Axure Software Solutions Inc v. iRISE

1. Case Identification

• Case #: IPR2015-00770
• Patent #: 7,861,158
• Filed: February 19, 2015
• Petitioner(s): Axure Software Solutions, Inc.
• Patent Owner(s): iRise, Inc.
• Challenged Claims: 1-22, 24-26, 30-37, 43-47, 49-51, 55-62, 68-72, 74-76, 80-87, and 96-98

2. Patent Overview

• Title: Collecting and validating requirements for computer applications
• Brief Description: The ’158 patent discloses methods and systems for collecting and validating requirements for a computer application under development. The invention involves creating simulated pages and user interface (UI) components for the proposed application, receiving requirements (e.g., textual statements about desired behavior), and associating those requirements with the corresponding simulated pages or UI components for review and validation.

3. Grounds for Unpatentability

Ground 1: Obviousness over Oyagi - Claims 1-6, 8-15, 17-22, 24-25, 30-36, 43-47, 49-50, 55-61, 68-72, 74-75, 80-86, and 96-98 are obvious over a single reference.

• Prior Art Relied Upon: Oyagi (Patent 6,199,193).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Oyagi, which discloses a "software design evaluation server" for facilitating end-user participation in software development, teaches every limitation of the challenged claims. Oyagi describes presenting a "prototype" of an application to a user, allowing the user to provide "comments and suggestions" (the claimed "requirements") about display screens and data items. These comments are then associated with specific parts of the prototype and distributed to developers. Petitioner contended this system inherently performs the claimed steps of creating simulated pages, receiving requirements, associating them with UI components, and displaying them together for validation. For example, Oyagi’s "comment-space inclusive prototype" was alleged to be a computer-viewable document that displays simulated pages, UI components, and associated requirements, enabling a user to validate them as claimed.
  • Key Aspects: This ground asserted that Oyagi alone renders the vast majority of the claims obvious. Petitioner argued that concepts such as interactivity, HTML pages, and specific UI elements like forms and buttons were either explicitly taught by Oyagi or would have been obvious implementations of its system to a person of ordinary skill in the art (POSITA) at the time.

Ground 2: Obviousness over Oyagi in view of Morgan - Claims 7, 16, 37, 62, and 87 are obvious.

• Prior Art Relied Upon: Oyagi (Patent 6,199,193) and Morgan (WO 99/08182).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addressed claims requiring the simulation of "storage and retrieval" of data. Petitioner asserted that while Oyagi teaches presenting a prototype in a web browser, Morgan explicitly teaches using scripting languages like CGI to "query databases and retrieve other selected information" and "create a web page dynamically." Morgan further teaches that such scripting languages make it easy for developers to "rapidly prototype and develop" applications. Thus, Morgan supplied the express teaching of simulating data storage and retrieval in a web-based prototype environment.
  • Motivation to Combine: A POSITA would combine Oyagi and Morgan because both references address techniques for prototyping software applications. A POSITA viewing Oyagi's browser-based prototype system would have been motivated to incorporate Morgan's well-known CGI scripting techniques to improve the prototype's functionality, specifically to add dynamic data handling like storage and retrieval, which Morgan teaches makes prototyping faster and easier.
  • Expectation of Success: Combining Oyagi’s web-based prototype with Morgan’s scripting for data retrieval was a straightforward application of known methods that would predictably result in a more functional and realistic prototype.

Ground 3: Obviousness over Oyagi in view of Elderbrock - Claims 26, 51, and 76 are obvious.

• Prior Art Relied Upon: Oyagi (Patent 6,199,193) and Elderbrock (Microsoft FrontPage 2000 Bible).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addressed claims requiring the ability to change the display from showing both the simulation and requirements areas to showing only the simulation area. Petitioner argued that Oyagi’s Figure 5, showing a prototype area and a comment area side-by-side in a single window, suggests a two-frame layout in a web browser. Elderbrock, a guide to web development, explicitly taught the use of resizable frames and draggable divider bars as a common feature in a web browsers to make websites "more visitor-friendly." Elderbrock's teaching, when applied to Oyagi, would allow a user to drag the divider bar to hide the requirements (comment) area, thus meeting the claim limitation.
  • Motivation to Combine: A POSITA implementing Oyagi's two-panel display in a web browser would have been motivated to incorporate the standard, usability-enhancing feature of resizable frames taught by Elderbrock. The motivation was simply to improve user experience by applying a known and desirable web design technique to Oyagi's system.
  • Expectation of Success: Implementing resizable frames in a browser-based application was a well-known, conventional technique at the time. A POSITA would have had a high expectation of success in applying this feature to Oyagi’s prototype display to achieve the predictable result of a resizable, user-friendly interface.

4. Key Claim Construction Positions

• "requirement": Petitioner argued for adopting the explicit definition from the ’158 patent’s specification: "a statement or portion of a statement regarding the desired or necessary behavior of a prospective or subject computer implemented software application." This construction was asserted to be broader than a construction used during prosecution and critical to mapping Oyagi’s "comments and suggestions" to the claimed term.
• "simulation": Petitioner proposed construing "simulation" simply as "a representation." This was intended to remove the term "interactive" from a prior district court construction of the term, arguing that its inclusion would introduce ambiguity and redundancy with other claim language.
• "consistent user interface": Petitioner proposed the plain and ordinary meaning: "a user interface which is generally uniform in appearance." This was relevant to arguments that using a standard web browser, as taught in Oyagi, would inherently provide such an interface.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and cancellation of claims 1-22, 24-26, 30-37, 43-47, 49-51, 55-62, 68-72, 74-76, 80-87, and 96-98 of the ’158 patent as unpatentable.