PTAB

IPR2014-00533

Google Inc v. Micrografx LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method of Providing Interactive Vector Graphics Over a Network
  • Brief Description: The ’854 patent discloses systems and methods for providing interactive vector graphics over a network. The invention involves a network-accessible, interactive vector object with an associated graphical image, where a user interaction within a predefined "active area" of the object triggers a predetermined command, such as displaying a webpage.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-3, 5, 7, 10-12, 14, 16, 19, 44, 54-57, 59, 61-66, 68, 69, and 71 under 35 U.S.C. §102 by Pesce

  • Prior Art Relied Upon: Pesce (VRML – Browsing and Building Cyberspace by Mark Pesce, 1995).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Pesce, which describes Virtual Reality Modeling Language (VRML), discloses every element of the challenged claims. Pesce teaches creating interactive 3D vector objects (e.g., a "sun" object) that can be downloaded over a network. These objects have predefined active areas (the surface of the object) that are associated with commands. For instance, Pesce describes using a "WWWAnchor" node to link a vector object (the sun) to a URL, such that clicking on the object causes an HTML browser to navigate to that URL. This functionality directly maps to the ’854 patent’s core concept of an "interactive vector object" with an "active area predefined by the vector object" associated with a "command to be performed in response to an event therein," which was the basis for the patent's allowance.

Ground 2: Anticipation of Claims 1-3, 5, 10-12, 14, 19, 44, 54-57, 59, 62-66, 68, and 69 under 35 U.S.C. §102 by Roy

  • Prior Art Relied Upon: Roy (Patent 5,966,135).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Roy, which discloses a system for creating and viewing interactive maps from vector-based data, anticipates the challenged claims. Roy describes map objects (e.g., states, cities) created from vector data that can be displayed as graphical images and interacted with by a user. These map objects include an active area (the surface of the map object) that, when clicked, triggers a command, such as jumping to a URL via an HTML anchor tag or zooming in. Roy’s system uses a browser plug-in to render the vector map data, corresponding to the claimed client-server architecture. Petitioner contended that Roy’s disclosure of vector-based map objects with embedded URL links fully discloses the key limitations of the independent claims.

Ground 3: Claims 7, 16, 61, and 71 are obvious over Roy in view of Davis

  • Prior Art Relied Upon: Roy (Patent 5,966,135) and Davis (Web Browsing with Netscape Navigator by Steve Davis et al., 1995).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targets dependent claims that add the limitation of a command operable to "recolor the image of the vector object on the client system." Petitioner argued that while Roy discloses the base invention (interactive vector map objects with links), it does not explicitly teach recoloring the object upon interaction. Davis, however, teaches this exact feature as a common internet norm, describing how a followed hyperlink is displayed in a different color (e.g., purple) to indicate it has been previously chosen.
    • Motivation to Combine: A POSITA would combine the teachings of Roy and Davis for several predictable reasons. First, it was a common and well-known technique to provide visual feedback to users by changing the color of a clicked link to improve usability. Second, applying Davis's color-change feedback to Roy's interactive map system would be a simple application of a known technique to improve a similar device, yielding predictable results. The combination would provide users with a clear indication of which map links they had already followed, enhancing the functionality of Roy's system without changing its fundamental operation.
    • Expectation of Success: A POSITA would have had a high expectation of success in implementing this combination. Recoloring a graphical link was a routine and straightforward programming task at the time, and its application to Roy's vector objects would have presented no undue technical challenges.

4. Key Claim Construction Positions

  • "interactive vector object": Petitioner proposed construing this term as "a computer software object that includes vector data, properties, and an 'active area' of the graphical image." This construction was argued to be consistent with the specification's description of an object defined by vector data that can respond to user events via commands defined in its properties.
  • "active area": Petitioner proposed this term means "an area that is associated with a command that is performed when an event, such as a mouse click, is recognized within the area." This construction emphasizes that the area itself is linked to a command, which is central to Petitioner's argument that both Pesce and Roy disclose this feature.
  • "vector graphics network file": Construed as "computer software capable of connecting to a server over a network and retrieving vector graphics files over the network," potentially composed of a network application file and a vector graphics extension. This construction supports mapping the prior art's browser and plug-in/renderer components to the claimed system.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5, 7, 10-12, 14, 16, 19, 44, 54-57, 59, 61-66, 68, 69, and 71 of the ’854 patent as unpatentable.