PTAB

IPR2015-00219

CoreLogic Inc v. Boundary Solutions Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Multi-Jurisdictional Digital Parcel Map Database
  • Brief Description: The ’352 patent describes a Geographic Information System (GIS), specifically a national online parcel-level map data portal. The system is designed to retrieve and display geographic parcel boundary polygon maps from a multi-jurisdictional database, allowing users to access parcel data from various jurisdictions through a centralized server.

3. Grounds for Unpatentability

Ground 1: Obviousness over Harder and ARC/INFO - Claims 1-23 are obvious over Harder in view of ARC/INFO.

  • Prior Art Relied Upon: Harder (a 1998 publication titled “Serving Maps on the Internet: Geographic Information on the World Wide Web”) and ARC/INFO (a 1997 publication titled “Understanding GIS, The ARC/INFO Method”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Harder disclosed a web-based GIS with a client-server architecture for a specific county. This system received user requests (e.g., by address or parcel ID) and returned a map of the selected parcel along with adjacent parcels from a digital database. Petitioner contended that while Harder taught a system for a single county, it was a multi-jurisdictional database as it contained data for different towns within that county. For limitations not expressly in Harder, such as organizing a database by separate directories for different states and searching using a jurisdictional identifier, Petitioner turned to ARC/INFO. ARC/INFO, a product explicitly used in Harder's system, taught configuring GIS databases with data layers for different geographic areas (counties, states) and using identifiers as keys to link and search jurisdictional data.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references because Harder's system already used the ARC/INFO product for its functionality. A POSITA would have been motivated to apply ARC/INFO’s well-known database design principles—such as organizing data by jurisdiction and using identifiers for efficient searching—to Harder’s system. This would have been a predictable step to improve the efficiency, scalability, and data management of a multi-jurisdictional system.
    • Expectation of Success: Combining these known database access and organization techniques would have predictably resulted in an efficient system for retrieving and displaying parcel data from a database spanning multiple jurisdictions.

Ground 2: Anticipation by Oosterom - Claims 12-15 and 17-21 are anticipated by Oosterom.

  • Prior Art Relied Upon: Oosterom (a 2001 publication titled “Spatial data management on a very large cadastral database”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Oosterom alone disclosed every element of the challenged claims. Oosterom described the nationwide Netherlands Cadastre, a system for managing and displaying parcel data for the entire country. Petitioner argued this system constituted a multi-jurisdictional parcel map database, as it covered provinces, cities, and towns. The system was network-based, received requests from remote users via servers, and used unique, nationwide identifiers (jurisdictional identifiers) to search the database for selected parcels and surrounding parcels. Oosterom also taught linking parcel data to a non-graphic administrative database and normalizing data through defined attributes and classifications, thereby meeting all limitations of the specified claims.

Ground 3: Obviousness over Oosterom and Roy - Claims 1-3, 7-8, and 23 are obvious over Oosterom in view of Roy.

  • Prior Art Relied Upon: Oosterom (as described above) and Roy (Patent 5,966,135).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued Oosterom taught most limitations of the challenged claims, including a server-based system for searching a multi-jurisdictional database using identifiers to retrieve parcel maps. However, for the specific limitation of organizing the database into "separate service area directories corresponding to multiple jurisdictional service areas within two or more states" (claim 1[e]), Petitioner cited Roy. Roy disclosed a GIS that configured its database to store data for multiple jurisdictions (e.g., states, counties) in separate map layers or files, which were maintained in data source directories.
    • Motivation to Combine: A POSITA would have found it obvious to configure the database of Oosterom’s national system using the organizational method taught by Roy. Structuring the data into separate directories for different jurisdictions (like states or provinces) would be a predictable and common-sense design choice to improve data management, access, and retrieval in a large-scale relational database like Oosterom's.
    • Expectation of Success: Applying Roy's conventional data structuring method to Oosterom's system would have foreseeably yielded a more organized and efficiently searchable database without altering its fundamental operation.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Harder and ARC/INFO with DeMers for its teachings on database indexing (Ground 2), and combining Oosterom and Roy with Harder and/or DeMers to disclose highlighting features and the use of look-up tables (Grounds 5 and 6).

4. Key Claim Construction Positions

  • “jurisdiction”: Petitioner proposed that this term should be construed broadly as “a geographical area to which a common association or authority applies,” including areas like zip codes, towns, cities, counties, states, and private associations. This broad construction was argued to be consistent with the specification’s varied examples.
  • “service area directories”: Petitioner proposed this term means “subsets of a database for service areas (e.g., jurisdictions).” As the term was not expressly defined, Petitioner argued its meaning should be derived from the patent’s description of organizing jurisdictional databases (e.g., for a county) into individual directories, files, or folders.
  • “multi-jurisdictional database”: Petitioner argued this term should be construed as “a collection of data relating to two or more jurisdictions,” consistent with the plain meaning of the words and the patent’s description of assembling a parcel-level digital database from various urban jurisdictions.

5. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-23 of the ’352 patent as unpatentable.