PTAB

IPR2015-00226

CoreLogic Inc v. Boundary Solutions Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Geographic Information Systems Data Portal
  • Brief Description: The ’946 patent relates to Geographic Information Systems (GIS), specifically a method and system for a national online parcel-level map data portal. The system retrieves geographic parcel boundary maps and associated attribute data from a multi-jurisdictional database for electronic display.

3. Grounds for Unpatentability

Ground 1: Obviousness over Harder and Longley - Claims 1-10 and 12-21 are obvious over Harder in view of Longley.

  • Prior Art Relied Upon: Harder (a 1998 publication titled “Serving Maps on the Internet: Geographic Information on the World Wide Web”) and Longley (a 2001 publication titled “Geographic Information Systems and Science”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Harder, which describes web-based GIS applications, taught the core elements of the challenged claims. This included an interactive method for retrieving parcel maps and linked attribute data using a client-server architecture. Harder was alleged to disclose activating a terminal, accessing an application, and entering a parcel attribute (like an address) to call up a selected parcel map, which is then displayed highlighted among surrounding parcels. While Harder disclosed systems spanning multiple jurisdictions (e.g., national to county drill-down), Petitioner asserted it did not explicitly teach a multi-state database comprising multiple distinct jurisdictional databases. Longley was introduced to supply this teaching, as it described GIS databases maintaining parcel information across multiple jurisdictions like states and sub-regions, using jurisdictional identifiers such as state FIPS codes in data tables.
    • Motivation to Combine: A POSITA would combine Harder's web-based GIS interface with Longley's teachings on configuring multi-jurisdictional databases to create a more efficient and scalable system for accessing parcel data across multiple states. Petitioner contended this combination was logical because both references described features of ESRI systems, a major GIS software provider. The combination would have involved applying Longley's known database organization principles to Harder's known front-end system.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. Modifying Harder's database structure using the well-documented techniques in Longley was a predictable implementation. Furthermore, using indexing (as taught by both references) to speed up searches in the combined system was a well-known database optimization technique that would have predictably improved performance.

Ground 2: Obviousness over Harder, Longley, and Roy - Claim 11 is obvious over Harder and Longley in view of Roy.

  • Prior Art Relied Upon: Harder, Longley, and Roy (Patent 5,966,135).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically addressed claim 11, which adds the ability to highlight several parcel boundary polygons at once and query the database for a consolidated data table. Petitioner argued that the base combination of Harder and Longley taught highlighting and querying a single selected parcel. Roy was introduced to teach the multi-selection capability, as it disclosed a GIS where a user can select "multiple map objects" by "using a spatial technique of enclosing multiple objects within a circle or polygon" and then generate reports on the selected objects.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Roy's multi-selection feature into the Harder/Longley system to provide a more powerful, user-friendly querying tool. This modification would have been a common-sense improvement to enhance the functionality of the base system by allowing users to analyze groups of properties, a foreseeable need in a GIS.

Ground 3: Obviousness over Kearney and ARC/INFO - Claims 1-6, 20, and 21 are obvious over Kearney in view of ARC/INFO.

  • Prior Art Relied Upon: Kearney (a 1997 conference proceeding titled “Internet Access to Real Property Information”) and ARC/INFO (a 1997 ESRI publication titled “Understanding GIS, The ARC/INFO Method”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented this as an alternative ground. Kearney was asserted to disclose an online system for retrieving parcel boundary maps and attribute data for an entire Canadian province, thus teaching a multi-jurisdictional (though not multi-state) system. Kearney allegedly taught the core claim elements, including accessing multi-jurisdictional databases and normalizing data into fixed formats. However, Kearney did not explicitly disclose a multi-state database or certain advanced indexing techniques. ARC/INFO, an ESRI product manual, was introduced to teach organizing GIS databases with data sets and layers corresponding to different geographic areas, including counties and states, and using indexing and look-up tables to accelerate data access.
    • Motivation to Combine: A POSITA would have been motivated to modify Kearney's provincial-level system to cover multiple states by applying the well-known and commercially documented database design principles from ARC/INFO. This would have improved the system's versatility and applicability, expanding a regional solution to a national one, which was a known goal in the GIS field.
    • Expectation of Success: A POSITA would have expected success because the combination involved applying standard, documented database techniques (from ARC/INFO) to an existing type of online GIS (from Kearney). The use of indexing via look-up tables to efficiently query jurisdictional data was a known technique for improving performance in large databases.

4. Key Claim Construction Positions

  • "jurisdiction": Petitioner argued for a broad construction of this term, which appears in independent claims 1 and 20. Based on its use in the patent specification, Petitioner proposed the 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 was central to Petitioner's argument that the prior art systems, which operated on county, provincial, or national levels, were indeed "multi-jurisdictional."

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-21 of the ’946 patent as unpatentable.