RPX Corp v. Applications In Internet Time LLC

1. Case Identification

• Case #: IPR2015-01751
• Patent #: 7,356,482
• Filed: August 17, 2015
• Petitioner(s): RPX Corporation
• Patent Owner(s): Applications in Internet Time, LLC
• Challenged Claims: 1, 7-21, 27-41, 47-59

2. Patent Overview

• Title: System and Method for Dynamically Generating an Application
• Brief Description: The ’482 patent relates to systems and methods for dynamically generating a software application using a multi-layered architecture. While the specification describes managing information affected by regulatory changes, the challenged claims broadly cover a four-layer structure analogous to a model-view-controller (MVC) framework operating in a client-server environment.

3. Grounds for Unpatentability

Ground 1: Anticipation by Popp - Claims 1, 7-13, 18-21, 27-33, 38-41, 47-52, 57-59 are anticipated by Popp under 35 U.S.C. §102(e).

• Prior Art Relied Upon: Popp (a U.S. Patent with a 1995 filing date).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Popp disclosed a client-server system for generating dynamic web page user interfaces (UIs) for a database application that meets every limitation of the challenged claims. Popp’s architecture was alleged to map directly to the claimed four-layer system: a database containing application-specific data corresponds to the "first layer"; application-generic Web page objects used for the UI correspond to the "second layer"; a scriptedControl object that integrates data from the first two layers to generate the UI corresponds to the "third layer"; and an inputControl object that automatically detects user input and modifies data corresponds to the "change management layer." The inputControl object was also identified as the claimed "intelligent agent."

Ground 2: Anticipation by Kovacevic - Claims 1, 8, 10, 19-21, 28, 30, 39-41, 47, 49, 58, 59 are anticipated by Kovacevic under 35 U.S.C. §102(b).

• Prior Art Relied Upon: Kovacevic (a printed publication describing the MUSE system).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Kovacevic disclosed the MUSE system for generating UIs for web-based tutoring applications, which employs an MVC-like architecture that anticipates the claims. In this system, an application-specific library for a particular tutoring course corresponds to the "first layer." A sharable, interaction-specific library of generic UI primitives constitutes the "second layer." A "main program" that maps primitives from both libraries to construct the UI serves as the "third layer." Finally, "sequencing control primitives," which monitor user input to enable or disable UI elements, were argued to be the claimed "change management layer" and "intelligent agents."

Ground 3: Obviousness over Balderrama in view of Java Complete - Claims 1, 7-12, 19-21, 27-32, 39-41, 47-51, 58, 59 are obvious over Balderrama in view of Java Complete.

• Prior Art Relied Upon: Balderrama (a U.S. Patent) and Java Complete (a 1996 printed publication).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that Balderrama taught a networked point-of-sale system that disclosed most claim elements. In Balderrama, outlet-specific data files form the "first layer," a shared template presentation forms the "second layer," a "configuring routine" that combines them forms the "third layer," and an "update/modification detector" that triggers re-configuration upon data changes serves as the "change management layer." Balderrama, however, did not explicitly disclose using a browser application on its client terminals.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Balderrama's system with the teachings of Java Complete to implement the client-side application in a browser using a Java applet. Java Complete explicitly taught that using browsers and Java was a simple and advantageous method for delivering client-server applications and specifically highlighted order-entry systems (the subject of Balderrama) as a "good example" of an application that would benefit from this approach.
  • Expectation of Success: A POSITA would have had a high expectation of success, as combining these known technologies was routine and presented clear benefits of ease of implementation and broad delivery of business information using readily available web browsers.

• Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 13-17, 33-37, and 52-56 based on the combination of Popp and Anand, arguing Anand supplied teachings for specific UI buildable items like reports, views, and queries not explicitly detailed in Popp.

4. Key Claim Construction Positions

• "change management layer for automatically detecting changes that affect an application": Petitioner argued this term, which was added to overcome rejections during prosecution, had no established meaning to a POSITA. Therefore, it should be given its plain meaning and construed functionally as simply "a layer for automatically detecting changes that affect an application." This construction was central to mapping the prior art.
• "intelligent agent": Petitioner highlighted that the ’482 patent provided two distinct definitions for this term, raising a potential indefiniteness issue under 35 U.S.C. §112. However, Petitioner contended that the components in the prior art (e.g., Popp's inputControl object) satisfied both definitions.
• "means for..." terms: For several means-plus-function limitations (e.g., in claims 9, 41, and 48), Petitioner argued that the specification failed to disclose corresponding structure or algorithms, rendering the claims indefinite. For the purpose of the IPR, Petitioner proposed construing these terms as a general-purpose server/client system programmed to perform the recited functions.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1, 7-21, 27-41, and 47-59 of Patent 7,356,482 as unpatentable.