PTAB

IPR2014-00118

Oracle Corp v. Thought Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Displayable Presentation Page and SQL Searchable Relational Data Source Implementation of a System, Method and Software for Creating or Maintaining Distributed Transparent Persistence of Complex Data Objects and their Data Relationships
  • Brief Description: The ’600 patent concerns systems and methods for achieving "transparent persistence" of complex data objects. The technology allows software programmers to create, save, and manage data objects without needing to handle the lower-level technical details of how those objects are stored in a relational database.

3. Grounds for Unpatentability

Ground 1: Anticipation by Mullins - Claims 1-3 and 5-12 are anticipated by Mullins under 35 U.S.C. §102.

  • Prior Art Relied Upon: Mullins (Application # 2003/0046266).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mullins disclosed every element of the challenged claims. Mullins described a system for “creating or maintaining distributed transparent persistence of complex data objects,” which it termed a Complex Data Object Graph (CDOG) model. Petitioner contended this CDOG model directly corresponded to the claimed "object graph model." Furthermore, Mullins allegedly taught using a "repository" to store definitions for mapping database relationships to object links, fulfilling the limitations of independent claim 1 regarding a set of stored definitions for relationships between a data source schema and objects. For dependent claims, Petitioner asserted Mullins disclosed providing persistence without modifying the object model (claim 2), operating in a distributed network (claim 3), and using a generic EJB stateful session bean (claim 5).

Ground 2: Anticipation by Demuth - Claims 1-3, 5, and 7-12 are anticipated by Demuth under 35 U.S.C. §102.

  • Prior Art Relied Upon: Demuth (Application # 2003/0212987).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Demuth, which described a "client container" to transparently manage and persist parts of an EJB-hosted application, taught all limitations of the claims. Demuth’s disclosure of a "domain object model" and a "domain object graph" was mapped to the claimed object graph model. Petitioner asserted that Demuth’s teaching of an EJB container mapping entity beans to a database using JDBC constituted the claimed "set of definitions... stored in a repository." Petitioner further argued Demuth’s container-managed system inherently met claim 2’s limitation of not requiring modifications to the object model, as this is a key benefit of container-managed persistence. Demuth’s description of a distributed computing architecture and its use of Session Beans were argued to meet the limitations of claims 3 and 5.

Ground 3: Obviousness over Demuth, Britton, and Althoff - Claims 1-17 are obvious over Demuth and/or Britton in combination with Althoff under 35 U.S.C. §103.

  • Prior Art Relied Upon: Demuth (Application # 2003/0212987), Britton (Patent 6,401,101), and Althoff (Patent 6,374,252).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Demuth and Britton each disclosed the core elements of a system for transparent object persistence. Althoff was introduced as teaching a method for modeling object-oriented database structures and translating them to relational database structures via a graphical user interface (GUI). Petitioner argued Althoff’s system provided a meta-model that functions as a repository for definitions and allows a user to create, edit, and persist database objects, directly teaching or suggesting the repository and user-interaction limitations of the claims.
    • Motivation to Combine: A POSITA would combine these references to enhance existing transparent persistence systems. Specifically, a POSITA would integrate Althoff’s user-friendly GUI and its system for modeling and translating object structures into the container-managed persistence frameworks of Demuth or the object management system of Britton. This combination would yield the predictable result of a more robust and user-friendly system for creating and maintaining persistent object models.
    • Expectation of Success: The combination involved applying a known user interface and object modeling technique (Althoff) to well-understood object persistence systems (Demuth, Britton), leading a POSITA to have a high expectation of success.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges against claims 1-17 based on various combinations of Demuth, Britton, Althoff, Mullins, Kurniawan (a 2002 Java programming guide), Mital (Patent 6,003,040), and Chow (Application # 2003/0149689).

4. Key Claim Construction Positions

  • Petitioner argued that several key terms should be given the broad construction provided by the patent’s explicit "Definitions" section. These constructions were central to mapping the prior art.
  • "Object": Construed as "either a template or an instance." This broad definition allowed Petitioner to map prior art references that discussed either class definitions (templates) or instantiated objects.
  • "Persist / persistence": Construed simply as "store." This interpretation avoided any specific technical requirements for the storage mechanism, facilitating a broader application of prior art teachings related to data storage.
  • "Displayable presentation page": Construed as "a parameterized template for a user interface component," allowing Petitioner to map prior art web-based interfaces, such as Java Server Pages (JSP), to this limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-17 of the ’600 patent as unpatentable under 35 U.S.C. §§ 102 and 103.