Axure Software Solutions Inc v. iRISE

1. Case Identification

• Case #: IPR2015-00775
• Patent #: 7,861,158
• Filed: February 19, 2015
• Petitioner(s): Axure Software Solutions, Inc.
• Patent Owner(s): iRise, Inc.
• Challenged Claims: 28, 29, 38, 53, 54, 63, 78, 79, 88, 93-95

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 during its development. The technology involves displaying an interactive simulation area with user interface components that mimic the application's behavior alongside a separate requirements area that displays textual statements describing desired behaviors for those components, and maintaining an association between them.

3. Grounds for Unpatentability

Petitioner asserted that the challenged claims, which depend from independent claims 19, 43, and 68, are unpatentable. The petition first incorporated its analysis from a co-pending IPR (IPR2015-00770) arguing that the independent claims are obvious over Oyagi (Patent 6,199,193) to provide a foundation for the dependent claim challenges.

Ground 1: Obviousness over Oyagi and Vaidyanathan - Claims 28, 53, and 78 are obvious over Oyagi in view of Vaidyanathan.

• Prior Art Relied Upon: Oyagi (Patent 6,199,193) and Vaidyanathan (Patent 6,502,233).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued Oyagi teaches the foundational system of the independent claims: a software design evaluation server that presents a "comment-space inclusive prototype" to users for feedback. This system includes a prototype area (the claimed "simulation area") and a comment space (the "requirements area") where users can provide feedback on UI components. Vaidyanathan teaches an "automatic help module" that displays information, such as comments associated with an identifier, in a tooltip box when a user’s cursor hovers over or clicks on that identifier. This combination, Petitioner asserted, teaches the limitations of claim 28, including monitoring a cursor and displaying a corresponding requirement in response to selecting an identifier.
  • Motivation to Combine: A POSITA would combine Vaidyanathan's user interface feature with Oyagi's system to improve developer efficiency. This combination would allow a user to view comments associated with a prototype element without shifting focus away from the prototype to the comment space, yielding a predictable improvement.
  • Expectation of Success: The combination involved incorporating a known user interface feature (tooltips) into a known type of software development tool to achieve a predictable result.

Ground 2: Obviousness over Oyagi, Vaidyanathan, and Carroll - Claims 29, 54, and 79 are obvious over Oyagi in view of Vaidyanathan, further in view of Carroll.

• Prior Art Relied Upon: Oyagi (Patent 6,199,193), Vaidyanathan (Patent 6,502,233), and Carroll (Patent 6,762,777).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds on the combination of Oyagi and Vaidyanathan. Petitioner asserted that Carroll adds the teaching of a "freely editable popup window" that allows a user to enter textual information to be associated with a highlighted region of content. This functionality directly maps to the additional limitations of claim 29, such as "receiving one or more attributes to form a requirement for the requirements area" and associating that new requirement with the identifier.
  • Motivation to Combine: A POSITA would incorporate Carroll’s editable pop-up feature into the Oyagi/Vaidyanathan system to create more flexible and information-rich documents and to provide "powerful document annotation technology." This was a known technique for improving software to achieve the benefits described by Carroll.

Ground 3: Obviousness over Oyagi and Boulton - Claims 38, 63, and 88 are obvious over Oyagi in view of Boulton.

• Prior Art Relied Upon: Oyagi (Patent 6,199,193) and Boulton (Patent 5,566,291).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that while Oyagi teaches generating a report of user feedback (requirements) for developers, Boulton teaches an enhanced feedback system that includes contextual information. Specifically, Boulton discloses that feedback can include an image or picture of the object the user was viewing at the time of comment. This teaching directly maps to the limitations of claim 38 requiring a report that includes "an image corresponding to the selected user interface components."
  • Motivation to Combine: Both Oyagi and Boulton operate in the same field of software development and user feedback. A POSITA would combine Boulton’s teaching of providing visual context with Oyagi’s feedback reporting system to make the feedback more useful and actionable for developers, which would be a predictable and desirable result.

Ground 4: Obviousness over Oyagi - Claims 93-95 are obvious over Oyagi.

• Prior Art Relied Upon: Oyagi (Patent 6,199,193).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Oyagi alone renders obvious the means-plus-function limitations of claims 93-95. Oyagi’s "software design evaluation server" was argued to be the structure for the claimed "means for displaying" the simulation and requirements areas. The "identification data storage unit" and "user feedback distribution unit" in Oyagi were identified as the structure for the claimed "means for associating" UI components with their corresponding statements and maintaining that association.

4. Key Claim Construction Positions

• "requirement": Petitioner argued that the term should be construed according to its explicit definition in the specification as "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 narrower than a construction previously adopted by the BPAI during prosecution.
• "simulation": Petitioner proposed that "simulation" should be construed as "a representation." It argued that including "interactive" in the construction, as a district court had done for a related patent, would be redundant and inconsistent with the claim language, which already recites an "interactive simulation area."
• Means-Plus-Function (Claim 93): For the limitation "a means for associating," Petitioner identified the corresponding structure as a "computer system... programmed to enable a user, via user interface elements, to create an association." Petitioner contended this function requires special programming beyond a general-purpose computer.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 28, 29, 38, 53, 54, 63, 78, 79, 88, and 93-95 of the ’158 patent as unpatentable.