PTAB

IPR2015-00228

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 ’957 patent relates to Geographic Information Systems (GIS), and specifically to a method for creating and accessing a national online parcel-level map data portal. The system aims to retrieve geographic parcel boundary maps and associated attribute data from a multi-jurisdictional database that has been normalized to a common data protocol.

3. Grounds for Unpatentability

Ground 1: Obviousness over Harder and Longley - Claims 1-10 and 12-19 are obvious over Harder in view of Longley.

  • Prior Art Relied Upon: Harder (a 1998 publication on web-based GIS titled "Serving Maps on the Internet") and Longley (a 2001 publication titled "Geographic Information Systems and Science").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Harder disclosed an interactive, web-based GIS with a client/server architecture for retrieving parcel maps and linked attribute data. Harder's system allowed users to query a county's land records database by address or parcel ID and displayed a highlighted map of the selected parcel with its attributes. While Harder taught systems spanning multiple jurisdictions (e.g., statewide), Petitioner asserted it did not explicitly disclose a national database comprising multiple distinct jurisdictional databases. To bridge this, Petitioner cited Longley, which described server-based GISs that maintain parcel information in multiple databases for different jurisdictions (e.g., states) and use jurisdictional identifiers like state FIPS codes to link and organize the data.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Harder and Longley because both references described features of ESRI-based GIS systems. It would have been a common-sense modification to apply Longley's teachings on structuring multi-jurisdictional databases (using distinct tables and identifiers for states) to Harder's web-based map retrieval system to create a more efficient and scalable national system.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because using indexes and lookup tables with jurisdictional identifiers (as taught by Longley) to speed up searches in large databases was a well-known and predictable technique. Combining these known database configuration methods with Harder’s system would foreseeably improve the performance of locating parcel data in a national database.

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

  • Prior Art Relied Upon: Harder (1998 publication), Longley (2001 publication), and Roy (Patent 5,966,135).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Harder and Longley to address claim 11, which required highlighting several parcel polygons at once and querying the database to generate a data table for them. Petitioner contended that Roy taught this missing element. Roy disclosed a computer-implemented GIS where a user can make "requests for additional information" related to "multiple map objects" by using a spatial technique like enclosing them within a circle or polygon, with the resulting information presented in a report.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Roy's multi-selection and reporting capabilities into the GIS of Harder and Longley. This modification would provide a more powerful and user-friendly querying technique, improving the overall user experience by allowing for the analysis of multiple parcels simultaneously, which was a foreseeable improvement.

Ground 3: Obviousness over Kearney and ARC/INFO - Claims 1-8 and 16-19 are obvious over Kearney in view of ARC/INFO.

  • Prior Art Relied Upon: Kearney (a 1997 conference proceeding on internet access to real property information) and ARC/INFO (a 1997 ESRI publication on GIS methods).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kearney disclosed a web-based system for retrieving parcel boundary maps and attribute data for an entire Canadian province. Kearney taught maintaining multiple jurisdictional databases on a regional basis, normalizing data into fixed formats, and using a parcel-based index. However, it did not explicitly describe a national database. To supply this, Petitioner cited ARC/INFO, a foundational text on ESRI's GIS product, which taught how to configure databases for parcels, counties, and states (forming a national database) and how to use techniques like data layers and look-up tables to organize data and accelerate queries.
    • Motivation to Combine: A POSITA would have been motivated to scale up Kearney's regional system to a national one using the well-established database design principles disclosed in ARC/INFO. Modifying Kearney to provide parcel data on a national level was presented as a predictable application of ARC/INFO's widely known technologies to improve the system's versatility and applicability.
    • Expectation of Success: The combination was asserted to be a predictable substitution of one known method (regional data provisioning) for another (national data provisioning) using standard, known techniques for organizing and indexing large-scale geographic data.

4. Key Claim Construction Positions

  • "jurisdiction": Petitioner proposed that the broadest reasonable interpretation of "jurisdiction" should be "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 construction was argued to be consistent with the specification's varied examples (metropolitan areas, states, counties, towns, zip codes) and was central to establishing that the prior art's multi-level geographic systems met the "multi-jurisdictional" claim limitations.

5. Arguments Regarding Discretionary Denial

  • The petition noted the existence of a co-pending litigation in which the Patent Owner asserted the ’957 patent against the Petitioner. The case, filed on February 19, 2014, in the Northern District of California (case no. 5:14-cv-00761), was pending at the time the IPR petition was filed.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-19 of the ’957 patent as unpatentable.