PTAB

IPR2014-00079

Apple Inc v. Evolutionary Intelligence LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Creating and Manipulating Information Containers with Dynamic Registers
  • Brief Description: The ’682 patent describes systems and methods for performing computer-based searches. The technology uses logically defined "containers" to encapsulate information, where each container has associated "registers" that hold data, including historical interaction data, to refine and personalize search results.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-23 by Wachtel

  • Prior Art Relied Upon: Wachtel (Patent 6,195,654)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wachtel, which discloses a system for personalized web searches, teaches every element of the challenged claims. Wachtel’s client-based repositories of information (e.g., interest profiles, category databases) that are dynamically updated based on user interactions correspond to the claimed "plurality of containers." The data within these repositories, such as interest categories and user profile numbers, function as the claimed "container registers." Petitioner asserted Wachtel’s use of historical interaction data (e.g., previously accessed information, rejected categories) to refine searches meets the limitation of searching "historical data" associated with the containers. For independent claims 18, 20, and 22, Petitioner contended that Wachtel’s server evaluating "preferred" and "not preferred" client IDs to identify useful preference information constitutes the claimed "polling" of "gateways." The client databases that generate personalized search rules serve as the claimed gateways. For the various dependent claims, Petitioner mapped features in Wachtel such as its use of tree data structures (claim 2), sharing of preference information between clients (claim 3), and use of pre-defined formats for results (claim 4) to the claimed limitations.

Ground 2: Obviousness of Claims 3, 5, and 6 over Wachtel in view of Culliss

  • Prior Art Relied Upon: Wachtel (Patent 6,195,654), Culliss (Patent 6,006,222)
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claim 3’s requirement of "providing information identifying containers that have previously been used to respond to one or more processed queries that are substantially similar to the search query." Petitioner argued that if Wachtel alone was found not to teach this element, its disclosure of a personalized search system could be combined with Culliss. Culliss teaches improving search quality using a thesaurus technique that leverages previously conducted searches involving similar concepts or terms.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Wachtel and Culliss because both are directed to techniques for improving Internet-based searching. A POSITA would have been motivated to incorporate the known thesaurus technique from Culliss into Wachtel's system to enhance the relevance and quality of search results, a predictable improvement.
    • Expectation of Success: A POSITA would have had a high expectation of success, as incorporating a known search improvement technique (thesaurus based on prior searches) into a known search system was routine and simple for a person of ordinary skill at the time.

Ground 3: Obviousness of Claims 4, 5, 6, and 7 over Wachtel in view of SavvySearch

  • Prior Art Relied Upon: Wachtel (Patent 6,195,654), SavvySearch (a 1997 publication by A. Howe)
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed limitations in claims 4 and 7 related to using "search templates" and providing results with a "title" and "short description." If Wachtel were deemed insufficient, Petitioner argued for its combination with SavvySearch, a meta-search engine that uses different search templates (e.g., Brief, Normal, Verbose) to perform searches and present results. The format of presenting website addresses with a brief description was a feature of SavvySearch.
    • Motivation to Combine: A POSITA would combine the teachings because both references are directed to improving internet search performance using historical data and structured formats. It would have been a natural design choice to implement the established search template and results presentation methods of SavvySearch within the personalized search framework of Wachtel to provide more useful and conventionally formatted results to the user.
    • Expectation of Success: The combination would have yielded predictable results, as implementing pre-defined search templates and result formats was a conventional design choice in the field of search engines.
  • Additional Grounds: Petitioner asserted additional challenges, including that claims 3, 5, and 6 are obvious over Wachtel in view of Chang (Patent 6,298,343), which teaches using a search history table to improve search efficiency.

4. Key Claim Construction Positions

  • "container": Petitioner argued for a broad construction encompassing any "logically defined data structure that contains a whole or partial digital element," based on the specification's definition. This broad scope was critical to mapping Wachtel’s databases and client profiles to the claimed "containers."
  • "register" / "container register": Petitioner proposed that a "register" encompasses "a value or code associated with a container." This construction allowed data points like user interest categories or profile numbers in Wachtel to be read on the claim term.
  • "gateway": Petitioner argued this term should be construed broadly as "code that governs interactions between containers and that can alter registers associated with containers." This construction was based on functional language in the specification and allowed server interfaces and personalized search algorithms in Wachtel to meet the "gateway" limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-23 of the ’682 patent as unpatentable.