PTAB

IPR2015-01434

Microsoft Corp v. Bradium Technologies LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Optimized Image Delivery Over Limited Bandwidth Communication Channels
  • Brief Description: The ’343 patent discloses a client-server system for efficiently delivering large, high-resolution images over limited bandwidth networks. The system pre-processes a source image into a series of derivative images with progressively lower resolutions, which are subdivided into image parcels (tiles), to enable progressive rendering on a client device based on prioritized requests.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-9, 13, and 17-19 over Potmesil and Hornbacker

  • Prior Art Relied Upon: Potmesil (a 1997 journal article, “Maps Alive: Viewing Geospatial Information on the WWW”) and Hornbacker (WO 99/41675).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Potmesil and Hornbacker collectively teach all limitations of the challenged claims. Potmesil taught an online system for viewing geographic information that uses a "tile server" to store images in a multi-resolution, power-of-two pyramid (i.e., "mip-maps") for fast access, scrolling, and zooming on various client devices, including cellular phones. Hornbacker taught a client-server system for displaying portions of very large images over a network, where documents were divided into fixed-size tiles (e.g., 128x128 pixels) and organized into a hierarchy of tiles at different resolutions spaced by factors of two. The combination disclosed requesting image tiles based on user navigation and rendering them on a client device.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine Potmesil and Hornbacker because both references address the same well-known technical problem: visualizing large amounts of image data over a network on a client device with limited resources. They employed similar solutions involving tiled, multi-resolution image hierarchies. The European counterpart to Hornbacker was noted to have cited Potmesil, explicitly recognizing the relevance of its teachings.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references, as their teachings were complementary for creating an efficient, networked image visualization system.

Ground 2: Obviousness of Claims 10-12, 14-16, and 20 over Potmesil, Hornbacker, and Lindstrom

  • Prior Art Relied Upon: Potmesil, Hornbacker, and Lindstrom (a 1997 technical report, “An Integrated Global GIS and Visual Simulation System”).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Lindstrom to the combination of Ground 1 to teach the additional limitations of the dependent claims. Petitioner asserted that Lindstrom taught specific features not explicitly detailed in Potmesil or Hornbacker, including: sorting data parcel requests in a dynamically updated priority queue (Claim 10), limiting rendering based on client display resolution to optimize level-of-detail (LOD) (Claim 14), and using a multi-threaded display process on the client to improve system utilization and management (Claims 12 and 20).
    • Motivation to Combine: A POSITA seeking to implement the system of Potmesil and Hornbacker would have been motivated to consult Lindstrom, which operated in the same technical field and provided known techniques for improving performance. Lindstrom’s teachings on priority queues, LOD management, and multi-threading represented practical implementation details for optimizing the performance of any client-server geographic imaging system.
    • Expectation of Success: A POSITA would expect success in integrating Lindstrom’s performance-enhancing features into the base system of Potmesil and Hornbacker, as these were known methods for managing data flow and processing in computer graphics.

Ground 3: Obviousness of Claims 1, 2, 4-11, and 13-19 over Rutledge, Ligtenberg, and Cooper

  • Prior Art Relied Upon: Rutledge (Patent 6,650,998), Ligtenberg (Patent 5,682,441), and Cooper (Patent 6,118,456).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued this alternative combination of references also rendered the claims obvious. Rutledge taught a map database with map tiles of different zoom levels and resolutions that a user could retrieve in a hierarchical order. Ligtenberg taught a file format for efficiently downloading and rendering tiled images over a network, including recursively compressing tiles into a series of reduced-resolution versions. Cooper taught a technique for optimizing rendered image quality based on a user’s viewpoint by requesting object data from a server in a priority order, which is recalculated as the viewpoint changes.
    • Motivation to Combine: A POSITA would combine these references as they all address techniques for communicating visual data from a server to a client over a limited bandwidth network. Petitioner argued a POSITA would find it obvious to use Ligtenberg's efficient file format and Cooper's viewpoint-based prioritization to improve the performance and user experience of Rutledge’s map browsing system, thereby reducing latency and making more efficient use of network bandwidth.
    • Expectation of Success: The combination was presented as a predictable integration of complementary technologies. Combining a base map tiling system (Rutledge) with an efficient data format (Ligtenberg) and an intelligent, priority-based data request mechanism (Cooper) would have been a straightforward design choice with a high expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including Ground 4 (adding Hassan to the Rutledge combination for claim 3’s recitation of mobile devices) and Ground 5 (adding Austreng to the Rutledge combination for claims 12 and 20’s multi-threading limitations).

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’343 patent as unpatentable under 35 U.S.C. §103.