PTAB

IPR2014-00413

SAP America Inc v. Arunachalam Lakshmi

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Real-Time Web Transactions
  • Brief Description: The ’894 patent describes a computer-implemented method and system for completing real-time transactions over the Web. The technology is based on a three-tier architecture involving a point-of-service Web application, an overlay service network, and back-end merchant services, which are connected via object routing at the OSI application layer without using Common Gateway Interface (CGI) scripts.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chelliah, Edwards, and Lawlor - Claims 1, 3, 4, 5, 8, 14, 15, 17, and 18 are obvious over Chelliah in view of Edwards and Lawlor.

  • Prior Art Relied Upon: Chelliah (Patent 5,710,887), Edwards ("Object Wrapping (for WWW)" publication, April 1995), and Lawlor (Patent 5,220,501).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chelliah taught a foundational web-based e-commerce architecture using distributed program objects, such as CORBA-defined objects, to handle online transactions between customers and merchants. However, Chelliah did not explicitly teach running its service network "on the Web." Edwards allegedly supplied this teaching by disclosing a CORBA client-server architecture where objects communicate over the Web using HTTP via an Object Request Broker (ORB), thereby creating a service network over a standard IP-based facility. To meet limitations in dependent claims and the "loan Web application" limitation in independent claim 1, Petitioner relied on Lawlor, which disclosed systems for remote retail banking and financial services, including online loan applications and fund transfers.
    • Motivation to Combine: A POSITA would combine Chelliah's e-commerce object architecture with Edwards's Web-based CORBA implementation to leverage the ubiquity of the World Wide Web for commercial transactions, a predictable evolution of the technology. A POSITA would further incorporate the known online financial services of Lawlor into this framework to broaden the commercial applicability of the platform to the banking sector.
    • Expectation of Success: Combining known software architectures (CORBA) with standard network protocols (HTTP) to deliver known commercial services (e-commerce, online banking) would have been a straightforward integration with a high expectation of success.

Ground 2: Obviousness over Chelliah, Edwards, and CompuServe - Claims 7 and 13 are obvious over Chelliah in view of Edwards and CompuServe.

  • Prior Art Relied Upon: Chelliah (Patent 5,710,887), Edwards ("Object Wrapping (for WWW)" publication, April 1995), and CompuServe ("Using CompuServe, Special Edition" publication, August 1995).
  • Core Argument for this Ground:
    • Prior Art Mapping: The base combination of Chelliah and Edwards was argued to provide the core object-oriented e-commerce system operating over the Web, as described in Ground 1. Petitioner asserted that CompuServe, which disclosed the EAASY Sabre online travel reservation system, supplied the specific limitations of claims 7 and 13. The CompuServe reference taught a system for real-time travel reservations, including car rentals, via a user interface, thus teaching a "travel reservation Web application" and a "car rental Web application" as recited in the claims.
    • Motivation to Combine: A POSITA would have been motivated to apply the general-purpose e-commerce framework taught by Chelliah and Edwards to specific, valuable commercial applications. Since online travel reservation systems like that in CompuServe were well-known, it would have been a natural and obvious step to implement such a service using the more advanced object-based architecture.
    • Expectation of Success: Implementing a known online service (travel reservations) on a known web-based object architecture represented a predictable combination of existing technologies.

Ground 3: Obviousness over Chelliah, Edwards, and Bartlett - Claim 11 is obvious over Chelliah in view of Edwards and Bartlett.

  • Prior Art Relied Upon: Chelliah (Patent 5,710,887), Edwards ("Object Wrapping (for WWW)" publication, April 1995), and Bartlett ("Experience with a Wireless World Wide Web Client" publication, March 1995).

  • Core Argument for this Ground:

    • Prior Art Mapping: Again relying on Chelliah and Edwards for the base e-commerce architecture, Petitioner cited Bartlett to teach the final element of claim 11: accessing a Web application from a "cellular device." Bartlett disclosed a Web client that included a personal digital assistant (PDA) connected to a workstation via a Motorola cellular phone and modem. This system allowed the PDA to receive Web data over an analog cellular network, thus teaching an "Internet communications device" that is a "cellular device."
    • Motivation to Combine: With the increasing prevalence of mobile and wireless technology, a POSITA would have been motivated to adapt existing Web-based services, such as the e-commerce platform of Chelliah/Edwards, for use on emerging cellular devices to expand the service's accessibility and user base.
    • Expectation of Success: Petitioner argued that substituting a known wired method of accessing the internet with a known wireless method, as taught by Bartlett, would be a predictable design choice that would yield the expected result of mobile access to the web service.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds that claims 2, 6, 9, 10, 12, and 16 are obvious over Chelliah and Edwards alone, and that claim 19 is obvious over the four-way combination of Chelliah, Edwards, Lawlor, and Bartlett. These grounds relied on similar arguments regarding the core architecture and the addition of specific application-level or device features from the prior art.

4. Key Claim Construction Positions

  • "point-of-service Web application": Petitioner proposed construing this term as "a software program that facilitates execution of a transaction requested by a user over the Web." This construction, adopted from a related IPR, framed the core functionality of the claimed system.
  • "overlay service network" / "service network on the Web": Petitioner argued these related terms should be construed as "a network on which one or more services other than an underlying network communications service is provided over the Web." This interpretation was critical to applying prior art that disclosed web-based services to the claims.
  • "real-time": Petitioner proposed this term be construed as "non-deferred," consistent with a construction from a related proceeding. This was used to argue that the prior art's transactional systems met the temporal requirements of the claims.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-19 of Patent 8,346,894 as unpatentable.