PTAB

IPR2015-00788

Google Inc v. Art+com InNOvatIONPool GmbH

Log In
Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Method and Device for Pictorial Representation of Space-Related Data
  • Brief Description: The ’550 patent discloses a method for providing pictorial representations of geographical objects, such as the Earth. The system uses a plurality of spatially distributed data sources and a hierarchical data structure (e.g., a quadrant tree) to progressively represent a user-selected field of view in different resolutions.

3. Grounds for Unpatentability

Ground 1: Obviousness over Core Visualization System - Claims 1, 2, 14, 18, 27, 28, 30, 32, 34, 39, 43, and 48 are obvious over Leclerc in view of Fuller.

  • Prior Art Relied Upon: Leclerc (a 1995 technical note from SRI Int’l titled Terravision: A Terrain Visualization System) and Fuller (a 1993 Mitre Corp. report titled An Overview of the MAGIC Project).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Leclerc’s TerraVision system disclosed most limitations of independent claim 1. This system generates real-time, synthetic representations of terrain from data stored in a remote database, allows a user to "roam about" a terrain from various vantage points, and uses a quadtree structure for a "recursive subdivision" technique to represent the terrain at different resolutions. Petitioner asserted that Fuller disclosed the claimed "plurality of spatially distributed data sources" by describing a distributed image server system, comprising "multiple, coordinated data servers" distributed around a wide-area network, which was specifically designed to support the TerraVision application.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Leclerc and Fuller because both references explicitly describe different, complementary components of the same government-funded initiative, the MAGIC Project. Fuller’s distributed server system was developed as a requirement for, and to provide data to, Leclerc’s TerraVision application. The combination was thus a predictable implementation to achieve a scalable, high-performance visualization system.
    • Expectation of Success: A POSITA would have had a high expectation of success because the references describe components that were expressly designed to function together. Combining Fuller's high-speed, parallel data server with Leclerc's visualization front-end was the intended architecture of the MAGIC project and would predictably improve data retrieval speed and the ability to handle large terrain datasets.

Ground 2: Obviousness over Leclerc, Fuller, and Delorme - Claims 3, 46, and 83 are obvious over Leclerc and Fuller in view of Delorme.

  • Prior Art Relied Upon: Leclerc, Fuller, and Delorme (Patent 4,972,319).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner established the base system using Leclerc and Fuller as detailed in Ground 1. To meet the additional limitation of "determining the data and/or the co-ordinates of the data in terms of a new co-ordinate system" after a change in view, Petitioner relied on Delorme. Delorme disclosed a global map generating system that uses a "32 bit offset coordinate structure" to define mapping data within tiles at each of 32 different levels of magnitude (i.e., altitude). This structure enables the system to handle data across a wide range of resolutions as a user zooms in or out.
    • Motivation to Combine: A POSITA would combine Delorme with the Leclerc/Fuller system to improve its method of handling data transformations across multiple resolutions. Since the TerraVision system already allowed users to move between high and low altitudes, a POSITA would have been motivated to incorporate a known technique like Delorme's coordinate system to efficiently and accurately manage the required data conversions, thereby improving performance and visual fidelity.
    • Expectation of Success: Success was expected because applying a known offset coordinate system, as taught by Delorme, was a well-understood technique for improving similar geographical visualization devices that manage massive datasets at various interactive resolutions.

Ground 3: Obviousness over Leclerc, Fuller, and Hitchner - Claim 25 is obvious over Leclerc and Fuller in view of Hitchner.

  • Prior Art Relied Upon: Leclerc, Fuller, and Hitchner (a 1992 ACM SIGGRAPH proceeding titled Virtual Planetary Exploration).

  • Core Argument for this Ground:

    • Prior Art Mapping: The combination of Leclerc and Fuller teaches a method for representing a "heavenly body" (claim 18), such as the Earth, using terrain data. Petitioner argued that Hitchner provided the final element for dependent claim 25: representing the object "in the form of a globe." Hitchner’s system, designed for the virtual exploration of Mars, explicitly disclosed that its terrain modeling includes planet surface curvature and maps the height field "onto the surface of a sphere."
    • Motivation to Combine: A POSITA seeking to create a more realistic and accurate visualization of a large-scale geographical object like a planet, as taught by Leclerc/Fuller, would be motivated to incorporate known methods for spherical mapping. Hitchner provided this exact solution in the analogous field of planetary visualization.
    • Expectation of Success: A POSITA would have expected success because mapping a height field to a sphere, as taught by Hitchner, was a known and straightforward algorithm for rendering planets. It was directly applicable to the terrain visualization system of Leclerc/Fuller to improve its realism.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations with: Samet (to teach an octant tree as an alternative to a quadrant tree); Gobetti (to teach hyperlinking and annotating the visual representation); and Wysocki (to teach using an automatic position-fixing system like GPS to determine the field of view).

4. Key Claim Construction Positions

  • "pictorial representation": Petitioner argued this term should be construed as "image data representation," based on the patent's focus on generating images and keeping processing requirements low.
  • "plurality of spatially distributed data sources": Petitioner proposed this term means "two or more separate data sources," consistent with the specification’s description of "data memories" being distinct from "central memories" and located at separate research institutes or satellites.
  • "field of view": Petitioner argued this term should be construed as "the portion of the object to be observed," based on explicit language in the patent’s specification describing the observer's selected portion.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-3, 14, 18, 25, 27-30, 32, 34, 35, 39, 43, 46, 48, 51-53, 58, 61, 63, and 83 of Patent RE44,550 as unpatentable under 35 U.S.C. §103.