PTAB

IPR2014-00080

Apple Inc v. Evolutionary Intelligence LLC

Log In
Key Events
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 discloses a system for searching and managing data using "information containers." These containers feature "dynamic registers" that store and update historical data based on user interactions, which is then used to refine and improve subsequent searches.

3. Grounds for Unpatentability

Ground 1: Claims 1-23 are anticipated by Cullis under 35 U.S.C. § 102

  • Prior Art Relied Upon: Cullis (Patent 6,006,222).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cullis discloses a computer-based search system that meets every limitation of the challenged claims. Cullis’s system uses an "index" to match keywords from search queries to articles; Petitioner asserted this index is the claimed "container." The various data elements within the index—such as key term scores, probability scores, and comparison scores derived from historical user interactions (e.g., access frequency)—function as the claimed "container registers." Petitioner contended that Cullis’s method of using this historical data to rank results, presenting those results to the user as a new collection of "squibs" (the "new container"), and updating the scores based on subsequent user interactions fully anticipates the methods recited in the independent claims.

Ground 2: Claims 1-23 are anticipated by SavvySearch under 35 U.S.C. § 102

  • Prior Art Relied Upon: SavvySearch (Howe, A., "SavvySearch: A Meta-Search Engine that Learns which Search Engines to Query," Jan. 28, 1997).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the SavvySearch metasearch engine anticipates all challenged claims. SavvySearch uses a "metaindex" that stores "learned associations" indicating which search engines perform best for specific keywords. This historical performance data, based on user activity like "visits" (positive reinforcement) or "no results" (negative reinforcement), was argued to be the claimed "container registers having...historical data." The overall process in SavvySearch—receiving a query, using the metaindex to select search engines, and displaying the integrated results on a new webpage—was mapped directly to the claimed method. Petitioner identified the results webpage as the claimed "new container" that encapsulates the search results.

Ground 3: Claims 4 and 23 are obvious over Cullis in view of SavvySearch under 35 U.S.C. § 103

  • Prior Art Relied Upon: Cullis (Patent 6,006,222) and SavvySearch (a 1997 publication).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that if Cullis were found not to explicitly teach storing information in "one or more search templates" (claim 4) or "providing a list characterizing...search query templates to formulate subsequent search queries" (claim 23), these features are disclosed by SavvySearch. SavvySearch describes presenting results in different formats (e.g., Brief, Normal, Verbose) that function as templates. It also discloses embedding the original search plan in the results page, allowing a user to select and refine the search, which meets the limitation of providing templates for subsequent queries.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Cullis and SavvySearch because both are directed to improving internet search technologies. A POSITA would have recognized the benefit of integrating SavvySearch’s user-friendly result templates and query refinement capabilities into Cullis’s search system to enhance its functionality and user experience.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination merely involved applying known search interface techniques from SavvySearch to the analogous search and ranking system of Cullis.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 3, 5, and 6 are obvious over Cullis in view of Chang (Patent 6,298,343), and claims 15 and 16 are obvious over Cullis in view of Wachtel (Patent 6,195,654), relying on similar theories of combining known search features.

4. Key Claim Construction Positions

  • "container": Petitioner argued this term should be construed as a logically defined data structure that contains a whole or partial digital element, a set of digital segments, a system component, a process, or other containers.
  • "register" and "container register": Petitioner proposed construing "register" as a value or code associated with a container. A "container register" would be a register appended to the logical enclosure of an information container that governs interaction and records historical data.
  • "gateway": As the patent does not expressly define this term, Petitioner argued its usage indicates it should be construed as an interface between a process, system component, container, or register, which governs interactions and manages data collection.

5. Relief Requested

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