Apple Inc v. Evolutionary Intelligence

1. Case Identification

• Case #: IPR2014-00086
• Patent #: 7,010,536
• Filed: October 22, 2013
• Petitioner(s): Apple Inc.
• Patent Owner(s): Evolutionary Intelligence, LLC
• Challenged Claims: 2-14, 16

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 data using "information containers." These containers are logically defined data enclosures that encapsulate digital information and include associated "dynamic registers" (values or code) and "gateways" (interfaces) to control their interactions with other system components.

3. Grounds for Unpatentability

Ground 1: Claims 2-14 and 16 are anticipated by Gibbs under 35 U.S.C. § 102(e)

• Prior Art Relied Upon: Gibbs (Patent 5,836,529).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Gibbs, which discloses an object-oriented computer system for managing a railroad network, teaches every element of the challenged claims. The petitioner mapped the abstract terminology of the ’536 patent to the concrete components of the Gibbs system. Specifically, the various software "objects" in Gibbs (e.g., train objects, car objects, map objects) were alleged to be the claimed "containers," as they are logically defined data enclosures. The data attributes associated with these objects, such as unique IDs, location coordinates, status, and performance statistics, were argued to meet the limitations of the claimed "plurality of registers." Finally, the program instructions, routines, and network interfaces within Gibbs's objects that govern how they interact with each other were identified as the claimed "gateways." For example, the petitioner asserted that Gibbs's disclosure of objects having locational attributes that are monitored to trigger alerts satisfies the "active space register" limitation of claim 2. Similarly, the ability of map objects in Gibbs to access and display transport objects within specific geographic boundaries was argued to disclose the "passive register for identifying space" limitation.

4. Key Claim Construction Positions

• Petitioner asserted that the claim terms should be given their broadest reasonable construction and proposed the following interpretations, which it argued were consistent with the specification and the Patent Owner's infringement contentions in parallel litigation.
• Container: Proposed construction was "a logically defined data structure that contains a whole or partial digital element (e.g., text, graphic, photograph, audio, video, or other), or set of digital segments, or any system component or process, or other containers or sets of containers." This broad construction was central to mapping the term onto the "objects" described in the Gibbs prior art.
• Register: Proposed construction was "a value or code associated with a container." This interpretation allowed Petitioner to map the term to the various data fields and attributes associated with the objects in Gibbs.
• Gateway: Proposed construction was "code that governs interactions between containers and that can alter registers associated with containers." This construction was used to argue that the routines and application programming interfaces (APIs) described in Gibbs met this limitation.
• Means-Plus-Function Claims (9-12): Petitioner contended that claims 9-12 are indefinite under 35 U.S.C. §112. It argued that the ’536 patent specification fails to disclose any specific algorithm corresponding to the functions recited in these claims (e.g., "means for acting upon another container," "means for gathering information"). According to Petitioner, the patent only identifies a general-purpose processor, which is insufficient structure for a computer-implemented means-plus-function limitation.

5. Relief Requested

• Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 2-14 and 16 of the ’536 patent as unpatentable.