitioner contended the only difference was that Davis identified type names and table names in the same attribute, rather than separate attributes as claimed, which it characterized as a trivial and obvious design choice. For claim 12, which requires a record identifier, Petitioner asserted this was inherent in any relational database or would be obvious to add by combining Davis with Khoyi, which explicitly teaches link records with record identifiers and entity types.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the teachings of Davis and Khoyi to add explicit record identifier and entity type attributes, as taught by Khoyi, to the relational tables of Davis to improve data retrieval and management.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success as both references operate within the well-established field of relational databases and address similar data structure and relationship concepts.

Ground 2: Obviousness over Cammarata - Claims 10-13 and 15-16 are obvious over a 1989 publication by Cammarata.

  • Prior Art Relied Upon: Cammarata ("Extending a Relational Database with Deferred Referential Integrity Checking and Intelligent Joins," a 1989 publication) and Khoyi (Patent 5,206,951).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Cammarata discloses a knowledge base, or “Intelligent Information Dictionary” (IID), to capture implicit semantics of a relational database. The “IID metadata” was asserted to function as an entity definition table, defining an entity type (e.g., “COUNTRY”) and identifying an associated instance table (the “country” table). The “IID interlinks” records were alleged to function as a relation definition table, defining relationship types and identifying the tables involved. While Cammarata stores this metadata in a non-tabular format, Petitioner argued it would have been obvious to a POSITA to store this structured data in conventional database tables for logical organization and easier querying.
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to implement Cammarata's dictionary concepts using standard relational tables, as taught throughout the prior art, to improve the system's structure, performance, and maintainability. The motivation to combine with Khoyi was the same as in Ground 1.
    • Expectation of Success (for §103 grounds): A POSITA would expect success in tabularizing Cammarata’s metadata, as this represented a routine application of basic database design principles to the structured information disclosed.

Ground 3: Obviousness over Fujisawa - Claims 10-13 and 15-16 are obvious over Fujisawa, optionally in view of Davis or Khoyi.

  • Prior Art Relied Upon: Fujisawa (Patent 4,868,733), Davis, and Khoyi.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fujisawa teaches an “entity relation” database model with tables that perform the same functions as those claimed. Fujisawa’s Table “C” lists concepts (e.g., “Computer”) and was argued to be an entity definition table. Its Table “S,” which contains instances of those concepts, was mapped to the claimed entity instance table. Likewise, Fujisawa’s Table “R” defines generic relationships (e.g., “RUN”) and was mapped to the claimed relation definition table, while its Table “r” stores specific instances of those relationships, mapping to the relation instance table. For the dependent claims, Petitioner argued it would have been obvious to combine Fujisawa with Davis to partition instance tables by entity type for improved efficiency.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the teachings of Fujisawa and Davis to enhance Fujisawa's database model with the more structured, multi-table schema of Davis. This would improve the efficiency of processing database queries by partitioning a general instance table (like Fujisawa's) into specific entity instance tables.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success in applying the structural enhancements from Davis to the database model of Fujisawa, as both concern methods for organizing and relating data in database systems.

4. Key Claim Construction Positions

  • For the purposes of the IPR, Petitioner adopted the claim constructions proposed by the Patent Owner in a co-pending district court litigation. Key adopted constructions included:
    • Entity Definition Table: Construed as a "relational database table that defines one or more entity types and stores one or more entity type records."
    • Entity Type Record: Construed as a "record in an entity definition table, said record containing, as two separate attributes, an entity type and a table identifier of an entity instance table."
    • Relation Definition Table: Construed as a "relational database table that defines one or more relation types and stores one or more relation type records."
    • Relation Type Record: Construed as a "record in a relation definition table, said record containing, as two separate attributes, a relation type and a table identifier of a relation instance table."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 10-13 and 15-16 of the ’520 patent as unpatentable.