Apple Inc v. Rensselaer Polytechnic Institute

1. Case Identification

• Case #: IPR2014-00320
• Patent #: 7,177,798
• Filed: January 3, 2014
• Petitioner(s): Apple Inc.
• Patent Owner(s): Rensselaer Polytechnic Institute
• Challenged Claims: 1-21

2. Patent Overview

• Title: Natural Language Interface Using Constrained Intermediate Dictionary of Results
• Brief Description: The ’798 patent describes a method for processing natural language queries to search databases. The system receives unconstrained user input, uses a metadata database to interpret the input without user augmentation, identifies relevant database objects, and determines combinations of those objects to generate a search result for the user.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-6, 9-12, 14-17, and 20-21 under 35 U.S.C. §102 by Bouchou

• Prior Art Relied Upon: Bouchou (Beatrice Bouchou and Denis Maurel, Using Transducers in Natural Language Database Query, 4th International Conference on Applications of Natural Language to Information Systems).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Bouchou discloses a natural language database querying system that anticipates every limitation of the challenged claims. The system in Bouchou processes user queries in French using a "cascade of sequential transducers," which Petitioner contended functions as the claimed "metadata database." This transducer system incorporates an electronic dictionary containing information about database structure (information models), keywords, linguistic operators (case information), and database contents (database values). Petitioner asserted that Bouchou’s system performs a search based on the user's input "without augmentation," identifies database objects, determines combinations of those objects to form a formal SQL query, and ultimately displays results to the user, thereby meeting all limitations of independent claims 1 and 9. Petitioner further mapped elements of Bouchou to dependent claims related to mapping queries to combinations, resolving ambiguity using linguistic operators (rules), and the inherent graphical structure of transducers.

Ground 2: Anticipation of Claims 1-11 and 13-21 under 35 U.S.C. §102 by Dar

• Prior Art Relied Upon: Dar (DTL’s DataSpot: Database Exploration Using Plain Language, Data Technologies Ltd.).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Dar’s "DataSpot" system, a tool for exploring databases using plain language, anticipates the challenged claims. The system’s core component is a "hyperbase," which Petitioner argued is a "metadata database" as claimed, because it stores linguistic thesaurus information, keywords, user-defined associations (case information), and data objects. Petitioner argued that Dar discloses a system that accepts free-form, unconstrained natural language queries and performs a search based on the input without user supplementation. The search process identifies relevant "hyperbase nodes" (database objects) and determines combinations by searching for connections between nodes in the hyperbase structure. The ultimate results are returned to the user on an HTML page, allegedly satisfying all limitations of the independent claims.

Ground 3: Obviousness of Claim 12 under 35 U.S.C. §103 over Dar

• Prior Art Relied Upon: Dar, in view of the knowledge of a Person of Ordinary Skill in the Art (POSITA).
• Core Argument for this Ground:
  • Prior Art Mapping: Claim 12, which depends from claim 11, adds the limitation that the "database query is formulated in a structured query language (SQL) query." Petitioner argued that even if Dar does not explicitly teach the use of SQL, adding this feature would have been obvious to a POSITA.
  • Motivation to Combine: At the time of the invention, SQL was a well-known and conventional language for interfacing with relational databases. A POSITA implementing a natural language query system like Dar's would have been motivated to use SQL to formulate the final query sent to the underlying database, as it was a standard, predictable, and readily available tool for that exact purpose.
  • Expectation of Success: The combination would have involved applying a known technique (SQL querying) to a known system (Dar's natural language interface) to yield predictable results. A POSITA would have had a high expectation of success in implementing this combination.
• Additional Grounds: Petitioner asserted that claims 1-11 and 13-21 are anticipated by Warthen (Patent 6,584,464) and that claim 12 is obvious over Warthen, based on similar anticipation and obviousness theories.

4. Key Claim Construction Positions

• "Natural Language Input": Petitioner adopted the Patent Owner's proposed construction from concurrent litigation, arguing the term means "input that is articulated in a human language in a way that a native speaker could understand and use sensibly." This broad construction was central to arguing that prior art systems processing queries in English or French met the limitation.
• "Without Augmentation": Petitioner argued this phrase should be construed as being "based on the natural language input provided by the user, without user supplementation of the input through the addition of information or structure." This construction was key to asserting that prior art systems that automatically processed raw user queries, without requiring further user interaction to refine the query, satisfied this claim element.
• "Metadata Database": Petitioner contended this term should be construed as a "database including information about structuring, using, or interpreting data," again adopting the Patent Owner's litigation position. This allowed Petitioner to map structurally different prior art components, such as Bouchou's "cascade of transducers" or Dar's "hyperbase," to this claim element by focusing on their function.

5. Relief Requested

• Petitioner requests the institution of an inter partes review and the cancellation of claims 1-21 of Patent 7,177,798 as unpatentable.