Microsoft Corp v. Enfish LLC

1. Case Identification

• Case #: IPR2013-00560
• Patent #: 6,163,775
• Filed: September 3, 2013
• Petitioner(s): Microsoft Corporation
• Patent Owner(s): Enfish, LLC
• Challenged Claims: 17-23 and 47-53

2. Patent Overview

• Title: User-Adjustable Database System
• Brief Description: The ’775 patent discloses a database system featuring a flexible, self-referential logical table that stores both data and schema information. The system utilizes concepts from relational and object-oriented databases, including variable-length object identification numbers (OIDs) and a bi-directional keyword indexing method for contextual searching.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 17 and 47 are anticipated by Smith under 35 U.S.C. §102(e)

• Prior Art Relied Upon: Smith (Patent 5,404,510).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Smith, which teaches the design of indexes in a relational database management system, discloses every limitation of independent claims 17 and 47. Smith describes a computer system with memory for storing and retrieving data in logical tables comprised of rows (records) and columns (attribute sets). Petitioner asserted that Smith’s use of an "employee ID" to identify records and a "column object id" to identify columns inherently discloses the claimed OIDs and the first and second address segments used to locate a cell. Finally, Smith is explicitly directed to indexing data in a table, thus meeting the final limitation for a "means for indexing data."

Ground 2: Anticipation - Claims 17-18 and 47-48 are anticipated by VB3 under 35 U.S.C. §102(b)

• Prior Art Relied Upon: Visual Basic Programming System Manual for Windows Version 3.0 ("VB3").
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that the VB3 manual, a printed publication from 1993, anticipates the challenged claims as an alternative to Smith. VB3 describes a database management system where "Table," "Dynaset," and "Snapshot" objects function as the claimed "logical table." Petitioner mapped VB3's "Fields" to the claimed "attribute sets" and its "records" (rows) directly to the claimed records. VB3 was argued to disclose OIDs through its use of primary keys and pointers to identify records, and ordinal numbers or Field pointers to identify columns. VB3 also explicitly teaches creating indexes to speed up data access, satisfying the indexing limitation. For dependent claims 18 and 48, Petitioner argued VB3 teaches the means for searching using its index objects and the means for inserting new records into indexed tables.

Ground 3: Obviousness - Claims 19-20 and 49-50 are obvious over VB3 in view of Jensen under 35 U.S.C. §103

• Prior Art Relied Upon: VB3 (Visual Basic Programming System Manual for Windows Version 3.0) and Jensen (Patent 5,615,362).

• Core Argument for this Ground:

  • Prior Art Mapping: These dependent claims add limitations requiring bi-directional pointers between a searched cell containing a keyword and an inserted record corresponding to that keyword. Petitioner argued that while VB3 discloses using index objects with internal pointers from an index to a record, Jensen teaches using pointers as object attributes to allow object instances to refer to each other.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Jensen's teaching of bi-directional object pointers with VB3's indexed database system. The motivation was to enhance the functionality of the database by creating explicit, two-way links between related data records, a known method for improving data relationship management.
  • Expectation of Success: A POSITA would have a reasonable expectation of success in implementing Jensen's pointers within VB3's database structure, as both references deal with fundamental and compatible database concepts of data storage, indexing, and object referencing.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of VB3 with Salton (for advanced search techniques), VB3 with Smith ’162 (for folder-type records), and VB3 with SQL-92, Clifton, and Chawathe (for folder-type records and heterogeneous data integration).

4. Key Claim Construction Positions

• "Logical Table": Petitioner proposed this term be construed as "a conceptual framework that organizes data into rows and columns." This construction was argued to be broad but consistent with the specification's distinction between a logical structure and a physical one. It was important for mapping prior art systems like Smith and VB3, which used conventional table structures, onto the claims.
• "Object Identification Number (OID)": Petitioner proposed the construction "a value that identifies an object." This broad construction was based on the common understanding in the art and was necessary to argue that identifiers like primary keys (e.g., "employee ID" in Smith) or pointers in prior art databases met the OID limitation, even if not explicitly labeled as such.
• Means-Plus-Function Terms: For terms like "means for configuring" and "means for indexing," Petitioner identified the function (e.g., "configuring memory according to a logical table") and argued the corresponding structure was a "general purpose computer or other similar digital device" running a database management program. This broad structural interpretation was key to asserting that the conventional computer systems described in Smith and VB3 provided the necessary structure.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 17-23 and 47-53 of the ’775 patent as unpatentable.