PTAB

IPR2013-00563

Microsoft Corp v. Enfish LLC

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Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Data Storage and Retrieval System and Method
  • Brief Description: The ’604 patent discloses a database system featuring a "self-referential" logical table that stores both data and schema information. The system utilizes variable-length object identification numbers (OIDs) to identify rows and columns, and employs an inverted index structure to facilitate searching.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 17 and 47 by Smith

  • Prior Art Relied Upon: Smith (Patent 5,404,510).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Smith, which is directed to designing indexes in a relational database management system, discloses every element of claims 17 and 47. Smith teaches a database system that stores and retrieves data in memory, configured according to logical tables with rows (records) and columns (fields). Petitioner asserted that Smith’s use of an "employee ID" to identify records and a "column object id" to identify columns meets the OID limitations for rows and columns, respectively. Finally, Smith’s core purpose is to optimize the use of indexes for tables, directly teaching the "means for indexing data" limitation.
    • Key Aspects: Petitioner contended that Smith’s disclosure of standard relational database components, such as primary keys and indexed tables, inherently anticipates the allegedly novel features of the ’604 patent.

Ground 2: Anticipation of Claims 17-18, 24, 47-48, and 54 by VB3

  • Prior Art Relied Upon: Visual Basic Programming System Manual for Windows Version 3.0 ("VB3").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the VB3 manual, a printed publication from 1993, describes a data management system that anticipates the challenged claims. VB3 discloses logical tables (e.g., Table, Dynaset, and Snapshot objects) comprising rows (records) and columns (fields). Petitioner argued that VB3’s primary keys or pointers for records satisfy the row OID limitation, while the ordinal position or pointers for fields satisfy the column OID limitation. VB3 explicitly teaches adding an index to a database to increase access speed, meeting the "means for indexing" limitation. For claims 24 and 54, Petitioner argued VB3's "Index Collection," which points to an "Index Object," meets the limitation of a logical cell including a pointer to an index record.

Ground 3: Claims 16 and 46 are obvious over SQL-92 in view of Chawathe

  • Prior Art Relied Upon: SQL-92 (an ANSI database standard) and Chawathe (a paper titled "The TSIMMIS Project: Integration of Heterogeneous Information Sources").

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the SQL-92 standard discloses all base limitations of claims 16 and 46, including the use of logical tables, rows, columns, and OIDs (e.g., primary keys, row numbers, or column names). The central issue addressed by this ground is the limitation requiring OIDs to be of "variable length." While SQL-92 allows for variable-length primary keys and column names, Petitioner presented an alternative obviousness argument.
    • Motivation to Combine: Petitioner contended that SQL-92 does not explicitly state that non-text OIDs like column ordinal numbers are variable length. Chawathe, which describes a project using a "SQL-like language," expressly discloses an "Object-ID: A unique variable-length identifier for the object." A POSITA would combine Chawathe with the well-known SQL-92 standard to gain the flexibility of variable-length identifiers, as both references operate in the same technical field of database management and use similar query languages.
    • Expectation of Success: A POSITA would have a high expectation of success in implementing a known type of identifier (variable-length) from Chawathe into the standard, ubiquitous structure of SQL-92, as it was a predictable design choice to enhance database flexibility.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges, including combinations of VB3 with Jensen (Patent 5,615,362) for bi-directional pointers, VB3 with Salton (an information retrieval textbook) for advanced searching and weighing techniques, and VB3 with Clifton (a paper on hypertext databases) for back-pointers from data to an index.

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 broad construction was central to Petitioner's argument, allowing conventional database tables from the prior art, which separate schema and data, to meet the claim limitation.
  • "Object Identification Number (OID)": Petitioner proposed this term be construed as "a value that identifies an object." This broad interpretation allowed common database features like primary keys, row numbers, ordinal positions, or even memory address pointers in the prior art to satisfy the OID limitations, countering any potential argument that the ’604 patent required a specific, novel OID structure.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 16-30 and 46-60 of the ’604 patent as unpatentable.