PTAB

IPR2014-00083

Apple Inc v. Evolutionary Intelligence LLC

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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 ’536 patent describes a system for managing information using "containers," which are logically defined data structures that encapsulate digital information. These containers feature dynamic "registers" (metadata) and "gateways" (interfaces) that govern how the containers interact with other data, processes, and systems based on various parameters, particularly time and space.

3. Grounds for Unpatentability

Ground 1: Claims 1, 3-15 are obvious over Cree in view of Scully under 35 U.S.C. §103.

  • Prior Art Relied Upon: Cree (Patent 4,866,611) and Scully (Patent 4,819,191).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Cree and Scully, which describe related aspects of the same IBM calendaring system, discloses all limitations of the challenged claims. The "container" of the claims was mapped to the calendar data structure (CAD) in the prior art, which holds information about a calendar event. The various "registers" were mapped to data fields and structures within the CAD system.
      • Plurality of Registers: Petitioner asserted that the multiple data fields within the prior art's CAD structure (e.g., time, location, creator) correspond to the claimed "plurality of registers."
      • First Register (Unique ID): This limitation was mapped to the unique ID number and date stamp assigned to each calendar event in the Cree/Scully system.
      • Time-Based Registers (Active, Passive, Neutral): Petitioner mapped these distinct register types to various time-related data points in the prior art. The "active time register" was equated to a user-set trigger time that initiates an action (e.g., playing a sound). The "passive time register" was mapped to timestamps that record when a data structure was modified or to times indicating a user's availability. The "neutral time register" was mapped to other interaction times, such as modification timestamps or secondary trigger times. Petitioner argued that even if not explicitly present, adding an additional time register would have been an obvious design choice.
      • Gateway: This was mapped to the trigger mechanism in Cree/Scully that executes an action (e.g., launching a program) in response to a time-based condition, thereby controlling the interaction of the calendar event "container" with other system processes.
      • Dependent Claims: Petitioner argued that the additional limitations in dependent claims 3-8 and 13-15 were also taught by the combined references. For example, the "container history register" (claim 3) and "system history register" (claim 4) were mapped to modifiable event status data and timestamps that record past interactions and modifications within the calendaring system. The "predefined," "user-created," and "system-defined" registers (claims 5-7) were mapped to default values, user-entered event data, and system-generated timestamps, respectively.
    • Motivation to Combine: Petitioner asserted a strong motivation to combine Cree and Scully. Both patents were assigned to IBM, shared a common inventor (Keith Scully), and expressly cross-referenced each other as "related applications." Petitioner contended they describe different but complementary components of a single, integrated calendaring system, making their combination by a Person of Ordinary Skill in the Art (POSITA) logical and intuitive.
    • Expectation of Success: A POSITA would have had a high expectation of success in combining the references because they were designed to work together as part of the same system, and their teachings were highly interrelated and complementary.

4. Key Claim Construction Positions

  • Container: Petitioner argued for a broad construction of "container" as any logically defined data structure that encapsulates a digital element, system component, or other containers. This construction was crucial for mapping the term to the prior art's "calendar data structure" (CAD).
  • Register: The term "register" was proposed to encompass any value or code associated with a container. This allowed Petitioner to map the various data fields within the prior art's CAD, such as timestamps and user-input fields, to the claimed registers.
  • Gateway: Petitioner proposed that "gateway" should be construed as code that governs interactions between containers and can alter registers. This construction was supported by the patent owner's own litigation contentions, where it allegedly equated gateways with Application Program Interfaces (APIs), and it enabled mapping the term to the trigger and reconciliation processes in the prior art.

5. Key Technical Contentions (Beyond Claim Construction)

  • Indefiniteness of Means-Plus-Function Claims: A central contention was that claims 9-12, which recite means-plus-function limitations (e.g., "means for acting upon another container"), are invalid under §112. Petitioner argued that the ’536 patent fails to disclose the specific algorithm corresponding to the claimed functions. The specification allegedly only identifies a generic "processor" as the structure, which is insufficient for computer-implemented functions under established case law. While raising this as a fatal flaw, Petitioner proceeded with its §103 analysis by assuming, for argument's sake, that the "means" was a processor performing the recited function.

6. Relief Requested

  • Petitioner requested that the PTAB institute an inter partes review and cancel claims 1, 3-15 of the ’536 patent as unpatentable.