PTAB

IPR2015-01432

Microsoft Corp v. Bradium Technologies LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: System and methods for network image delivery with dynamic viewing frustum optimized for limited bandwidth communication channels
  • Brief Description: The ’794 patent discloses a client-server system for efficiently delivering large, high-resolution images, such as geographic maps, over limited bandwidth networks. The system pre-processes a source image into multiple levels of progressively lower-resolution image "parcels" (tiles), which are requested by a client based on the user's current viewpoint to enable rapid, progressive rendering.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 2 are obvious over Potmesil, Hornbacker, and Lindstrom.

  • Prior Art Relied Upon: Potmesil (a 1997 article titled "Maps Alive: Viewing Geospatial Information on the WWW"), Hornbacker (WO 1999/041675), and Lindstrom (a 1997 technical report titled "An Integrated Global GIS and Visual Simulation System").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these references taught all elements of the challenged claims. Potmesil disclosed a client-server system for viewing geospatial data over the web, using a "tile server" that stores images in a multi-resolution pyramid for fast access and caching based on user viewpoint. Hornbacker taught a system for displaying large images retrieved from a server by dividing them into a hierarchy of tiles at different resolutions for progressive enhancement. Lindstrom described a system for viewing large-scale geographic data that used a pyramidal structure, processed tile requests via a prioritized queue, and employed level-of-detail (LOD) management to optimize rendering.
    • Motivation to Combine: A POSITA would combine these references as they all addressed the common problem of efficiently visualizing large image datasets over a network. Petitioner contended that a POSITA would integrate Lindstrom’s sophisticated priority queue and LOD management into Potmesil’s foundational map browsing system to improve performance. Hornbacker’s teachings on tile hierarchy and progressive display would be a natural and predictable solution to apply within such a system to further manage bandwidth. The European counterpart to Hornbacker was noted to have cited Potmesil, demonstrating the recognized relevance between the teachings.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining these compatible technologies because they were all directed at solving the same well-known latency and bandwidth issues associated with networked image delivery, using similar tile-based, multi-resolution approaches.

Ground 2: Claim 1 is obvious over Rutledge, Ligtenberg, and Cooper, and Claim 2 is obvious over Rutledge, Ligtenberg, Cooper, and Migdal.

  • Prior Art Relied Upon: Rutledge (Patent 6,650,998), Ligtenberg (Patent 5,682,441), Cooper (Patent 6,118,456), and Migdal (Patent 5,760,783).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted this combination also rendered the claims obvious. Rutledge disclosed a map database with map tiles organized by different zoom levels and resolutions, which a user terminal retrieves hierarchically over a network. Ligtenberg taught an efficient file format for subdividing images into rectangular tile arrays and creating a series of reduced-resolution versions to optimize retrieval. Cooper disclosed a technique for optimizing rendered image quality in a 3D scene by assessing the importance of objects based on the user's viewpoint, requesting data in a priority order, and recalculating priority as the viewpoint changes. For claim 2, Migdal was added for its teachings on using three-dimensional texture rendering and "clip maps" to efficiently render photographic terrain textures, reducing memory and processor requirements.
    • Motivation to Combine: Petitioner argued that a POSITA would be motivated to combine these references to create a more efficient and responsive map visualization system. Rutledge’s map browsing system would benefit from Ligtenberg’s efficient file format, reducing I/O and CPU load. Incorporating Cooper’s viewpoint-based prioritization scheme would further improve the user experience by reducing visual latency over limited bandwidth networks. For the method of claim 2, which involves 3D space, adding Migdal’s texture mapping techniques was presented as a logical step to further optimize performance by reducing the memory footprint for rendering terrain.
    • Expectation of Success: There would be a high expectation of success, as the references provided complementary solutions to interrelated problems in the same technical field. Combining Ligtenberg's file format, Cooper's prioritization logic, and Rutledge's mapping framework involved applying known optimization techniques in their intended environments.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1 and 2 of the ’794 patent as unpatentable.