PTAB

IPR2015-00225

CoreLogic Inc v. Boundary Solutions Inc

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and System for Retrieving and Displaying Geographic Parcel Boundary Polygon Maps
  • Brief Description: The ’352 patent relates to a Geographic Information System (GIS) for providing online access to parcel-level map data. The system uses a centralized server to search a multi-jurisdictional database and deliver geographic parcel boundary maps to a user for display.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 12-18 are anticipated by Majid under 35 U.S.C. §102

  • Prior Art Relied Upon: Majid (“A multi-purpose cadastre prototype on the World Wide Web,” a thesis published in 2000).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Majid’s disclosure of a server-based Multi-Purpose Cadastre (MPC) system meets every limitation of independent claim 12. Majid’s system receives requests for parcel information from a client, searches a multi-jurisdictional database containing parcel data, and transmits parcel boundary polygon map data for the selected parcel and surrounding parcels back to the client for display. Petitioner further contended that Majid discloses the limitations of dependent claims 13-18, such as allowing user requests based on parcel attributes (e.g., owner’s name, postal address), linking attribute data to the parcel map, and highlighting the selected parcel on the transmitted map.

Ground 2: Obviousness - Claims 1-6, 12-18, and 23 are obvious over Majid in view of Nearhood under 35 U.S.C. §103

  • Prior Art Relied Upon: Majid (a 2000 thesis) and Nearhood (Patent 7,249,072).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Majid discloses the fundamental system for retrieving and displaying parcel maps from a multi-jurisdictional database. To the extent Majid does not explicitly teach searching using a “jurisdictional identifier” or arranging records in “separate service area directories” corresponding to different states, Nearhood supplies these teachings. Nearhood discloses a system for managing multi-jurisdictional property tax data where parcel information is stored in tables (directories) and searched using unique jurisdictional identifiers corresponding to specific counties and states.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Nearhood's explicit use of jurisdictional identifiers and directory-based data structures with Majid’s system to more efficiently manage and search a large-scale, multi-jurisdictional database. Petitioner argued this combination addresses the known "daunting task" of managing such databases and would have been motivated by the resulting improvements in productivity and cost reduction, as taught by Nearhood.
    • Expectation of Success: Combining these known database management techniques was a predictable solution for improving the performance of a GIS system like Majid's.

Ground 3: Obviousness - Claims 7, 8, and 19-22 are obvious over Majid, Nearhood, and Longley under §103

  • Prior Art Relied Upon: Majid (a 2000 thesis), Nearhood (Patent 7,249,072), and Longley (“Geographic Information Systems and Science,” a 2001 publication).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination of Majid and Nearhood by adding the teachings of Longley to address limitations in claims 7, 8, and 19-22, which require searching an “index of jurisdictional databases.” Petitioner argued that while Majid and Nearhood provide the core system, Longley explicitly teaches that indexes were well-known data structures used to “speed up searching” in GIS database systems. Longley describes various geographic indexing techniques, including using identifiers in an indexed list to first find an object’s location before retrieving its full geometry and attributes.
    • Motivation to Combine: A POSITA would incorporate the indexing techniques taught by Longley into the Majid/Nearhood system for the known and predictable benefit of improving search efficiency and system performance. This modification would provide faster response times, a critical factor for an online, user-facing system handling large amounts of spatial data.
    • Expectation of Success: Implementing a known indexing method to improve the speed of a database search was a common and well-understood practice in the art, ensuring a high expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds that combined Majid, Nearhood, and Dugan (Patent 5,499,325) to teach highlighting a parcel by increasing its brightness (claim 6), and a broader obviousness challenge to all claims based on Majid and Longley.

4. Key Claim Construction Positions

  • "jurisdiction": Petitioner proposed this term be construed as “a geographical area to which a common association or authority applies, such as a zip code, town, city, county, district, state, country, and public or private association or organizational areas.” This broad construction is central to arguing that the prior art's management of data by state or county meets the "multi-jurisdictional" limitations.
  • "service area directories": Proposed as “subsets of a database for a service area (e.g., jurisdiction).” This construction allows Petitioner to map the prior art's use of database tables or organized files associated with specific geographic areas to the claim language.
  • "multi-jurisdictional database": Proposed as “a collection of data relating to two or more jurisdictions.” This construction aligns with the general concept of GIS databases that aggregate information from different geographic or administrative regions.

5. Relief Requested

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