PTAB

IPR2015-01435

Microsoft Corp v. Bradium Technologies LLC

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1. Case Identification

2. Patent Overview

  • Title: Optimized Image Delivery Over Limited Bandwidth Communication Channels
  • Brief Description: The ’506 patent discloses a client-server system for distributing large, complex images (e.g., geographic maps) over limited bandwidth networks. The system pre-processes a high-resolution source image into a series of derivative images with progressively lower resolutions, subdivides them into fixed-size image parcels (tiles), and transmits them to a client device based on a priority system to enable progressive rendering.

3. Grounds for Unpatentability

Ground 1: Claims 1-21 are obvious over Potmesil, Hornbacker, and Lindstrom.

  • Prior Art Relied Upon: Potmesil ("Maps Alive: Viewing Geospatial Information on the WWW," a 1997 article), Hornbacker (PCT Publication No. WO 99/41675), and Lindstrom ("An Integrated Global GIS and Visual Simulation System," a 1997 tech report).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Potmesil and Hornbacker collectively disclose the core elements of the challenged claims. Potmesil taught a client-server system for viewing geospatial information over the web, including a "tile server" that stores images in a power-of-two pyramid (mip-maps) for fast access, zoom, and scroll operations on various devices, including mobile phones. Hornbacker taught a system for displaying large images retrieved from a server by dividing them into a hierarchy of tiles at different resolutions and requesting them via HTTP. Petitioner asserted these references together teach requesting prioritized image tiles of varying resolutions for display on a client device. Lindstrom was argued to provide additional implementation details, teaching an online client-server system for viewing geographic data that uses a prioritized queue and image cache for processing tile requests, thereby improving performance.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references because they all address the same technical problem: visualizing large image datasets obtained over a network on a client device with limited memory and bandwidth. Petitioner noted that the European counterpart to Hornbacker expressly cited Potmesil, demonstrating that a POSITA would have considered these teachings together. A POSITA would have integrated Lindstrom’s prioritized queue and multithreaded system to speed up processing and improve the user experience in the system of Potmesil.
    • Expectation of Success: The combination involved applying known techniques (prioritized queues, hierarchical tiling) to solve a known problem (network latency in image delivery), and the references operated in the same technical field, providing a POSITA with a reasonable expectation of success.

Ground 2: Claims 1-3, 5-10, 12-17, and 19-21 are obvious 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 contended that this combination also taught all key limitations. Rutledge disclosed a map database with map tiles of different resolutions and zoom levels, which a user terminal could retrieve in a hierarchical order. Ligtenberg disclosed an efficient file format for downloading and rendering images over a network by subdividing them into rectangular tiles and recursively compressing them into a series of reduced-resolution tiles. Cooper disclosed a technique for optimizing rendered image quality based on a user’s viewpoint by prioritizing the request for graphical objects from a server. Collectively, Petitioner argued these references teach a system for retrieving multi-resolution map tiles from a server based on user viewpoint and priority.
    • Motivation to Combine: A POSITA would have been motivated to combine these references to create a more efficient and responsive map viewing application. The map browsing system of Rutledge would benefit from Ligtenberg's efficient file format, which allows for selective retrieval of image data at a desired resolution, thereby optimizing bandwidth usage. The combination would be further improved by incorporating Cooper's prioritization scheme, which would reduce visual latency by requesting data based on importance to the user's current view, creating a more seamless browsing experience over a limited bandwidth network.
    • Expectation of Success: The references address complementary aspects of the same problem. Combining Ligtenberg's data format with Rutledge's mapping system and Cooper's prioritization logic represented a predictable integration of known solutions to enhance system performance, leading to a high expectation of success.

  • Additional Grounds: Petitioner asserted that claims 4, 11, and 18, which recite various mobile and portable devices, were obvious over the combination of Rutledge, Ligtenberg, and Cooper in further view of Hassan (Patent 5,940,117). Hassan was cited for its teaching of progressively downloading multi-resolution images to mobile cellular devices.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review (IPR) and the cancellation of claims 1-21 of the ’506 patent as unpatentable.