PTAB

IPR2013-00479

Facebook Inc v. Software Rights Archive LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Indexing, Searching and Displaying Data
  • Brief Description: The ’494 patent discloses a computer-based research tool for indexing, searching, and displaying data. The invention purports to improve upon conventional Boolean textual searching by creating a "numerical representation" of data objects and using "references, patterns, and similarity" to search, with disclosed applications including the Internet and World Wide Web.

3. Grounds for Unpatentability

Ground 1: Anticipation and Obviousness over the Fox Papers - Claims 18-20, 48, and 49 are anticipated by or obvious over Fox

  • Prior Art Relied Upon: Fox SMART (a 1983 Cornell University technical report), Fox Thesis (a 1983 Cornell University thesis), and Fox Collection (a 1983 Cornell University technical report), collectively "the Fox Papers."
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fox SMART and Fox Thesis each individually anticipate the challenged claims. The Fox Papers describe the "SMART" information retrieval system, which performs the claimed method of analyzing a database. The system creates a "first numerical representation" of direct relationships by processing bibliographic citations to create vectors and subvectors. It then generates a "second numerical representation" (e.g., bibliographic coupling or co-citation submatrices) based on an analysis of the first representation to account for indirect relationships. Petitioner asserted these second representations are stored as part of an "extended vector" and are used for searching and clustering to identify and display relevant documents. For dependent claims, the Fox Papers were alleged to teach ranking objects using the numerical representations and semantical factors (claim 48) and considering the quantity of direct relationships (claim 49).
    • Motivation to Combine (for §103 grounds): Petitioner contended that a person of ordinary skill in the art (POSITA) would have been motivated to combine the Fox Papers. All three publications were authored by Dr. Edward Fox, arose from the same doctoral thesis project, and were originally part of a single, larger document that was split due to page limits. They collectively describe a single, complete research project, providing a clear motivation for a POSITA to read and apply their teachings together.
    • Expectation of Success (for §103 grounds): The references describe an already-implemented system (SMART), providing a POSITA with a clear expectation of success in combining their teachings.

Ground 2: Anticipation over Thompson - Claims 18-20, 48, and 49 are anticipated by Thompson

  • Prior Art Relied Upon: Thompson (a 1989 University of Massachusetts thesis, "The Design and Implementation of an Intelligent Interface for Information Retrieval").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Thompson describes the "Intelligent Interface for Information Retrieval" (I3R) system, which anticipates every limitation of the challenged claims. Thompson discloses analyzing a database of documents by creating a first numerical representation of direct relationships (citation links). The system then explicitly uses these citation links to generate a second numerical representation accounting for indirect relationships, namely bibliographic coupling (BC) and co-citation (CC) links. This data is stored in the system's VAX/RMS file structures. The I3R system uses these stored representations for "cluster search" variations to identify objects, which are then displayed to the user. Thompson also disclosed using the representations along with semantical factors to rank objects for display (claim 48) and considering quantities of citations when generating indirect links (claim 49).

Ground 3: Obviousness over Egger, Fox Envision, and Saito - Claims 45 and 51 are obvious

  • Prior Art Relied Upon: Egger PCT (WO 95/00896), Fox Envision (a 1993 journal article), and Saito Clustering (a 1990 journal article).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that applying the citation-analysis methods of Egger PCT (which has the same disclosure as the ’494 patent’s parent) to the World Wide Web was obvious. Claim 51 adds the limitation of identifying web sites using a Universal Resource Locator (URL). Fox Envision was cited as expressly teaching the application of existing information retrieval techniques to emerging "wide area hypertext systems . . . like the WorldWideWeb." Claim 45 adds limitations requiring the second numerical representation to be a "value" generated by analyzing "direct link weights in a set of paths." Petitioner asserted that Saito Clustering taught an obvious solution by applying a weighting factor to each link in an indirect citation path, diminishing the value with path length, to create a "total-citation matrix" used for ranking.
    • Motivation to Combine (for §103 grounds): A POSITA would combine these references to enhance the known citation-based retrieval methods of Egger PCT for use on the emerging World Wide Web, a combination explicitly motivated by Fox Envision. To improve ranking in such a system, it would have been obvious to incorporate the path-weighting techniques taught by Saito to account for the diminishing relevance of more distant links.
    • Expectation of Success (for §103 grounds): Because the references applied known retrieval principles to a new but analogous data structure (hypertext), a POSITA would have had a reasonable expectation of successfully implementing such a system.

  • Additional Grounds: Petitioner asserted numerous additional grounds, including anticipation challenges based on Tapper 1976, Tapper 1982, and Salton 1963. Further obviousness challenges were asserted based on combinations of the Saito Papers, the Tapper Papers, Fox Hypertext, Little, and Zizzo to address web-related limitations in claims 45, 51, and 54.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 18-20, 45, 48, 49, 51, and 54 of the ’494 patent as unpatentable under 35 U.S.C. §§ 102 and/or 103.