PTAB

IPR2015-00222

CoreLogic Inc v. Boundary Solutions Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Geographic Information Systems
  • Brief Description: The ’352 patent relates to a Geographic Information System (GIS), specifically a national online parcel-level map data portal. The system aggregates digital parcel map data from multiple, distinct jurisdictions into a centralized, multi-jurisdictional database that can be searched to retrieve and display parcel boundary polygon maps.

3. Grounds for Unpatentability

Ground 1: Obviousness over Harder, Du, and MacDonald - Claims 1-8, 11, and 23 are obvious over Harder in view of Du and MacDonald.

  • Prior Art Relied Upon: Harder ("Serving Maps on the Internet," a 1998 publication), Du (Patent 6,732,120), and MacDonald ("Building a Geodatabase," a 1999 publication).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Harder disclosed a foundational web-based, client-server GIS for retrieving and displaying parcel maps for a given jurisdiction, including highlighting selected parcels and showing attribute data. However, Petitioner contended Harder did not expressly teach searching a multi-jurisdictional database using an index of jurisdictional identifiers. Du allegedly supplied this by teaching a method of storing multi-jurisdiction geographic data by dividing maps into "uniquely identified cells," which serve as an index of jurisdictional identifiers to speed up data retrieval. For claims requiring data arranged in "separate service area directories," Petitioner asserted that MacDonald taught organizing GIS datasets into file directories corresponding to the specific jurisdiction to which the data pertains (e.g., counties, states).
    • Motivation to Combine: A POSITA would combine Harder and Du to improve the search speed and efficiency of Harder's system, a predictable and common-sense modification for handling large datasets. A POSITA would further incorporate MacDonald's teachings to logically organize the combined multi-jurisdictional database by jurisdiction, thereby improving data management, access, and retrieval. The shared focus of all three references on ESRI-based GIS systems provided a strong basis for their combination.
    • Expectation of Success: Success would be expected, as the combination involved applying known and predictable database indexing and data organization techniques to a standard GIS architecture to achieve the foreseeable result of improved performance and manageability.

Ground 2: Obviousness over Harder and Longley - Claims 1-23 are obvious over Harder in view of Longley.

  • Prior Art Relied Upon: Harder ("Serving Maps on the Internet," a 1998 publication) and Longley ("Geographic Information Systems and Science," a 2001 publication).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented an alternative invalidity theory. Petitioner again relied on Harder for the base web GIS system. Instead of Du, Petitioner argued Longley taught the key missing elements. Longley allegedly described server-based GIS systems that search and retrieve parcel data from multi-jurisdictional databases spanning multiple states and sub-regions. Critically, Longley disclosed configuring these databases with tables linked by jurisdictional identifiers, such as state "FIPS" identifiers, which serve as keys to assist in searching for data. This provided the claimed "jurisdictional identifier" used to search a "multi-jurisdictional database."
    • Motivation to Combine: A POSITA would be motivated to modify Harder's database architecture using Longley's well-known methods for configuring and searching large databases. Petitioner framed this as a simple substitution of one known method of organizing and searching a GIS database (Longley's) for another to more easily manage parcel information across jurisdictions and make searching more efficient.
    • Expectation of Success: The combination of Harder and Longley was presented as predictable, as it involved implementing a well-documented database configuration to enhance the performance of a known GIS system, a common practice in the field.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claim 6 based on Harder, Du, MacDonald, and Dugan (Patent 5,499,325), where Dugan was cited for its teachings on distinguishing displayed areas by modifying visual characteristics like brightness. A similar ground against claim 6 was asserted based on Harder, Longley, and Dugan.

4. Key Claim Construction Positions

  • "jurisdiction": Petitioner proposed that under the broadest reasonable interpretation, this term meant "a geographical area to which a common association or authority applies," including not just formal political entities but also zip codes, towns, cities, counties, and districts. This broad construction was critical to applying prior art examples from various types of geographical areas to the claim limitations.
  • "service area directories": Petitioner proposed this term be construed as "subsets of a database for service areas (e.g., jurisdictions)." This construction allowed Petitioner to argue that data structures described in the prior art, such as file folders or database tables corresponding to different geographic regions, satisfied this claim limitation.
  • "multi-jurisdictional database": Petitioner argued this term meant "a collection of data relating to two or more jurisdictions." This straightforward construction was consistent with the patent's disclosure and supported the combination of prior art references that aggregated data from different sources or regions.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-23 of the ’352 patent as unpatentable.