PTAB

IPR2014-00117

Oracle Corp v. Thought Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Dynamic Object-Driven Database Manipulation and Mapping System
  • Brief Description: The ’912 patent describes a multi-user data caching system for object-relational mapping to improve database access performance. The system uses a central notification component to manage cache consistency by sending messages to invalidate or update client caches when underlying data is changed.

3. Grounds for Unpatentability

Ground 1: Obviousness over Franklin in view of WLS - Claims 1-3, 8-10, and 12 are obvious over Franklin in view of WLS.

  • Prior Art Relied Upon: Franklin (a 1997 ACM article titled "Transactional Client-Server Cache Consistency") and WLS (WebLogic Server 6.1 Documentation, 2002).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Franklin, a foundational paper on client-server database caching, discloses all elements of the independent claims except potentially for an explicit "Java Messaging Service (JMS) or other reliable messaging service." Franklin taught a client-server system where a "Concurrency Control Manager" on the server tracks the location of cached data pages on clients. When a page is updated and saved to the primary data source, this manager sends invalidation messages to all other clients caching that page. Petitioner contended this manager functions as the claimed "unit notification system (UNS)." Franklin’s system inherently requires reliable messaging to maintain cache consistency, thus disclosing the concept.
    • Motivation to Combine: WLS was a well-known commercial server product that explicitly disclosed using JMS for enterprise messaging. A POSITA seeking to implement the robust caching system of Franklin would naturally turn to a standard, reliable messaging service like the JMS described in WLS to ensure that invalidation messages were properly delivered between system components. Both references address the same problem of maintaining data consistency in a distributed system.
    • Expectation of Success: A POSITA would have a high expectation of success, as integrating a standard messaging service (like JMS from WLS) into a distributed database architecture (like Franklin's) was a routine and well-understood task.

Ground 2: Anticipation by Zaharioudakis - Claims 1-3, 8-10, and 12 are anticipated by Zaharioudakis.

  • Prior Art Relied Upon: Zaharioudakis (a 1997 article titled "Adaptive, Fine-Grained Sharing in a Client-Server OODBMS: A Callback-Based Approach").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Zaharioudakis described a client-server Object-Oriented Database Management System (OODBMS) with a data-shipping architecture that anticipates the claimed invention. Zaharioudakis taught a "Concurrency Control Manager" that stores information on the location of cached data copies. When a client updates an object, the server issues "callback requests" to all other sites holding a cached copy, causing them to mark the object as "unavailable" (i.e., invalid). This manager and callback mechanism directly correspond to the claimed UNS sending invalidation messages. When a client later requests the unavailable object, it is re-fetched from the server, satisfying the claim limitation for updating the cache after invalidation.

Ground 3: Anticipation by Challenger - Claims 1, 3, 8, 9, and 12 are anticipated by Challenger.

  • Prior Art Relied Upon: Challenger (Patent 6,026,413).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued Challenger, which discloses caching for dynamic documents, taught the claimed system. Challenger described a "cache manager" that provides APIs for specifying dependencies between a cached object and its underlying data source. The cache manager tracks these dependencies and, whenever a process modifies the underlying data, it automatically "invalidates all cached objects which depend on the underlying data being updated." Petitioner asserted this cache manager is the claimed UNS. Challenger further disclosed logic for either updating or invalidating cached objects, satisfying the claim requirement that other user caches can read updated data from the source upon access attempts.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges based on Franklin and Zaharioudakis. These grounds proposed combining the base references with:

    • JVM (a 1997 Java Virtual Machine specification) to add the "object language virtual machine environment" limitation of claims 2 and 10.
    • Chang (Patent 5,627,979) or Mullins (Patent 5,857,197) to add the "transparent persistence" and "Object to Relational Mapping Repository" limitations of claims 4-7, 11, and 13-16.
    • Moss (a 1992 IEEE article) to add the limitation of preloading data into a cache, as opposed to only lazy loading.

4. Key Claim Construction Positions

  • unit notification system (UNS): Petitioner argued this term should be construed broadly as "any software component that manages storage locations of data or objects in caches and can send messages to the caches." This construction allowed mapping the term onto components like the "Concurrency Control Manager" in Franklin and Zaharioudakis, which perform this function without being explicitly named "UNS."
  • reliable messaging service: Petitioner proposed this term means "any messaging service that sends messages that will be received according to guarantees made by the service." This construction did not require an explicit mention of JMS, allowing the inherent need for reliable message delivery in the prior art caching schemes to satisfy the limitation.
  • transparent persistence: Citing the ’912 patent’s provisional application, Petitioner defined this as "the process of persisting data objects that are not inherently database aware," which facilitated mapping the term onto prior art object-relational mapping systems.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-16 of the ’912 patent as unpatentable.